Industrial Waste
Management
-------
This Guide provides state-of-the-art tools and
practices to enable you to tailor hands-on
solutions to the industrial waste management
challenges you face.
WHAT'S AVAILABLE
• Quick reference to multimedia methods for handling and disposing of wastes
from all types of industries
• Answers to your technical questions about siting, design, monitoring, operation.
and closure of waste facilities
• Interactive, educational tools, including air and ground water risk assessment
models, fact sheets, and a facility siting tool.
• Best management practices, from risk assessment and public participation to
waste reduction, pollution prevention, and recycling
-------
^DGEMENTS
The fotowing members of the Industrial Waste Focus Group and the Industrial Waste Steering Commute aregrateftjy
acknowledged far al of their dme and assistance m the development of this guidance document
'ICUS
Grou; .
rout own, lilts lyuw ^iiaiu^a
Company
Walter Carey. Nestle USA. Inc and
New Milford Farms
Rama Chaturvedi Bethlehem Steel
Corporation
H.C. Clark. Rice University
Barbara Dodds. League of Women
voters
Chuck Feerick. Exxon Mobil
Corporation
Stacey Ford. Exxon Mobil
Corporation
Robert Giraud DuPont Company
John Harney. Citizens Round
Tabte/PURE
Kyle Isakower. American Petroleum
Institute
Richard Jarman, National Food
Processors Association
James Meiers, Cinergy Power
Generation Services
Scott Murto. General Motors and
American Foundry Society
James Roewer, Edison Electric
Institute
Edward Repa. Environmental
Industry Association
Tim Saytor, International Paper
Amy Schalfer, Weyerhaeuser
Ed Skemote, WMX Technologies. Inc
Michael Wach Western
Environmental Law Center
David Wels, University of South
*"•*-•"* Medical Center
i-ai owin. Cherokee Nation of
Oklahoma
rocu?.
Wl* wtMMIUd. WMMIU l*IUW
Brian Forrestal. Laidlaw Waste
Systems
Jonathan Greenberg, Browning-
Ferns Industries
Michael Gregory, Arizona Toxics
Information and Sierra Club
Andrew Miles, The Dexter
Corporation
Gary Robbins, Exxon Company
Kevin San. National Paint & Coatings
Association
Bruce Steter. American Iron & Steel
Lisa Williams, Aluminum Association
and Territorial Solid Waste
Management Officials
Marc Crooks. Washington State
Department of Ecology
Cyndi Darling. Maine Department of
Environmental Protection
Jon Dilliard Montana Department of
Environmental Qualty
Anne Dobbs. Texas Natural
Resources Conservation
Commission
Richard Hammond. New York Slate
Department of Environmental
Conservation
Elizabeth Haven California State
Waste Resources Control Board
Jim HuD. Missouri Department of
Natural Resources
Jim Knudson. Washington State
Department of Ecology
Chris McGuire, Florida Department
of Environmental Protection
Gene Mitchell Wisconsin
Department of Natural Resources
William Pounds. Pennsylvania
Department of Envtanmental
Protection
Bjjan Sharafkhani Louisiana
Department of Environmental
Qualty
James Warner, Minnesota Pollution
Control Agency
rmitaa omit, ntmio uupwUinfn Of
Environmental Protection
NormGumenik Arizona Department
of Environmental Qualty
Steve Jenkins, Alabama Department
of Environmental Management
Jim North Arizona Department of
Environmental Qualty
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Industrial waste is generated by the production
of commercial goods, products, or services.
Examples include wastes from the production
of chemicals, iron and steel, and food goods.
-------
RCRA Public Participation Manual
1996 Edition
United States Environmental Protection Agency
Office of Solid Waste, Permits Branch
Mail Code 5303 W
401 M Street,, SW
Washington, DC 20460
-------
Table of Contents
Chapter 1: Introduction
Overview of this Manual 1-1
The Big Picture 1-3
RCRA and its 1984 Amendments 1-3
RCRA Facility Permitting 1-4
The RCRA Corrective Action Program 1-5
Public Participation in the RCRA Program 1-6
Chapter 2: Guidelines for a Successful Public Participation Program
What is Public Participation? 2-1
Why Bother with Public Participation? 2-2
What Makes a Successful Public Participation Program? 2-3
Dialogue and Feedback 2-3
Honesty and Openness 2-4
A Commitmentto the Public 2-5
An Informed and Active Citizenry 2-5
Starting Early 2-7
Assessing the Situation 2-8
Planning for Participation 2-14
Understanding and Interaction Between Stakeholders 2-18
Promoting Environmental Justice 2-18
Supporting Community-Based Environmental Protection 2-21
Re-Evaluating and Adjusting the Public Participation Program 2-22
Summary 2-24
Exhibit 2-1: Determining the Likely Level of Public Interest in a RCRA Facility.... 2-25
Exhibit 2-2: Steps in Evaluating Facilities and Gathering Information 2-26
Chapter 3: Public Participation During the RCRA Permitting Process
Introduction 3-1
Public Participation During the Permit Decision Process 3-3
Step One: The Pre-Application Phase 3-3
The Pre-Application Meeting 3-4
Notice of the Pre-Application Meeting 3-9
The Facility Mailing List 3-13
Step Two: Application Submittal and Review 3-16
Step Three: The Draft Permit, Public Comment Period,
and Public Hearing 3-18
Step Four: Response to Comments and Final Permit Decision 3-20
Public Participation During the Life of a Facility 3-21
Interim Status Public Participation 3-21
Permit Modifications 3-22
Public Participation in Closure and Post-Closure 3-29
Closure and Post-Closure at Permitted Facilities 3-30
Closure and Post-Closure at Interim Status Facilities 3-30
Summary 3-32
Exhibit 3-1: Public Participation Requirements for Class 1, 2,
and 3 Permit Modifications 3-34
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Chapter 4: Public Participation in RCRA Corrective Action Under Permits
and §3008(h) Orders
Introduction 4-1
Current Status of the Corrective Action Program 4-2
Special Consideration for Public Participation Activities
Under §3008(h) Orders 4-4
Public Participation in Corrective Action 4-6
Initial Site Assessment (RFA) 4-7
Site Characterization (RFI) 4-9
Interim Actions 4-11
Evaluation of Remedial Alternatives (CMS) 4-12
Remedy Selection 4-13
Remedy Implementation (CMI) 4-15
Completion of Remedy 4-16
Summary 4-17
ChapterS: Public Participation Activities: How to do Them
Introduction 5-1
Directory 5-2
Appendices
A: List of EPA Contacts (including the RCRA Hotline, the Public Information Center,
and the RCRA Information Center)
B: List of State Environmental Agencies
C: League of Women Voters Contact List
D: Environmental Justice Public Participation Checklist
E: Guidance for Community Advisory Groups at Superfund Sites
F: Public Participation Regulations in 40 CFR Part 25
G: Public Participation Regulations in 40 CFR 124 Subpart A
H: Examples of Public Notices
I: Examples of Additional RCRA Public Participation Tools (Fact Sheets, News Releases,
Public Involvement Plans)
J: The Hazardous Waste Facility Permitting Process ~ Fact Sheet
K: RCRA Expanded Public Participation Final Rule and Brochure
L: Modifying RCRA Permits-- Fact Sheet
M: Public Participation Resources Available to the Permitting Agency
N: Memorandum: Implementation of the RCRA Expanded Public Participation Rule
-------
O: Overview of Public Participation in the Entire RCRA Program ~ Excerpt from 1990 RCRA
Orientation Manual
P: Public Participation in Enforcement and Compliance
Q: RCRA Public Participation Manual Revisions ~ Task Group Participants
R: Accessing EPA Information
S: Pollution Prevention & Small Business Assistance Contacts
T: Glossary of Acronyms
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Statement
This manual reviews regulatory requirements and
provides policy guidance to help implement the RCRA
program. The policies set forth in the attached manual
are not final agency action, but are intended solely as
guidance. They are not intended, nor can they be relied
on, to create any rights enforceable by any party in
litigation with the United States. EPA officials may decide
to follow the guidance provided, or to act at variance with
the guidance, based on an analysis of specific site
circumstances. The Agency also reserves the right to
change this guidance at any time without public notice.
This manual replaces and supersedes the 1993 RCRA
Public Involvement Manual (EPA 530-R-93-006). This
manual is designed for use by agency staff, public interest
organizations, private citizens, and owners/operators of
hazardous waste management facilities.
Acknowledgments
The RCRA Public Participation Manual was developed by
the Office of Solid Waste with the invaluable help of a task
group comprised of EPA and State regulators, industry
representatives, and representatives of public interest
groups. EPA would like to thank the members of the task
group who provided their able services to this effort. For
a full listing of participants, please refer to Appendix Q.
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What This Manual Can Do For You
A Handbook for All
Stakeholders
This document is a user's manual for public participation activities in the
permitting process. In the same way that a user's manual explains how a
car or an appliance works, this manual explains how public participation
works in the RCRA permitting process and how citizens, regulators, and
industry can cooperate to make it work better.
EPA teamed up with a diverse group of stakeholders from the
environmental community, industry, and government agencies to produce
this manual. The manual emphasizes the importance of cooperation and
communication, and highlights the public's role in providing valuable input
during the permitting process. The manual also furthers EPA's
commitments to early and meaningful involvement for communities, open
access to information, and the important role of public participation in
addressing environmental justice concerns.
EPA wrote this manual to help all stakeholders in the permitting process.
Here is how the manual can help you:
If you are a citizen...
This manual provides a clear description of the many public participation
activities that are required by federal regulations. The manual also points
out steps that agencies, company owners, and public interest groups can
take to provide more public input into the process. In this manual, you will
also find a list of people and organizations that you can contact to learn
more about the permitting process and about community organizing.
If you are a government regulator...
This manual provides specific details about public participation
requirements and outlines EPA's current policies. The manual also
explains activities that you can conduct to provide better information to the
public and to invite more public input into your RCRA permitting work.
By reading this manual, you will learn how to open a dialogue with other
stakeholders, how to assess communities and be sensitive to their concerns,
how to plan for public participation, how to fulfill all the regulatory
requirements, and how to go beyond the requirements.
If you are a member of a public interest or environmental group...
Reading this manual will let you know what public participation events are
required under federal regulations, and how your organization can get
involved. It provides useful tips, based on the experience of public
participation practitioners, on how to interact with other stakeholders and
-------
Other Sources of
Information
how to conduct public participation activities. The manual also provides
contacts and publications that you can tap into for more information.
If you own or operate a hazardous waste management facility...
This manual describes when and how to conduct the pubic participation
events involved in the permitting process. It points out the events you are
responsible for and lets you know how the permitting agency will conduct
other activities. By reading the manual, you will find out how to interact
with the community around your facility, and how to be sensitive to their
concerns, and how to cooperate and communicate with all stakeholders.
The manual also describes public participation opportunities you can
provide that go beyond the requirements.
EPA is compiling a reference list of public participation and risk
communication literature. For this list, EPA is interested in the following
subjects areas: community organizing, community involvement and
participation, environmental justice, risk communication, creative problem-
solving, alternative dispute resolutions, participatory activities,
environmental activism, and information-sharing. EPA is not interested in
technical documents or data related to permitting. To initially solicit items
for the reference list, EPA published a notice in the Federal Register (61
FR 15942). EPA intends to update the list periodically; any additional
items people wish to propose for inclusion in the reference list may be
submitted to the attention of the RCRA Permits Branch, Office of Solid
Waste (5303W), U.S. Environmental Protection Agency, 401 M Street SW,
Washington, DC 20460. Please do not send the original document. Include
the full names of all authors, full titles, publisher, date of publication, city
where the work was published, an abstract, and an address and/or phone
number where one can write or call to obtain the publication (if applicable).
An initial draft of this reference list is available through the RCRA Hotline,
or through the RCRA Information Center, in Docket Number F-95-PPCF-
FFFFF, (see Appendix A for the appropriate telephone numbers).
If you are not trying to find out about public participation in the permitting
process for facilities that store, treat, or dispose of hazardous wastes, then
this manual will not be the best one for you. The following are suggestions
of places to look for related information:
• If you are trying to learn more about public participation in the
Superfund program, refer to Community Relations in Superfund: A
Handbook (USEPA, EPA/540/R-92/009, OSWER Directive
9230.0-3C, January 1992).
• If you are trying to learn more about the siting of hazardous waste
management facilities prior to permitting, you will most likely need
to contact your local or state officials. See Appendix B for a list of
state agency contacts. EPA is planning to issue guidance on this
-------
topic during 1996. Contact the RCRA Hotline (see Appendix A for
the number) for more information.
• If you are trying to learn about hazardous substances (other than
wastes) stored by facilities or amounts of toxic substances released
to the environment, you will want to find out more about the
Emergency Planning and Community Right-to-Know Act
(EPCRA), or and the Toxics Release Inventory (TRI). Call EPA
HQ, your Regional Office, or the RCRA/Superfund Hotline (see
Appendix A for phone numbers ) for more information.
Information on accessing EPA data is available in Appendix R.
• If you are trying to find out about how the public can participate in
siting municipal waste landfills, refer to Sites for Our Solid Waste:
A Guidebook for Effective Public Involvement (USEPA, EPA/530-
SW-90-019, March 1990).
If you are unsure about whether a facility in your area will need a RCRA
permit, you can contact your State agency or your Regional EPA office
(see the Appendices A and B for numbers).
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Chapter 1
Introduction
Overview of this
Manual
This manual covers
federal public
participation
requirements. States
may have additional
requirements.
This manual is a guide to improving cooperation and communication
among all participants in the RCRA permitting process. Like the
September 1993 RCRA Public Involvement Manual (EPA530-R-93-006),
this manual outlines public participation procedures and what staff in EPA
and RCRA-authorized state programs can do to ensure that the public has
an early and meaningful role in the process. However, this new manual
goes beyond the scope of past manuals by providing public participation
guidance to regulated industries and the communities that interact with
them.
The broader scope of today's manual reflects EPA's belief that all
stakeholders have a role in providing for meaningful public participation.
Permitting agencies, public interest organizations, community members,
and regulated facilities are all stakeholders in RCRA permitting actions.
Each group has an interest in the permitting process and, moreover, can
take steps to increase public participation and improve communication.
This manual provides guidance for all RCRA stakeholders who seek to
achieve these goals. Of course, the Federal and State agencies still
administer RCRA and its public participation activities, but EPA
acknowledges that members of communities and owners and operators of
hazardous waste management facilities also play an integral role in the
permitting process.
One reason for the broader scope of this guidance document is that facility
owners and operators have more formal responsibilities than ever in RCRA
public participation. This trend in EPA's approach, demonstrated through
regulations such as the permit modifications procedures in 40 CFR 270.42
(52 FR 35838, September 23, 1987) and the part 124 changes in the "RCRA
Expanded Public Participation" rule (60 FR 63417-34, December 11, 1995),
has made facility owners and operators responsible for a number of public
participation activities ~ from public notices to meetings and information
repositories. These new regulations underscore EPA's support for
strengthening the link between facilities and their host communities.
This manual will also be helpful to many private companies that have
adopted, or are establishing, public participation programs as part of their
commitment to good corporate citizenship. While these activities often
take place outside of the official RCRA permitting process, EPA supports
Chapter 1: Introduction
Page 1-1
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Some of the most
meaningful involvement for
citizens may occur outside
of the official process.
facilities in their efforts to inform and involve the public. This manual will
guide facility owners and operators as they implement the public
participation requirements of the RCRA program, especially those in the
RCRA Expanded Public Participation rule. The manual will help facility
owners and operators go beyond the regulatory requirements, expand their
public participation activities, and build lasting relationships with
surrounding communities.
Citizens are an essential component of the RCRA permitting process. The
formal public participation activities, required by regulation, aim to provide
citizens with both access to information and opportunities to participate in
the process. Some citizens and other groups have expressed concerns about
barriers to involvement in RCRA permitting. EPA was also concerned —
as are many members of the public - that formal public participation
begins too late in the permitting process and that RCRA permitting
information is not always accessible to people. In response to these
concerns and others, EPA promulgated the RCRA Expanded Public
Participation rule. We hope that this rule and its accompanying policy
statement will improve access to permitting information and enhance public
participation.
EPA recognizes that valuable public participation can take place outside of
the formal procedures mandated by regulation. Through informal channels,
citizens communicate and interact with other citizens, public interest
groups, regulated facilities, and permitting agencies. EPA supports
communities in their efforts to carry out informal means of participation
that go beyond regulatory standards. Some of the most meaningful and
informative involvement for citizens may come through activities not
organized by permitting agencies or regulated facilities. We hope that this
manual will be a valuable resource for communities and public interest
groups that are concerned about RCRA facilities in their area.
Following this introductory chapter, the manual is organized as follows:
Chapter 2, "Guidelines for a Successful Public Participation
Program," introduces some basic public participation concepts and
points out principles of public participation that we encourage all
RCRA stakeholders to follow.
Chapter 3, "Public Participation in RCRA Permitting," covers the
basic steps in the RCRA permitting process and the public
participation activities that accompany them. After reviewing the
requirements, the chapter provides a list of additional participation
activities to supplement the requirements.
Chapter 4, "Public Participation for RCRA Corrective Action Under
Permits and §3008(h) Orders," details EPA's public participation
guidelines for the corrective action program. This chapter reflects the
Chapter 1: Introduction
Page 1-2
-------
current agency position on these issues as the corrective action
program continues to evolve.
Chapter 5, "Public Participation Activities: How to do Them,"
provides detailed descriptions for dozens of public participation
techniques - required and optional, formal and informal. The chapter
explains all of the public participation methods mentioned in the
previous chapters and provides information on additional methods.
The Appendices provide resources that will help any participant in the
RCRA permitting or corrective action programs. Included in the
Appendices are: phone numbers and addresses for contact persons at
all state agencies, the 10 EPA Regional offices, and EPA
Headquarters; current permitting fact sheets; example notices and
press releases; and EPA policy memoranda.
If you already have a general knowledge of the RCRA permitting program,
you may want to skip ahead to Chapter 2 at this point.
The Big Picture
RCRA and its 1984
Amendments
The RCRA program involves many people and organizations with roles
that vary greatly. Congress writes or amends the Act which, when signed
by the President, becomes law. After the Office of Solid Waste and Emer-
gency Response (OSWER) at EPA develops the regulations that more
specifically define and explain how the law will be implemented, the
RCRA program is implemented by both EPA Headquarters (OSWER) and
staff in EPA regional offices. The states may, in turn, apply to EPA for the
authority to run all or part of the RCRA program. In doing so, a state may
adopt the federal program outright or develop its own program, as long as it
is at least as stringent and as broad in scope as the federal program. The
regulated community is involved with the RCRA program because it must
comply with the law and its regulations. Finally, the general public
participates by providing input and comments at almost every stage of the
program's development and implementation.
The Resource Conservation and Recovery Act, an amendment to the Solid
Waste Disposal Act, was enacted by Congress in 1976 to address a problem
of enormous magnitude ~ how to safely manage and dispose of the huge
volumes of municipal and industrial solid waste generated nationwide. The
goals set by RCRA were:
• To protect human health and the environment;
• To reduce waste and conserve energy and natural resources; and
Chapter 1: Introduction
Page 1-3
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RCRA GOALS
To protect human health
and the environment
To reduce waste and
conserve energy and
natural resources
To reduce or eliminate the
generation of hazardous
waste as expeditiously as
possible
• To reduce or eliminate the generation of hazardous waste as
expeditiously as possible (also referred to as waste minimization and
pollution prevention).
The Act continues to evolve as Congress amends it to reflect changing
needs. It has been amended several times since 1976, most significantly on
November 8, 1984. The 1984 amendments, called the Hazardous and Solid
Waste Amendments (HSWA), significantly expand the scope and
requirements of RCRA. The HSWA provisions related to corrective action
at RCRA facilities are described later in this chapter.
The program outlined under Subtitle C of the Act is the one most people
think about when RCRA is mentioned. Subtitle C establishes a program to
manage hazardous wastes from cradle to grave. The objective of the
Subtitle C program is to ensure that hazardous waste is handled in a manner
that protects human health and the environment. To this end, EPA
established regulations under Subtitle C regarding the generation;
transportation; and treatment, storage, and disposal of hazardous waste.
These regulations are found in Title 40 of the Code of Federal Regulations
(CFR), in Parts 261-266 and Parts 268-270. [Note: The CFR contains all
the general and permanent rules published by the Executive departments
and agencies of the Federal Government.]
The Subtitle C program has resulted in perhaps the most comprehensive
regulatory program EPA has ever developed. The Subtitle C regulations
first identify those solid wastes that are "hazardous" and then establish
various administrative requirements for the three categories of hazardous
waste handlers: (1) generators; (2) transporters; and (3) owners or
operators of treatment, storage, and disposal (TSD) facilities. This manual
applies only to the TSD facilities, and the term "facilities" in this manual
refers only to TSD facilities. The Subtitle C regulations set technical stan-
dards for the design and safe operation of hazardous waste facilities. These
standards are designed to minimize the release of hazardous waste into the
environment. Furthermore, the regulations for RCRA facilities serve as the
basis for developing and issuing (or denying) permits to each facility. Issu-
ing permits is essential to the Subtitle C regulatory program because it is
through the permitting process that the regulatory agency actually applies
the technical standards to facilities.
RCRA Facility
Permitting
Owners or operators of TSD facilities are required to submit a
comprehensive permit application covering all aspects of the design,
operation, maintenance, and closure of the facility. Owners and operators
are also required to certify annually that they have a waste minimization
program in place. Many companies have found waste minimization is
often a cost-effective alternative or supplement to waste management.
Facilities in existence on November 19, 1980, operate under interim status
until a final permit decision is made. Similarly, facilities that are in
Chapter 1: Introduction
Page 1-4
-------
The RCRA
Corrective Action
Program
existence when new regulations are promulgated that subject them to
RCRA Subtitle C may also operate under interim status while they proceed
through the permitting process. New facilities are ineligible for interim
status and must receive a RCRA permit before construction can commence.
The permit application is divided into two parts: A and B. Part A is a short,
standard form that collects general information about a facility. Part B is
much more detailed and requires the owner or operator to supply detailed
and highly technical information about facility operations. Because there is
no standard form for Part B, the owner or operator must rely on the
regulations to determine what to include in this part of the application.
Existing facilities that received hazardous waste on or after November 19,
1980, or subsequently fell under Subtitle C due to new regulations,
submitted their Part As when applying for interim status. Their Part B
applications can be either submitted voluntarily or called in by the
regulatory agency. Owners or operators of new facilities must submit Parts
A and B simultaneously at least 180 days prior to the date on which they
expect to begin physical construction; however, construction cannot begin
until the agency has issued the permit. Permit applications are processed
according to the procedures found in 40 CFR Part 124.
RCRA requires owners and operators of RCRA facilities to clean up
contamination resulting from present and past practices, including those
practices of previous owners of the facility. These clean up activities are
known as corrective action. HSWA added three provisions for corrective
action, thus significantly expanding EPA's authority to initiate corrective
action at both permitted RCRA facilities and facilities operating under
interim status. Section 3004(u) of HSWA requires that any permit issued
under RCRA §3005(c) to a facility after November 8, 1984 address
corrective action for releases of hazardous wastes or hazardous constituents
from any solid waste management unit (SWMU) at the facility. If all
corrective action activities cannot be completed prior to permit issuance,
then the permit must include a "schedule of compliance" establishing
deadlines and financial assurances for completing the required corrective
actions. Section 3004(v) authorizes EPA to require corrective action
beyond the facility boundary, if necessary. Finally, §3008(h) authorizes
EPA to issue administrative (i.e., enforcement) orders or bring court action
to require corrective action or other measures, as appropriate, when there
is, or has been, release of hazardous waste or hazardous constituents from a
RCRA facility operating under interim status.
Corrective action is typically carried out by the facility owner or operator
under the requirements or conditions stated in the RCRA permit or
administrative order. In some cases, the owner or operator is required,
through an order, to begin corrective action prior to permit issuance. If the
regulatory agency issues a permit to the facility prior to completion of all
activities specified in the order, then the agency may require the owner or
Chapter 1: Introduction
Page 1-5
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Public Participation
in the RCRA
Program
operator to continue all or some of the activities under the order, or may
incorporate the requirements of the order into the RCRA permit schedule of
compliance.
Section 7004(b) of RCRA gives EPA broad authority to provide for,
encourage, and assist public participation in the development, revision,
implementation, and enforcement of any regulation, guideline, or program
under RCRA. In addition, the statute specifies certain public notices (radio,
newspaper, and a letter to relevant agencies) that EPA must provide before
issuing any RCRA permit. The statute also establishes a process by which
the public can dispute a permit and request a public hearing to discuss it.
In fulfilling its statutory mandate, EPA has written regulations to
implement the RCRA program. To carry out its public participation
responsibilities under the Act, EPA has used its authority to develop
specific public participation activities in the RCRA permitting program. As
we explain in more detail in the following chapters, EPA's RCRA
regulations provide for public participation at all hazardous waste
management facilities - from before permit application, through the
permitting process, and during the permit life.
Chapter 1: Introduction
Page 1-6
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Chapter 2
Guidelines for a Successful Public
Participation Program
What is Public
Participation?
Public participation
increases the public's
ability to understand and
influence the process.
The RCRA permitting process brings government, private industry, public
interest groups, and citizens together to make important decisions about
hazardous waste management facilities. These groups and individuals have
a stake in the facility under consideration, its operations, corrective action,
or changes in its design or administration. As "stakeholders" they will
communicate and interact throughout the permitting process and possibly
throughout the life of the facility.
Public participation plays an integral role in the RCRA permitting process.
Officially speaking, EPA uses the term "public participation" to denote the
activities where permitting agencies and permittees encourage public input
and feedback, conduct a dialogue with the public, provide access to
decision-makers, assimilate public viewpoints and preferences, and
demonstrate that those viewpoints and preferences have been considered by
the decision-makers (see 40 CFR 25.3(b)). "The public" in this case refers
not only to private citizens, but also representatives of consumer,
environmental, and minority associations; trade, industrial, agricultural, and
labor organizations; public health, scientific, and professional societies;
civic associations; public officials; and governmental and educational
associations (see 40 CFR
25.3(a)). When one
considers "the public" in
this broad sense, public
participation can mean any
stakeholder activity carried
out to increase public's
ability to understand and
influence the RCRA
permitting process.
the public
the facility
the agency
Figure 1 — The Public Participation Triangle
We can represent the
relations between these
stakeholders as a triangle with the regulators, the facility owner/operator,
and the interested public each forming a corner. Out of each corner runs a
Chapter 2: Guidelines for Success
Page 2-1
-------
Public
participation is a
dialogue.
Why Bother With
Public
Participation?
Public input can
help the agency and
the permittee make
better technical
decisions.
line that represents each group's communication with the other participants
in the process.
In the best case, the stakeholders interact well, the lines of communication
are strong between all the parties, and information flows in both directions
around the triangle. This last point is important: public participation is a
dialogue. You will read more about this dialogue later in this chapter.
There are a number of reasons why agencies, facilities, and interest groups
should provide for RCRA public participation and why citizens should
make an effort to participate in RCRA decision-making. The first, and
most obvious reason, is that facilities and permitting agencies are required
to conduct public participation activities under the Act and its
implementing regulations. Additional activities provided by facilities,
agencies, and other organizations in the community can complement the
required activities.
The second reason to bother with public participation is "good
government." Permitting agencies are charged with making many
controversial decisions, which should not be made by technical expertise
alone. Public participation in controversial decision-making is an essential
element of the good government philosophy. Community members have a
right to be heard and to expect government agencies to be open and
responsive.
In addition to providing good government, the third reason for encouraging
public input is that it can help agencies reach better technical solutions and,
thus, make better policy decisions. Public input can also help permittees or
prospective applicants make better business and technical decisions. A
community is most qualified to tell you about its own needs, and people
who live with a facility every day will have the familiarity to provide useful
insights. Experience has shown that RCRA actions often benefit from
public participation. With public input, permitting decisions can gain a
breadth and an appreciation of local circumstances that technical staff alone
could not provide.
The fourth reason to bother with public participation is that RCRA actions
are more likely to be accepted and supported by community members who
can see that they have had an active role in shaping the decision. Showing
community members that the regulatory agency or the facility is willing to
address community concerns will establish the foundation for improved
understanding and community involvement in the process, even if members
of the community do not always agree with the outcome of that process.
By promoting public participation, permitting agencies can reduce the
potential for concern over less consequential risks and dedicate more
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What Makes A
Successful Public
Participation
Program?
Dialogue and Feedback
The address and phone
number of a contact
person should appear on
fact sheets, notices and
other outreach materials.
Public participation
should encourage
"feedback loops."
resources to addressing serious risks and issues. Many companies have
also found that promoting early and meaningful public participation can
save resources in the long run by avoiding delays and lawsuits based on
public opposition.
A successful public participation program is inclusive. It allows members
of the community to have an active voice in the RCRA decision-making
process. Agency staff, facility personnel, and citizens will be able to talk
openly and frankly with one another about RCRA-related issues, and search
for mutually-agreeable solutions to differences.
In addition to the paragraph above, a successful public participation
program will meet the targets set out in the subsections that make up the
remainder of this chapter. The principles in these following subsections are
applicable to all public participation activities.
A vital and successful public participation program requires a dialogue, not
a monologue. In other words, information must flow in loops between any
two stakeholder groups. For example, the regulators should not just release
information to the facility owner/operator, who passes it to the community,
who then contacts the regulators. The regulator should make the
information available to everyone and ask for feedback. Each corner of
the triangle must keep the two-way conversation going with the two
remaining corners.
Open communication lines require participants to be accessible to the other
stakeholders. An effective way to make your group accessible is to
designate a contact person for every permitting activity. The contact
person should make his or her address and phone number available to the
other stakeholders by printing it on any fact sheets or other informational
materials produced by the organization. The contact person will field all
inquiries on the permitting activity at hand. Other people involved in the
process will appreciate this single and accessible point of contact.
Without an active two-way communications process, no party will benefit
from the "feedback loop" that public participation should provide. For
example, if the regulatory agency sends out a fact sheet about an upcoming
permit action, that fact sheet alone does not constitute public participation.
Missing is the "feedback loop," or a way for the agency to hear from those
who read the fact sheet. To get feedback, the agency might name a contact
person in the fact sheet and encourage telephone or written comments,
place calls to civic or neighborhood associations, visit a community group,
or hold a meeting or workshop to discuss material in the fact sheet.
Feedback loops enable the agency to monitor public interest or concern,
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Members of the public
have valid concerns and
can often improve the
quality of permits and
agency decisions.
Honesty and Openness
adjust public participation activities, and respond quickly and effectively to
changing needs. The feedback loop is a useful tool for all stakeholders in
the process.
Even if a feedback loop operates successfully, public participation cannot
be successful if the permitting agency or the facility is reluctant or unable
to consider changes to a proposed activity or permit action based on public
comment or other input. While the decision-makers at the agency or the
facility need not incorporate every change recommended by the public,
they should give serious consideration to these suggestions and respond by
explaining why they agree or disagree. Members of the public, like other
stakeholders in the process, have valid concerns and can often contribute
information and ideas that improve the quality of permits and agency
decisions. Regulators and facility owner/operators should take special
notice of this point and make available more opportunities for public
participation.
As we emphasized in the section above, participants in the RCRA
permitting process should make all efforts to establish open paths of
communication. Being honest and open is the best way to earn trust and
credibility with the other stakeholders in the process. Making information
available to the community and providing for community input can
improve public perception of the permitting agency or the facility and lead
to greater trust and credibility. Trust and credibility, in turn, can lead to
better communication and cooperation and can focus the public debate on
issues of environmental and economic impacts.
Establishing trust should be the cornerstone of your public participation
activities. The following is a list of things to remember when establishing
your credibility:
1. Remember the factors that are necessary for establishing trust ~
consistency, competence, care, and honor.
2. Encourage meaningful involvement by other stakeholders.
3. Pay attention to process.
4. Explain the process and eliminate any mystery.
5. Be forthcoming with information and involve the public from the
outset.
6. Focus on building trust as well as generating good data.
7. Follow up. Get back to people. Fulfill your obligations.
8. Make only promises that you can keep.
9. Provide information that meets people's needs.
10. Get the facts straight.
11. Coordinate within your organization.
12. Don't give mixed messages.
13. Listen to what other stakeholders are telling you.
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A Commitment to the
Public
An Informed and Active
Citizenry
14. Enlist the help of organizations that have credibility with
communities.
15. Avoid secret meetings.
This list was adapted from the manual Improving Dialogue With
Communities (New Jersey Department of Environmental Protection, 1988).
This manual and a number of other sources produced by states, EPA, trade
groups, and public interest groups are available for more information on
trust and credibility factors.
Public officials have ethical obligations to the public that have a practical
value in building the foundation necessary for successful communication:
* informing the public of the consequences of taking, or not taking, a
proposed action;
* showing people how to participate so that interested people can;
* keeping the public informed about significant issues and proposed
project changes;
* providing all segments of the public with equal access to information
and to decision-makers;
* assuring that the public has the opportunity to understand official
programs and proposed actions, and that the government fully
considers the public's concerns; and
* seeking the full spectrum of opinion within the community, not only
from the business community and other agencies, but also from
neighborhood and community groups, environmental organizations,
and interests with other points of view.
(Adapted from Sites for our Solid Waste, Environmental Protection
Agency, EPA/530-SW-90-019, March 1990 and 40 CFR 25.3(c)).
If you are a citizen who is interested in a permitting issue, the regulations
provide a number of opportunities to access information and get involved.
The following activities are some things citizens can do to be influential
and well-informed participants.
• Contact the permitting agency early. Identify the designated contact
person for the project (the name should be on fact sheets and notices,
or available by calling the agency).
• Do background research by talking to local officials, contacting
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research or industrial organizations, reading permitting agency
material, and interacting with interested groups in the community.
Perform an assessment. Request background information from the
permitting agency, local officials, and the facility ownership. Ask
about day-to-day activities, the decision-making structure, and current
policies and procedures; inquire about how the proposed project fits
into larger political issues, local planning, and the facility's business
plans. Request special information that may open up additional
solutions, including pollution prevention approaches that may reduce
or recycle the amount of waste that is managed in the facility.
Ask to have your name put on the facility mailing list for notices, fact
sheets, and other documents distributed by the agency. Add your
name to mailing lists maintained by involved environmental groups,
public interest and civic organizations.
Tell the permitting agency, the facility owner/operator, and other
involved groups what types of public participation activities will be
most useful for you and your community. Inform them about the
communication pathways in your area (e.g., what newspapers people
read most, what radio stations are popular), the best locations for
information repositories and meetings, and other information needs in
the community (e.g., multilingual publications).
Submit written comments that are clear, concise, and well-
documented. Remember that, by law, permitting agencies must
consider all significant written comments submitted during a formal
comment period.
Participate in public hearings and other meetings; provide oral
testimony that supports your position. Remember that a public
hearing is not required unless someone specifically requests one in
writing.
If any material needs further explanation, if you need to clear up some
details about the facility or the permitting process, or you would like
to express specific concerns, then request an informational meeting
with the permitting agency or the appropriate organization, such as
the State's pollution prevention technical assistance office.
Follow the process closely. Watch for permitting agency decisions
and review its responses to public comments. Be aware that you have
an opportunity to appeal agency decisions.
Remember that your interest and input are important to the agency
Chapter 2: Guidelines for Success Page 2-6
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and other concerned stakeholders.
• To get tips about community organizing, information about how to
participate in the regulatory process, or possible referrals to other
involved groups in your area, you can contact the local League of
Women Voters chapter. If you cannot contact a local chapter, or one
does not exist, you can contact the state chapter. Phone numbers and
addresses are provided in Appendix C.
EPA encourages citizens to consider these recommendations and follow
them where applicable. At the same time, EPA recognizes that the best
way to participate will be different in every situation. Citizens should
contact other concerned persons, community organizations, and
environmental groups to determine how citizens can best influence the
permitting process.
Starting Early
A good public participation effort involves the public early in the process,
encourages feedback, and addresses public concerns before initial
decisions. The permitting agency, the facility owner/operator, and public
interest organizations involved in the RCRA permitting process should
make all reasonable efforts to provide for early stakeholder participation
and open access to information. These efforts should include informing and
seeking feedback from impacted communities before any significant
actions. You should avoid the appearance of making decisions before
public input. Even in cases where the facility and the agency meet
privately in the early stages of the process, they should keep up the lines of
communication with the public. One State agency has found success by
making a meeting summary available to the public in an information
repository whenever the regulators meet with facility staff. Such gestures
can increase public faith while reassuring people that the agency will seek
public input before making major permitting decisions.
EPA encourages public participation activities throughout the RCRA
permitting process, especially when the activities foster an early, open
dialogue with potentially affected parties. This can be particularly effective
in exploring alternatives to treatment or that go beyond compliance,
including for example, pollution prevention.
Early outreach and straightforward information can establish trust among
the other stakeholders while reducing misinformation and rumors. Key
contacts in the community should always know about planned activities that
will be visible to members of the community, such as construction work or
excavation related to facility expansions or corrective action. Interested
people or groups in the community can use early participation activities to
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Start early and plan
ahead: public interest in a
facility can grow rapidly
and unexpectedly.
make their concerns and suggestions known before major decisions take
place. Since early participation activities may be the first word that people
hear about a permitting activity, EPA is requiring expanded notice efforts
before the facility submits a permit application (see "Notice of the Pre-
Application Meeting" in Chapter 3). All stakeholders should use their
knowledge of individual communities and local communication channels
(e.g., contacts in the community, the media, civic and religious
organizations) to foster effective information-sharing.
RCRA regulations require facilities and agencies to start public
participation activities prior to application submittal, and continue them
through the entire life of the permit. In essence, the facility owner or
operator cannot put off public participation. EPA encourages permit
applicants and permit holders to take early public participation activities
seriously ~ early activities can set the tone for the permitting process and
even the entire life of the facility.
Setting up an effective public participation program is a valuable use of
time and resources. External pressure to start public participation work
may not be present at the outset of a project, because members of the public
may be unaware of the facility's operations and the regulatory agency's
activities. However, public interest in a facility can grow rapidly and
unexpectedly. Participants can best prepare for such situations by assessing
their communities, taking proactive steps, and preparing for contingencies.
Getting the news out early gives people time to react. Other stakeholders
can offer better information and suggestions when they have some time to
think about it. For example, a facility can better incorporate community
concerns into its permit application if it hears public concerns well before
application submittal. Agencies and facilities owe the public the same
courtesy, allowing citizens adequate time to review, evaluate, and comment
on important information. By the same token, citizen participants should
do their best to make their interests known early. If a citizen is invited to
participate early, but decides not to and raises issues at the end of a process,
then that citizen risks losing credibility with other stakeholders in the
process.
Finally, extensive early outreach (as we point out in the following section)
will make the permitting process or the corrective action smoother over the
long run. Early outreach brings issues to the surface before stakeholders
have invested great amounts of time and resources in a project; these issues
are easier to address at an early stage. Moreover, early outreach minimizes
the possibility that the public will feel like the agency or the facility is
surprising them with an undesirable project. By providing early notice,
agencies and facilities can avoid the public reactions that have "blind-
sided" some projects in the past.
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Assessing the Situation
Every community is
different. What works
in one community may
not work in another.
Public participation
activities should
change over time to
suit the level of
interest in a facility.
Community assessments are an important step to take before preparing or
revising a public participation strategy. Assessments are essential tools for
facility owners who are applying for a RCRA permit (including interim
status facilities), seeking a major permit modification, or undertaking
significant corrective action. Permitting agencies should focus their
assessments on communities where a major new facility is seeking a
permit, or in other cases where permitting activity or corrective action has
the potential to evoke public interest. Additionally, assessments may be
appropriate at any stage during the life of a facility, especially in situations
where the level of public interest seems to be changing.
Community assessments allow agencies, facility owners, and public interest
groups to tailor regulatory requirements and additional activities to fit the
needs of particular communities. Each community is different and has its
own way of spreading information and getting people interested. Important
institutions and groups will also vary from place to place, as will
socioeconomic status, culture and traditions, political and religious activity,
and values. The facility owner, public interest groups, and the agency
should make all reasonable efforts to learn the facts about the affected
community. These data are essential to choosing public participation
activities that will be useful and meaningful for the community.
Determining the Level of Public Interest
Some permitting activities do not generate much interest or concern among
community members. Other activities will evoke strong interest and will
require a much greater public participation effort. Although there are no
hard and fast rules that make a facility a low- or high-profile facility, the
level of interest will depend on a number of factors, such as (1) the type of
RCRA action and its implications for public health and welfare; (2) the
current relationships among the community, the facility, the regulatory
agency or agencies, and other groups; and (3) the larger context in which
the RCRA action is taking place, including the political situation,
economics, and important community issues. Exhibit 2-1 (at the end of
this Chapter) provides a guide for determining a facility's potential to be
low-, medium-, or high-interest to the public.
While these guidelines can be useful as an early planning tool to predict
public interest, agencies and facility owners should be flexible and prepared
for rapid changes in the level of public interest in a permitting activity. The
apparent level of public interest does not always reflect the potential for
public interest. In some cases, the regulatory minimum will be sufficient.
In other cases, the agency or facility should be prepared to provide
additional input and information, as needed. Public participation activities
should correspond to the level of community interest as it changes over
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time.
Public interest, environmental, and civic organizations also assess their
communities to determine the amount of interest in a permitting activity.
These organizations can take steps to encourage public participation in the
permitting process. Door-to-door canvassing, public information sessions,
flyers, fact sheets, neighborhood bulletins, and mailings are all methods of
sharing information with the public and encouraging citizen involvement.
Organizations that are attempting to encourage public participation may
find the rest of this section useful. In addition, more information for such
groups is available by contacting the League of Women Voters (see
Appendix C for contacts).
Community Assessment Methods
Facility owners should gather background information about the
community before seeking a permit or a permit modification. Regulators
should find out about community concerns at the outset of a major project
or any project that seems likely to raise significant public interest. Public
interest groups may want to perform similar background work. As
emphasized in the previous section, understanding a community is essential
to creating a successful public participation effort.
The facility owner is responsible for collecting his or her own information
about a community before initiating any permitting activity (e.g., before
requesting a permit modification or applying for a permit). Permitting
agencies, on the other hand, should dedicate their resources, using their
own judgment, to learning about concerns in the community and assessing
communities where there is a high level of interest in a permitting activity.
In some cases, permitting agencies and facility owners have cooperated to
do joint outreach activities, and believe that the agency presence has made
members of the community more comfortable during interviews or other
activities. EPA does not recommend such cooperation as a rule (because,
for example, other stakeholders could perceive this as "taking sides").
Permitting agencies should use their discretion and maintain the agency's
proper role during any such activities.
EPA recommends the following steps for gathering information about the
community. Although facility owners may want to follow these steps
before every major permitting activity (e.g., applying for a permit or a
major modification), permitting agencies should focus on major activities at
facilities that have the potential to raise significant public interest:
• Reviewing news clippings and other information that indicates how
the community is reacting to the facility or the permitting activity.
Chapter 2: Guidelines for Success Page 2-10
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of public interest.
• Talking to colleagues or anyone who has experience working with
members of the particular community.
• Contacting companies, universities, local governments, civic groups,
or public interest organizations that already have experience in the
community. These groups may be able to provide useful information
about community concerns, demographics, or reactions to other
industry in the area. They may be able to point you towards other
existing sources of community information.
If it seems like there is a low level of interest in the facility at this point,
and things are not likely to change, the agency and the facility owner can
begin planning the required public participation activities.
If, however, the facility shows indications of being a moderate- to high-
interest level facility, a more detailed analysis of the community might be
necessary, and additional public participation activities planned.
• To get a fuller picture, staff from the agency or the facility should
consider contacting community leaders and representatives of major
community groups to talk about the facility and the planned RCRA
EPA recommends ... .
.... . action. These interviews should represent a fair cross-section of
community interviews r
when there is a high level
viewpoints in the community. The community representatives may
have a feel for how much community interest there is in a permitting
activity. They also may be able to provide advice on how to handle
the situation.
• If there are indications of likely high interest from the outset (e.g., a
facility that is likely to be controversial is seeking a permit), the
agency or the facility owner should consider conducting a broad range
of community interviews with as many individuals as possible,
including the facility's immediate neighbors, representatives from
agencies that will participate in the RCRA action, community
organizations, and individuals who have expressed interest in the
facility (e.g., people on the agency's mailing list, newspaper
reporters, local officials). A detailed discussion of how to conduct
community interviews is provided in Chapter 5.
• After collecting the necessary information, the agency or the facility
may wish to prepare a brief summary of major community concerns
and issues (no more than five pages). The summary can be integrated
into the public participation plan document or used as the basis for
developing a "Question and Answer"-type fact sheet to distribute
back to the community. See Chapter 5 for additional information on
these activities.
Exhibit 2-2 at the end of this Chapter summarizes the steps to take in
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The scope of the
affected community
will vary from facility
to facility.
determining the level of public interest in facilities and gathering
background information.
Targeting Public Participation in Communities
This initial assessment should provide a good idea about the scope and
makeup of the "affected community." Pinpointing the affected community
can be a difficult process; everyone has a different definition. EPA will not
try to define the affected community here because its composition will vary
with the particular characteristics of each facility and its surrounding
community. In some cases, however, it may be appropriate to target a
segment of the population that is broader than the "affected community."
For instance, the appropriate target for early public notices and some other
activities may go beyond people who are directly affected, to include
citizens who are potentially interested or concerned about the facility. EPA
recognizes that the distinction between "affected" and "concerned" or
"interested" will not be completely clear in all cases. Permitting agencies
should use their best judgment.
EPA realizes that resources will limit the breadth of any public
participation program and that focus is necessary. It is clear that some
people will have a more direct interest than others in a particular permitting
activity. Given practical resource limitations, public participation activities
should focus first on people with a more direct interest in a RCRA facility,
while also realizing that "direct interest" is not always determined by
physical proximity to a facility alone. It is impossible to point out all
people who have a direct interest, but, as a general guideline, people with
the most direct interests will live in the general vicinity of the facility, or
have the potential to be affected by releases to groundwater, air, surface
water or the local environment (e.g., through game, livestock, or agriculture
or damage to natural areas). Direct interests may also include people who
live on or near roads that will accept increased traffic of hazardous waste-
carrying vehicles. EPA acknowledges that people residing a significant
distance from the facility may have legitimate and important concerns, but
EPA thinks it is reasonable to focus limited public participation resources
on communities with direct interests. See the section on "The Mailing
List" in Chapter 3 for a list of organizations that you should consider when
thinking about the interested or affected community.
The Citizen's Role
Citizens in the community may want to assess the permitting situation, the
agency (or agencies) involved, and the facility owner/operator. As we
pointed out in the section above, citizens can get background on a
permitting issue by talking to local officials, contacting research or
industrial organizations, reading permitting agency material, and interacting
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Valuable public
interaction can take place
outside of the formal
permitting process.
with interested groups in the community. Citizens may also want to find
out about day-to-day activities at the facility or the agency, the decision-
making structures they use, and their current policies and procedures.
Citizens may want to get more information on the owner's/operator's
involvement with other facilities or other activities. The contact persons
for the facility and the agency are also good to know. Citizens can also talk
to local officials, the agency, or the facility to find out how the proposed
project fits into larger political issues, what local planning issues are
involved, and what the facility's business plans are.
Individual community members can take part in the assessment process by
providing input to other stakeholders through interviews, focus groups, or
other methods used in community assessments (also see the section on "An
Informed and Active Citizenry" earlier in this Chapter). This guidance
manual gives an overview of the RCRA permitting process which
individual community members may find helpful. The Appendices at the
end of this manual provides other resources and contacts (the RCRA
Hotline, agency phone numbers, and League of Women Voters' contacts)
that citizens can access. EPA is also compiling a reference list of public
participation and risk communication literature. The list is available
through either the RCRA Information Center, in Docket Number F-95-
PPCF-FFFFF, or through the RCRA Hotline (see Appendix A for
appropriate telephone numbers). Members of the public can find out about
permit activities in their area by contacting the permitting agency, talking
to environmental groups or public interest organizations, reading state,
federal, and private environmental publications in the library, looking for
zoning signs or other announcements, attending public meetings and
hearings, watching the legal notice section of the newspaper or checking
display advertisements, listening to local talk shows, or keeping up with
local events through town bulletins, associations, or council meetings.
In addition, members of the community can contact the permitting agency
or the facility ~ outside of any formal activity ~ to give early input and to
share their concerns. Community members should suggest public
participation activities, meeting locations, or means of communication that
will work well in their community. This sort of informal communication,
via letter or interview, can be very helpful, especially in terms of
establishing a public participation plan (see Chapter 5 for a description of
public participation plans). EPA also recognizes that valuable public
interaction takes place outside of the formal permitting process. Citizens
may choose to contact other groups in the community that have an interest
in the permitting activity. Environmental, public interest, and civic
organizations often play a role in the RCRA permitting process. These
groups can provide interested citizens the opportunity to participate in
efforts to influence the permitting process through collective action.
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Alternatively, citizens may see fit to create new organizations to discuss
issues related to the permitting process or to provide input into the process.
Planning for
Participation
The plan should create a
structure for information
to flow both to and from
the public.
A good public participation program avoids misunderstandings by
anticipating the needs of the participants. It provides activities and
informational materials that meet the needs of, and communicate clearly to,
specific community members and groups. The public participation plan is
the agency's schedule and strategy for public participation during the initial
permitting process, significant corrective actions, and other permitting
activities at facilities receiving high levels of public interest.
After assessing the situation, the agency should have an approximate idea
of how interested the public is in the facility. Based on the information
from the community assessment, the agency should draft a plan addressing
public participation activities throughout the prospective permitting process
and the life of the facility. For permitting activities and corrective actions
that do not raise a high level of public interest in the community, the public
participation plan will be a simple document, outlining the regulatory
requirements. Major permitting activities and other high-interest activities
will require a more detailed plan with participation opportunities that go
beyond the requirements. Agency staff should keep in mind that
community interest in a particular facility can change at any time; good
plans will prepare for contingencies.
EPA recognizes that permitting agencies do not always have the resources
they need to perform all the public participation activities they would like
to perform. Agency staff must consider resources in all stages of the
process, but particularly when developing a public participation plan. To
make fewer resources go further, agencies should consider working with
community groups, public interest organizations, and facility
owners/operators to plan public participation events. Some relatively
inexpensive activities can be very effective. More information on making
use of additional resources is available in Appendix M. Information on the
resources needed to perform specific public participation activities is
available in Chapter 5.
The goal of the public participation activities in the plan is to meet the
specific needs of members of the community by creating a structure for
information to flow both to and from the public. Anyone who plans public
participation activities should strive for useful and timely exchange of
information with the public. Again, EPA strongly encourages anyone
conducting public participation activities to solicit public input on the types
of communication and outreach activities that will work best in each
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community. The agency, facility, civic and public interest groups should
coordinate their public participation efforts, emphasizing two-way
information exchange and avoiding unnecessary duplication in their
activities.
To identify activities for the public participation program, the agency
should go through the following steps:
1. list the major community issues and concerns;
2. list the community characteristics that will have a bearing on
how you address these issues; and
3. list the activities that will address the community's concerns
during the permitting process and, if applicable, corrective
action.
Once the agency has outlined activities for the facility at hand, it should put
together a strategy for implementing the activities. In general, the
following are the areas of responsibility for public participation that the
agency should consider:
• Interacting with the media, especially on high-profile facilities. If
there is a high degree of interest in the facility, it will be important to
have a media contact person who can get information out quickly,
accurately, and consistently. The assistance of a public affairs office
is often necessary (where applicable).
• Interacting with elected officials. For facilities receiving a
moderate to high level of interest, it is often beneficial to work with
elected officials to provide them with information they need to answer
their constituents' questions. Put together a team of people who can
fill the information needs of public officials. This team should
include senior people who can answer policy questions when
necessary.
• Answering telephone and written inquiries. It is important to
follow up on all requests for information that you receive from
stakeholders. Designate one person to be responsible for putting
together the answers to questions in a form that is understandable to
the public. This "contact person" should be named in all fact sheets
and public notices. Remember the importance of two-way
communication and the public participation triangle.
• Coordinating public participation with other stakeholders. It is
crucial that all the people who are working on public participation be
aware of what activities are being planned for the facility and any
other facilities in the area, so that activities can complement each
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Public participation
activities should
coincide with major
steps in the
permitting process.
other whenever possible. At the least, try to avoid conflicts between
competing activities. Be sensitive to major events (e.g., celebrations,
other meetings, religious revivals, fundraisers, elections) and
important dates (e.g., local holidays, graduations) in the community.
• Maintaining the mailing list and information repositories. A
mailing list is required under RCRA and the agency should update it
to include new people or organizations who have expressed an interest
in the facility. The facility and other organizations should refer to the
agency any requests to be on the official facility mailing list. If public
information repositories are established for the facility, they should be
indexed and updated at least quarterly, or as required by the
permitting agency. The facility may want to obtain a copy of the
mailing list to use for distributing information.
• Planning and conducting public meetings. Set-up and coordination
are critical to the success of public meetings. Public participation
staff will need to choose a location for meetings based on public input
and the need for comfort and accessibility. The public participation
coordinator will need to schedule speakers, plan the agenda, and
provide a mediator (if necessary) at the meeting. Chapter 5 provides
more detail on public meetings, hearings, workshops, etc.
• Handling production/distribution/placement of information,
including fact sheets, public notices, news releases, meeting
handouts and overheads, etc. Much of your public participation
time will be spent developing and producing information for
interested stakeholders. Permitting agency staff may want to refer to
Appendix M for a list of resources that can ease fact sheet and infor-
mation production. Sometimes you may need to refer stakeholders to
other agencies that have information readily available, such as the
State pollution prevention technical assistance office, which often
have fact sheets and technical experts available. A list of pollution
prevention contacts is included in Appendix S.
The next step is to figure out a schedule of public participation activities.
This schedule should include activities that are required by EPA
regulations. In general, the timing of additional public participation
activities should correspond to the completion of major steps in the
technical process (e.g., application submittal, draft permit issuance,
completion of the RFI). These are the times when members of the public
may have new questions or concerns about the proposed action or the
facility in light of new information, especially during corrective action.
The regulators and the facility owner/operator should also be prepared to
notify the public when any major activity will be taking place at the facility
(e.g., start of construction for corrective action) or has taken place (e.g.,
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Communities can
provide valuable advice
on what public
participation activities
will work best.
emergency response to releases).
Permitting agencies should take the lead in writing and revising public
participation plans, while allowing for input from other stakeholders and
coordinating with activities held by the facility, public interest groups, and
community organizations. The agency may want to involve other
stakeholders in a group process to form a comprehensive plan. Depending
on the amount of public interest in a facility, the plan could be an informal
one- or two-page document or a formal public involvement plan that will
be available to members of the community for comment. At a minimum,
the plan should include a list of the specific public participation activities
for the facility and a schedule for when they will occur. We encourage
agencies to make these plans - formal and informal ~ available to the
public.
Developing a written public participation plan will help staff account for all
the necessary steps in the permitting or corrective action process. A formal
plan will also let the public know what type of activities to expect during
the process. EPA recommends that a formal plan contain the following
sections:
executive summary;
introduction/overview;
facility history;
the RCRA action taking place;
summary of community interviews, outlining concerns;
a description of any early consultation (e.g., interviews with
group leaders) that led to development of the plan;
a list of the major issues likely to emerge during the process;
an estimation of the level of public interest likely to be
generated by the decision under consideration;
public participation activities and schedule;
a list of the agencies, groups, and key individuals most likely to
be interested in the process;
a list of key contacts; and
information on meeting and repository locations, where
applicable.
EPA encourages permitting agencies to seek public input on the plans; final
plans should be available for public review. This sort of input is important
for getting the public involved early in the process. In addition,
communities can provide useful advice on what channels of communication
will work best in the area and what sort of activities will provide the most
effective participation. Communities can provide practical solutions that
improve communication and may even save resources. For example, in
one community where rumors spread easily, citizens suggested that the
agency put status reports on voicemail so that people could call in for
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Understanding and
Interaction Between
Stakeholders
regular updates.
There are numerous ways that the community can contribute during the
planning stage. Citizens can decide how interested they are in a particular
activity by discussing issues with other stakeholders, accessing relevant
documents, or calling hotlines or other experts. Those who would like to
participate in the formal process can use this time to raise questions or
develop their ideas. Some citizens may want to submit comments to the
agency on the public participation plan. Moreover, EPA encourages
interested citizens to meet together to discuss the potential impact of RCRA
actions on their communities. Citizen groups may want to invite experts
from the facility, the permitting agency, engineers, environmental
contractors, scientists, health experts, and attorneys to speak at their
meetings.
While each stakeholder shares the responsibility of providing open and two-
way communication, the roles and responsibilities of the different
stakeholders differ substantially. Participants in the RCRA permitting
process should acknowledge these differences and account for them as they
approach the process. We encourage participants to do their best to
understand the interests and concerns of the other participants by following
the principles below:
* Strive to respect other stakeholders and their opinions. Avoid
personal attacks.
* Understand that people have different levels of understanding of
RCRA. Not everyone is an expert, but everyone should have the
chance to know all the facts.
* Realize that decisions made during the permitting process can have
profound economic and social impacts. These decisions are very real
and important; people will live and work with them every day.
* Acknowledge that statutory and regulatory requirements limit what
can happen during the permitting process. Remember that everyone -
- citizens, regulators, facility owners/operators, and public interest
workers - has resource and time constraints
* Recognize that people have concerns that go beyond the scientific or
technical details. These concerns deserve respect.
* Build your credibility by being fair, open, and respectful.
* Try to understand the values and interests of other stakeholders before
jumping to conclusions.
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Promoting
Environmental Justice
New EPA rules will
empower
communities by
giving them a greater
voice in the permitting
process.
Environmental justice refers to the fair distribution of environmental risks
across socioeconomic and racial groups. Some groups and individuals
associated with environmental justice issues have raised the concern that
EPA and some State environmental agencies do not provide equal
protection under the nation's environmental laws. With regard to the
RCRA permitting program, most of the concern surrounds the potential
additional risk that hazardous waste facilities may pose when located near
low-income or minority communities that already face an environmental
burden from multiple sources.
On February 11, 1994, the President issued Executive Order 12898,
directing federal agencies to identify and address the environmental
concerns and issues of minority and low-income communities. EPA is
committed to the principles in this Executive Order. Furthermore, in an
effort to make environmental justice an integral part of the way we do
business, the Agency issued a policy directive, in September 1994
(OSWER 9200.3-17), that requires all future OSWER policy and guidance
documents to consider environmental justice issues.
EPA is committed to equal protection in the implementation and
enforcement of the nation's environmental laws. Moreover, providing
environmental justice for all U.S. residents is a major priority for EPA.
In the area of public participation, the Agency has made changes that will
empower communities and potentially increase their voice in the permitting
process. In the "RCRA Expanded Public Participation" rule (60 FR 63417-
34, December 11, 1995), EPA created more opportunity for public
involvement in the permitting process and increased access to permitting
information. The rule gives all communities a greater voice in decision
making and a clear opportunity to participate in permit decisions early in
the process.
EPA strongly encourages facilities and permitting agencies to make all
reasonable efforts to ensure that all segments of the population have an
equal opportunity to participate in the permitting process and have equal
access to information in the process. These efforts may include, but are not
limited to:
• Providing interpreters, if needed, for public meetings.
Communicating with the community in its language is essential for
the two-way information flow required to ensure the public an
equitable voice in RCRA public participation activities.
• Providing multilingual fact sheets and other information. Making
sure that the materials presented to the public are written clearly in
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the community's primary language.
• Tailoring your public participation program to the specific needs
of the community. Developing a program that specifically addresses
the community's needs will demonstrate to community members your
interest in achieving environmental equity and fostering a sense of
cooperation.
• Identifying internal channels of communication that the
community relies upon for its information, especially those
channels that reach the community in its own language. Examples
of these "channels" are a particular radio show or station, a local
television station, a non-English newspaper, or even influential
religious leaders. By identifying and making use of these valuable
communication channels, you can be sure that the information you
want to publicize reaches its target audience.
• Encouraging the formation of a citizens advisory group to serve
as the voice of the community. Such groups can provide meaningful
participation and empowerment for the affected community (see
Chapter 5 for more detail).
(Additional steps you can take to promote environmental justice are
available in Appendix D).
Although EPA has taken steps on a national level to address environmental
justice issues, many of these issues can be addressed more effectively at a
local level and on a site-specific basis. Local agencies and leaders have an
important role to play in addressing environmental justice concerns.
The RCRA permitting process is intended to ensure that facilities are
operated in a manner that is protective of human health and the
environment. Environmental justice concerns are often broader in scope,
going beyond the technical design and operation of the facility to include
socio-economic, ethnic, and racial factors for the surrounding community.
Within the context of public participation in RCRA permitting, the best
way to address environmental justice concerns is through active
communication. Keeping open lines of communication among permitting
agencies, facility owners, and community members is a good way to
promote awareness and understanding of the permitting process, the facility
operations, and the community's concerns. Providing frequent
opportunities for community participation empowers the community to play
an important role throughout the process.
Permitting agencies should be forthright in explaining the scope and
limitations of permitting regulations to the community. Agencies should
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Supporting Community-
Based Environmental
Protection
The best solutions to
many environmental
challenges are available
at the community level.
also make sure that citizens understand their rights within the permitting
process (e.g., submitting comments, requesting a public hearing, appealing
permit decisions). Facility owners should strive to establish good relations
with the community and routinely interact with community members and
organizations, seeking input and feedback when making significant
decisions. Communities should gather information about other rights,
outside of the permitting process, such as those afforded under Title VI of
the Civil Rights Act.
In its May, 1995 Action Plan, EPA's Office of Solid Waste and Emergency
Response (OSWER) endorses community-based environmental protection
(CBEP). CBEP is a method of solving environmental problems in the
context of the community in which they occur. OSWER's plan points to
CBEP as a method that "brings the government closer to the people it is
meant to serve." It also heralds CBEP as "a new way of accomplishing
traditional tasks in a more effective, more responsive manner."
Stakeholder involvement is one of the keys to CBEP. OSWER's plan
points to CBEP efforts as ones that "must empower and equip the
community to participate in environmental decisions, taking into account
not only the human but also the ecological and socioeconomic health of a
place." Thus, the involvement and cooperation of the community, facility
owners and operators, and agency personnel in the permitting process will
fuel CBEP efforts. Moreover, increased access to information and
opportunities for participation in the permitting process (like those in the
RCRA Expanded Public Participation Rule ) will empower communities
and enable them to practice CBEP.
We encourage permitting agencies, facility owners and operators, public
interest groups, and members of the community to carry out the spirit of
this manual. As we emphasized in the section on "Promoting
Environmental Justice" above, the best solutions to many environmental
challenges are available at the local community level, and no problem can
be solved without input from local stakeholders. Only by cooperating,
communicating, and providing feedback and equal opportunities can
community-based programs reach their potential for solving environmental
problems.
Permitting agencies can take a lead role in promoting a CBEP approach by
discussing RCRA issues in coordination with other environmental concerns
in a given area. Program distinctions between water, air, waste, and toxics
are less important to stakeholders outside of the agency. Agency staff
should be prepared to address RCRA concerns in the context of air and
water issues that may reach beyond a particular facility. Many companies
are particularly interested in finding opportunities to reduce process wastes
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Re-evaluating and
Adjusting the Public
Participation Program
through pollution prevention and recycling that affect air, water, and waste
permit requirements. Several states are embarking on "whole facility"
approaches to permitting to take advantage of this approach. Permitting
agencies should consider using fact sheets and availability sessions to
explain RCRA's relationship to other programs. Combining public
meetings across program lines could also make the entire environmental
picture more clear to stakeholders.
As RCRA activity increases at a facility and becomes more visible, public
interest in a site can increase dramatically. Interest can also fade away
without warning. Participants in the permitting process should anticipate
and plan for sudden changes in the level of interest in a facility. Periodic
communication with key community contacts can help to anticipate
changes in the attitude or interest of other stakeholders. All participants
should make sure to keep their key contacts informed of all planned
activities ~ especially activities that are highly visible and tend to raise a lot
of interest, such as construction work or excavation related to cleanups.
In addition, at facilities that are receiving high levels of public interest, the
agency or the facility may want to conduct follow-up community
interviews at a key point (or points) in the decision-making process. These
interviews will help predict major shifts in public interest or concern. The
agency should also encourage members of the community to submit
comments throughout the process and especially during formal comment
periods. Agency staff should make clear to the public (e.g., through fact
sheets) how the comment and response process works.
Permitting agencies, facility owners, and other involved organizations
should evaluate the effectiveness of public participation programs regularly
through the process. The permitting process is complex and the best way to
measure the success of a public participation plan is not always clear. The
following are indicators that a public participation program is working:
stakeholders are not asking the same questions over and over
again;
stakeholders are not raising concerns about a lack of
information;
the appropriate contact person is handling inquiries in a timely
manner;
most of the public participation time is not devoted to correcting
breakdowns in the information-sharing triangle (see above)
between the community, the agency, and the facility;
the channels of communication are well-defined and open;
interested parties are providing informed comments on the
project; and
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The best way to evaluate
the success of a public
participation program is to
ask other stakeholders what
is and isn't working.
members of the public are bringing their concerns to
stakeholders that are actively involved in the process, rather than
taking them directly to the press or elected officials.
Creative, more flexible, technical solutions, including pollution
prevention solutions, are being explored.
If the program is not achieving these objectives, then the agency, facility,
and involved groups need to assess their techniques and determine what
changes will improve the program. If members of the community are
dissatisfied, then public participation activities may not be reaching the
right target audiences. The community may not have adequate access to
information or may not be understanding it because it is too complex. In
some cases, the public may need more detailed information. The
community may feel uncomfortable in relations with the facility or the
agency, or the agency or the facility may be uncomfortable relating to the
community. The facility may not understand its role in the process in
relation to the agency's role. All of these difficulties can reduce the
effectiveness of the public participation program. The best way to find out
what is going wrong is to talk to the community and the other stakeholders.
Ask them what is working and where improvements are needed. Modify
public participation activities based on their suggestions and your own time
and resource limitations.
Members of the community should have a chance to evaluate the public
participation activities that the agency, the facility, and public interest or
other groups are employing. EPA encourages participants to solicit
feedback from the public, going beyond the regulatory requirements where
necessary. Surveys, interviews, or informal meetings are all effective
ways to gather feedback. In addition, the agency, facility, and involved
groups should explain the permitting process to the community, update the
community on significant activities, and provide information that
community members can access and understand. If these standards are not
being met, then the community should communicate its concerns to the
appropriate contact person. Citizen input is the feedback that makes two-
way communication work. All involved organizations should create a
means for citizens to let them know if public participation activities are not
working (e.g., use of a contact person, suggestion boxes, hotlines, surveys,
etc.). Once these organizations know where the breakdown is occurring,
they can adjust their programs to address community concerns.
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Chapter Summary
Public participation, defined broadly, is any stakeholder activity carried out to increase public input or understanding of the
RCRA permitting process.
The public participation triangle represents the communication between the public, regulators, and the facility.
Public participation is based on a dialogue.
Public participation is required, it can lead to better technical decisions, and it can engender public support for a project.
A successful public participation program allows members of the community to have an active voice in the process and to have
free access to important information. Participants in a successful program will also pursue the following benchmarks:
Creating a dialogue that provides for feedback;
Establishing trust and credibility in the community through honesty and openness;
Fostering an informed and active citizenry that follows the process, gives input to other stakeholders, and discusses
issues with other concerned groups and people;
Ensuring that public officials meet their obligations to the public;
Involving the public early in the process, receiving feedback, and addressing public concerns before making
decisions;
Assessing the community to find out from citizens what types of activities would best allow them to participate;
Planning your public participation activities ahead of time, allowing flexibility for changing interest levels in the
community;
Understanding and respecting the values and limitations of other stakeholders;
Taking steps, such as issuing multilingual fact sheets or encouraging the formation of citizen advisory groups, to
ensure that all segments of the interested community have an equal opportunity to receive information and
participate in the process;
Supporting efforts to respond to environmental challenges on a community level; and
Periodically evaluating the effectiveness of your program in the community and adjusting as community attitudes
and interest levels evolve.
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Exhibit 2-1
Determining the Likely Level of Public Interest in a RCRA Facility
Level of Interest
Type of RCRA Action
Community Members' Relationships With
Facility/Regulatory Agency
Larger Context
Low Level of Public Interest in
a Facility
The RCRA activity is unlikely to be
controversial (e.g., a routine modification)
There is no contamination at the facility that
could come into direct contact with the public
People do not live near the facility
There is a history of good relations between the facility
and members of the community
Members of the community have expressed confidence
in the regulatory agency and/or the facility
The facility receives very little media
attention and is not a political issue
Community members have not shown any
past interest in hazardous waste issues
Moderate Level of Public
Interest in a Facility
The RCRA action may involve activities, such
as §3008(h) corrective action activities, that
contribute to a public perception that the
facility is not operating safely
Examples may include permits for storage and
on-site activities and routine corrective
actions.
Highly toxic and/or carcinogenic wastes may
be involved (e.g., dioxins)
A relatively large number of people live near the facility
There is a history of mediocre relations between the
facility and members of the community
The facility is important to the community economically,
and the action may affect facility operations
Members of the community have had little or poor
contact with the regulatory agency
Local elected officials have expressed concern about the
facility
Community members have shown concern
about hazardous waste issues in the past
The facility receives some media attention
and there are organized environmental
groups interested in the action
There are other RCRA facilities or CERCLA
sites in the area that have raised interest or
concern
High Level of Public Interest in
a Facility
The RCRA action includes a controversial
technology or is high-profile for other reasons
(e.g., media attention)
Highly toxic and/or highly carcinogenic
wastes are involved (e.g., dioxins)
There is potential for release of hazardous
substances or constituents that poses potential
harm to the community and the environment
There is direct or potential community contact
with contamination from the facility (e.g., con-
taminated drinking water wells or recreation
lake)
The nearest residential population is within a one-mile
radius
A relatively large number of people live near the facility
There is a history of poor relations between the facility
and the community
The facility has violated regulations and community
members have little confidence in the regulatory agency
to prevent future violations
There is organized community opposition to the facility's
hazardous waste management practices or to the action
Outside groups, such as national environmental
organizations, or state or federal elected officials have
expressed concern about the facility or action
The economy of the area is tied to the facility's operations
Community members have shown concern
about hazardous waste issues in the past
Facility activities are an issue covered widely
in the media
There is interest in the facility as a political
issue, at the local, state, or federal level (e.g.,
statewide and/or national environmental
groups are interested in the regulatory action)
There are other issues of importance to
members of the community that could affect
the RCRA action (e.g., concern over a cancer
cluster near an area where a facility is
applying for a permit to operate an inciner-
ator)
There are other RCRA facilities or CERCLA
sites nearby that have been controversial
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Exhibit 2-2
Steps in Evaluating Facilities and Gathering Information
Step 1: Review the RCRA Action
Is it:
D Likely to be a controversial action (e.g., permitting a commercial waste management facility)
D Unlikely to be a controversial action
Step 2: Talk to colleagues who have worked in this community about their
interactions with members of the public
• Has there been a large degree of public interest or concern about other projects?
• Have members of the public shown confidence in the regulatory agency?
Step 3: Review regulatory agency (or any other) files on the facility
Are there:
D A lot of inquiries from members of the public
Major concern(s)
Any organized groups?
i?
D Few inquiries from members of the public
D Clippings from newspapers or other media coverage
Step 4: Formulate your preliminary impression of the community based on the above information
Step 5: Talk with several key community leaders to confirm your impression
People to interview:
1.
2.
3.
Step 6: Determine the anticipated level of community interest based on the above information
D Low (go to Step 7)
D Moderate (next step: conduct additional community interviews with one member of each community
subgroup)
D High (next step: conduct a full set of community assessment interviews)
Step 7: Write a brief summary of any major community concerns/issues
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Chapter 3
Public Participation During the
RCRA Permitting Process
Introduction
States may have their
own public participation
requirements in addition
to the federal
The previous chapter examined the importance of public participation and
the information-sharing triangle, while reviewing the critical components
for building a successful public participation program. Chapter 3 describes
the specific public participation activities that EPA requires or recommends
during each phase of the RCRA permitting process, beginning before
submission of the RCRA part B permit application, continuing through the
preparation of draft and final permit decision, and throughout the life of the
RCRA permit.
Section 7004(b) of RCRA and EPA's permitting regulations, found in 40
CFR Parts 124 and 270, form the foundation for mandatory public
participation activities during the permitting process for both operating and
post-closure permits. The reader should note that the corrective action
schedule of compliance and other corrective action provisions are typically
part of the RCRA permit under 40 CFR Part 270 (unless carried out under
an enforcement order). Changes to these sections of the permit must follow
the permit modifications procedures of 40 CFR Part 270.41 or 270.42. We
review the corrective action public participation procedures in Chapter 4.
RCRA permitting regulations require an array of public participation
procedures during the permitting process and the life of the permit.
However, situations often occur where the facility and the agency will need
to go beyond the requirements in 40 CFR Parts 124 and 270. Following the
assessment and planning guidance we provided in Chapter 2, participants in
the permitting process will discover whether a certain permitting activity
deserves greater public participation. Regulators, facility staff, or
community groups may want to consider expanded public participation
activities (described in this chapter and in Chapter 5) ~ if resources allow -
at priority facilities, controversial facilities, or at facilities where the
affected community has a particular need for greater involvement or access
to information. Participants in the process should seek input from other
stakeholders to determine if the public participation activities are adequate.
The permitting agency may suggest that the facility or public interest
Chapter 3: RCRA Permitting
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Public participation
activities should fit the
diversity, character, and
culture of the affected
community.
groups conduct additional activities to supplement required activities and
strengthen communication and trust among stakeholders. In addition, EPA
encourages the community to suggest additional public participation
activities to the permitting agency, the facility, or community and public
interest groups.
In December 1995, EPA expanded the public participation requirements in
the RCRA program by promulgating new regulations. The new
regulations, known as the "RCRA Expanded Public Participation" rule (60
FR 63417, December 11, 1995), require earlier public involvement in the
permitting process, expand public notice for significant events, and enhance
the exchange of permitting information. The new requirements, which we
describe more fully in this chapter, include: (1) a public meeting held by
the facility prior to submitting the part B RCRA permit application; (2)
expanded notice requirements, including use of a posted sign, a broadcast
notice, and a newspaper display advertisement to publicize the meeting; (3)
notification of the public when the agency receives a permit application and
makes it available for public review; (4) permitting agency discretion to
establish an information repository, which will be supplied and maintained
by the applicant or permit holder; and, (5) additional notices during the trial
burn period for combustion facilities.
In addition to the new regulatory requirements, EPA is taking steps to
ensure equitable public participation in the RCRA permitting process. On
December 20, 1995 EPA Office of Solid Waste and Emergency Response
(OSWER) Assistant Administrator Elliot Laws issued a memorandum to
the EPA Regional Administrators stating the Agency's policy to ensure
equal access to permitting information and provide an equal opportunity for
all citizens to be involved in the RCRA permitting process (see Appendix
N). In this manual, we are strongly encouraging facilities to meet the same
standard of equitable public participation. EPA is committed to equal
protection of our citizens under the nation's environmental laws and urges
all participants in the RCRA permitting process to strive for environmental
justice, equal opportunity to participate in permitting, and equal access to
information.
To meet this standard, EPA (when it is the permitting agency) will issue
multilingual notices and fact sheets and use translators, where necessary, in
areas where the affected community contains significant numbers of people
who do not speak English as a first language. In addition, the Agency
recommends that facilities make efforts to tailor public participation
activities to fit the diversity, character, and culture of the affected
community. When communicating with a community, participants in the
permitting process should take into account the particular pathways and
methods of information transfer that are used by that community. These
principles are applicable to all public participation activities, and EPA
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Public Participation
During the Permit
Decision Process
Step One: The Pre-
Application Stage
encourages their adoption by all participants in the RCRA permitting
process. See the section entitled "Promoting Environmental Justice" in
Chapter 2 for more information.
The permit decision process is composed of a number of steps. Each step
is accompanied by public participation requirements. As we have
mentioned, the regulatory minimum for public participation may not be
sufficient in all cases. Permitting agencies and facilities should consider
going beyond the regulatory requirements, where necessary, to provide for
meaningful and equitable public participation.
For the sake of simplicity, in this manual we will divide the permit decision
process into four steps:
• the pre-application stage;
• application submittal, agency notice and review;
• preparation of the draft permit, public comment period, and the
public hearing; and
• response to public comments and the final permit decision.
Stakeholders should keep in mind that the permit decision process is
lengthy and can be complex and confusing. Keeping the lines of
communication open during the process takes effort on the part of all
participants. This effort is especially critical during the long periods of
time while the agency is reviewing the permit or the facility may be
responding to a Notice of Deficiency (which we describe later in this
Chapter). The agency, the applicant, and other interested groups should
take steps to keep the community involved and informed during these
"down" times.
We also encourage stakeholders to learn about the process, ask questions,
and discuss it with the other participants. Permitting agencies in particular,
should make efforts to disseminate fact sheets and information packages
about the permitting process. Agencies, public interest groups, or facilities
may want to perform other public information tasks (see chapter 5 for
descriptions) to ensure that all stakeholders understand, and are
comfortable with, the permitting process.
Required Activities
The RCRA Expanded Public Participation rule requires a new permit
applicant (or a facility that is applying to renew a permit while making
significant changes) to hold a public meeting prior to submitting the part B
RCRA permit application. This meeting is the earliest formal step in the
Chapter 3: RCRA Permitting
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The Pre-Application
Meeting
The pre-application
meeting will allow the
facility to hear and
respond to public
concerns.
RCRA permitting process.
Early public input can improve the quality of any permitting activity; the
public can contribute information and recommendations that will be helpful
to agencies as they make permitting decisions and to facilities as they
develop their applications and proposals.
The most important goal EPA hopes to achieve from the pre-application
meeting requirement is the opening of a dialogue between the permit
applicant and the community. We believe that the applicant should open
this dialogue at the beginning of the process. The meeting will give the
public direct input to facility personnel; at the same time, facility personnel
can gain an understanding of public expectations and attempt to address
public concerns before submitting a permit application. We hope that this
requirement will help address the public concern that public participation
occurs too late in the RCRA permitting process.
Conducting the Meeting
The pre-application meeting should provide an open, flexible, and informal
occasion for the applicant and the public to discuss the various aspects of a
hazardous waste management facility's operations. Discussion at the pre-
application meeting need not concern the technical aspects of the permit
application in extensive detail; such technical examination is more suited to
the draft permit stage (which we describe later in this Chapter). We
anticipate that the applicant and the public will use this meeting to share
information, learn about each other's concerns, and start building the
framework for a solid working relationship. The pre-application stage is
also an excellent time to explore the facility's level of expertise in waste
minimization and pollution prevention, and the potential for involving the
facility's waste minimization experts in the public participation process.
While a formal meeting style (i.e., like a public hearing) may suit some
permitting situations, EPA realizes that it will not fit in all cases. With this
idea in mind, EPA has written the regulations to allow flexibility in the type
of "meeting" held by the permit applicant. For instance, an applicant may
decide to hold an availability session or open house (see Chapter 5) in place
of a traditional meeting. As long as this approach meets the requirements
and the spirit of § 124.31 (as presented in this section), EPA will not
preclude applicants from tailoring meeting styles to fit particular situations.
Regardless of the type of meeting that the applicant decides to hold, the
applicant (as well as the other participants in the process) should strive for
equitable participation and access to information during the pre-application
meeting and the notice of the meeting (see "Promoting Environmental
Chapter 3: RCRA Permitting
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Addressing community
concerns at the start of a
project can prevent
misunderstanding and
opposition in the long run.
Justice" in Chapter 2 and the Introduction to this Chapter).
At the meeting, permit applicants should address, at the level of detail that
is practical (based on available information), the following topics: what
type of facility the company will operate; the location of the facility; the
general processes involved and the types of wastes to be generated and
managed at the facility; and the extent to which waste minimization and
pollution prevention may supplement or replace waste treatment needs. The
discussions should also include the transportation routes to be used by
waste transporters and planned procedures and equipment for preventing or
responding to accidents or releases.
These are examples of the types of issues that might be of particular
concern to a community and about which the community might be able to
provide useful suggestions to the applicant. The applicant might then be
able to incorporate that information into the proposed facility design or
operations, either as part of the initial application, if time allows, or at
subsequent stages in the process (e.g., in submitting revisions to its
application, or in responding to a Notice of Deficiency issued by the
permitting agency). By learning about and addressing public concerns up
front, the applicant may be able to prevent misunderstanding from
escalating into community opposition. Moreover, the public will have a
clear and open opportunity to interact and communicate with the potential
applicant.
The applicant should make a good faith effort to provide the public with
sufficient information about the proposed facility operations. While we do
not expect applicants to go into extensive detail at the pre-application stage,
they should provide the public with enough information to understand the
facility operations and the potential impacts on human health and the
environment. We encourage applicants to provide fact sheets, information
packets, or other materials (see Chapter 5) that explain the proposed
operations, company policies, waste minimization proposals, or other
information that is relevant to the proposed facility.
The permitting agency may choose to make permitting and pollution
prevention fact sheets available at the meeting. One such fact sheet is
included as Appendix J of this manual. EPA recommends that permit
applicants distribute this fact sheet (or a similar one produced by the state
agency) at the pre-application meeting, especially in cases where a
representative of the permitting agency does not attend. EPA does not
expect permit applicants to answer questions about the RCRA permitting
process at the pre-application meeting ~ particularly where the applicant is
not sure of the answer. We advise the applicant to let a representative of
the permitting agency answer such questions. If an agency representative is
not available at the meeting, then the applicant should provide the name of
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The facility must
conduct the pre-
application meeting.
an agency contact person and the number of the RCRA Hotline (available
in Appendix A) or an applicable State information line.
Some applicants may want to consider inviting or hiring a moderator to
conduct the pre-application meeting. The moderator should be a neutral
third party (e.g., a civic organization, non-profit community group, or a
consultant) that is not a stakeholder in the permitting decision process. A
moderator can lend objectivity to the proceedings and help to keep the
discussions fair, under control, and on track. Regardless of whether a third
party conducts the meeting, facility representatives should be present to
answer questions and interact with the community.
EPA regulations are flexible with regard to conducting the pre-application
meeting. One of the few requirements is for the applicant to post a sign-in
sheet, or a similar mechanism, to allow participants to volunteer their
names and addresses for inclusion on the facility mailing list (see §
124.3 l(b)). The applicant should understand that attendees may not want
to put their names on a mailing list; the sign-in sheet always should be
voluntary. The applicant should make clear at the meeting that people can
contact the permitting agency directly to add their names to the facility
mailing list at any time.
The applicant must submit the list of attendees, along with a "summary" of
the pre-application meeting, as a component of the part B permit
application. We do not intend for the meeting summary to be a verbatim
account of the meeting. EPA recognizes how difficult it is to keep a word-
for-word record of a public meeting. Applicants should make a good faith
effort to provide an accurate summary of the meeting. While the
regulations do not indicate a particular format for the meeting summary, we
recommend a type-written document that identifies major issues, points
made in support of those issues, and any response made by the applicant or
other attendees.
As mentioned above, the applicant must submit the summary as a
component of the part B application. This component should be a
typewritten hard-copy. Since the part B application is available for review
by the public, attaching the summary as part of the application assures that
people who are unable to attend the meeting will have an opportunity to
find out what happened. We encourage applicants to make the summary
available in other formats where a community has special needs (e.g., on
audio tape for visually impaired residents).
The RCRA Expanded Public Participation rule requires the facility to
conduct the pre-application meeting. We believe that the applicant should
conduct the meeting in an effort to establish a dialogue with the
community. EPA encourages permitting agencies to attend pre-application
Chapter 3: RCRA Permitting
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meetings, in appropriate circumstances, but the facility must conduct the
pre-application meeting. Agency attendance may, at times, be useful in
gaining a better understanding of public perceptions and issues for a
particular facility, and for clarifying issues related to the permitting
process. However, agency staff should ensure that their attendance does
not detract from the main purposes of the meeting, such as opening a
dialogue between the facility and the community, and clarifying for the
public the role of the applicant in the permitting process.
The regulations do not preclude State agencies and permit applicants from
working together to combine State siting meetings with pre-application
meetings. EPA encourages them to do so, provided that the combined
meetings fulfill the requirements in § 124.31. If meetings are combined,
the portion of the meeting that is dedicated to the RCRA facility permit
must be run by the applicant; the regulatory agency must give the applicant
the floor for a sufficient time period. In notifying the public of the meeting,
under § 124.31(d), the applicant must make clear that the RCRA portion of
the meeting is separate from the general siting discussion.
The pre-application meeting will provide the community with a clear entry
point for participation at an early stage in the permitting process. We
encourage members of the community to become involved at the pre-
application stage. Public comments and suggestions are easier for the
facility to address at this early stage than later on in the process. For this
reason, public input can have a greater impact at this stage. Interested
citizens should attend the meeting and participate in the informal dialogue.
The public can learn more about the facility and the company seeking a
permit before attending the meeting by contacting the facility, or by
contacting other stakeholders in the community. Some community
members may want to research to learn more about the planned (or already
existing) facility. If you are interested in obtaining more information on the
facility or the permitting process, you may want to contact the permitting
agency or the corporation that owns the facility. Additional information
about past and present owners, past waste spills and releases, complaints,
and the status of other state, local, and federal permits may be available
from the following: the planning board, City Hall or the town council, the
county health department, local newspapers, the library, and local fire and
rescue departments. These sources will give you access to information
such as deeds and environmental testing results.
Meeting attendees can become part of the facility mailing list by adding
their names and addresses to the sign-up sheet at the meeting or by sending
their names directly to the permitting agency. People on this list will
receive any significant information sent out by the agency or the facility
regarding the facility.
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The applicant should avoid
scheduling the meeting at a
time that conflicts with
other important community
activities.
Citizens should note that not all aspects of the permit application will be
clear at the pre-application stage, in part, because EPA is encouraging
facilities to meet with the public before making all final decisions on their
permit applications. This way, the facility owner/operator will be more
flexible and can react more effectively to suggestions and concerns raised
in the meeting. Participants at the meeting should note that the facility
owner/operator will not know the answer to all questions about the
permitting process. The permitting agency and the RCRA/Superfund
Hotline will be available to answer questions about the permitting process
and other RCRA requirements (remember that States may have different
procedures than EPA)..
Date, Time, and Location of the Meeting
The timing of the meeting is flexible. EPA believes that flexibility is
necessary because the optimal timing for the meeting will vary depending
on a number of factors, including the nature of the facility and the public's
familiarity with the proposed project and its owner/operator. The applicant
should choose a time for the meeting while considering the following
factors: (1) the community must receive adequate notice before the facility
submits a permit application; (2) the facility's plans for construction or
operation need to be flexible enough to react to significant public concerns
and to make changes to the application, if necessary; (3) the meeting should
not take place so long before submittal of the application that the
community will forget the facility. We encourage applicants to make a
good faith effort to choose the best date for the pre-application meeting.
While the final rule requires the facility to hold only one pre-application
meeting, cases may arise where more than one meeting is preferable. For
instance, if a facility holds one public meeting and takes several months to
a year to submit the application, then the facility owner/operator should
consider holding a second meeting. In other cases, the facility may want to
hold a few meetings of different types (e.g., a public meeting as well as an
availability session). Of course, permitting agencies or other stakeholder
groups may decide to hold additional public meetings where appropriate.
The permit applicant should encourage full and equitable public
participation by holding the pre-application meeting at a time and place that
is convenient to the public. The applicant should schedule the meeting at a
time when the community is most likely to be available. Many
communities, for instance, may prefer a meeting held after normal business
hours. Meeting schedulers should avoid holding the meeting at a time that
will conflict with important community activities (e.g., social, religious, or
political events, other meetings, school activities, or local occasions). The
applicant should also make sure that the meeting place has adequate space
and is conducive to the type of meeting that the applicant will conduct.
Chapter 3: RCRA Permitting
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Notice of the Pre-
Application Meeting
Finally, the meeting location should have suitable access for all persons; if
such a location cannot be procured, then the applicant should make all
reasonable efforts to provide for equitable participation in the meeting (e.g.,
by responding to written comments).
Some members of the affected community may not feel comfortable with
meetings held on facility property. Applicants should address community
concerns in this area. EPA encourages applicants to hold the pre-
application meeting on neutral public ground, such as a local library, a
community center, a fire station, town hall, or school.
EPA developed the pre-application meeting notice requirements with the
goal of encouraging facilities to reach as many members of the public as
possible, within reasonable means. The expanded notice requirements are
intended to reach a broad audience and to encourage as many people as
possible to attend the meeting. Attendance at the meeting may also provide
an indication of the level of public interest in the facility, although low
attendance does not necessarily equal low interest. Using the list of
attendees from the meeting will allow agencies to develop larger mailing
lists; these lists, in turn, will help the facility and the agency to update more
people more often about the permitting process.
The new rule requires the applicant to provide notice of the pre-application
meeting to the public in three ways:
• A newspaper display advertisement. The applicant must print a
display advertisement in a newspaper of general circulation in the
community. The display ad should be located at a spot in the paper
calculated to give effective notice to the general public (see the example in
Appendix H). The ad should be large enough to be seen easily by the
reader. In addition to the display ad, we also encourage facilities to place
advertisements in free newspapers, community bulletins, newsletters, and
other low-cost or free publications. In some cases, potential interest in the
facility may extend beyond the host community. Under these
circumstances, we encourage the applicant either to publish the display ad
so that it reaches neighboring communities or to place additional ads in the
newspapers of those communities.
• A visible and accessible sign. The applicant must provide notice on a
clearly-marked sign at or near the facility (or the proposed facility site). If
the applicant places the sign on the facility property, then the sign must be
large enough to be readable from the nearest point where the public would
pass ~ on foot or by vehicle ~ by the site. EPA anticipates that the signs
will be similar in size to zoning notice signs required by local zoning
boards (of course, this size will vary according to the prerogative of the
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Choose notice methods
that will spread the
word over all segments
of the affected
community.
zoning board). If a sign on the facility grounds is not practical or useful -
for instance, if the facility is in a remote area - then the applicant should
choose a suitable alternative, such as placing the sign at a nearby point of
significant vehicular or pedestrian traffic (e.g., the closest major
intersection). In the case that local zoning restrictions prohibit the use of
such a sign in the immediate vicinity of the facility, the facility should
pursue other available options, such as placing notices on a community
bulletin board or a sign at the town hall or community center. EPA intends
the requirement that the sign be posted "at or near" the facility to be
interpreted flexibly, in view of local circumstances and our intent to inform
the public about the meeting. In addition to the requirements of § 124.31,
we encourage the applicant to place additional signs or flyers in nearby
commercial, residential, or downtown areas. Supermarkets, hardware or
department stores, malls, libraries, or local gathering places may have
bulletin boards for posting notices and flyers. EPA encourages facilities to
keep track of posted signs and remove them after the meeting.
• A broadcast media announcement. The applicant must broadcast the
notice at least once on at least one local radio or television station. EPA
expects that the applicant will broadcast the notice at a time and on a
station that will effectively disseminate the notice. The applicant may
employ another medium, aside from television or radio, with prior approval
of the permitting agency. Many communities run their own cable channels
for local news and activities; this medium may be used to target a local
audience, often at no charge. Television spots may be advantageous for
delivering pertinent information about a hazardous waste management
facility directly to the people at home.
Sample notices are provided in Appendix H and more may be available by
contacting the permitting agency.
EPA encourages facilities to pick a mixture of public notice tools that
meets the regulations and will allow the affected community to receive
equitable, timely, and effective notice of the pre-application meeting. Such
a mixture may include a number of different and specialized notices that
target specific groups within each community. One example of such a
targeted notice would be the use of a translated advertisement on Chinese-
speaking local access television station to reach a Chinese-American
enclave in an area where the community members are affected by the
permitting activity. Specific segments of the affected community can be
targeted by strategic placement of the newspaper display ad, the timing and
station of a radio spot, the geographic location of signs, use of free
newspapers, and multi-lingual notices. EPA does not require that the
applicant try to reach the largest audience with each method of public
notice (e.g., the radio spot need not be placed on the most popular station).
Instead, the applicant should use a combination of methods (including
Chapter 3: RCRA Permitting
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translations) to spread the word over all segments of the affected
community, taking into account the channels of information that are most
useful in reaching diverse groups.
EPA encourages applicants to go beyond the minimum requirements in the
regulations when providing notice of the pre-application meeting. The
following suggestions will help in providing an effective broadcast notice.
In some rural areas, community members may listen to or watch
predominantly one radio or television station; in this case, the applicant
should use this station as the vehicle for the notice. Some areas are part of
a radio market (i.e., defined by services such as Arbitron's Radio Market
Definitions) or television market and have competing radio and television
stations. Where there is more than one station, the facility owner or
operator should consider carefully the likely audience of the station in order
to ensure that a substantial number of people will see or hear the ad. Areas
with many competing stations are more likely to have audiences that may
be delineated, for instance, by age, ethnicity, or income. In these situations,
broadcasting the notice on several stations, or in more than one language,
may be beneficial. In all cases, EPA suggests that the announcement occur
at listening or viewing hours with a substantial audience - hours that will
vary for each community as well as for specific groups. The facility may
consult with broadcast stations and community members to determine the
best times to broadcast the notice.
The regulations also require the applicant to send a copy of the notice to the
permitting agency. Applicants must follow this provision, but we
encourage facilities to contact the appropriate agencies before this stage.
Applicants should consider informing the agency of their intent to seek a
permit before planning the pre-application meeting. Like other
stakeholders in the permitting process, the permitting agency can benefit
from receiving information as early as possible in the process. In addition,
the permitting agency may be able to provide guidance about how to run
the pre-application meeting or what types of public notice work best in a
particular community.
EPA also encourages the applicant to send a copy of the notice to all
members of the facility mailing list, if one exists. This suggestion applies
especially to facility owners who are applying for a permit renewal and
must comply with § 124.31 because they are seeking to make a change on
the level of a class 3 permit modification. At these facilities, the mailing
list will already exist and people on the list will be interested in learning
about the most recent activity at the facility. A mailing list will most likely
not exist for new applicants.
Getting the word out at this early stage is essential to assuring adequate
community participation during the entire permitting process. For this
Chapter3: RCRA Permitting Page 3-11
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Free papers, existing
newsletters, press releases,
and word-of-mouth are
inexpensive ways to notify
the public.
reason, we encourage the applicant to take additional steps, within
reasonable means, to announce the meeting. We do not intend for
applicants to spend large amounts of additional time and resources; on the
contrary, there are many simple and inexpensive mechanisms for
distributing information. Free announcements on television or radio,
advertisements in free papers, town newsletters, flyers, small signs, and
press releases are all ways to disseminate information at little or no cost.
We also encourage facilities to pass information through local community
groups and Local Emergency Planning Committees (established under
section 301 of the Superfund Amendments and Re-Authorization Act
(SARA)), professional and trade associations, planning commissions, civic
leaders, school organizations, religious organizations, and special interest
groups. Other stakeholders involved in the process are also good conduits
for spreading news about the pre-application meeting.
The regulations require that the notice contain several pieces of
information: (1) the date, time, and location of the meeting; (2) a brief
description of the purpose of the meeting; (3) a brief description of the
facility and proposed operations, including the address or a map (i.e., a
sketched or copied street map) of the facility location; (4) a statement
encouraging people to contact the facility at least 72 hours before the
meeting if they need special access to participate in the meeting; and (5) the
name, address, and telephone number of a contact person for the applicant.
The format of the notice is flexible as long as it communicates this
information. The description of the purpose of the meeting should explain
the facility's intent to submit a permit application and set out other
objectives for the meeting. When describing the facility, the
owner/operator should briefly cover what sort of facility it is or will be
(e.g., a hazardous waste incinerator), what types of wastes it may handle,
and what sort of operations will take place at the facility (e.g., types of
manufacturing, commercial treatment of waste, etc.). For the facility map,
the owner/operator should provide a photocopy of a street map or a
sketched map, the purpose of which is to let the public know just where the
facility is or will be. Finally, persons needing "special access" would
include anyone who may have difficulty with stairs or some entrances,
persons who are visually or hearing impaired, or any person who foresees
some difficulty in attending the meeting without some help. EPA does not
expect facilities to provide transportation to persons who cannot find other
means of reaching the meeting.
The telephone contact provided by the applicant in the pre-application
notice is an important addition to the public participation resources during
this phase. EPA encourages members of the community to contact the
facility, the permitting agency (see Appendices A and B for State and
Federal contacts) or other interested groups in the community, as necessary,
Chapter 3: RCRA Permitting
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to become acquainted with the permitting process and the facility plans.
The Facility Mailing
List
The permitting agency
should develop the
mailing list early.
EPA is not requiring the facility to submit proof of the public notice;
however, we are requiring the facility to keep proof of the notice. The
Agency is concerned that proof of the notices may be needed in the case of
a lawsuit. The applicant should establish a simple file containing proofs for
the notice. Acceptable forms of proof would include a receipt for the radio
or TV broadcast, a photograph of the sign, and a photocopy of the
newspaper advertisement or tear sheets.
The permitting agency is responsible for developing a representative
mailing list for public notices under § 124.10. EPA is emphasizing the
early development of a thorough mailing list as a critical step in the public
participation process. If the mailing list allows the agency to keep
important groups and individuals in the community up-to-date on activities
at a facility, then the permitting agency and the facility will be better able
to gauge community sentiment throughout the permitting process. See the
section on "Mailing Lists" in Chapter 5 for additional information.
EPA anticipates that the meeting attendee list required under § 124.3 l(c)
will help the agency generate the mailing list by identifying people or
organizations who demonstrate an interest in the facility and the permit
process.
In the past, mailing lists have not been fully developed, oftentimes, until the
agency issued the draft permit or intent to deny the permit. EPA believes
that the mailing list is an integral public participation tool which permitting
agencies should create as early as possible in the process. Our intent in
having the permit applicant submit the list of meeting attendees under §
124.3 l(c) was to allow the agency to formulate the mailing list at an earlier
stage in the permitting process. Aside from the names identified by the
permit applicant, we encourage permitting agencies to enhance the mailing
list by contacting a wide variety of groups and individuals, such as: civic
organizations, religious groups, public interest organizations, recreational
groups, professional/trade associations, Local Emergency Planning
Committees (LEPCs), emergency response and local health care personnel,
environmental justice networks, educational and academic organizations,
city hall and elected officials, planning and zoning boards, local
development councils, involved State and Federal agencies, newspapers
and reporters, immediate neighbors and property holders, other nearby
companies or business groups, facility employees, and plant tour attendees.
In addition, we encourage the agency to maintain and update the lists
regularly. All commenters on permitting documents, attendees at any
public meetings or persons using information repositories should be placed
on the mailing list, or have the option of putting their names on the list.
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Members of the community and other interested groups or individuals can
contact the permitting agency to have their names put on the facility
mailing list. Community and public interest organizations may want to
provide the permitting agency with names for the mailing list. Refer to
Appendices A and B if you would like to find the addresses and phone
numbers of EPA's Regional offices and the state environmental agencies.
Public participation
activities should be
geared to the potential
level of community
interest.
Additional Activities
The level of public participation activities should correspond to the
potential level of community interest in the permitting process. To
determine the need for additional activities, participants should consider
conducting a community assessment (see Chapters 2 and 5). If the level
of interest is high, participants will want to do a more thorough needs
assessment and prepare a formal public participation plan (see Chapters 2
and 5).
EPA encourages applicants to provide fact sheets, information packets, or
other materials (see Chapter 5) at the pre-application meeting. The
permitting agency may also choose to make permitting fact sheets available
at the meeting. One such fact sheet is included as Appendix J of this
manual. EPA recommends that permit applicants distribute this fact sheet
at the pre-application meeting, especially in cases where a representative of
the permitting agency does not attend.
To provide widespread notice of the pre-application meeting, the applicant
may want to use notice methods that go beyond the requirements. Some of
these methods, such as public service announcements , existing
newsletters and publications , and newspaper inserts are described in
Chapter 5.
In some cases, the agency, facility, or a community group may find it
appropriate to hold an additional meeting during the pre-application stage.
Availability sessions or open houses can provide the public with an
opportunity to discuss issues face-to-face with officials or other interested
people.
The "RCRA Expanded Public Participation" rule gives the permitting
agency the authority to require the facility owner or operator to establish an
information repository at any point in the permitting process or during the
life of a facility. The agency should assess the need for the repository by
considering a variety of factors, including: the level of public interest; the
type of facility; the presence of an existing repository; and the proximity to
the nearest copy of the administrative record. The information repository
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An information
repository makes
information accessible to
the public in a
convenient location.
can improve the permitting process by making important information
accessible to the public in a convenient location. (See Chapter 5 for more
detail on information repositories). Of course, EPA encourages facilities or
interested community groups to establish their own repositories for public
access to information. Chapter 5 provides more guidance on how to
establish a repository.
Some permitting information is quite technical and detailed. Members of
the public and other stakeholders may find this information difficult to
interpret. EPA encourages permitting agencies, facilities, and community
groups to provide fact sheets and additional materials to make technical and
complicated information more accessible to people who are not RCRA
experts. Workshops or availability sessions may be useful for explaining
technical information. Some citizens or community groups may want to
consult other sources for help in interpreting scientific and technical data.
If you are looking for such help, you may want to contact the permitting
agency, facility staff, or other sources such as local colleges, universities,
public interest groups, environmental and civic organizations. Additional
contacts may be available in the local community. Interested citizens may
be able to find out about these contacts by talking to local newspapers and
other media who cover environmental issues. People who are interviewed
for or quoted in news articles can be an additional source for information.
Getting as much input as possible from the community during these initial
phases of the RCRA permitting process and before a draft permit is issued
will be very useful during the draft permit stage. The draft permit will be
more responsive to the needs and concerns of the community, and the
community will be more likely to accept the permit conditions if it sees that
its concerns have been heard.
Though the early meeting may reduce public concern that the agency and
the facility are making important decisions before the public becomes
involved, some concern may still remain. The agency and the facility are
likely to have meetings that cannot, for practical purposes, be open to
public participation. One State agency found that by making notes from
these meetings available through an information repository , public trust in
the agency increased.
Step Two: Application
Submittal and Review
Required Activities
After the permit applicant has met with the public and considered
recommendations and input from the community, he or she may choose to
pursue a RCRA permit and then submit a RCRA part B permit application
Chapter 3: RCRA Permitting
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New EPA rules make
permit applications
available to the public
during agency review.
to the permitting agency. Upon receiving the permit application, the
permitting agency must, under § 124.32, issue a public notice to the
facility mailing list and appropriate units of state and local government.
The notice will inform recipients that the facility has submitted a permit
application for agency review. In addition, the notice will inform the
recipients of the location where the application is available for public
review.
Both of the provisions mentioned in the previous paragraph are the result of
the RCRA Expanded Public Participation rule. EPA composed these
regulations as a way to inform the public about the status of a facility's
permit application early in the process .
Before issuing the notice at application submittal, the permitting agency
should solicit community suggestions and input on the best place to put the
application for public review (agency personnel may have gathered this
information during an earlier stage in the process). We encourage the
agency to issue the notice as soon as is practically possible after receiving
the application. The notice must contain the following information: (1)
the name and telephone number of the applicant's contact person; (2) the
name and telephone number of the permitting agency's contact office, and a
mailing address to which information, opinions, and inquiries may be
directed throughout the permit review process; (3) an address to which
people can write in order to be put on the facility mailing list; (4) the
location where copies of the permit application and any supporting
documents can be viewed and copied; (5) a brief description of the facility
and proposed operations, including the address or a map (i.e., a sketched or
copied street map) of the facility location on the front page of the notice;
and (6) the date that the application was submitted.
Permitting agencies must place the application and any supporting
materials somewhere in the vicinity of the facility or at the permitting
agency's offices. The permitting agency should be sensitive to the burden
on members of the affected community when determining where to place
the application. Many communities do not have the resources or the time
to travel several hours just to access permitting information. To make
information available in these situations, the permitting agency should
place the application in a place with public access in the general vicinity of
the facility (e.g., a public library or community center). If such placement
of the document is impractical, the agency should make sure that the public
has other access to permitting information. For instance, the agency could
require the facility to establish an information repository under § 124.31. If
the community's information needs are on a lower level, the agency may
want to make a short summary of the permit application available to the
affected community. In some cases, making information available in
electronic form (e.g., via diskette or Internet) may be useful.
Chapter 3: RCRA Permitting
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The application should
be available for review
in the vicinity of the
facility.
We recommend that, where feasible, the agency place the application in a
location where copying facilities are available and the public has adequate
access to the documents. EPA also recommends that the application be in a
locale where the documents will be secure and readily available. The
application should go in the information repository, if one exists. If not, a
public library or other building in the vicinity of the facility may provide a
suitable choice. The permitting agency's headquarters or satellite office
may be adequate if not too far from the facility.
Additional Activities
The permit application review process is often lengthy. It may take
anywhere from one to five years to issue a permit, depending on the facility
type and level of facility owner or operator cooperation. Permit applicants
and regulators should recognize that members of the public have pointed
out that they often feel "in the dark" during this phase. We encourage
agencies and facilities to maintain a good flow of information during
application review. If resources are available, permitting agencies and
facilities should plan activities during this time period to keep citizens
informed about the status of the process. Holding workshops, conducting
informal meetings, and providing periodic fact sheets and press releases
about the facility, opportunities for pollution prevention, and the RCRA
permit process can spread information and keep the community involved.
Identifying a contact person to accept comments and answer questions
will also enhance communication. A (toll-free) telephone hotline with
recorded status reports can reduce the potential for rumors.
EPA encourages permitting agencies to respond (e.g., in writing, by phone,
by holding a meeting) to comments and requests from the public during the
application review process. Agencies should make good faith efforts to
address public concerns and issues.
In situations where a community wants more information about potential
operations at a facility and the health and environmental risks of those
operations, citizens or the agency can work with the facility to set up
facility tours and observation decks during the public comment period.
These activities will give the community a first-hand look at a facility and
the operations and activities happening on-site. (Note that safety and
liability issues need to be considered before a decision is made to include
these activities.) These activities may be particularly useful for a new
facility or when a facility proposes a new or different technology. Facility
tours also may be particularly effective for explaining pollution prevention
accomplishments and opportunities. Similarly, facility owners or operators
may wish to coordinate with community leaders to tour the community.
This may be useful for understanding potential community concerns.
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Step Three: The Draft
Permit, Public
Comment Period, and
Public Hearing
Required Activities
After the permitting agency reviews the permit application, it must notify
the applicant in writing. If the application is incomplete, the permitting
agency may request that the applicant submit the missing information. This
request is known as a Notice of Deficiency (NOD). The permitting agency
may issue several NODs before the application is finally complete.
Once an application is complete, the permitting agency will make a
decision to issue a draft permit or a notice of intent to deny the permit
application (which is a type of draft permit). In either case, the agency
must notify the public about the draft permit. In the notice, the permitting
agency must announce the opening of a minimum 45-day public comment
period on the draft permit. The agency must print the notice in a local
paper, broadcast the notice over a local radio station, and send a copy of the
notice to the mailing list, relevant agencies, and applicable state and local
governments. We encourage agencies to attempt to reach all segments of
the affected community, within reasonable means, when issuing the notice
of the draft permit (see "Step One: The Pre-Application Stage" above and
Chapter 5 for more information on how to notify the public). Although the
agency is not required to retain documentation of the notice, we
recommend keeping a simple file with proof of the notices. Forms of proof
might include a receipt for the radio ad and a photocopy of the newspaper
add.
EPA regulations require the permitting agency to prepare a fact sheet or a
statement of basis to accompany every draft permit. This fact sheet (or
statement of basis) is required by regulation and is different than commonly
used informational fact sheets. This fact sheet must explain the principal
facts and the significant factual, legal, methodological and policy questions
considered in preparing the draft permit. The fact sheet must also include,
when applicable, the following (see § 124.8(b)):
• a brief description of the type of facility or activity which is the
subject of the draft permit;
• the type and quantity of wastes that are proposed to be handled
at the facility;
• a brief summary of the basis for the draft permit conditions;
reasons why any requested variances or alternatives to required
standards do or do not appear justified;
a description of the procedures for reaching a final decision on
the draft permit, including (1) the beginning and ending dates of
the comment period and an address to which comments can be
sent, (2) procedures for requesting a hearing and the nature of
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By law, the agency must
consider and respond to all
significant comments
received during the
comment period.
the hearing, and (3) any other public participation procedures
before the final permit decision; and
the name and telephone number of a person to contact for
additional information.
EPA recommends that the permitting agency include the fact sheet with the
notice of the draft permit and make the fact sheet available to all interested
parties.
Any person may request a public hearing during the public comment
period. The agency must hold a public hearing if someone submits a
written notice of opposition to a draft permit and a request for a hearing, or
if the public demonstrates, by the number of requests for a public hearing, a
significant degree of public interest in the draft permit. The Director also
may hold public hearings at his or her discretion. The agency must notify
the public about the hearing at least 30 days prior to the hearing. The
agency may choose to combine the hearing notice with the draft permit
notice. See Chapter 5 for information on holding a public hearing.
Citizens may want to request a public hearing as a forum for airing
community concerns. The hearing will be a standard meeting, attended by
the agency and other interested parties.
There is more required public participation during the draft permit stage
than at any other time during the permitting process. We strongly
recommend that permitting agencies prepare public participation plans (see
Chapter 5), even for the least controversial facilities, just to keep track of
the activities during this stage.
The comment period on the draft permit allows anyone to submit their
concerns and suggestions to the agency in writing. The permitting agency
must, by law, consider all comments (see § 124.11) in making the final
permit decision. In addition, the agency must briefly describe and respond
to all significant comments raised during the comment period or during the
public hearing. EPA encourages participants to submit comments during
this period.
You can use public
participation activities to
explain technical issues
or the permitting
process.
Additional Activities
Permitting agencies can keep the process open by sharing all NOD
information with the public, whether through the administrative record, an
information repository , or another activity, such as a workshop. If the
details of the NOD are too arcane or technical, the agency can provide a
short fact sheet. The fact sheet should not gloss over any major omissions,
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but, by the same token, it should point out when an omission is of a less
serious nature.
Interested community groups or the permit applicant may decide to provide
additional public participation activities during this stage. Some
suggestions for useful activities would include explaining the NOD process
and discussing technical issues in the application by holding availability
sessions. Another option is for citizens or other stakeholders to request
one-on-one or small informal meetings with the permitting agency, the
permit applicant, or community groups. Stakeholder groups can improve
their communication and interaction by meeting together in an informal
forum. An informal meeting may also be more appealing to some
participants, who may see activities like public hearings as overly
confrontational.
The permitting agency may want to provide a news release when issuing
the draft permit or intent to deny.
The agency, facility, or a public interest group may want to organize an
availability session , facility tours, or some other activity prior to the
comment period so that the public can be better informed about the facility.
Some permitting agencies have held public meetings prior to a public
hearing to provide a better forum to discuss issues. Telephone hotlines or
voicemail recordings can supplement public notices to inform the
community about the dates and locations of public participation events.
Step Four: Response
to Comments and
Final Permit Decision
Remember that
State procedures
may be different.
Required Activities
After the public comment period closes, the regulatory agency reviews and
evaluates all written and oral comments and issues a final permit decision.
The agency must send a notice of decision (not to be confused with a
"notice of deficiency," see above) to the facility owner or operator and any
persons who submitted public comments or requested notice of the final
permit decision. The agency must also prepare a written response to
comments that includes a summary of all significant comments submitted
during the public comment period and an explanation of how, in making the
final permit decision, the agency addressed or rejected the comments. This
summary shows the community that the agency considered the
community's concerns when making the final permit decisions. The agency
must make the response to comments document available as part of the
administrative record.
Additional Activities
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If there was high interest during the comment period, the agency or the
facility may want to issue a news release and fact sheet when the decision
is finalized to inform a wide audience. The permitting agency may choose
to update and release the fact sheet required in § 124.8.
Public Participation
During the Life of a
Facility
Interim Status Public
Participation
When writing RCRA, Congress granted special status to facilities that
existed when the statute went into effect and for facilities that would be
brought under RCRA by new regulations. EPA refers to these facilities as
having "interim status." According to RCRA, interim status facilities do
not need a permit to operate; instead, while they are seeking permits, they
follow a category of regulations created specifically for them by EPA.
When EPA or a State issues a RCRA operating permit to one of these
facilities, the facility loses its interim status.
Because interim status facilities can operate without a permit, many people
are concerned that some of these facilities are not as safe as permitted
facilities. Interim status facilities are not required to follow - since they
are not permitted - any standardized public participation procedures or
permit modification standards (that is, until the facility owner applies for a
permit). Given all these conditions, interim status facilities often pose
public participation challenges even though many such facilities have been
operating for years.
Regulatory agencies may need to use innovative techniques to
communicate with and provide information to communities around interim
status facilities. EPA acknowledges that every situation will require a
different type and level of community involvement. If interest grows in a
certain facility, the agency should consider holding a workshop or an
availability session . Information repositories are another available tool
(see Chapter 5). The agency should take steps to explain the special
situation of interim status facilities to citizens. Of course, if an interim
status facility begins to attract public interest, permitting agencies should
consider moving the facility towards getting a permit and undergoing the
public participation steps in the permitting process.
Owners and operators of interim status facilities should involve the public
even before they formally start to pursue a RCRA permit. One thing the
facility owners could do to improve access to information is to make a draft
part B application available to the public before submitting it to the
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Permit Modifications
Modifications can be
initiated by either the
agency or the facility.
permitting agency. Facility owners who submitted part B applications in
the past might make their applications available as well. (Note: any
interim status facility that submits its part B application on or after June 11,
1996, will be subject to the standards of the RCRA Expanded Public
Participation Rule and, thus, its application will be available for public
review upon submission). The facility may also want to set up an on-site
information booth or provide other background materials to the public.
Establishing a contact person and making his or her name available to the
public can improve communication between the facility and the
community. Experience has shown that a good facility-community
relationship during interim status will make for a more cooperative
permitting process.
Members of the public will often have questions or concerns while a
facility is in interim status. Citizens can contact the facility, the regulatory
agency, or the RCRA/Superfund Hotline to ask questions or to inquire
about other sources of information. Citizens may also want to contact
public interest organizations, local government, or other involved citizens
for more information. Interim status facilities will eventually need to enter
the RCRA permitting process, which citizens can use as an opportunity to
air concerns and to encourage the facility to make important changes.
Over time, a permitted facility may need to modify its permit. Just as
public participation is a component of the initial permit process, it is also a
part of the permit modification process. This section discusses different
kinds of permit modifications and their corresponding public participation
requirements. It is important to note that public participation
responsibilities and activities vary depending on, first, who initiated the
modification (i.e., the regulatory agency or the facility owner or operator)
and, second, the degree to which the modification would change substantive
provisions of the permit. No matter who initiates the modification, when a
modification is proposed, only those permit conditions subject to
modification are reopened for public comment.
State permitting agencies may have modifications processes that differ from
the federal requirements. Contact your State agency (see Appendix B) for
more details.
There are many reasons to modify a permit. In some cases, the regulatory
agency may initiate a permit modification under 40 CFR 270.41. This
section of the regulations identifies three causes for which the regulatory
agency may require a permit modification: (1) alterations or additions to
the permitted facility or activity; (2) new information received by the
regulatory agency; or (3) new standards, regulations, or judicial decisions
affecting the human health or environmental basis of a facility permit. In
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When a facility initiates a
modification, it is
responsible for some
public participation
activities.
addition, the regulatory agency may modify a compliance schedule for
corrective action in the permit. Modifications initiated by the regulatory
agency are subject to the full 40 CFR Part 124 permitting requirements, as
described earlier in this chapter. Specifically, the permitting agency must
• Issue public notice of the draft modification;
• Prepare a fact sheet or statement of basis;
• Announce a 45-day public comment period;
• Hold a public hearing, if requested, with 30-day advance notice;
• Issue notice of the final modification decision; and
• Consider and respond to all significant comments.
More often, however, the facility owner or operator requests a permit
modification to improve facility operations or make changes in response to
new standards. Facility-initiated modifications are categorized under 40
CFR 270.42 as Class 1, 2, or 3 according to how substantively they change
the original permit. Class 1 modifications require the least public
involvement; Class 3, the most. Like agency-initiated modifications, a
decision to grant or deny a Class 3 permit modification request is subject to
the public participation procedures of 40 CFR Part 124.
Since facility owners or operators initiate modifications more often than the
regulatory agency, the remainder of this chapter lays out the requirements
for facility-initiated modifications. The permitting agency is also
encouraged to follow these public participation activities, even if not
required under an agency-initiated modification. Appendix L consists of an
EPA fact sheet entitled "Modifying RCRA Permits," which provides more
detail on permit modifications and associated public participation activities.
Exhibit 3-1 at the end of this Chapter presents an easy-to-read synopsis of
modification requirements and timelines.
When the Facility Owner or Operator Initiates a
Modification
When a facility owner or operator wants to change a RCRA permit, he or
she informs the regulatory agency and interested members of the public,
either before making the change if it is substantive (Class 2 or 3), or soon
after (with a few exceptions), if the change is minor (Class 1). In any case,
this is relatively early notification for members of the public, who often
perceive that RCRA actions are "done deals" by the time public comment is
solicited.
The facility owner or operator is responsible for conducting most of the
public participation for modifications he or she initiates. In addition, the
facility, rather than the regulatory agency, bears the burden of explaining
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and defending its actions to the public. To ensure that the facility's public
participation efforts are successful, staff from the facility and the agency
should discuss how to conduct the required activities; the agency should
provide guidance and assistance where necessary. Moreover, EPA
encourages facilities to consult with communities to determine what
activities will best promote public participation.
Class 1 Modifications
Class 2 modifications
require a number of
activities, including a
public notice, comment
period, and a public
meeting.
Class 1 modifications address routine and administrative changes, including
updating, replacing, or relocating emergency equipment; updating certain
types of schedules identified in the permit; improving monitoring,
inspection, recordkeeping, or reporting procedures; and updating sampling
and analytical methods to conform with revised regulatory agency guidance
or regulations. They do not substantively alter the conditions in the permit
or reduce the facility's ability to protect human health and the environment.
With a few exceptions, most Class 1 modifications do not require approval
from the regulatory agency before they are implemented. (The exceptions
are listed in Appendix I to 40 CFR 270.42.)
The only public involvement requirement for Class 1 modifications is that
within 90 days of implementing a change, a facility must send a public
notice to all parties on the mailing list compiled by the permitting agency .
The facility is responsible for obtaining a complete facility mailing list
from the agency. (For more information on mailing lists see Chapter 5.)
Any member of the public may ask the agency to review a Class 1
modification.
Class 2 Modifications
Class 2 modifications address facility-initiated changes in the types and
quantities of wastes managed, technological advances, and new regulatory
requirements, where such changes can be implemented without
substantively altering the facility's design or the management practices
prescribed by the permit. Class 2 modifications do not reduce, and, in most
cases should enhance, the facility's ability to protect human health and the
environment. During a Class 2 modification, there may be good
opportunities to explore "low tech" pollution prevention opportunities that
reduce waste generation but do not require major process changes (e.g.,
segregating waste streams, modifying maintenance procedures, or installing
closed loop recycling).
Class 2 modifications require the facility to submit a modification request
and supporting documentation to the regulatory agency. In addition, the
facility must notify the people on its mailing list about the modification
Chapter 3: RCRA Permitting
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request and publish this notice in a major local newspaper of general
circulation. The facility must publish the notice and mail the letter within
seven days before or after it submits the request to the regulatory agency.
The newspaper notice marks the beginning of a 60-day public comment
period and announces the time and place of a public meeting. In addition,
the notice must identify a contact person for both the facility and the
regulatory agency and must contain the statement, "The permittee's
compliance history during the life of the permit being modified is available
from the regulatory agency contact person." The notice should state that
public comments must be submitted to the permitting agency's contact
person.
The public comment period provides an opportunity for the public to
review the modification request at the same time as the permitting agency.
The facility must place the request for modification and supporting
documentation in a location accessible to the public in the vicinity of the
facility (see guidance on information repositories in Chapter 5 for suitable
locations). The facility must conduct the public meeting no earlier than 15
days after the start of the 60-day comment period and no later than 15 days
before it ends. The meeting, which tends to be less formal than a public
hearing held by the regulatory agency in the draft permit stage, provides for
an exchange of views between the public and the owner or operator and a
chance for them to resolve conflicts concerning the permit modification.
The meeting must be held, to the extent practicable, in the vicinity of the
permitted facility (the guidance on thepre-application meeting, earlier in
this chapter, is applicable to this public meeting ).
The requirements for this meeting, like the pre-application meeting, are
flexible. The facility is not required to provide an official transcript of the
meeting, though we encourage owners/operators to consult the community
and find out if this information would be useful. The permitting agency is
not required to attend the meeting or respond to comments made there;
however, EPA recommends that agency staff attend the meeting to clarify
questions about the permitting process and to find out about any public
concerns and how the owner or operator plans to address them.
The permitting agency is required to consider all written comments
submitted during the public comment period and must respond in writing to
all significant comments in its decision . EPA expects that the meeting will
provide information to the public and improve the written comments
submitted to the permitting agency. EPA anticipates that community input
at the meeting may also result in voluntary revisions in the facility's
modification request.
As the following paragraphs explain, the Class 2 modification procedures
were written to ensure quick action by the agency. However, when seen by
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the public, these procedures can be very confusing. A simple solution that
the permitting agency or the facility should consider is to provide a fact
sheet or a time table to the public at the meeting.
The procedures for Class 2 modifications include a default provision to
ensure that the permitting agency responds promptly to the facility's
request. The agency must respond to Class 2 modification requests within
90 days or, if the agency notifies the facility of an extension, 120 days. At
any time during this 120-day period, the agency can: (1) approve the
request, with or without changes, and modify the permit accordingly; (2)
approve the request, with or without changes, as a temporary authorization
having a term of up to 180 days; or (3) deny the request. If the permitting
agency does not reach a final decision on the request within this period, the
facility is granted an automatic authorization that permits it to conduct the
requested activities for 180 days. Activities performed under this authori-
zation must comply with all applicable federal and state hazardous waste
management regulations. If the agency still has not acted within 250 days
of the receipt of the modification request, the facility must notify persons on
the facility mailing list within seven days, and make a reasonable effort to
notify other persons who submitted written comments , that the automatic
authorization will become permanent unless the regulatory agency approves
or denies the request by day 300. The public must always have a 50-day
notice before an automatic authorization becomes permanent. The agency
must notify persons on the facility mailing list within 10 days of any
decision to grant or deny a Class 2 modification request. The agency must
also notify persons on the facility mailing list within 10 days after an
automatic authorization for a Class 2 modification goes into effect.
At any time during the Class 2 procedures the agency may also reclassify
the request as a Class 3 modification if there is significant public concern
about the proposed modification or if the agency determines that the facil-
ity's proposal is too complex for the Class 2 procedures. This
reclassification would remove the possibility of a default decision.
As previously indicated, the permitting agency may approve a temporary
authorization under 40 CFR 270.42(b) for 180 days for a Class 2
modification. In addition, the agency may grant a facility temporary
authorization under 40 CFR 270.42(e), which would allow the facility,
without prior public notice and comment, to conduct certain activities
necessary to respond promptly to changing conditions. The facility must
notify all per sons on the facility mailing list about the temporary
authorization request within seven days of the request. Temporary
authorizations are useful for allowing a facility owner or operator to
perform a one-time or short-term activity for which the full permit
modification process is inappropriate, or for allowing a facility owner or
operator to initiate a necessary activity while his or her permit modification
Chapter3: RCRA Permitting Page 3-26
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Class 3 modifications are
more likely than other
modifications to raise
concern.
is undergoing the Class 2 review process. A temporary authorization is
valid for up to 180 days, and the permitting agency may extend the
authorization for an additional 180 days if the facility initiates the
appropriate Class 2 modification process for the covered activity. In
addition, any extension of the activity approved in the temporary
authorization must take place under Class 2 procedures.
Class 3 Modifications
Class 3 modifications address changes that substantially alter a facility or
its operations. For example, a request to manage new wastes that require
different management practices is a Class 3 modification.
Class 3 modifications usually involve changes that are broader or more
detailed than Class 1 or 2 modifications; they are also more likely to raise
concern. Though the Class 3 modifications process allows significant
opportunity for public participation, additional activities may be helpful in
some situations. Permit holders, regulators, and community interest groups
may want to consider taking steps to encourage earlier participation.
Facilities, in particular, should recognize that some Class 3 modifications
will significantly alter their operations. In such cases, and in all cases
where public interest may be high, permittees should consider providing
information and public participation activities prior to submitting the
modification request.
When concern is high, it is critical for the facility to consult with the
agency to make sure that the facility knows how to conduct the required
public participation activities. In some cases, the permitting agency might
encourage the facility to go beyond the requirements and hold workshops
and publish fact sheets to explain the proposed change. Public
participation activities held by the agency or public interest groups can
supplement the regulatory requirements.
As with Class 2 modifications, Class 3 modifications require the facility to
submit a modification request and supporting documentation to the
permitting agency, and notify persons on the facility mailing list about the
modification request and publish notice in a major local newspaper of
general circulation. The facility must publish the notice and mail the letter
within seven days before or after the submitting the modification request to
the regulatory agency. The notice must contain the same information as the
Class 2 notification (see above), including an announcement of a public
meeting to be held by the facility at least 15 days after the notice and at
least 15 days before the end of the comment period. The newspaper notice
marks the beginning of a 60-day public comment period.
Chapter 3: RCRA Permitting
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Class 3 modifications are
subject to the same
public participation
procedures as permit
applications.
In holding a public meeting during the comment period, the facility owner
or operator should follow the guidance for the pre-application meeting
above. The requirements for this meeting are flexible. The facility is not
required to provide an official transcript, though we encourage
owners/operators to consult the community and find out if this information
would be useful. As with Class 2 modifications, the agency is not required
to attend the meeting or to respond to comments made at the meeting.
However, it is important that the permitting agency attend the facility's
public meeting in order to gauge concern about the proposed change and
prepare appropriately for a public hearing, if one is requested. By attending
the public meeting, the agency may learn whether it needs to conduct
additional public participation activities (e.g., hold a workshop or informal
meetings) after preparing the draft modification. The agency can also
clarify questions about the permitting process. The agency should consider
responding to issues raised at the meeting as part of the response to
comments for the 60-day comment period. Of course, people who attend
the meeting have the opportunity to submit formal comments to the
permitting agency during the comment period.
At the conclusion of the 60-day comment period, the agency must consider
and respond to all significant written comments received during the
comment period. The agency must then either grant or deny the Class 3
permit modification request according to the permit modification
procedures of 40 CFR Part 124.
Class 3 modifications are subject to the same review and public
participation procedures as permit applications, as specified in 40 CFR
270.42(c). The agency is required to perform the following tasks:
• Preparation of draft permit modification conditions or notice of intent
to deny the modification;
• Publication of a notice of the agency's draft permit decision, which
establishes a 45-day public comment period on the draft permit
modification;
• Development of a fact sheet or statement of basis ;
• Holding a public hearing, if requested, with 30-day advance notice ;
• Issuance of the notice of decision to grant or deny the permit
modification; and
• Consideration and response to all significant written and oral
comments received during the 45-day public comment period.
With Class 3 permit modifications, the public has 60 days to comment on
the facility's requested modification and another 45 days to comment on the
agency's draft permit modification or proposed notice of intent to deny the
modification. And, in addition to the public meeting held by the facility
owner or operator, the public may also request a public hearing with the
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agency.
Public Participation
in Closure and Post-
Closure
Closure and Post-
Closure at Permitted
Facilities
The permitting agency must notify persons on the facility mailing list
within 10 days of any decision to grant or deny a Class 3 modification
request. As with Class 2 modifications, the regulatory agency may grant a
facility a temporary authorization to perform certain activities requested in
the Class 3 modification for up to 180 days without prior public notice and
comment. For example, the agency may grant temporary authorizations to
ensure that corrective action and closure activities can be undertaken
quickly and that sudden changes in operations not covered under a facility's
permit can be addressed promptly. Activities performed under a temporary
authorization must comply with all applicable federal and state hazardous
waste management regulations. The facility must issue a public notice to
all persons on the facility mailing list within seven days of submitting the
temporary authorization request. The agency may grant a temporary
authorization without notifying the public. The permitting agency may
reissue a temporary authorization for an additional 180 days provided that
the facility has initiated the appropriate Class 3 modification process for the
activity covered in the temporary authorization and the agency determines
that the extension is warranted to allow the facility to continue the activity
while Class 3 procedures are completed. See Appendix L for an EPA fact
sheet on modifying RCRA permits.
Facilities may discontinue operations at one or more units for a number of
reasons. For example, units may have reached capacity, the facility owner
or operator may no longer wish to accept wastes, or the facility may have
lost interim status and be required to close by the permitting agency.
During closure, facility owners or operators complete treatment, storage,
and disposal operations; apply final covers or caps to landfills; and dispose
of or decontaminate equipment, structures, and soil. Post-closure, which
applies only to land disposal facilities that do not "clean close" (i.e., remove
all contaminants from the unit), is normally a 30-year period after closure
during which owners or operators of disposal facilities conduct monitoring
and maintenance activities to preserve the integrity of the disposal system.
EPA regulations (40 CFR 264.112 and 264.118) require facilities seeking
operating permits to submit closure and post-closure plans (if appropriate)
with their Part B applications in accordance with 40 CFR 270.14(b)(13).
Furthermore, land disposal facilities that leave wastes in place when they
close must obtain a post-closure permit, which specifies the requirements
for proper post-closure care. Consequently, the public has the opportunity
to comment on a facility's closure and post-closure plans and any
amendments made to the plans as part of the permitting process and permit
modification procedures, as described earlier in this chapter.
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Public participation for the
post-closure phase must
address public concerns about
corrective action.
Closure and Post-
Closure at Interim
Status Facilities
Facilities seeking permits for post-closure are exempt from the pre-
application meeting requirement (§ 124.31) in the RCRA Expanded Public
Participation rule. The facility, permitting agency, or community group
may decide to hold some type of meeting prior to issuance of the post-
closure permit. Refer to Chapter 5 for information on public meetings,
availability sessions , and workshops.
The permitting agency or other involved organizations should be aware of
closure issues that may concern the public, and they should plan public
participation activities accordingly. For example, if the public has
reservations about how "clean" the facility will actually be after the facility
closes, public interest groups, the agency, or the facility may want to
provide fact sheets or conduct educational workshops and informational
meetings about the closure plan and the conditions at the facility.
If the facility owner or operator is leaving a facility, and possibly even the
community, the public may be very concerned about whether the facility
owner or operator will really be vigilant in monitoring the post-closure
operations at the facility or will have enough financial resources to do so.
Moreover, almost all post-closure permits will contain schedules of
compliance for corrective action if a facility closes before all necessary
corrective action activities are completed. As a result, public participation
events in the post-closure phase need to address community concerns about
corrective action. (See Chapter 4 for additional information on corrective
action activities.) Note, however, that unless corrective action is required
in the post-closure permit, public interest in closure plans is usually limited.
Facilities may also close under interim status, often under enforcement
orders. Facilities that are closing under interim status must submit closure
and post-closure plans (if appropriate) under 40 CFR 265.112 and 265.118.
Public participation activities for interim status facilities during the closure
and post-closure processes are specified in 40 CFR 265.112(d)(4) and
265.118(f). The regulations require that the permitting agency provide the
public and the facility, through a newspaper notice, with the opportunity to
submit written comments on the closure and post-closure plans and request
modifications to the plans no later than 30 days from the date of the notice .
EPA encourages permitting agencies to use other methods of notice, as
appropriate, to announce the meeting. In response to a request, or at its
own discretion, the agency may hold a public hearing on the plan(s), if
such a hearing might clarify one or more of the issues concerning the
plan(s). The agency must provide public notice at least 30 days before the
hearing. The agency will approve, modify, or disapprove the plan(s) within
90 days of their receipt.
The public can petition the permitting agency to extend or reduce the post-
Chapter 3: RCRA Permitting
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closure care period applicable to an interim status facility or land disposal
unit. Whenever the agency is considering a petition on a post-closure plan,
it will provide the public and the facility, through a public notice in the
newspaper, with the opportunity to submit written comments within 30 days
of the date of the notice. Again, EPA encourages permitting agencies to go
beyond the newspaper notice requirement, as appropriate, to disseminate
the notice. In response to a request or at its own discretion, the agency may
hold a public hearing on the post-closure plan, if such a hearing might
clarify one or more of the issues concerning the plan. The agency must
provide public notice of the hearing at least 30 days before it occurs. If
the agency tentatively decides to modify the post-closure plan, 40 CFR
265.118(g)(2) requires that the agency provide the public and the facility,
through a public notice in the newspaper, with the opportunity to submit
written comments within 30 days of the date of the notice , as well as the
opportunity for a public hearing. After considering the comments, the
regulatory agency will issue a final decision.
An interim status facility may amend its closure plan at any time prior to
the notification of partial or final closure, and its post-closure plan any time
during the active life of the facility or during the post-closure care period.
An owner or operator with an approved closure or post-closure plan must
submit a written request to the permitting agency to authorize a change. In
addition, the agency may request modifications to the closure and post-
closure plans. If the amendment to the closure plan would be a Class 2 or
Class 3 modification, according to the criteria specified in 40 CFR 270.42,
then the modification to the plan will be approved according to the
procedures in 40 CFR 265.112(d)(4) detailed above. Similarly, if the
amendment to the post-closure plan would be a Class 2 or Class 3
modification, according to the criteria specified in 40 CFR 270.42, the
modification will be approved according to the procedures in 40 CFR
265.118(1), also described above.
Chapter Summary
Some permitting situations will call for public participation that goes beyond the regulatory requirements
The "RCRA Expanded Public Participation" rule (60 FR 63417, December 11, 1995), provides for earlier public participation in
the permitting process, expands public notice for significant events, and enhances the exchange of permitting information
EPA strongly encourages permitting agencies and facilities to ensure equal access to permitting information and provide an equal
opportunity for all citizens to be involved in the RCRA permitting process
The permit decision process and the required public participation activities can be divided into four key steps :
1. The Pre-Application Stage
- Facility gives public notice and holds an informal public meeting
Chapter3: RCRA Permitting Page 3-31
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- Agency develops a mailing list
- Additional activities that may apply include: community assessments, public participation plans, information
repositories, and fact sheets
2. Application Submittal, Notice, and Review
- Agency issues a notice to the facility mailing list and state and local governments
- Agency makes application available for public review
- Additional activities that may apply include: observation decks, facility tours, community tours, workshops, and news
conferences.
3. Preparation of Draft Permit, Public Comment Period, and the Public Hearing
Agency issues public notice of draft permit (or intent to deny)
Agency prepares a fact sheet or statement of basis
Agency announces a 45-day public comment period
Hold a public hearing, if requested or at the agency's discretion, with 30-day advance notice
Additional activities that may apply include: information sessions, workshops, news releases, and fact sheets.
4. Response to Public Comments and the Final Permit Decision
Agency responds to all significant comments raised during the public comment period, or during any hearing
Agency issues notice of final permit decision
The regulatory agency can initiate a permit modification under 40 CFR 270.41 following the full permitting procedures of 40 CFR
Part 124. A facility may also initiate a Class 1, 2, or 3 permit modification under 40 CFR 270.42. For facility-initiated
modifications, public participation activities are required of both the facility and the regulatory agency, as described below:
1. Class 1
Facility Requirements:
Notify mailing list within 90 days
2. Class 2
Facility Requirements:
Notify mailing list and public newspaper notice
Announce 60-day public comment period
Place modification request and supporting documentation in an accessible location in the vicinity of the facility
Hold public meeting
If the regulatory agency does not act within 250 days of the modification request, notify mailing list that automatic
authorization will become permanent in 50 days
Regulatory Agency Requirements:
Allow 60 days for public comment on the modification request
Consider all written comments and respond in writing to all significant comments
Issue notice to the mailing list within 10 days of any decision to grant or deny a modification request
Issue notice to the mailing list within 10 days after an automatic authorization goes into effect
3. Class 3
Facility Requirements:
Notify mailing list and publish newspaper notice
Announce 60-day public comment period
Place modification request and supporting documentation in an accessible location in the vicinity of the facility
Hold public meeting
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Regulatory Agency Requirements:
Allow 60 days for public comment on the modification request
Issue public notice
Prepare a fact sheet or statement of basis
Announce a 45-day public comment period on draft permit decision
Hold a public hearing, if requested, with 30-day advance notice
Issue or deny the modification request
Respond to written and oral comments from the 45-day comment period
Consider and respond to all significant written comments received during the 60-day comment period
For Class 2 or 3 modifications, the permitting agency may grant a facility temporary authorization to perform certain activities for
up to 180 days. The facility must notify the public within seven days of making the request. The agency may grant a temporary
authorization without prior public notice and comment.
For facilities seeking permits, the public has the opportunity to comment on closure and post-closure plans and any amendments to
the plans as part of the permitting process and permit modification procedures. The public can also comment and request hearings
on closure and post-closure plans submitted by interim status facilities. The permitting agency can initiate, and the facility can
request, modifications to interim status plans; these requests are also subject to public comment.
Post-closure permits and plans often mandate corrective action.
Chapter3: RCRA Permitting Page 3-33
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Exhibit 3-1
Public Participation Requirements for Class 1, 2, and 3 Permit Modifications
Class 1
Type of Changes — Routine and administrative changes
Required Activities
Within 90 days of implementing a change, facility must notify all parties on mailing list.
Class 2
Type of Changes — Improvements in technology and management techniques
Required Activities
Day 1: Regulatory agency receives modification request.
Day 7: Facility publishes newspaper notice, notifies mailing list, and places copy of permit modification request and
supporting documents in accessible location.
Days 15-45: Facility holds public meeting.
Day 60: Written public comments due to regulatory agency.
Day 90: Regulatory agency response to modification request due, including response to written comments. Deadline may be
extended 30 days.
Day 120: If regulatory agency has not responded, requested activity may begin for 180 days under an automatic
authorization.
Day 250: If regulatory agency still has not responded, facility notifies public that authorization will become permanent
unless regulatory agency responds within 50 days.
Day 300: If regulatory agency has not responded, activity is permanently authorized.
Regulatory agency must notify mailing list within 10 days of any decision to grant or deny modification request, or after an
automatic authorization goes into effect.
Class 3
Type of Changes — Major changes to a facility and its operations
Required Activities
Day 1: Regulatory agency receives modification request.
Day 7: Facility publishes newspaper notice, notifies mailing list, and places copy of the permit modification request and
supporting documents in an accessible location.
Days 15-45: Facility holds public meeting.
Day 60: Written public comments due to regulatory agency.
After the conclusion of the 60-day comment period, the regulatory agency must grant or deny the permit modification request
according to the permit modification procedures of 40 CFR Part 124. These include:
• Issuing public notice of the draft permit modification or intent to deny the modification;
• Preparing a fact sheet or statement of basis;
• Announcing a 45-day public comment period;
• Holding a public hearing, if requested, with a 30-day advance notice;
• Considering and responding to all significant written and oral comments received during the 45-day comment period; and
• Issuing notice of the final permit modification.
In addition, the regulatory agency must consider and respond to all significant written comments received during the 60-day
comment period.
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Chapter 4
Public Participation in RCRA
Corrective Action Under Permits and
§300800 Orders
Introduction
Corrective action
may take place under
a permit or an
enforcement order.
RCRA requires owners and operators of hazardous waste management
facilities to clean up contamination resulting from current and past
practices. These cleanups, known as corrective actions, reduce risks to
human health and the environment.
As with the rest of the RCRA program, state environmental agencies can
receive authorization from EPA to implement the corrective action
program. The corrective action requirements in authorized states must be
at least as stringent as the federal requirements and may be more stringent.
Where states implement the program, EPA plays an oversight role; the
Agency implements the program in non-authorized states.
This chapter lays out a framework for corrective action public participation
that follows the typical approach to facility cleanup (e.g., site investigation,
analysis of alternatives, remedy selection). However, alternative
approaches may be used provided they achieve the goals of full, fair, and
equitable public participation. More than 5,000 facilities are subject to
RCRA corrective action. The degree of cleanup necessary to protect human
health and the environment varies significantly across these facilities. Few
cleanups will follow exactly the same course; therefore, program
implementors and facility owners/operators must be allowed significant
latitude to structure the corrective action process, develop cleanup
objectives, and select remedies appropriate to facility-specific
circumstances. Similar latitude must be allowed in determining the best
approach to public participation, in order to provide opportunities
appropriate for the level of interest and responsive to community concerns.
At the federal level, corrective actions may take place under a RCRA
permit or as an enforcement order under §3008 of RCRA. In authorized
states, corrective action may take place under a state-issued RCRA permit,
a state cleanup order, a state voluntary cleanup program, or another state
cleanup authority. Since authorized states may use a variety or
combination of state authorities to compel or oversee corrective actions,
EPA encourages interested individuals to check with their state agency to
gather information on the available public participation opportunities.
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The RCRA corrective action program is the counterpart of EPA's other
hazardous waste clean-up program, "Superfund," which is formally known
as the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA). Unlike most Superfund clean-ups, RCRA
corrective actions generally take place at facilities that continue to operate,
and the current facility owner or operator is involved in the cleanup.
Because cleanups under RCRA and Superfund often involve similar issues,
EPA encourages equivalent public participation procedures in the two
programs. Thus, parts of this chapter will refer you to the Community
Relations in Superfund handbook (EPA/540/R-92/009, January 1992),
which is available by calling the RCRA/Superfund Hotline at 1-800-424-
9346.
Current Status of
the Corrective
Action Program
The ANPR emphasizes
areas of flexibility in
corrective action and
describes how the
program is improving.
Although Subpart S
regulations are not final,
much of the 1990 proposal is
routinely used as guidance by
permit writers.
On May 1, 1996, EPA published an Advance Notice of Proposed
Rulemaking (ANPR) in the Federal Register (61 FR 19432). The Notice:
(1) presents EPA's strategy for writing final corrective action regulations;
(2) describes the current corrective action program and requests
information to help EPA identify and implement improvements to the
program; and (3) emphasizes areas of flexibility in the current program and
describes program improvements already underway.
Public participation during corrective action derives from a combination of
regulations and EPA guidance. The regulations set out requirements that
facilities and agencies must meet when a permit is issued or modified,
under 40 CFR parts 124 and 270, to incorporate corrective action
provisions. EPA guidance, on the other hand, suggests additional
provisions that the permitting agency may include in the permit. One
example of such guidance for corrective action activities is the Proposed
Subpart S rule (55 FR 30798, July 27, 1990). The Subpart S regulations are
not final, but much of the 1990 proposal is routinely used as guidance by
permit writers.:
Since there are no regulations requiring public participation under §3008(h)
orders, any such activities are based on guidance. EPA policy states that
the opportunities for public participation should be generally the same as
those
Two provisions of the 1990 proposal were promulgated in 1993: the final corrective action management unit (CAMU) and
temporary unit regulations on February 16, 1993 (58 FR 8658). Under this final rule, CAMUs and temporary units may be
designated by the regulatory agency in the permit prior to or during remedy selection according to the procedures in 40 CFR
270.41; these units may also be implemented through the use of Section 3008(h) orders or order modifications. Conversely, the
facility may request a permit modification to implement a CAMU following the Class 3 permit modification process defined in 40
CFR 270.42. If approval of a temporary unit or time extension for a temporary unit is not requested under a Class 3 permit
modification or obtained under a regulatory agency-initiated modification, the facility owner or operator may request approval for
a temporary unit according to the procedures for a Class 2 permit modification. Chapter 3 (RCRA Permitting) discusses the public
participation activities associated with each level of permit modification.
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In the 1996 ANPR, the
Agency reaffirmed
using portions of the
1990 proposal as
guidance.
Public participation
should come early in
the corrective action
process.
opportunities that accompany corrective action under a permit (see the
section called "Special Considerations for Public Participation Activities
Under §3008(h) Orders" below).
The May 1, 1996 ANPR reaffirms the Agency's use of portions of the 1990
proposal as guidance, including many of the portions addressing public
participation in corrective action. While much of the 1990 proposal will
still be used as guidance, the ANPR emphasizes the need for flexibility in
developing site-specific corrective action schedules and requirements,
including public participation requirements tailored to meet the needs of the
local community.
As described in the ANPR, EPA is actively looking for opportunities to
identify and implement improvements to make the corrective action
program faster, more efficient, more protective, and more focused on
results. In the ANPR, the Agency emphasizes that revisions to the
corrective action program should also enhance opportunities for timely and
meaningful public participation.
This chapter outlines the public participation activities associated with the
corrective action process under both permits and §3008(h) orders. It
describes public participation activities currently required under federal
regulations and policies, as well as additional activities that EPA
recommends. If additional guidance is appropriate upon promulgation and
re-proposal of corrective action regulations, EPA will update this chapter
and make it available to the public.
The three paragraphs below provide a few guidelines for public
participation, in the form of overarching principles, which should be
considered throughout the corrective action process.
Early Participation
As we emphasized in Chapter 2, public participation should begin early in
the permitting process. It should also begin early in the corrective action
process. Many of the important decisions in a corrective action are made
during the site investigation and characterization. Overseeing agencies and
facilities should make all reasonable efforts to provide for early public
participation during these phases.
Consistency with Superfund
A significant portion of the RCRA corrective action process is analogous to
the Superfund process. Due to this similarity, EPA encourages permitting
agencies and facilities to make public participation activities under the
RCRA system consistent with those activities required under Superfund.
For example, RCRA interim actions should provide opportunities for
participation that are similar to, or go beyond, Superfund public
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Special
Considerations for
Public Participation
Activities Under
§3008(h) Orders
Under EPA policy,
public participation
requirements during
corrective action are
generally the same
under orders and
permits.
participation for removal actions, and similar opportunities for participation
should be available under both corrective measures implementation and a
Superfund remedial action.
Shared Responsibility for Public Participation
Activities
The corrective action process may involve cleanup steps that are initiated
by an overseeing agency or a facility owner/operator. Public participation
activities will often be more useful for the public if the party who
performed the latest cleanup step then conducts the public participation
activity. For instance, if the facility owner/operator does a facility
investigation, then it would usually be more appropriate for the facility
owner/operator to run the public meeting or whatever activity follows the
investigation. In addition, EPA recognizes that important forms of public
participation take place outside of the formal corrective action process.
The Agency encourages public interest, environmental, civic, and other
organizations to provide such activities. The Agency also encourages
citizens to discuss cleanup and permitting issues with knowledgeable
stakeholders in the community.
As we mentioned above, corrective action activities are conducted under an
order issued under RCRA Section 3008(h). RCRA 3008(h) orders may be
used to get corrective action started in advance of facility permitting or
when a facility is closing under interim status. RCRA 3008(h) orders may
be issued either on consent or unilaterally. A consent order is issued when
the facility and the regulatory agency have come to an agreement about the
corrective action; a unilateral order is issued when the regulatory agency
and the facility have been unable to agree about the need for, or the scope
of, corrective action.
As a matter of EPA policy, the substantive corrective action requirements
and public participation requirements imposed under an order are generally
the same as those that would occur if corrective action were taking place
under a permit (61 FR 19432, May 1, 1996); however, because orders have
significant administrative differences from permits there are some special
considerations. For example: under a §3008(h) order, there may be
limitations on the permitting agency's ability to release or discuss certain
information; no public participation activities are statutorily required under
§3008(h), though EPA policy is that public participation under corrective
action orders be generally the same as under permits; and, while facility
owner/operators may agree to conduct public participation activities under
a consent order, under a unilateral order public participation responsibilities
will likely fall to the permitting agency.
In addition to ensuring that appropriate public participation activities occur
during implementation of a corrective action order, in some cases, it may
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be useful to begin public participation prior to the issuance of the order by
assessing the community's concerns and identifying the most appropriate
means of addressing those concerns. (Assessing a community's concerns
and planning for public participation is discussed in greater detail in
Chapter 2.) When corrective action will take place under a consent order,
care should be taken to explain to the community that corrective action
orders on consent are not traditional enforcement actions in that they are
simply means to expedite initiation of corrective action activities; they are
not typically issued in response to a violation at the facility.
Limitations on Releasing Information: When the agency is negotiating
an order with the facility, confidentiality of certain information must be
maintained. The aim of these negotiations is to encourage frank discussion
of all issues and to resolve differences, thereby allowing the agency to issue
an order on consent rather than unilaterally. Agency staff should take
notice: public disclosure of some information may be in violation of state
and federal statutes, and could jeopardize the success of the negotiations, so
be sure to coordinate any public notices with enforcement staff before
releasing information.
Not being able to fully disclose information to the public can pose
problems, particularly in a community where interest is high and citizens
are requesting information. If interest in the facility is high, the project
manager, project staff, and the Public Involvement Coordinator should
discuss how to address citizens' concerns without breaching confidentiality.
At the very least, the public deserves to know why these limitations are
necessary and when and if they will be lifted.
Further constraints may be placed upon public participation if discussions
with the facility break down, and the case is referred to the Department of
Justice (DOJ) to initiate litigation. In this situation, public participation
planning should be coordinated with the lead DOJ attorney as well.
Strongly Suggested Versus Required Activities: As discussed earlier in
this Chapter, EPA's policy is that the substantive corrective action
requirements and public participation requirements imposed under an order
should be generally the same as those that would occur if corrective action
were taking place under a permit. U.S. EPA's Office of Solid Waste and
Emergency Response has issued two directives addressing public
participation in §3008(h) orders: Directive 9901.3, Guidance for Public
Involvement in RCRA Section 3008(h) Actions (May 5, 1987) and
Directive 9902.6, RCRA Corrective Action Decision Documents: The
Statement of Basis and Response to Comments (April 29, 1991). These
directives suggest public participation activities in orders, even though such
activities are not required by statute. The directives suggest the following
activities after a proposed remedy has been selected:
• Writing a statement of basis discussing the proposed remedy;
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Public Participation
In Corrective Action
• Providing public notice that a proposed remedy has been selected and
the statement of basis is available;
• Providing a public comment period (30-45 days) on the proposed
remedy;
• Holding a public hearing if requested; and
• Writing a final decision and response to comments .
The remainder of this Chapter reflects EPA's support for having equivalent
public participation steps under both permits and orders. While there are
no requirements for public participation under orders, EPA strongly
suggests the activities reviewed in this Chapter. In our review of the
corrective action elements (initial site assessment, site characterization,
etc.) in the following pages, we discuss public participation activities that
are required or additional. Because EPA strongly suggests public
participation activities under orders, we present them under the "Required
Activities" headings for each corrective action element.
Consent Versus Unilateral Orders: If the agency is issuing a consent
order, the agency should consider negotiating with the facility to have it
write a public participation plan (if community interest in the facility is
high), or at least conduct some activities as terms of the order. If the
agency is issuing a unilateral order, however, circumstances may be such
that it is necessary and/or appropriate for the agency to assume all or most
public participation responsibilities. Care must be used regarding the
disclosure of information prior to the issuance of a unilateral order.
Premature disclosure may place additional strain on the facility-agency
relationship.
Because corrective action activities involve investigation of releases and
potential releases of hazardous waste, the community is likely to take an
active interest. Corrective action investigations and remedial activities may
be very visible to the public. Experts visit the facility to conduct
investigations, trucks and equipment travel back and forth to the facility,
and government agencies oversee activities. Delays in the cleanup or long
"down times" between permitting activities are not uncommon. All of
these factors can heighten the anxiety and concern of the community.
Accordingly, the community may require more information on issues
related to current or potential contamination, including levels of
contamination, the extent of health and environmental risks, and the
potential for future risks. The public may also seek additional opportunities
to give input to the overseeing agency or the facility.
The regulatory requirements provide a baseline for adequate public
participation while leaving a great deal of flexibility in the program. Some
situations will call for public participation opportunities that go beyond the
regulatory baseline. Where regulations do not specify public participation
during corrective action, overseeing agencies and facility owners/operators
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A successful corrective
action program must be
procedurally flexible; no
one approach will be
appropriate for all facilities.
should develop site-specific public participation strategies that are
consistent with existing requirements and provide for full, fair, and
equitable public participation.
The scope and complexity of corrective actions will vary significantly
across facilities. For this reason, EPA has created a flexible program that
allows regulatory agencies to tailor corrective action requirements to
facility-specific conditions and circumstances. While EPA's public
participation regulations establish a baseline of requirements, some
situations will call for public participation opportunities that go beyond the
regulatory baseline. This is particularly true in the corrective action
program because many of the specific corrective action regulations,
including regulations for public participation, are not yet final and because
corrective action activities often occur outside the permitting process (e.g.,
under a federal or state order). In this chapter, we will discuss times during
the process when additional public participation can be critical. We
encourage stakeholders to follow the guidance in this chapter and Chapter 2
when planning for public participation in the corrective action process.
Corrective actions, like most site cleanup activities, usually involve several
key elements. These elements are:
• Initial Site Assessment (RCRA Facility Assessment (RFA));
• Site Characterization (RCRA Facility Investigation (RFI);
• Interim Actions;
• Evaluation of Remedial Alternatives (Corrective Measures
Study (CMS);
• Remedy Selection;
• Remedy Implementation (Corrective Measures Implementation
(CMI)); and
• Completion of the Remedy.
The corrective action process is not linear. The elements above should not
be viewed as prescribed steps on a path, but as evaluations that are
necessary to support good cleanup decisions. Because these elements may
not occur in the same order (or at all) at every facility, we encourage
planners to use them as general guidelines, while leaving flexibility for
changes. A successful corrective action program must be procedurally
flexible; no one approach to implementing these cleanup elements will be
appropriate for all facilities. The seven elements, and the public
participation activities associated with them, are described in the sections
below.
Refer to Chapter 3 for additional information on permitting, including
permit modifications, and Chapter 5 for specific details on public
participation activities described in this chapter.
The corrective action process usually begins with an initial site assessment,
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Initial Site
Assessment (RFA)
called a RCRA Facility Assessment or RFA. The RFA is conducted either
by the overseeing agency or by the facility with subsequent agency
approval. The purpose of an RFA is to gather data about a site, including
releases and potential releases of hazardous waste and hazardous
constituents, to determine whether a cleanup may be necessary. RFAs
usually include (1) a file review of available information on the facility; (2)
a visual site inspection to confirm available information on solid waste
management units (SWMUs) at the facility and to note any visual evidence
of releases; and (3) in some cases, a sampling visit to confirm or disprove
suspected releases.
The results of an RFA are recorded in an RFA report. The RFA report will
describe the facility and the waste management units present at the facility
and note any releases or potential releases. It will also describe releases
and potential releases from other, non-waste-management-associated
sources (e.g., a spill from a product storage tank). Interested individuals
may request copies of RFA reports from the appropriate EPA regional
office or state agency.
In addition to the information recorded in RFA reports, if corrective action
is taking place in the context of a RCRA permit, the permit application will
also describe the physical condition of the facility including its subsurface
geology, the waste management units present at the facility, and any
releases and potential releases.
The RFA report usually serves as the basis for future corrective actions at a
facility. If, after completion of the RFA, it appears likely that a release
exists, then the overseeing agency will typically develop facility-specific
corrective action requirements in a schedule of compliance, which will be
included in the facility's permit or in a RCRA Section 3008(h) corrective
action order.
In the case of corrective action implemented through a permit, the public
may comment on the schedule of compliance for corrective action during
permit issuance and subsequent permit modification (see Chapter 3 for
more information on the permitting process and permit modifications).
When corrective action is implemented though a 3008(h) order, the public
should be given an opportunity to comment on the schedule of compliance
when the order is issued; however, it may take many months of discussions
between the facility owner/operator and the overseeing agency before an
order is issued. In the meantime, the facility owner/operator may develop a
mailing list, modeled after the mailing list developed under the permitting
process, and a public participation plan .
On the day the order is issued, the administrative record, containing all
information considered by the agency in developing the order, is made
available for inspection by the public. The agency may also want to place a
copy of the administrative record at a local library close to the facility.
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The overseeing agency or facility owner/operator should consider writing a
fact sheet that gives details of the order and the corrective action process.
If there is a high level of interest in the facility, an open house or
workshop should be considered.
A RCRA Facility Investigation or RFI is necessary when a release or
potential release is identified and additional information is necessary to
determine the nature and scope of corrective action, if any, that is needed.
The purpose of an RFI is to characterize the nature and extent of
contamination at the facility and to support selection and implementation of
a remedy or remedies or, if necessary, interim measures.
Required Activities
If corrective action is being conducted in the context of a RCRA permit, the
public has the opportunity to review and comment on the scope of the RFI
and RFI schedules and conditions during permit issuance. The RFI is
usually conducted by following an agency-approved RFI plan. If the RFI
plan is incorporated into a permit by a permit modification, then the public
will have an opportunity to comment on the scope and schedule of the RFI
during the modification process. See Chapter 3 for more information on
public participation during permit modifications.
If corrective action is being conducted under a 3008(h) order, the public
should be given the opportunity to review and comment on the scope of the
RFI and RFI conditions when the order is issued and/or when the RFI
workplan is approved.
RFIs can often involve numerous rounds of field investigation and can take
months or even years to complete. During the RFI process, it may be
necessary to change the RFI requirements or modify the RFI schedule to
react to new information. When corrective action is being conducted in the
context of a RCRA permit, the public has an opportunity to comment on
changes to RFI conditions and schedules during the permit modification
process. Significant changes to the scope of RFI requirements are typically
Class 3 permit modifications, changes to RFI schedules or investigatory
details (e.g., a change in the number of samples to be collected in a given
sampling area) are typically considered either Class 1 or Class 2
modifications, depending on their significance. When corrective action is
being conducted under an order, the public's opportunities to review
changes to RFI conditions and schedules should be consistent with the
opportunities that are available under a permit. The facility mailing list,
developed during the initial stages of the permitting process, or a mailing
list developed during preparation of the corrective action order, should be
used and updated throughout the corrective action process in order to keep
members of the community informed. (See Chapters 3 and 5 for more
information on facility mailing lists.)
Chapter 4: Corrective Action and §3008(h) Orders Page 4-9
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In some cases (e.g., where there is a high level of public interest in
corrective action activities), the overseeing agency will determine that an
information repository is needed to ensure adequate public involvement.
When corrective action is being conducted under a RCRA permit the
agency can require the facility to establish a repository under § 270.30(m).
A repository at the RFI stage will provide access to information from an
early stage in the process, though the agency has the discretion to use this
provision at any stage in the permitting process or at any stage during the
corrective action. If the agency decides to require a repository, it will
direct the facility to notify the public of the existence of the repository,
including the name and phone number of a contact person. See Chapter 5
for more detail on information repositories.
Additional Activities
The start of the RFI usually marks the beginning of highly visible, on-going
corrective action activities at a facility. Because RFI activities are highly
visible and because many of the important decisions regarding the scope of
potential corrective actions may be made during the RFI, it will generally
be appropriate to reevaluate community concerns and the level of public
participation and to revise the public participation plan accordingly (see
Chapter 5) when RFIs begin. Such efforts early in the process, before
community concerns and issues become overwhelming, will be beneficial
in the long run.
Developing and distributing fact sheets throughout the RFI process is an
excellent way to keep in touch with the community. It is a good idea to
issue a fact sheet before the RFI begins to explain the investigation's
purpose and scope. Another fact sheet should be issued after the RFI is
completed to report the investigation results.
EPA encourages all facilities to make the results of the RFI readily
available to interested stakeholders. One means of providing access to the
information is to send a summary of the RFI report to the facility
mailing list, as proposed in the 1990 Subpart S proposal. The facility may
choose other means of distributing the information, such as through a fact
sheet or project newsletter . The full report should be made available for
review in an information repository , if one exists, or through some other
method that is convenient for the interested public.
The facility owner/operator should provide notice to all adjacent
landowners and other persons who may have been affected by releases of
contamination, via air or ground water, from the facility. EPA
recommends that the owner/operator follow the provisions in the 1990
proposal (proposed § 264.560(a) and (b)) for notifications for discoveries
of contamination (see 55 FR 30882).
Chapter 4: Corrective Action and §3008(h) Orders Page 4-10
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Informal meetings or workshops held by the facility, the permitting
agency, or public interest groups can provide valuable forums for
discussing community concerns.
Interim actions are activities used to control or abate ongoing risks to
human health or the environment in advance of final remedy selection. For
example, interim actions may be required in situations where contamination
poses an immediate threat to human health or the environment. They also
may be required to prevent further environmental degradation or
contaminant migration prior to implementing the final remedy. Interim
actions may occur at any point in the corrective action process; however,
they are often implemented during the RFI or CMS.
Required Activities
When corrective action is proceeding under a RCRA permit, the permit
may identify specific interim measures and/or stabilization measures (if
they are known at the time of permit issuance) or may have general
conditions that govern when interim measures might be required during the
course of the corrective action. In either case, the public can comment on
the interim measures strategy in the draft permit as part of the permitting
process.
When corrective action is proceeding under a 3008(h) order, the public
should have the opportunity to comment on specific interim measures or
general interim measure conditions when the order is issued, or otherwise
in a manner that is consistent with the opportunities available when
corrective action takes place under a permit.
Additional Activities
In recent years EPA has increasingly emphasized the importance of interim
measures and site stabilization in the corrective action program. In the
ANPR, EPA notes that an overriding goal in our management of the
corrective action program is to help reduce risks by emphasizing early use
of interim actions (while staying consistent with the environmental
objectives at the facility). If a facility owner/operator or the permitting
agency anticipates that an early interim action will be the only cleanup step
taken over a significant period of time, then the facility or the agency
should inform the public of such a plan and receive feedback, unless the
immediacy of the situation will not allow for feedback. The facility and the
agency should both announce a contact person to provide information and
respond to inquiries about the action. Agencies and facilities may find
Superfund guidance on removal actions useful in the RCRA context (see
Community Relations in Superfund: A Handbook, Chapter 5).
Chapter 4: Corrective Action and §3008(h) Orders Page 4-11
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Evaluation of
Remedial
Alternatives (CMS)
It is a good idea to keep the public informed of such activities by issuing
fact sheets or holding informal meetings . Because interim measures can
be conducted at any stage in the corrective action process, you should
incorporate activities related to interim measures into the rest of your
public involvement program.
When the need for corrective measures is verified, the facility may be
required to perform a Corrective Measures Study (CMS) to identify and
evaluate potential remedial alternatives. In cases where EPA or a state is
using performance standards or a similar approach and in cases where the
preferred remedial alternative is obvious (e.g., where EPA has issued a
presumptive remedy that is appropriate to site-specific conditions),
submission of a formal CMS may not be necessary.
Required Activities
When corrective action is proceeding under a permit, the permit schedule
of compliance may already include conditions that specify when a CMS is
warranted; the public can comment on these draft permit conditions at the
time of permit issuance. However, because the RFI and CMS phases may
last several years, depending on the complexity of the facility, the
community may be frustrated by the length of time involved and the lack of
information on results or findings. Significant changes to the scope of
CMS requirements, as specified in the permit, may be considered Class 3
permit modifications requiring significant public involvement. Changes to
the CMS schedule, or CMS details are typically considered class 1 or 2
permit modifications, as appropriate.
Public participation during corrective action under a 3008(h) order should
be consistent with public participation under a permit. The public should
have the opportunity to review and comment on the scope of the CMS and
CMS conditions when the order is issued and/or when the CMS
workplan is approved.
Additional Activities
In the 1996 ANPR, EPA emphasizes that it expects facility
owners/operators to recommend a preferred remedy as part of the CMS.
While there is no formal requirement for public participation at this time,
EPA strongly encourages the facility to present its preferred remedy to the
community before formally submitting it to the agency. The facility should
seek community input through an informal meeting, availability session ,
or another method that encourages dialogue. This early input is likely to
improve many preferred remedies and make them more agreeable to
communities. Moreover, it will make the facility and the overseeing
agency aware of community concerns and ways to address them.
Chapter 4: Corrective Action and §3008(h) Orders
Page 4-12
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Holding workshops and informal public meetings about the CMS
process, the remedies being considered, and the activities being conducted
at the facility will keep the community involved and informed. Fact sheets
distributed at significant milestones during the CMS can keep the
community abreast of the progress that has been made.
The agency and the facility should provide the name and number of a
contact person. A contact person will accept comments and answer
questions from the community, disseminate information, demonstrate the
agency's and facility's willingness to talk with the community, and give the
facility or the agency an opportunity to respond to public concerns. The
agency or the facility may even consider establishing a hotline if a large
number of people call with questions. The mailing list and local
newspapers are good ways to advertise availability of the hotline.
Selection Following receipt of a recommendation of a preferred remedy from the
facility owner/operator, the overseeing agency will review the preferred
remedy and other remedial alternatives and decide to tentatively approve
the preferred remedy, tentatively select a different remedy or require
additional analysis of remedial alternatives. The tentatively selected
remedy will then undergo public review and comment, usually in the form
of a proposed modification to the facility's permit or corrective action
order. Following public review, the agency will respond to public
comments and then modify the facility permit or corrective action order to
incorporate the remedy.
Required Activities
When corrective action is proceeding under a permit, public review and
comment on the tentatively selected remedy is generally conducted using
the procedures of 40 CFR 270.41 for agency-initiated permit modifications.
For such a modification, 40 CFR 270.41 requires the same level of public
participation as is required for a draft permit. The agency must release the
proposed modification for public review and issue a public notice
announcing that the proposed modification is available for review. The
agency must publish this notice in a major local newspaper, broadcast it
over local radio stations, and send it to all persons on the mailing list.
In addition, agency staff must prepare a fact sheet or statement of basis to
explain the proposed modification and the significant factual and legal
reasons for proposing the remedy. The statement of basis describes the
proposed remedy, but does not select the final remedy for a facility. This
approach allows for consideration of additional information during the
public comment period . Following the comment period, public comment
and/or additional data may result in changes to the remedy or in another
choice of remedy. After the agency has considered all comments from the
public, the final decision ~ selecting the remedy or determining the need to
Chapter 4: Corrective Action and §3008(h) Orders Page 4-13
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develop another option - is documented in the response to comments. (For
more information on statements of basis, refer to OSWER Directive
9902.6, RCRA Corrective Action Decision Documents: The Statement of
Basis and Response to Comments (April 29, 1991)).
A 45-day public comment period on the draft permit modification follows
publication of the public notice. The comment period provides the public
with an opportunity to comment, in writing, on conditions contained in the
draft permit modification. If information submitted during the initial
comment period appears to raise substantial new questions concerning the
draft permit modification, the agency must re-open or extend the comment
period.
The members of the public may request a public hearing on the draft
permit modification. If a hearing is requested, the agency must give a 30-
day advance notice to the community that states the time and place of the
hearing. The agency Director has the discretion to schedule a public
meeting or hearing even if the community does not request one. In some
cases, scheduling a public hearing before the public requests one may save
valuable time in the modification process and demonstrate a willingness to
meet with the community to hear its questions and concerns.
After the public comment period closes, the agency must review and
evaluate all written and oral comments and issue a final decision on the
permit modification. Then the agency must send a notice of decision to the
facility owner or operator and any persons who submitted public comments
or requested notice of the final decision and prepare a written response to
comments. This document must include a summary of all significant
comments received during the public comment period and an explanation
of how they were addressed in the final permit modification or why they
were rejected. The response to comments must be made available through
the Administrative Record and the information repository , if one was
established, and must be sent to the facility and all persons who submitted
comments or requested a copy of your response.
When corrective action is proceeding under a 3008(h) order, the Agency's
longstanding policy is that the public's opportunity to review and comment
on tentatively-selected remedies should be commensurate with the
opportunity that would be available if the corrective action were conducted
under a permit. At a minimum, this opportunity should include: publishing
a notice and a brief analysis of the tentatively-selected remedy (this is
typically referred to as a statement of basis) and making supporting
information available; providing a reasonable opportunity for submission of
written comments; holding a public hearing or public meeting, if requested
by the public or determined necessary by the overseeing agency; preparing
and publishing responses to comments; and, publishing the final remedy
decision and making supporting information available. Additional guidance
is available in OSWER Directives 9901.3, Guidance for Public
Chapter 4: Corrective Action and §3008(h) Orders Page 4-14
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Remedy
Implementation
(CMI)
Involvement in RCRA Section 3008(h) Actions (May 5, 1987) and 9902.6
RCRA Corrective Action Decision Documents: The Statement of Basis and
response to Comments (April 29, 1991).
Additional Activities
The agency, public interest groups, or the facility should consider holding
workshops or informal meetings during the public comment period to
inform the public about the proposed remedy. These discussion sessions
can be especially useful when information about corrective measures in a
draft permit modification is quite technical or the level of community
concern is high.
Once the overseeing agency modifies the permit or corrective action order
to include the selected remedy, the facility must begin to implement the
remedy. Remedy implementation typically involves detailed remedy
design, remedy construction, and remedy operation and maintenance; it is
called Corrective Measures Implementation or CMI. Corrective measures
implementation is generally conducted in accordance with a CMI plan,
approved by the overseeing agency.
Required Activities
When corrective action is proceeding under a permit, the public will have
an opportunity to comment on CMI conditions and schedules during the
permit modification for remedy selection or when the permit is modified to
incorporate the CMI plan. Significant changes to the scope of CMI may be
considered Class 3 permit modifications. Changes to the CMI schedule are
typically considered either Class 1 or Class 2 permit modifications, as
appropriate.
When corrective action is proceeding under a 3008(h) order, the public's
opportunity to comment on CMI conditions and schedules should be
consistent with the opportunities that would be available if corrective action
were taking place under a permit.
Additional Activities
Remedy implementation will often involve highly visible activities, such as
construction of new on-site treatment and containment systems, and staging
and transportation of large volumes of materials. These activities may
result in increased levels of public interest, which may already be high due
to the public's participation in remedy selection.
EPA recommends that the facility notify all individuals on the facility
mailing list when the construction plans and specifications are available for
public review. If the facility has established an information repository ,
Chapter 4: Corrective Action and §3008(h) Orders
Page 4-15
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Completion of
Remedy
then the plans should go in the repository; otherwise, the facility should
place the plans in a convenient location with public access.
As mentioned earlier, the corrective action process can take years to
complete. Additional public participation activities may be appropriate
during corrective measures implementation to inform the community of the
progress of the remedial action, especially if the public shows concern over
the pace and scope of the cleanup operations. In particular, it may be
useful to release periodic fact sheets to the community that report on
progress of the cleanup operations. It may also be helpful to hold an
availability session/open house near or on the site of the facility to
demonstrate or explain the activities involved in the remedy.
Once corrective measures are complete the overseeing agency will either
terminate the corrective action order or modify the permit to remove the
corrective action schedule of compliance. Decisions regarding completion
of corrective measures can be made for an entire facility, for a portion of a
facility, or for a specified unit or release. EPA policy is for the public to be
given an opportunity to review and comment on all proposals to complete
corrective action.
Required Activities
When corrective action is proceeding under a permit, proposals to complete
corrective measures should follow the procedures for Class 3 permit
modifications. See the section on Class 3 modifications in Chapter 3 for
details.
When corrective action is proceeding under a 3008(h) order and a proposal
to complete corrective measures is issued, the public should have notice
and comment opportunities that are consistent with the opportunities
available under the Class 3 permit modification procedures.
Additional Activities
In some cases, hazardous wastes or hazardous constituents will remain in or
on the land after completion of corrective measures. When this occurs, the
overseeing agency may require the facility to record a notation in the deed
to the facility property regarding the types, concentrations, and locations of
such waste or constituents.
Chapter 4: Corrective Action and §3008(h) Orders
Page 4-16
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Chapter Summary
At the federal level, corrective actions may take place under a RCRA permit or as an enforcement order under §3008 of RCRA.
In authorized states, corrective action may take place under a state-issued RCRA permit, a state cleanup order, a state voluntary
cleanup program, or another state cleanup authority. Authorized states may use a variety or combination of state authorities to
compel or oversee corrective actions.
EPA's recent Advance Notice of Proposed Rulemaking (ANPR) (61 FR 19432,May 1, 1996) for the corrective action program
does three things: (1) it presents EPA's strategy for writing final corrective action regulations; (2) it includes a description of the
current corrective action program and requests information to help EPA identify and implement improvements to the program;
and (3) it emphasizes areas of flexibility in the current program and describes program improvements already underway.
The ANPR also affirmed EPA's use of the 1990 proposal as guidance and emphasized the Agency's commitment to enhanced
public participation.
As a matter of EPA policy, the type and timing of public participation activities for §3008(h) orders are generally the same as
those for corrective action in permitting.
There are three important distinctions between conducting public participation in corrective action under a §3008(h) order and
through permitting:
1. Under a §3008(h) order, there may be limitations on the release or discussion of certain information;
2. No public participation activities are required under §3008(h) but they are strongly encouraged in guidance. In addition,
the agency may require the facility to conduct additional activities as a term in the order; and
3. Facilities may agree to conduct public participation activities under a consent order, however, under a unilateral order, the
responsibility will likely fall to the agency.
While being flexible, the corrective actions should provide for early public participation, seek consistency with Superfund
community involvement standards, and allow facility owner/operators to perform public participation activities where appropriate.
The corrective action process is composed of seven basic elements which are not prescribed steps, but evaluations that are
necessary to make good cleanup decisions. Because these elements may not occur in the same order (or at all) in every situation,
we encourage planners to use them as general guidelines, while leaving flexibility for changes. A successful corrective action
program must be procedurally flexible
The basic elements (with corresponding public participation activities that are currently required or suggested):
1. Initial Site Assessment (RCRA Facility Assessment)
Schedule of compliance will go into permit, where public can comment
For enforcement orders, the agency will release administrative record and make it available for public review. The
agency may provide a fact sheet and hold an open house or workshop.
2. Site Characterization (RCRA Facility Investigation)
Update mailing list, if necessary
Establish information repository, if required
Revise public participation plan
Modify permit, if necessary, to reflect changes to schedule of compliance
Under an order, provide notice and comment on the planned RFI
Develop fact sheets on the investigations
Mail summary of RFI Report to facility mailing list and make available to the public
Hold informal meetings or workshops
Issue notifications for discovery of contamination
Chapter 4: Corrective Action and §3008(h) Orders Page 4-17
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3. Interim Actions — May occur at any time during the process
Provide for public input and feedback , as appropriate given time constraints, and announce a contact person
Use fact sheets and informal meetings, if appropriate
4. Evaluation of Remedial Alternatives (Corrective Measures Study)
Hold informal meetings or workshops when facility presents preferred remedy
Identify a contact person
Develop fact sheets on the study
Establish a hotline
5. Remedy Selection
Agency-initiated permit modifications follow 40 CFR 124 procedures, including public notice, public comment
period, and a hearing (if requested)
For corrective action under an order, the agency should: publish a notice and a statement of basis; take public
comment; holding a public hearing or public meeting, if requested by the public or determined necessary by the
overseeing agency; prepare and publish responses to comments; and, publish the final remedy decision while making
supporting information available.
Hold workshop on proposed remedy
Once final remedy is selected, send out notice of decision
Issue response to comments
Hold informal meetings or workshops on the final remedy
6. Corrective Measures Implementation
Notify public when plans and specifications are available for review
Develop fact sheets on remedy implementation
Coordinate availability session/open house
7. Completion of Remedy
Agency may remove schedule of compliance from the permit or terminate the order by following the Class 3
modifications procedures for a permit or a similar process for an order.
Chapter 4: Corrective Action and §3008(h) Orders Page 4-18
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Chapter 5
Public Participation Activities:
How to Do Them
Introduction ^^s criaPter presents a "how-to" for a broad range of activities that
permititng agencies, public interest groups, and facility owners/operators
can use to promote public participation. The variety of activities in this
chapter should fit any situation: from the formal regulatory process that
EPA follows, to community-based discussions of RCRA issues, to events
held by the facility owner or operator.
Some of the activities in this chapter (for instance, public hearings) will be
more appropriately led by a permitting agency; however, all stakeholders
can learn more about the different kinds of activities by reviewing this
chapter. Moreover, EPA would like to emphasize that this list is not
exhaustive. You should consult with other stakeholders to determine if
these or any other public participation activities will best suit your
particular situation. Several of the appendices provide contact lists for
various stakeholder groups.
As we emphasized in the preceding chapters, public participation is a
dialogue. It involves both getting information out to other stakeholders and
getting feedback in the form of ideas, issues, and concerns. We have
divided this chapter's activities to reflect the dual role of public
participation. The first group of activities involves techniques that
disseminate information. The second group involves techniques that are
useful for gathering and exchanging information. Note that some of these
activities, such as informal meetings, are useful both for disseminating and
collecting information. On the other hand, some activities, such as public
notices, provide one-way communication. EPA encourages stakeholders to
combine public participation techniques so that they provide two-way
communication. For instance, if an agency issues a public notice, it should
create a feedback loop by including the name and number of a contact
person in the notice. Similarly, a facility or a public interest group could
provide for feedback in an information repository by asking users to
complete surveys or by assigning a staff person to answer questions at the
repository.
Chapter 5: Public Involvement Activities Page 5-1
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The following pages contain summaries of numerous public participation
activities, information on how and when to conduct them, an estimate of
how much effort they require, and their advantages and limitations. Each
summary includes a checklist to help in conducting the activity. Examples
of public notices and fact sheets are also included.
Use this directory to locate specific activities:
Public Participation Plans 5-4
l_ Disseminating Information
Public Notices 5-8
Newspaper Advertisements 5-9
Newspaper Inserts 5-9
Free Publications and Existing Newsletters 5-9
Public Service Announcements 5-10
Broadcast Announcements and Advertisements 5-10
Signs and Bulletin Boards 5-10
Telephone Networks or Phone Trees 5-11
Translations 5-16
Mailing Lists 5-19
Notices of Decision 5-24
Introductory Notices 5-26
Fact Sheets/Statements of Basis 5-29
Project Newsletters and Reports 5-34
Response to Comments 5-37
Information Repositories 5-40
Exhibits 5-47
Briefings 5-50
Presentations 5-53
Facility Tours 5-56
Observation Decks 5-59
News Releases and Press Kits 5-62
News Conferences 5-67
l_ Gathering and Exchanging Information
Community Interviews 5-70
Focus Groups 5-77
Door-to-Door Canvassing 5-80
Public Comment Periods 5-84
Unsolicited Information and Office Visits 5-87
Surveys and Telephone Polls 5-90
Contact Persons 5-94
Telephone Contacts 5-97
Telephone Hotlines 5-100
On-Scene Information Offices 5-103
Question and Answer Sessions 5-106
Information Tables 5-109
Informal Meetings with Other Stakeholders 5-112
Public Meetings 5-117
Public Hearings 5-123
Availability Sessions/Open Houses 5-130
Chapter 5: Public Involvement Activities Page 5-2
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Workshops 5-134
Attending Other Stakeholder Meetings and Functions 5-139
Citizen Advisory Groups 5-141
Chapter 5: Public Involvement Activities Page 5-3
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Public Participation
Plans
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None.
A public participation plan provides a community-specific plan for
interacting with a community regarding the permitting or corrective action
activities taking place at a RCRA facility. The plan, typically prepared by
the permitting agency, assesses the level of community interest as well as
the types of concerns identified through a variety of sources (e.g.,
community interviews ) and, based on this information, recommends
specific activities for involving the community in the RCRA process. See
the section on "Planning for Participation" in Chapter 2 and the detailed
sample plan in Appendix I for more information. Chapter 3 of Community
Relations in Superfund also provides useful guidance.
The level of detail in the plan will vary according to the probable level of
public interest, the type of permitting activity, the location of the facility,
and other applicable factors. The steps described in this section are not all
necessary in every plan. Depending on the situation, the public
participation plan may vary from a two-page schedule of activities to a
comprehensive study of the population, an itinerary of permitting activities,
and an analysis of community concerns.
A Public Participation Plan may take several days to two weeks to
complete. Revision of a plan could take a few days to a week. The range
of effort depends on the priority of the site and the complexity of the
activities performed at that site.
A Public Participation Plan should be based on information collected during
community interviews (if conducted) and information obtained from other
sources, such file searches, reviews of past media coverage, and
community assessments done by third parties (see the section entitled
"Planning for Participation" in Chapter 2). This information is analyzed
and organized into a community-specific plan. Typical sections of a public
participation plan are:
• Introduction ~ several paragraphs clearly explaining the purpose of
the document.
• Facility History ~ several paragraphs to several pages providing an
overview of the facility, its technical and regulatory history, and a
history of past community concerns and involvement in activities at
Chapter 5: Public Involvement Activities
Page 5-4
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the facility. Shortcut: attach the facility fact sheet if one already
exists.
Community Concerns ~ several paragraphs to several pages
summarizing the concerns identified during the community
interviews.
Objectives of the Plan ~ several paragraphs to several pages,
depending on the objectives, providing a narrative of the major
objectives of the plan. Objectives typically relate to the specifi
concerns outlined in the previous section.
tic
• Public Participation Activities ~ several paragraphs to several pages,
depending on the plan, describing the specific activities that will be
conducted to meet the objectives outlined in the previous section (e.g.,
meetings, fact sheets, briefings for local officials, etc.) and a schedule
for conducting these activities.
• Appendices - Appendices can be included to provide the mailing list,
media contacts, and public meeting and information repository
locations.
The activities in a public participation plan should be tailored to address
community concerns and needs. The plan should include the kinds of
activities that are discussed in this manual.
The plan should be presented in a public document that serves to
demonstrate to the community that the agency (and public interest groups
and the facility owner, if involved) listened to specific community concerns
and developed a specific program around those concerns. EPA encourages
permitting agencies to seek input from other stakeholders during
development of the plan. The facility owner and public interest groups can
provide information about their planned activities and the community
representatives can suggest the types of activities, information channels,
and logistics that will work best in the area.
Revisions of all or parts of the public participation plan for a facility may
be done in order to incorporate new information, reflect changes in
community concern, and adjust public participation activities to meet these
changes. A revision ensures that the plan remains sensitive to citizens'
concerns through the final phases of a permit determination or a corrective
action. It can also evaluate which public participation activities were
effective and which were not.
When to Use Public participation plans may be prepared:
At the beginning of the RCRA process (e.g., for facilities seeking a
permit or facilities beginning corrective action) to schedule activities
Chapter 5: Public Involvement Activities Page 5-5
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Accompanying
Activities
Advantages and
Limitations
and assign responsibilities;
• After community interviews (if conducted).
Public participation plans should be revised:
• When a significant change in community concerns or activities at the
facility occurs (e.g., after a remedy is selected or the facility proposes
a significant permit modification); and
• At least every two years for longer-term projects.
Although they are not necessary in every case, community interviews can
be very helpful when writing a plan. The plan typically includes the
mailing list and provides the locations of the information repositories and
public hearings.
Public participation plans establish a record of community concerns and
needs and a set of activities to meet those needs. Because the plans are
community-specific, they ensure that the community gets the information
they need in a fashion that is most useful and they assist the project staff in
making the most efficient use of their time when interacting with the
public.
The plan represents the agency's commitment to dedicate significant
resources to the activities specified; thus, agency staff should make certain
that resources are available to implement all activities identified in the plan.
The plan should not schedule activities that the agency will not be able to
conduct.
Community concerns can change significantly and may require that the
public participation plan be revised periodically. The plans should be seen
as "evolving" documents. The agency may need to revise the plan often,
conducting new community interviews each time. At the least, the agency
should be prepared to revise activities or expand activities as the project
proceeds.
Revising the plan will help to ensure that the agency continues to respond to
citizens' concerns during long-term projects. Minor changes also can help a
public participation planner; for example, the contacts list can incorporate
changes in addresses, new telephone numbers, and the names of new
officials.
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Checklist for Public Participation Plans
As applicable:
_ Review facility background file and other information sources
Review comments gathered during the community interviews
_ Coordinate with other key stakeholders to discuss the plan
Write draft plan
_ Introduction - explains the purpose of the document
Project History — provides an overview of the project, its technical and regulatory history,
and a history of past community concerns and involvement in the project (if available)
Community Concerns — summary of the concerns identified during the community
interviews
_ Objectives of the Plan - explains the major objectives relating to specific concerns
outlined in the previous section of the document
Public Participation Activities — describes the specific activities to be conducted to meet
the objectives of the plan and schedule
_ Appendices - provide information on key contacts, media, public meeting and information
repository locations.
Coordinate internal review of plan
_ Solicit community input on the plan
Prepare final plan based on comments
_ Distribute plan to information repositories if they exist, or make the plan available to the public
in a convenient place
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Public Notices
Regulatory
Requirements
The permitting agency must give official public notice when issuing the
draft permit (§ 124.10(c)), holding a public hearing under § 124.12, or
when an appeal is granted under § 124.19. This notice must be sent by the
agency to all relevant units of federal and local government, the applicant,
and all parties on the facility mailing list. In addition, the notice must be
broadcast over local radio stations and published in a daily or weekly major
local newspaper of general circulation.
A prospective permit applicant must issue a similar, but broader, public
notice to announce the pre-application meeting (§ 124.31). This notice
must be published as a display advertisement in a paper of general
circulation and must be sent to the permitting agency and appropriate units
of local government. The applicant must also post the notice as a sign at or
near the facility, and as a broadcast media announcement. The notice must
include the name, address, and telephone number of a contact person for
the applicant.
The facility owner/operator must provide public notice for permit
modfications (including modifications to incorporate corrective action
provisions) under § 270.42. For a class 1 modification, the facility must
notify the facility mailing list. For a class 2 modification, the facility must
notify the mailing list and publish a newspaper notice when requesting the
modification. The permitting agency must notify the mailing list within 10
days of granting or denying a modification request. For a class 3
modification, the facility must publish a newspaper notice and notify the
mailing list when requesting a modfication. The permitting agency must
follow the procedures for modifications in part 124 when granting or
denying the class 3 permit modification. The permitting agency will also
notify people on the mailing list and State and local government within 10
days of any decision to grant or deny a Class 2 or 3 modification request.
The Director also must notify such people within 10 days of an automatic
Class 2 modification goes into effect under § 270.42(b)(6)(iii) or (v).
If the permitting agency initiates the permit modification, under § 270.41,
then the agency must follow the notice requirements for a draft permit in §
124.10(c) (see above in this section). Agency-initiated modifications may
include modifications during the corrective action process.
If the permitting agency requires a facility to establish an information
repository under § 124.33 or § 270.30(m), the agency Director will specify
notice requirements. At the least, the facility will provide written notice to
the people on the mailing list.
Permitting agencies must also provide provide public notice during the trial
burn stage at permitted and interim status combustion facilities (§ 270.62(b)
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and (d); 270.66(d)(3) and (g)) and when an interim status facility undergoes
closure or post-closure (see §§ 265.112(d)(4) and265.118(f)).
Description of Activity Public notices provide an official announcement of proposed agency
decisions or facility activities. Notices often provide the public with the
opportunity to comment on a proposed action.
Most RCRA notices contain essentially the same types of information.
Where they differ is in how they are distributed by the agency or the
facility. Some go to members of the mailing list, some as legal
advertisements in the newspaper, and some others as signs or radio
advertisements. In all cases, EPA encourages facilities and permitting
agencies to make a good faith effort to reach all segments of the affected
community with these notices. As we mention earlier in this manual, any
organization that wants to provide public notice has a number of
inexpensive and simple options available to it, including: free circulars;
existing newsletters or organzation bulletins; flyers; bulletin boards; or
storefront signs.
There are many effective ways to spread information. However, the job of
anyone giving notice is to find out what information pathways will be most
effective in a particular community. Public interest groups, the facility, and
the permitting agency should seek community input on this topic. The
citizens of that community are the most qualified people to explain what
methods will work best in their community. Community interviews are
one way to learn more about how the citizens communicate.
The following are the most common ways to give public notice:
• Newspaper Advertisements . Traditionally, public notices have often
appeared as legal advertisements in the classified section of a
newspaper. While this method provides a standard location for the
ads, display advertisements (located along with other commercial
advertisements) are more likely to reach a larger audience. Display
advertisements offer an advantage over legal classified ads since they
are larger, easier to read, and are more likely to be seen by the casual
reader. A sample is available in Appendix H of this manual.
• Newspaper Inserts. Inserts stand out from other newspaper
advertisements since they come as a "loose" section of the newspaper
(a format often used for glossy advertisements or other solicitations).
They provide a way to reach beyond the most-involved citizens to
inform a broader segment of the community.
• Free Publications and Existing Newsletters . Placing a notice in a
newsletter distributed by a local government, a civic or community
organization, or in a free publication (e.g., a paper that highlights
local or community activities) is a generally inexpensive way to target
a specific audience or segment of the community. Some publications
may not be appropriate for communicating information from your
Chapter 5: Public Involvement Activities Page 5-9
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organization. By publishing information through a group that has a
specific political interest or bias, your organization may be perceived
as endorsing these views. Permitting agencies may want to avoid
associations with groups that appear to represent the agency's
interests. In any case, the relationship between your organization and
the newsletter or publication should be clear to the public.
You may want to consider some of the following options. Local
governments sometimes send newsletters or bulletins to their entire
population; such newsletters can reach an entire affected community.
Planning commissions, zoning boards, or utilities often distribute
regular newsletters; they may be willing to include information about
permitting activities. Newsletters distributed by civic, trade,
agricultural, religious, or community organizations can also
disseminate information to interested readers at low cost. Some
segments of the affected community may rely on a free local flyer,
magazine, independent or commercial newspaper to share
information.
Public Service Announcements . Radio and television stations often
broadcast, without charge, a certain number of announcements on
behalf of charities, government agencies, and community groups. In
particular, they are likely to run announcements of public meetings,
events, or other opportunities for the public to participate. One
drawback with a public service announcement is that you have no
guarantee that it will go on the air. If it does go on the air, it may
come at odd hours when relatively few people are listening.
Broadcast Announcements and Advertisements . A number of RCRA
notices must be broadcast over radio or another medium. Beyond
these requirements (which are further explained below and in the
section on "Notice of the Pre-Application Meeting" in Chapter 3), you
may consider providing notice via a paid TV advertisement or over a
local cable TV station. Paid advertisements can be expensive and
may be seen by the public as taking a side. You can avoid this
drawback by limiting information to the facts (e.g., time, date,
location of the meeting). Some local access cable TV stations run a
text-based community bulletin board, which may provide a useful
way to distribute information.
Signs and Bulletin Boards . The notice requirements for the pre-
application meeting (§ 124.31) require posting of a visible and
accessible sign. Signs can be a useful means of public notice,
especially for residents and neighbors of the facility or planned
facility. A sign on the site should be large enough so that passers-by,
whether by foot or by vehicle, can read it. If few people are likely to
pass by the site, consider posting the sign at the nearest major
intersection. Another option is to place posters or bulletins on
community bulletin boards (in community centers, town halls,
grocery stores, on heavily-travelled streets) where people are likely to
see them. The signs should contain the same information as a written
or broadcast notice.
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Telephone Networks or Phone Trees . This method provides an
inexpensive, yet personal, manner of spreading information. The lead
agency, facility, or organization calls the first list of people, who, in
turn, are responsible for calling an additional number of interested
people. Phone trees are a good way to provide back up plans or
reminders while reducing the number of calls made by individual staff
members. As an alternative to calling the first tier, the lead agency,
facility, or organization may want to distribute a short written notice.
Level of Effort
How to Conduct the
Activity
Preparing a public notice and arranging for its publication takes a day or
two, depending on the need for review. Producing a television or radio ad,
or building a sign will take longer, depending on the situation.
To prepare a public notice:
1. Identify the major media contacts. While there may be many daily
newspapers serving a particular area, use only one or two for the
public notice. In general, use the newspaper with the widest
circulation and greatest visibility in order to reach the most people
and elicit the greatest response. In some cases, you may want to
choose specific newspapers to reach target audiences; find out what
papers the affected community reads and place your notices there.
Use a similar strategy for notices in the broadcast media. If you are
giving notice via more than one media, you have more flexibility for
reaching specific audiences. See the section on "Notice of the Pre-
Application Meeting" in Chapter 3 for more information.
2. Take into account publication schedules. Many local or
community newspapers are published on a weekly or bi-weekly basis.
This may make it difficult to coordinate the publication of the notice
with the event. In such a case, consider using a city-wide newspaper
that is published more frequently. If the city-wide paper is not likely
to reach all segments of the affected community, you should make
efforts to supplement the newspaper notice with other means of notice
(e.g., signs or broadcast media).
3. Include the following information in the public notice:
• Name and address of the facility owner/operator;
• A brief description of the business conducted at the facility and
the activity that is the subject of the notice;
• Name, address and telephone number of an individual who can
be contacted for further information on the activity;
• A brief description of the comment procedures and the date,
time, and place of any hearing;
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When to Use
Accompanying
Activities
Advantages and
Limitations
• If the permit is issued by EPA, the location of the administrative
record and the times when it is open for public inspection; and
• Any additional information considered appropriate.
Also, try to format the notice so that it is eye-catching. A logo can
help.
4. Announce dates, times, and locations clearly in the public notice.
When announcing an event such as a hearing, make sure that the date
and time do not conflict with other public meetings, religious or non-
religious holidays, or other important community events.
5. Provide ample notice. For RCRA permits, the public notice must
allow at least 45 days for public comment. Public notice of a public
hearing must be given at least 30 days prior to the hearing. Be sure to
state the opening and closing dates for comment periods.
6. If possible, review a typeset version of the notice before it is
published to ensure accuracy.
7. Keep proof of the notice for your files. Newspapers often can
provide "tear sheets" as a record of the notice. Similar proofs are
available from radio or television stations. You should consider
keeping photgraphs of posted signs.
The "Regulatory Requirements" section above reviews the mandatory
public notices. In addition, agency personnel can use informal public
notices to announce other major milestones or events in the permit review
or corrective action process. Permitting agencies may also want to use
public notices when they are establishing mailing lists. The facility must
issue notices when it requests a permit modification, holds a pre-application
meeting, or establishes an information repository.
Public notices can be useful for any organization involved in the RCRA
permitting process. Whenever a public interest organization is planning an
activity, or would like to supplement notices given by the facility or the
agency, you may want to consider using one of the public notice methods in
this manual. Notices can also help build your mailing lists.
Public notices are used to announce public comment periods and public
hearings. They can also be used to announce other meetings and
milestones, opportunities to join the mailing list, as well as the availability
of an information repository , fact sheets, or other permitting information.
Public notices are an efficient, simple means of alerting the public to
important events. However, public notices should never substitute for other
activities that involve direct communication with the public.
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Public notices can be more effective, and provide more of a feedback loop,
when they are combined with a means of gathering information from the
public. Every notice should contain a contact person so that the public can
direct comments or questions to the agency, the facility, or other
stakeholder groups.
See "Description of Activity" above in this section for advantages and
limitations of specific notice methods.
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Checklist for Public Notices
_ Compile information to be included in the public notice:
Name of agency overseeing the permit or corrective action
_ Name, address, and phone number of contact person
Facility owner/operator and description of facility activities
_ Purpose of public notice
If applicable provide the date, time, and location of public hearing (or meeting)
_ Description of the procedures governing the public's participation in the process
Draft the public notice, announcement, or advertisement
_ Coordinate review of the draft public notice
Prepare final public notice
_ Receive final approval of public notice
Coordinate placement of the public notice in the local newspaper(s), coordinate distribution of the
public notice to the facility mailing list, submission to radio/television stations or other
publications (as applicable)
For publication in local newspaper(s):
Name of Newspaper Publication Days Advertising Deadline
_ Prepare procurement request or advertising voucher for public notice publication
Obtain price quotes (i.e., cost per column inch)
Determine size of public notice
Determine deadlines for publication of the public notice
_ Submit for publication
Request proof of publication; file proof in facility file
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Checklist for Public Notices (continued)
For distribution to the mailing list:
Verify that facility mailing list is up-to-date
_ Produce mailing labels
Distribute to the mailing list
For broadcast on local radio/television stations:
Verify media list
Prepare procurement request or advertising voucher for public notice spots
Obtain price quotes
Distribute to stations
Request proof of airing and file in facility file
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Translations
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None. EPA strongly recommends using multilingual fact sheets, notices,
and other information (as appropriate) to provide equal access to
information in the permitting process.
Translations provide written or oral information in a foreign language to a
community with a significant number of residents who do not speak
English as a first language. There are two types of translations:
• A written translation of materials originally written in English;
• A simultaneous verbal translation (i.e., word by word) of a
public meeting or news conference, usually with small headsets
and a radio transmitter.
Translations ensure that all community members are informed about
activities at a facility and have the opportunity to participate in the
decision-making process.
The amount of time needed to translate a document depends on the length
of the document and the complexity of the information in the document.
You should allow at least several days for translation.
To develop a successful translation:
1. Evaluate the need for a translation. Evaluate the demographic
characteristics of the community as well as the type of public
participation activities being planned. Consider whether citizens'
ability to take part in an activity is limited by their inability to speak
or understand English.
2. Identify and evaluate translation services . A successful translation
depends on the skill of the translator. More problems may be created
than solved if inaccurate or imprecise information is given. Many
translators will not be familiar with the technical terms associated
with hazardous materials and few, if any, will be familiar with the
RCRA permitting and corrective action processes. This problem may
be further compounded in the case of oral translations (especially
simultaneous translations) as there is no time for review or quality
control. Thus, it is necessary to contract someone with experience in
translating technical information and check the translator's work to
ensure that the content and tone are in keeping with the intent. You
also need to ensure that the translator uses the same dialect as those in
your intended audience.
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When to Use
Accompanying
Activities
Advantages and
Limitations
3. Avoid the use of jargon or highly technical terms . As a matter of
standard practice, a staff member should go over in advance all
technical and RCRA terms that may cause problems with the
translator.
4. For verbal presentations, public meetings, and news conferences,
plan what to say ahead of time . If the translator has a prepared
written speech to work with in advance, there is more time to work
out any vocabulary "bugs" and thereby reduce the chances of faltering
over unfamiliar material or making inaccurate word choices. If
possible, practice with the translator before the actual meeting or
presentation date.
5. Anticipate questions from the audience and reporters , and have at
least the technical aspects (e.g., chemical names, statistics) of the
answers translated in advance.
A translation can be used:
• When a signficant portion of the community does not speak
English as a first language. A written translation should be
provided for fact sheets or letters, unless a presentation or public
meeting would be more appropriate (e.g., the literacy rate
among the foreign-speaking community is low).
• Verbal translations are recommended where there is
considerable concern over the facility, extreme hostility, or
suspicion of the agency's efforts to communicate with
community members.
The need for translations is often determined during the community
assessment and community interviews . Translations are generally used
for fact sheets, public notices, presentations, public meetings, public
hearings, and news conferences .
Written translations and use of translators ensure that a greater number of
community members can participate effectively in the process and,
therefore, provide input to decisions concerning the RCRA-regulated
process. This effort assures the community of your organization's sincerity
in providing opportunity for public participation.
Translations are very costly, especially simultaneous translations of public
meetings. Sentence-by-sentence oral translations frequently double the
length of public meetings, and may make information more difficult to
present effectively and smoothly. In addition, very few translators are
familiar with the RCRA permitting and corrective action processes. For
facilities having highly volatile or sensitive problems, it may be difficult to
communicate your organization's position and involve community
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members in a constructive dialogue.
Checklist for Translations
Determine need for translations
Identify translation service or identify staff to provide translating services
Fact sheet translations
Provide English text (including text for graphics, headlines, fact sheet flag)
Meeting translations
Determine if translation will be simultaneous or if translations will occur following
statements.
_ If simultaneous, provide audio equipment for translator/participants
Prepare list of technical and RCRA terms that will need to be translated
_ Prepare, in advance with the translator, presentations, responses to questions
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Mailing Lists
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
The permitting agency must establish and maintain the facility mailing list
in accordance with § 124.10(c)(l)(ix). The agency must develop the list
by: (a) including people who request in writing to be on the list; (b)
soliciting persons for "area lists" from participants in past permit
proceedings in that area; and (c) notifying the public of the opportunity to
be put on the mailing list through periodic publication in the public press
and in such publications as Regional- and State-funded newsletters,
environmental bulletins, or State law journals.
Mailing lists are both important databases and essential communication
tools. Mailing lists ensure that concerned community members receive
relevant information. They allow messages to reach broad or targeted
audiences. The better the mailing list, the better the public outreach and
delivery of information. Mailing lists typically include concerned
residents, elected officials, appropriate federal, state, and local government
contacts, local media, organized environmental groups, civic, religious and
community organizations, facility employees, and local businesses.
It is recommended that you develop an internal distribution list at the same
time you prepare your external mailing list. The distribution list for
permitting agencies should include all technical project staff, public
involvement staff, legal staff, and staff from other affected programs (Air,
Water, etc.), as appropriate. This list will help ensure that all relevant
project staff receive the same information about all phases of the project.
Facilities and community organizations should follow similar procedures to
keep their staffs and members informed.
A mailing list can be developed in conjunction with other public
participation activities. Depending on the size of the list, inputting
information into a data base can take several days. Updating will require
approximately half a day per quarter.
To develop and update a mailing list, consider the following:
1. Solicit names, addresses, and phone numbers of individuals to be
included on the list. This should include individuals who put their
names and addresses on the sign-in sheet at the pre-application
meeting, if applicable. Telephone numbers are useful to have so that
you can contact these individuals for community interviews and to aid
you when you update your list.
Individuals to include in your mailing list:
Chapter 5: Public Involvement Activities
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• The people interviewed during community interviews, as well as
other names these people recommend;
• All nearby residents and owners of land adjacent to the facility;
• Representatives of organizations with a potential interest in an
agency program or action (e.g., outdoor recreation
organizations, commerce and business groups,
professional/trade associations, environmental and community
organizations, environmental justice networks, health
organizations, religious groups, civic and educational
organizations, state organizations, universities, local
development and planning boards, emergency planning
committees and response personnel, facility employees);
• Any individual who attends a public meeting, workshop, or
informal meeting related to the facility, or who contacts the
agency regarding the facility;
• Media representatives;
• City and county officials;
• State and Federal agencies with jurisdiction over wildlife
resources;
• Key agency officials; and
• The facility owner/operator.
2. Review background files to ensure all interested individuals are
included on the mailing list.
3. Input information into a computer system so that it can be
categorized and sorted and printed on mailing labels.
4. Send a letter or fact sheet to the preliminary mailing list
developed using 1) and 2) above. Inform key Federal, State, and
local officials, citizens, and other potentially interested parties of your
activities and the status of upcoming permit applications or corrective
actions. Ask whether they wish to receive information about this
facility. Ask them for accurate addresses and phone numbers of other
people who might be interested in the project.
5. Update your mailing list at least annually to ensure its correctness.
Mailing lists can be updated by telephoning each individual on the
list, and by using local telephone and city directories as references.
The permitting agency can update the official mailing list from time
to time by requesting written indication of continued interest from
those listed. The agency can then delete any people who do not
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When to Use
Accompanying
Activities
Advantages and
Limitations
respond (see § 124.10(c)(l)(ix)(C)).
See the section on "The Facility Mailing List" in Chapter 3 for more
information.
A mailing list is a required public participation activity for permitting.
Additional people may want to join the list if corrective action will take
place at a facility. Public interest groups or other involved organizations
often have mailing lists.
• Develop a mailing list as soon as possible during the permit
application phase, or as soon as the need for a RCRA Facility
Investigation is identified.
• Update the mailing list regularly.
Develop a distribution at the same time you develop a mailing list.
Mailing lists are useful in identifying individuals to contact for community
interviews. They are also needed to distribute fact sheets and other
materials on the facility. Public notices and sign-up sheets at public
meetings or information repositories can help you build mailing lists.
Mailing lists provide the names of individuals and groups interested in
activities at RCRA facilities. However, lists can be expensive and time-
consuming to develop, and they require constant maintenance.
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Checklist for Mailing Lists
Mailing List Development:
_ Verify the list format (i.e., name, title, company, address, phone number)
Consider issuing a public notice to solicit names for the mailing list
_ Identify people to be included on the list:
People who signed the attendance sheet at the pre-application meeting (if applicable)
_ City elected officials (mayor and council)
City staff and appointees (city manager, planning director, committees)
_ County elected officials (supervisors)
County staff and appointees (administrator, planning director, health director, committees)
_ State elected officials (senators, representatives, governor)
State officials (health and environment officials)
_ Federal elected officials (U.S. Senators, U.S. Representatives)
Federal agency officials (EPA)
_ Residents living adjacent to facility
Other interested residents
_ Media
Business groups of associations
_ Businesses possibly affected by the facility (i.e., located down-wind of facility)
The facility owner/operator
_ Consultants working on the project or related projects
Local environmental groups
_ Other civic, religious, community, and educational groups (e.g., League of Women Voters,
government associations, churches, homeowners and renters associations)
State and Federal Fish and Wildlife Agencies
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Checklist for Mailing Lists (continued)
Have list typed
_ Prepare mailing list
Store on computer data base
Mailing List Updates:
Verify names/addresses by searching telephone directory
_ Verify names/addresses by searching city directory
Verify names/addresses by calling each individual
_ Consider issuing a notice asking for written indication of continued interest (§
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Notices of Decision
Regulatory
Requirements
Description of Activity
RCRA requires the permitting agency to issue a notice of decision to
accompany the final permit decision (under § 124.15 procedures). The
agency must send the notice to the permit applicant and to any person who
submitted written comments or requested notice of the final permit decision
(§ 124.15). Note that Class 3 modifications and the corrective action final
remedy selection also follow § 124.15 procedures and require a Notice of
Decision.
A notice of decision presents the agency's decision regarding permit
issuance or denial or modification of the permit to incorporate changes such
as the corrective action remedy.
Level of Effort
How to Conduct the
Activity
When to Use
Accompanying
Activities
A notice of decision may take several days to write and review, depending
on the complexity. Allow time for several rounds of revisions. If you need
to develop graphics, such as site maps, allow time to produce the graphics.
The notice should briefly specify the agency's final decision and the basis
for that decision. The notice must also refer to the procedures for appealing
a decision. Notices of decision must be sent to the facility owner/operator
(permit applicant) and each person who submitted written comments or
requested notice of the final permit decision. You may want to send the
notice to other interested parties as well. Final permits generally become
effective 30 days after the notice of decision.
• When a permit decision has been finalized following the 45-day
public comment period;
• When the permitting agency makes its final decision regarding a
permit modification.
A response to comments document must be issued at the same time the
final permit decision is issued.
Advantages and
Limitations
The notice of decision provides a clear, concise public record of the
decision. However, the notice of decision should not be a substitute for
other activities that involve direct two-way communication with the public.
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Checklist for Notices of Decision
Determine contents of the notice of decision
_ Decision made and basis for that decision
Information on appeal procedures
_ Coordinate writing the notice with technical and legal staff
Technically accurate
_ Satisfies statutory requirements
Provides the public with all necessary information in a clear and concise manner
_ Coordinate internal review of notice of decision
Prepare final notice of decision based on internal review comments
Notify the facility owner/operator and anyone who submitted written comments or requested
notice of the final decision
Notify other interested parties of the decision
_ Place copy of the notice of decision in the administrative record and the information repository
(if one exists)
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Introductory Notices
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
While EPA regulations do not specifically require an introductory notice, §
124.32 provides for an agency notice at the time of application submittal.
Permitting agencies may want to consider the guidance in this section (in
addition to the § 124.32 requirements) when preparing the notice at
application submittal. Chapter 3 provides guidance specifically for the
notice at application submittal.
An introductory notice explains the agency's permit application review
process or the corrective action process and the opportunities for public
participation in that process.
The amount of time needed to prepare an introductory notice is based on
whether the notice is prepared as a public notice or a fact sheet. If prepared
as a public notice, allow a day or two for writing, review, and placement in
newspapers and other media. If prepared as a fact sheet, allow several days
to a week to write and review, depending on the layout and graphics used,
and several days for printing.
To prepare an introductory notice:
1. Determine the best method to explain the permit application
review or corrective action process. An introductory notice can be
presented as a public notice, a fact sheet, or a flier distributed to the
facility mailing list.
2. Prepare and distribute the notice. Coordinate the writing and
distribution of the notice with technical project staff. Take care to
write the notice avoiding technical terms and jargon.
3. Include an information contact. Provide the name, address, and
phone number of a contact person who the public can call if they have
questions or need additional information about the facility. You
might add a return slip to the notice for people to complete and return
to your organization if they would like additional information or to be
placed on a mailing list.
An Introductory Notice can be used:
• When you find the community knows little or nothing about the
RCRA process; and
• When you need to notify the public of how they can become
involved in the RCRA process.
Chapter 5: Public Involvement Activities
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Accompanying Informal meetings , availability sessions/open houses , or workshops may
A rtivitipQ ^e conducted following release of the notice.
A^ ™^rra^ ^^A An introductory notice informs the public about the agency s permit
/vdvaniages ana ... . ,, , ,-,,-,
application review process and how they can be involved in the process.
UlsaavaniagcS However, the notice is a one-way communication tool. A contact person
should be identified in the notice so that interested members of the
community can call this person if they have questions.
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Checklist for Introductory Notices
Determine how you will distribute the notice.
_ Public notice in newspaper
Fact sheet or flier sent to the mailing list
_ Prepare draft introductory notice
Include name and phone number of a contact person
_ Coordinate internal review of introductory notice
Write final introductory notice based on comments received during the internal review
_ Verify facility mailing list is up-to-date
Request mailing labels
_ Distribute introductory notice
Chapter 5: Public Involvement Activities Page 5-28
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Fact Sheets/
Statements of Basis
Regulatory
Requirements
Description of Activity
EPA's regulations require the agency to develop a fact sheet or a statement
of basis to accompany the draft permit. The agency will develop a fact
sheet for any major hazardous waste management facility or facility that
raises significant public interest (§ 124.8). The agency must prepare a
statement of basis for every draft permit for which a fact sheet is not
prepared (§ 124.7). Note that these requirements also apply to Class 3
modifications and agency-initiated modifications (such as the agency may
use at remedy selection), which must follow the part 124 procedures.
Specific requirements for these activities are described below under "How
to Conduct the Activity."
RCRA-required fact sheets and statements of basis summarize the current
status of a permit application or corrective action. This required fact sheet
(or statement of basis) is probably different than the commonly-used
informational fact sheets that most people recognize. The required fact
sheet must explain the principal facts and the significant factual, legal,
methodological and policy questions considered in preparing the draft
permit. They can vary in length and complexity from simple two-page
documents to 12-page documents complete with graphic illustrations and
glossaries.
The agency and other stakeholder groups may find it useful to develop
other fact sheets to be used in public participation activities. These
informal/informational fact sheets can explain difficult aspects of the
permitting process or provide technical information in language that an
ordinary person can understand. These fact sheets may come in many
different varieties and levels of detail.
Fact sheets are useful for informing all interested parties about the basis for
the permitting agency's decision regarding a facility permit or proposed
corrective action activities. They ensure that information is distributed in a
consistent fashion and that citizens understand the issues associated with
RCRA programs.
Statements of basis are generally shorter than fact sheets and summarize
the basis for the Agency's decision. Statements of basis are often used in
the corrective action program to summarize the information contained in
the RFI/CMS reports and the administrative record. They are designed to
facilitate public participation in the remedy selection process by:
• Identifying the proposed remedy for a corrective action at a facility
and explaining the reasons for the proposal.
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Level of Effort
How to Conduct the
Activity
• Describing other remedies that were considered in detail in the RFI
and CMS reports.
• Soliciting public review and comment on all possible remedies
considered in the RFI and CMS reports, and on any other plausible
remedies.
• Providing information on how the public can be involved in the
remedy selection process.
In emphasizing that the proposed remedy is only an initial
recommendation, the statement of basis should clearly state that changes to
the proposed remedy, or a change from the proposed remedy to another
alternative, may be made if public comments or additional data indicate
that such a change would result in a more appropriate solution. The final
decision regarding the selected remedy(ies) should be documented in the
final permit modification (if applicable) with the accompanying response to
comments after the permitting agency has taken into consideration all
comments from the public.
Fact sheets and statements of basis may take from two days to two weeks to
write, depending on their length and complexity. Allow time for several
rounds of revisions. Allow three days for printing. (Short Cut: Use
already developed RCRA templates with graphics that are on file at your
agency).
The first step in preparing a fact sheet is to determine the information to be
presented. EPA decisionmaking regulations require that RCRA permit fact
sheets contain the following types of information:
• A brief description of the type of facility or activity which is the
subject of the draft permit;
• The type and quantity of wastes covered by the permit;
• A brief summary of the basis for the draft permit conditions and the
reasons why any variances or alternatives to the proposed standards
do or do not appear justified;
• A description of the procedures for reaching a final decision,
including the beginning and ending dates of the public comment
period and the address where comments can be sent, and procedures
for requesting a public hearing; and
• Name and telephone number of a person to contact for additional
information.
A statement of basis is prepared the same way as a fact sheet. The
statement of basis summarizes essential information from the RFI and
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CMS reports and the administrative record. The RFI and CMS reports
should be referenced in the statement of basis. The statement of basis
should:
• Briefly summarize the environmental conditions at the facility as
determined during the RFI.
• Identify the proposed remedy.
• Describe the remedial alternatives evaluated in sufficient detail to
provide a reasonable explanation of each remedy.
• Provide a brief analysis that supports the proposed remedy, discussed
in terms of the evaluation criteria.
Select a simple format for presenting the information. Avoid using
bureaucratic jargon, acronyms, or technical language in the text, and be
concise.
Use formatting techniques to make the fact sheet or statement of basis more
interesting and easy-to-read. People are less likely to read a fact sheet or
statement of basis consisting of a solid sheet of typed text than one with
clear, informative illustrations. Moreover, a well-designed document
suggests that the permitting agency takes its public participation program
seriously.
Coordinate the production of these documents with technical project staff.
Technical staff should review them to ensure that the information conveyed
is accurate and complete. Outreach staff should review them to ensure that
the communication goals are being met.
Arrange for printing and distribute copies of the fact sheet or statements of
basis to the mailing list, place extra copies at the information repository,
and distribute additional copies at public meetings and hearings.
When to Use While fact sheets/statements of basis are required for draft permits, they
can also be helpful at other times in the permitting and corrective action
processes:
• During technical review of the permit application;
• At the beginning of a RCRA facility investigation;
• When findings of the RCRA facility investigation are available;
• When the corrective action is completed; and
• When the Notice of Decision is released.
In addition, fact sheets can be written to explain a facility inspection or
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Accompanying
Activities
Advantages and
Limitations
emergency action, a new technology, or a community-based activity.
Fact sheets and statements of basis can be particularly useful in providing
background information prior to a public meeting or public hearing.
Fact sheets and statements of basis are generally used in conjunction with
the mailing list, public notices, public comment periods , and public
meetings and hearings. However, as stated above, they can be helpful at
almost any stage in the permitting or corrective action processes.
Fact sheets and statements of basis are effective in summarizing facts and
issues involved in permitting and corrective action processes. They
communicate a consistent message to the public and the media. Produced
throughout the permitting or corrective actions processes, they serve to
inform the public about the regulatory process as well as the technical
RCRA issues and can aid in creating a general community understanding of
the project. They are relatively inexpensive and can be distributed easily
and directly to the mailing list. In addition, fact sheets and statements of
basis can be tailored to meet specific information needs identified during
community assessments.
However, a poorly written fact sheet or statement of basis can be
misleading or confusing. Documents of this type that are not written in an
objective style can be perceived as being too "persuasive" and considered
"propaganda" by mistrusting communities. Remember that fact sheets and
statements of basis are a one-way communication tool, and therefore should
always provide the name and telephone number of a contact person to
encourage comments and questions.
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Checklist for Fact Sheets/Statements of Basis
Determine purpose and focus of fact sheet or statement of basis
_ Develop outline
Organize contents in a logical manner
_ Determine appropriate graphics
Verify mailing list is up-to-date
_ Request mailing labels
Coordinate preparation of fact sheet or statement of basis with technical staff as appropriate
_ Draft text
Draft graphics
_ Draft layout
Place mailing coupon on reverse side of mailing label
_ Coordinate internal review of fact sheet or statement of basis
Incorporate revisions into final fact sheet or statement of basis
_ Proofread final fact sheet or statement of basis
Arrange printing of fact sheet or statement of basis
_ Select paper weight, ink color, and color paper
Print fact sheet or statement of basis
_ Distribute fact sheet or statement of basis to the mailing list and place additional copies in the
repository
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Project Newsletters
and Reports
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None.
Project newsletters and reports are means of direct communication that
keep interested people informed about corrective action and permitting
activities. Both publications provide a level of project detail that is not
usually available from the news media. A project newsletter uses a reader-
friendly, news-based format to provide regular updates on activities in the
permitting process and actions taking place at the facility. Project reports
may include official technical reports or other environmental documents
and studies related to a particular facility. Sending these reports directly to
key stakeholders can spread information more effectively than simply
placing the documents in an information repository.
Newsletters can require significant amounts of staff time and resources to
write, copy, and distribute. Direct transmission of reports will require less
staff time, but may cost more to copy and distribute.
To provide a project newsletter or project reports:
1. Assign a staff person to produce the newsletter. Instruct project
staff to direct relevant information and reports to this person.
2. Decide on a format and style for the newsletter. Evaluate the
resources you have available for the newsletter and decide what type
of newsletter you will produce. Keep in mind that a visually-
attractive newsletter with plenty of graphics and simple language is
more likely to be read. Avoid bureaucratic or technical jargon. The
newsletter should contain real news that is useful to people. Since
people who are not familiar with the project may pick up the
newsletter, write it so that first-time readers can understand it.
3. Provide for review. Permitting agencies, in particular, will want to
ensure the credibility of their newsletters by making sure that they are
objective. In such cases, you may consider asking a citizen advisory
group, a consultant, or a non-partisan civic group (e.g., the League of
Women Voters), to review the document. If the public has concerns
over the credibility of your organization, it may be beneficial for the
citizens advisory group or a neutral body to produce the newsletter.
An objective newsletter should candidly report all developments at
the facility.
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When to Use
Accompanying
Activities
Advantages and
Limitations
4. Summarize detailed reports. If you are distributing a technical
report, you should consider including a summary. Another option is
to include findings in the project newsletter and allow people to send
in a clip-out request form or contact your staff for copies of the full
report.
5. Check your mailing list. Make sure that your mailing list is up to
date and includes all interested stakeholders and media contacts (see
the section on Mailing Lists above).
6. Update your mailing list. Project newsletters may continue for a
number of years. You should consider updating your mailing list by
including an "address-currency" card in the newsletter on a regular
basis (e.g., once a year). By sending in this card, people will continue
to receive the newsletter.
Project newsletters and reports can provide detailed information about a
facility that is not usually available in the media. These methods may be
most useful when:
• there is a high level of public interest in a facility;
• when many citizens do not have access to an information repository,
or a repository has not been established;
• you would like to maintain project visibility during extended technical
studies; or
• presenting the results of detailed studies through a newsletter will
better inform the public.
A mailing list is essential for distribution of reports and newsletters. You
should consider availability sessions , open houses, or informal meetings
to explain the results of detailed reports and studies. Always include a
contact person in the newsletter or report.
Newsletters and project reports are useful ways to disseminate important
information to stakeholders. Making reports widely available can enhance
their credibility.
Newsletters may require significant amounts of staff time and resources.
Direct distribution of technical reports may create confusion if they are not
accompanied by a summary.
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Checklist for Project Newsletters and Reports
_ Assign a staff person to be in charge of producing the newsletter or reports
Direct the project staff (e.g., through a memo) to forward all relevant project information to the
newsletter director
_ Decide on format, style, and frequency of distribution
Draft the newsletter
_ Review the newsletter for content, style, simple language, and visual appeal
(If applicable) Send the newsletter to an assigned neutral party for review
_ If you produce detailed project studies or reports, write a summary in simple language and attach
to the report or include the summary in the newsletter
_ Distribute the newsletter to the mailing list
Update the mailing list on a regular basis
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Response to
Comments
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
According to § 124.17, the permitting agency must prepare a response to
comments at the time that it issues a final permit decision. The agency will
also issue a response to comments when making final decisions on
requested Class 2 and 3 permit modifications under § 270.42 and agency-
initiated modifications under § 270.41.
A response to comments identifies all provisions of the draft permit or
modification that were changed and the reasons for those changes. It also
briefly describes and responds to all significant comments on the draft
permit that were received during the public comment period.
The response to comments should be written in a clear and understandable
style so that it is easy for the community to understand the reasons for the
final decision and how public comments were considered.
A response to comments can be a time-intensive activity because of the
large amount of organization, coordination, and review needed. On
average, allow several hours per comment for completion, as some
questions may take only a few minutes to answer while others may involve
in-depth technical and legal responses. In general, preparing response to
comments documents can take from several days for low-interest facilities
to several weeks for high-interest facilities.
There is no required format for preparing response to comments
documents. However, several EPA Regions have adopted a two part
approach:
• Part I is a summary of commenters' major issues and concerns and
expressly acknowledges and responds to those issues raised by the
local community. "Local community" means those individuals who
have identified themselves as living in the immediate vicinity of a
facility. These may include local homeowners, businesses, the
municipality, and facility employees. Part I should be presented by
subject and should be written in a clear, concise, easy to understand
manner suitable for the public.
• Part II provides detailed responses to all significant and other
comments. It includes the specific legal and technical questions and,
if necessary, will elaborate with technical detail on answers covered
in Part I. It also should be organized by subject.
Think of Part I as a type of fact sheet for the detailed responses provided in
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When to Use
Part II. Because both parts deal with similar or overlapping issues, the
response to comments should state clearly that any points of conflict or
ambiguity between the two parts shall be resolved in favor of the detailed
technical and legal presentation in the second part.
In order to effectively address all public comments, closely coordinate the
preparation of responses with appropriate legal and technical staff. Also, it
is important to be certain that all comments are addressed. A system of
numbering all comments as they are received and referring to these
numbers in all internal drafts of the response document may help keep track
of them. Computer databases are a good way to keep track of and arrange
the comments.
In addition, the Response to Comments should include a summary that
discusses the following:
• The number of meetings, mailings, public notices, and hearings at
which the public was informed or consulted about the project;
• The extent to which citizen's views were taken into account in
decision-making; and
• The specific changes, if any, in the project design or scope that
occurred as a result of citizen input.
Response to comments documents must be sent to the facility
owner/operator and each person who submitted written comments or
requested notice of the final permit decision.
A response to comments is required for all final permit decisions and
decisions on class 2 and 3 modifications..
Accompanying
Activities
A response to comments usually accompanies the notice of decision
Advantages and
Limitations
A response to comments provides a clear record of community concerns. It
provides the public with evidence that their input was considered in the
decision process. The summary also is an aid in evaluating past public
participation efforts and planning for subsequent activities.
Comments may be difficult to respond to at times, like when the public
raises new issues, questions, or technical evidence during the public
comment period. The permitting agency may need to develop new
materials to respond to these questions.
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Checklist for Response to Comments
After reviewing comments, determine organization of document
_ Determine groups, subgroups of comments
Where applicable, paraphrase and summarize comments
_ Write a response for each comment, group or subgroup of comments
Prepare an introductory statement including:
_ A summary of the number and effectiveness of meetings, mailing, public notices, and
hearings at which the public was informed or consulted about the project
The numbers and kinds of diverse interests which were involved in the project
_ Prepare a summary statement including:
The extent to which citizen's views were taken into account in decision-making
_ The specific changes, if any, in the project design or scope that occurred as a result of
citizen input.
_ Coordinate internal review of the Response to Comments with all necessary departments (public
affairs, technical, legal)
Prepare final Response to Comments
_ Distribute Response to Comments to:
Information Repository
_ Facility owner/operator
Each individual who makes written or oral comments
_ Individuals who asked to receive the Response to Comments
Appropriate agency officials
Administrative Record
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Information
Repositories
Regulatory
Requirements
Description of Activity
EPA regulations authorize the permitting agency to require a facility to
establish an information repository during the permitting process (§ 124.33)
or during the active life of a facility (§ 270.30).
An information repository is a collection of documents related to a
permitting activity or corrective action. A repository can make information
readily available to people who are interested in learning about, or keeping
abreast of, RCRA activities in or near their community.
Information repositories are not mandatory activities in every situation. As
mentioned above, RCRA regulations give the permitting agency the
authority to require a facility to set up and maintain an information
repository. The agency does not have to require a repository in every case;
it should use its discretion. Additionally, a facility or an environmental
group may voluntarily set up a repository to make it easier for people in the
community to access information.
The size and location of the repository will depend on the type of
permitting activity. The regulations allow the permit applicant or permittee
to select the location for the repository, as long as it is in a location that is
convenient and accessible to the public. If the place chosen by the facility
does not have suitable access, then the permitting agency can choose a
more suitable location. EPA encourages the facility and the agency to
involve the public when suggesting a location for the repository — the
potential users of the facility are best qualified to tell you if it's suitable.
See #1 under "How to Conduct the Activity" below.
The information that actually goes in the repository can differ from case to
case, depending on why the repository was established. If the agency
requires a facility to establish the repository, then the agency will set out
the documents and other information that the facility must include in the
repository. The agency will decide what information will be most useful
according to the specifics of the case at hand. For instance, multi-lingual
fact sheets and other documents will be most appropriate in situations
where there are many non-English-speakers in an affected community.
Similarly, if the community needs assistance in understanding a very
technical permitting situation, then the agency and the facility should
provide fact sheets and other forms of information that are more accessible
to the non-technical reader. See #2 under "How to Conduct the Activity"
below.
The permitting agency should assess the need, on a case-by-case basis, for
an information repository at a facility. When doing so, the agency has to
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Level of Effort
How to Conduct the
Activity
consider a variety of factors, including: the level of public interest; the type
of facility; the presence of an existing repository; and the proximity to the
nearest copy of the administrative record. Since any of these other factors
may indicate that the community already has adequate access to
information, and since repositories can be resource-intensive, permitting
agencies should use this authority only in cases where the community has a
true need for additional access to information.
For example, in determining levels of public interest the agency staff will
want to consider: What kind of turnout has there been at public meetings?
What kind of responses during community interviews? What level of
media attention? How many inquiries have been coming in? What levels
of community involvement have there been in previous facility and/or local
environmental matters? If another repository already exists, can it be
augmented with materials to meet the information needs of the permit or
corrective action at hand? Is it located in a convenient and accessible
place? [Note: If a facility has an existing repository that does not
completely satisfy the need that the agency identifies, then the agency may
specify additional steps that the facility must take to make the repository
meet the public need.]
Is the nearest copy of the administrative record "close enough"? The
answer to this question could depend on a few things. Ask yourself some
other questions first. For example: Can people get there by public
transportation or only by a personal vehicle (i.e, by car or taxi)? Do most
people in the community rely on public transportation, or do most people
have and use their own cars? Apart from whether it is accessible by public
transportation or personal vehicle, how long is the trip? Is the
administrative record available for review on weekends or after business
hours?
Depending on the amount of available documentation, the information
repository may take a week to establish, including compiling and indexing
documents and arranging for placement in a library or other location.
Updating may take a day or two every quarter. A public notice announcing
the availability of the information repository may take between a day to
write, review, and place in newspapers or send to the mailing list.
To establish an information repository:
1. Determine a suitable location. For repositories established under §§
124.33 or 270.30, the initial choice of location is made by the facility.
If the agency decides that the facility-proposed location is not
suitable, then the agency will suggest another location.
Whether required or established voluntarily, the repository should be
be convenient and accessible for people in the community. Whoever
establishes the repository should consider, in particular, locations
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suggested by community residents. Typical locations include local
public libraries, town halls, or public health offices.
A facility may choose to set up the repository at its own offices.
Before doing so, the facility owner or operator should discuss his or
her intent with community representatives and/or the agency. It is
important to confirm that people are comfortable about coming onto
facility property and trust that you will properly maintain the
information in the repository.
Facility owners and operators should be sensitive to the concern that
some citizens have about repositories that are on facility property.
Some people do not feel comfortable when they need to attend a
meeting or a function on the facility grounds. If the members of your
community may feel uncomfortable at the facility, then you should
make all efforts to establish the repository at a suitable off-site
location. All repositories should be in a location where its users will
feel comfortable when accessing information.
In evaluating potential sites for the repository, there are several
factors to consider. The location should have adequate access for
disabled users, should be accessible to users of public transportation
(where applicable), and should be open after normal working hours at
least one night a week or on one weekend day. Repositories should
be well lit and secure.
A facility should also ensure that someone in its company and
someone at the repository location are identified as the information
repository contacts ~ to make sure that the information is kept up-to-
date, orderly and accessible.
Depending on the level of community concern, or the location of the
facility relative to the surrounding communities, more than one
repository may be desirable. For example, if a county seat is several
miles from the RCRA-regulated facility, and county officials have
expressed a strong interest in the facility, two repositories may be
advisable: one in the community closest to the facility, and the other
in the county seat.
2. Select and deposit the materials to be included in the repository.
For repositories established under EPA's regulations, the permitting
agency will decide, on a case-by-case basis, what documents, reports,
data, and information are necessary to help the repository fulfill its
intended purposes, and to ensure that people in the community are
provided with adequate information. The agency will provide a list of
the materials to the facility. The agency has the discretion to limit the
contents of repositories established under §§ 124.33 and 270.30.
While there is no outright ban on materials, EPA encourages
regulators to ensure that repository materials are relevant and
Chapter 5: Public Involvement Activities Page 5-42
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appropriate.
Facilities, permitting agencies, and public interest groups may decide
to establish repositories aside from those required by regulation.
Whoever establishes a repository should consult the public regarding
what materials would be most useful to members of the surrounding
community. EPA encourages parties to place substantive and
appropriate materials in the repository.
If you are establishing an information repository, you should consider
including the following documents:
• Background information on the company or facility;
• Fact sheets on the permitting or corrective action process;
• Meeting summary from the pre-application meeting (if one was
conducted);
• Public involvement plan (if developed);
• The draft permit;
• Reports prepared as part of the corrective action investigations,
including the RCRA Facility Assessment (RFA), the RCRA
Facility Investigation (RFI), and the Corrective Measures Study
(CMS);
• Fact sheets prepared on the draft permit or corrective action
plan;
• Notice of decision;
• Response to comments;
• Copies of relevant RCRA guidance and regulations;
• A copy of the Cooperative Agreement, if the state is the lead
agency for the project;
• Documentation of site sampling results;
• Brochures, fact sheets, and other information about the specific
facility (including past enforcement history);
• Copies of news releases and clippings referring to the site;
• Names and phone numbers of a contact person at the facility and
at the permitting agency who would be available to answer
questions people may have on the materials in the repository;
and
• Any other relevant material (e.g., published studies on the
potential risks associated with specific chemicals that have been
found stored at the facility).
You should organize the documents in binders that are easy to use and
convenient for the on-site repository host. For projects that involve a
large number of documents, separate file boxes should be provided as
a convenience to the repository host to ensure that the documents
remain organized.
3. Publicize the existence of the repository. For repositories required
under RCRA regulations, the permitting agency will direct the
facility, at a minimum, to announce the repository to all members of
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When to Use
Accompanying
Activities
Advantages and
Limitations
facility mailing list. If you establish a repository aside from EPA's
regulations, you should be sure to notify local government officials,
citizen groups, and the local media of the location of the project file
and hours of availability. Newsletters of local community
organizations and church groups are another means of notifying the
public.
4. Keep the repository up-to-date by sending new documents to it as
they are generated. If the permitting activity is controversial or
raises a lot of community interest, you should consider providing
several copies of key documents so that community members can
check them out for circulation. For repositories required under
RCRA regulations, the facility is responsible for updating the
repository with new documents and maintaining the documents in the
repository.
An information repository is recommended:
• When the agency requires the facility to establish an information
repository. In making its determination, the agency will
consider relevant factors, including: the level of public interest;
the type of facility; the presence of an existing repository; and
the proximity to the nearest copy of the administrative record;
and
• When interest in the facility is high and the public needs
convenient access to relevant facility documents.
The contact person(s) should be responsible for making sure that all
relevant materials have been filed in the repository.
If you establish a repository, you may want to consider setting aside time at
the repository to periodically staff a "walk-up" information table . An
information table would entail having a representative from your
organization, the permitting agency, or both, available to answer questions
that repository visitors may have. You may decide to establish the
information table on a routine basis (for example, once a month) or at key
milestones in the permitting or corrective action process (for example, after
a draft permit decision or completion of the RFI).
An information repository provides local officials, citizens, and the media
with easy access to accurate, detailed, and current data about the facility. It
demonstrates that your organization is responsive to citizens' needs for
comprehensive information on the facility.
An information repository is a one-way communication tool and does not
allow for interaction between citizens and your organization (unless used in
Chapter 5: Public Involvement Activities
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conjunction with a "walk-up" information table). The information
repository may also include technical documents, which may be difficult
for citizens to understand.
Chapter 5: Public Involvement Activities Page 5-45
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Checklist for Information Repositories
[Note: this checklist contains all the steps for information repositories required under §§ 124.33 and
270.30. Anyone who is establishing a repository apart from these requirements should check above in
this section to find out which steps apply].
Determine location of Information Repository; check with agency
_ Establish contact with the director of the location determined above
Mail a letter to the permitting agency confirming the location of the Information Repository
_ Agency will mail a list of required documents to the facility
Collect and compile the documents to include in the Information Repository
_ Documents sequentially numbered
Index prepared
_ Documents placed in notebooks
Deliver documents to location determined above
_ Have location director sign a letter/memo acknowledging receipt of the documents
Send a notice to the facility mailing list indicating the availability of the Information Repository;
provide additional means of notice (e.g., newspaper, broadcast media) as appropriate
_ Update the Information Repository as key public documents are available and at key technical
milestones
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Exhibits
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
Exhibits are visual displays such as maps, charts, diagrams, photographs, or
computer displays. These may be accompanied by a brief text explaining
the displays and the purpose of the exhibit. Exhibits provide a creative and
informative way to explain issues such as health risks or proposed
corrective actions. They make technical information more accessible and
understandable.
Exhibits may take from one day to one week to write, design and produce
depending on the complexity of the exhibit. Computer software production
will take longer. Allow time for review of the exhibit's design and concept.
To develop and display an exhibit:
1. Identify the target audience. Possible audiences include:
• General public;
• Concerned citizens;
• Environmental/Public Interest groups;
• Media representatives; and
• Public officials.
2. Clarify the subject. Possible subjects include:
• The RCRA program or the permit or corrective action process;
• Historical background on the facility;
• Public participation activities;
• Corrective action or waste management technologies; and
• Health and safety issues associated with the facility.
3. Determine where the exhibit will be set up. If the general public is
the target audience, for example, assemble the exhibit in a highly
visible location, such as a public library, convention hall, or a
shopping center. If concerned citizens are the target audience, set up
a temporary exhibit at a public meeting, availability session/open
house, or an informal meeting . An exhibit could even be as simple
as a bulletin board at the site or staff trailer.
4. Design the exhibit and its scale according to the message to be
transmitted. Include photos or illustrations. Use text sparingly.
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When to Use
Accompanying
Activities
Advantages and
Limitations
Exhibits can be used:
• When level of interest in the facility is moderate to high;
• When information to be conveyed can be explained graphically;
• When staff time is limited and the audience is large;
• When a display can enhance other information being distributed;
and
• When displays will be useful over long periods of time and at
different facilities (e.g., generic posterboards on RCRA
process).
Exhibits are useful at public meetings, public hearings, and availability
sessions/open houses . If an observation deck is installed at a site, a
nearby exhibit could explain corrective action or compliance activities
under way.
Exhibits tend to stimulate public interest and understanding. While a news
clipping may be glanced at and easily forgotten, exhibits have a visual
impact and leave a lasting impression. Exhibits also can convey
information to a lot of people with a low level of effort.
Although exhibits inform the public, they are, for the most part, a one-way
communication tool. One solution to this drawback is to attach blank
postcards (surveys) to the exhibit, encouraging viewers to comment or
submit inquiries by mail to the agency. Another approach is to leave the
phone number of the contact person who can answer questions during
working hours. However, these requests must be answered or citizens may
perceive the agency as unresponsive to their concerns. Finally, computer
touch screens can provide some feedback by answering common questions
about an exhibit.
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Checklist for Exhibits
Determine purpose, use of exhibit
_ Identify the audience
Clarify the message
_ Determine where and how the exhibit will be displayed
Free-standing
Table-top display
_ Will the exhibit need to be easily transported?
Coordinate design and construction with public involvement coordinator (and
contractors, if available)
_ Write copy
Determine graphics
Design the exhibit
Coordinate review of the design, text, and graphics
_ Complete the exhibit based on review comments
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Briefings
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
Briefings are useful for sharing information with key stakeholders, whether
they are involved regulators, elected officials, or members of involved
public interest or environmental groups. You can use briefings to inform
other stakeholders about the status of a permit application or corrective
action; to provide them with materials such as technical studies; results of
the technical field and community assessments; and engineering designs.
These sessions are conducted in person, and the briefings usually precede
release of information to the media or occur before a public meeting.
Briefing key stakeholders is particularly important if an upcoming action
might result in political controversy.
Briefings will usually take a day to plan and conduct.
To schedule and hold briefings:
1. Inform your audience far in advance of the date of the briefing. It is
usually best to hold the initial briefing in a small public room, such as
a hotel meeting room, conference room, or at the stakeholders'
offices. Where relationships might be antagonistic, it may be best to
hold the briefing in a neutral location.
2. Present a short, official statement explaining the information in the
context of the RCRA process and announcing future steps in the
process.
3. Answer questions about the statement. Anticipate questions and be
prepared to answer them simply and directly.
If the briefing has been requested, find out in advance the information
that the stakeholders seek and prepare to answer these and related
questions.
Briefings are appropriate:
• When key stakeholders have expressed a moderate to high level of
concern about the facility or the process;
• Before the release of new information to the media and the public;
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Accompanying
Activities
When unexpected events or delays occur; and
At any point during the permit or corrective action processes. If local
officials have expressed concern during the preliminary assessment of
the facility, a briefing may be appropriate to explain the RCRA
permitting or corrective action program and the technical actions that
are scheduled for the facility.
Briefings usually precede news conferences, news releases, informal
meetings, or public meetings .
Advantages and
Limitations
Briefings allow key stakeholders to question you directly about any action
prior to public release of information regarding that action. By providing a
"heads up," you can prepare other key stakeholders to answer questions
from their constituents when the information becomes public. Briefings
also allow for the exchange of information and concerns.
Because briefings are normally offered to a small select group, they are not
considered to be general information dissemination to the public. Care
must be taken to provide the public with ample opportunity to receive
information. At briefing sessions, include the appropriate officials, taking
care not to exclude people key to the public participation process. Avoid
the perception that you are trying to bury facts or favor special interest
groups.
Although briefings can be an effective tool for updating key stakeholders
(e.g., state and local officials, community leaders, involved regulators) they
always should be complemented by activities to inform the general public,
such as informal meetings with small groups, public meetings, or news
conferences.
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Checklist for Briefings
Determine date, time, and location of briefing.
Date:
Time:
Location:
Notify key state and local officials, citizens, and other interested parties of the briefing
Prepare presentation
Prepare any handout materials
Conduct briefing
Follow-up on any questions you are unable to answer during the briefing
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Presentations
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
Presentations are speeches, panel discussions, video tapes or slide shows
held for local clubs, civic or church organizations, school classes, or
concerned groups of citizens to provide a description of current RCRA
activities. They help improve public understanding of the issues associated
with a permitting or corrective action.
One to two days may be needed to set up and schedule the presentation,
prepare for it, give the presentation, and follow up on any issues raised.
Add more time if you need to prepare visual equipment.
Develop procedures that can be changed easily to suit different audiences.
To conduct presentations:
1. Contact groups that may be interested in learning about your
work. Announce the program through the media and in your
publications. Adjust the tone and technical complexity of any
presentation to suit the audience's needs.
2. Select a standard format such as the following:
• Introduce yourself, your organization, the RCRA permitting or
corrective action process, and the facility;
• Describe the issues that affect your audience;
• Discuss what is being currently done; and
• Discuss how citizens can play a part in making decisions about
the facility.
3. Set a time limit of 20 minutes. Consider having several staff
members deliver short segments of the presentation. Allow time for a
question-and-answer session .
4. Schedule presentations at convenient times, possibly evenings or
weekends, or during regularly-scheduled meetings of other groups.
Consult with members of your target audience to find out what time is
best for them.
5. Select supporting materials (slides, graphics, exhibits, etc.) that will
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When to Use
Accompanying
Activities
Advantages and
Limitations
hold the audience's attention but not distract from the speaker's
message. Conduct a trial run in front of colleagues and rehearse the
presentation as much as possible.
If substantive issues or technical details cannot be handled in the
time allowed for the presentation, name a contact for further
information.
Presentations may be held:
• When there is moderate to high interest in a facility;
• When it is practical to integrate short RCRA presentations into
meetings on other subjects; and
• When a major milestone in the RCRA process is reached.
Fact sheets or handouts should be distributed so that participants have
something to refer to after the presentation. Incorporating exhibits into
your presentation will hold the audience's attention and aid in their
understanding of the material. Question and answer sessions will help
clear up any misunderstanding about the presentation and allow you to
address complex issues in more detail
Because the presentation is delivered in person, the audience has a chance
to ask questions, and the presenter can gauge citizens' concerns. Also,
many people can be reached at one time, reducing individual inquiries.
Making project staff available for community speeches and presentations
will signal your organization's interest in the community.
Presentations require substantial effort to be effective. A poorly planned
presentation can distort residents' views of the situation.
Because the presentation is rehearsed, accommodating different or
unanticipated concerns of the audience can be difficult. Handle these
concerns during a question-and-answer session after the presentation.
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Checklist for Presentations
Contact groups that may be interested in a presentation
_ Determine message(s) to be presented based on stated community interests/concerns
Prepare presentation(s) based on responses from groups contacted
_ Prepare handout materials
Prepare exhibits or other visual materials
_ Determine what staff are available for presentations
Schedule presentations
_ Conduct rehearsals
Conduct presentations
_ Conduct follow-up question-and-answer session after presentations
Respond to questions you were unable to answer
_ Contact group regarding other presentation topics in which they may be interested
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Facility Tours
Reeulatorv None, though the tour will have to comply with facility safety plans.
Requirements
Description of Activity Facility tours are scheduled trips to the facility for media representatives,
local officials, and citizens during which technical and public outreach staff
answer questions. Facility tours increase understanding of the issues and
operations at a facility and the RCRA-regulated process underway.
Level of Effort Facility tours generally take a day to plan and conduct.
HOW tO Conduct the To conduct facility tours:
Activity 1 _ plan the tour ahead of time>
The facility owner/operator may decide to conduct a tour, or the
agency may set up a tour of the facility. If agency staff plan to lead
the tour, they should coordinate with the facility owner/operator.
Citizens groups should arrange tours with the facility owner/operator.
If there is a Citizens Advisory Panel, the members could lead or
participate in tours.
Before the tour, you should:
• Determine tour routes;
• Check on availability of facility personnel, if needed; and
• Ensure that the tour complies with the safety plan for the site.
If it is not possible to arrange tours at the facility (e.g., the facility is
under construction or not yet built), perhaps it would be possible to
arrange a tour at one like it. Interested community members may
benefit from touring a facility that has similar operations or where
similar technologies have been applied. Touring a RCRA-regulated
facility can give residents a clearer perception of what to expect at
their own site.
2. Develop a list of individuals that might be interested in
participating in a tour, including:
• Individual citizens or nearby residents who have expressed
concern about the site;
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When to Use
Accompanying
Activities
Advantages and
Limitations
• Representatives of public interest or environmental groups that
have expressed interest in the site;
• Interested local officials and regulators;
• Representatives of local citizen or service groups; and
• Representatives of local newspapers, TV, and radio stations.
3. Determine the maximum number that can be taken through the
facility safely. Keep the group small so that all who wish to ask
questions may do so. Schedule additional tours as needed.
4. Think of ways to involve tour participants. A "hands-on"
demonstration of how to read monitoring devices is one example.
5. Anticipate questions. Have someone available to answer technical
questions in non-technical terms.
Tours may be conducted:
• When there is moderate to high interest in the facility, especially
among elected officials;
• When it is useful to show activities at the facility to increase
public understanding or decrease public concern;
• When it is practical and safe to have people on facility grounds;
and
• During the remedial phase of corrective action.
Fact sheets, exhibits, and presentations complement facility tours. An
observation deck near the facility would allow them to watch the progress
of activities on their own. An on-scene information office would allow
for an agency official to be around and for less formal tours of the facility.
An alternative to a facility tour would be a videotape presentation
showing activity and operations at the facility. This would be effective in
cases where tours cannot be conducted.
Facility tours familiarize the media, local officials, and citizens with the
operations and the individuals involved in the permitting or corrective
action. Unreasonable fears about the risks of the facility may be dispelled,
as might suspicion of corrective action crews working at the facility. The
result is often better understanding between stakeholders.
Facility tours require considerable staff time to arrange, prepare, and
coordinate. Staff may have difficulty gaining site access for non-agency
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people. Insurance regulations for the facility and liability, safety and injury
considerations may make tours impossible.
Checklist for Facility Tours
Determine need for facility tours
Coordinate tours with the facility
_ Tour routes
Facility personnel
_ Tour dates
Compliance with health and safety
Determine maximum number of people that can be taken on the tour
Notify interested citizens on availability of facility tours
_ Call interested citizens
Distribute mailing to facility mailing list
_ Have citizens respond and reserve space on the tour
Determine plant staff or agency staff to conduct tour
Prepare responses to anticipated questions
Conduct tours
Follow-up on any requested information from interested citizens
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Observation Decks
Regulatory
Requirements
Description of Activity
Level of Effort
When to Use
None.
How to Conduct the
Activity
An observation deck is an elevated deck on the facility property, near the
area where corrective or RCRA-regulated activities are in progress. The
deck allows interested citizens to observe facility activities or corrective
actions directly in order to remove some of the unfamiliarity, and hence
fear, that may encompass RCRA-regulated activities.
Maintaining an observation deck may be a time-intensive activity
depending on the deck's hours of operation. Up to 40 hours a week may be
necessary to staff the deck. Short Cut: Consider hiring a contractor to staff
the deck, or limit the hours when it is open to the public.
To use an observation deck, the agency and the facility should work
together to:
1. Decide whether or not an observation deck is needed or desirable.
Gauge community interest in the facility and whether or not there is a
location for a deck that would facilitate observation.
2. Coordinate deck construction. Determine the best location for the
observation deck keeping in mind safety and public access issues.
3. Coordinate staffing of the observation deck. Determine the hours
of operation for the observation deck. Identify staff to supervise the
observation deck and prepare staff to answer questions from the
public.
4. Announce the availability of the observation deck. Notify the
community that the deck is available through public notices, fact
sheets, and a mailing to the facility mailing list.
An observation deck may be used:
• When community interest or concern is high;
• When the community's understanding of facility operations will
be enhanced by direct observation;
• When there will be sufficient activity at the site to promote the
community's interest;
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When staff are available to supervise public use of the deck and
answer questions;
When it is physically possible to set up an observation deck in a
place where there is no danger to the public;
When a corrective action is being implemented; and
When a new technology is being tested or implemented.
Accompanying An observation deck could complement periodic facility tours or an on-
Activities scene information office . Citizens can initially be informed about
operations or corrective actions during the tours, then can monitor the
progress of these activities at their convenience from the observation deck.
Fact sheets or an informative exhibit placed near the deck also could
further aid in explaining facility activities.
Advantages and An observation deck allows citizens and media representatives to observe
T imitations s^e activities without hindering the activities.
Constructing and occupying an observation deck is expensive and needs to
be supplemented with an informational/interpretive program, so that
citizens understand what they see. Further, health and safety issues must
thoroughly be considered so that any visitor to the observation deck is not
endangered by activities at the facility.
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Checklist for Observation Decks
Determine need for an observation deck
_ Coordinate with facility
Identify staff available to supervise the observation deck and answer questions from interested
citizens
_ Coordinate deck construction
Set hours of operation for the observation deck
_ Notify interested citizens of availability of observation deck
Public notice
_ Fact sheet
Mailing to facility mailing list
Maintain observation deck
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News Releases and
Press Kits
Regulatory
Requirements
Description of Activity
Level of Effort
None.
News releases are statements that you or your organization send to the
news media. You can use them to publicize progress or key milestones in
the RCRA process. News releases can effectively and quickly disseminate
information to large numbers of people. They also may be used to
announce public meetings, report the results of public meetings or studies,
and describe how citizen concerns were considered in the permit decision
or corrective action.
Press kits consist of a packet of relevant information that your organization
distributes to reporters. The press kit should summarize key information
about the permitting process or corrective action activities. Typically a
press kit is a folder with pockets for short summaries of the permitting
process, technical studies, newsletters, press releases, and other background
materials.
If your organization has public affairs personnel, you should coordinate
with them to take on media contact responsibilities.
News releases generally take eight hours to write, review, and distribute to
the media.
How to Conduct the
Activity
To prepare news releases and press kits:
1. Consult with external affairs personnel who regularly work with
the local media. External affairs personnel will assure that you
adhere to organization policy on media relations. They will assist in
drafting the news release and can provide other helpful suggestions
about the release and the materials for the press kit.
2. Identify the relevant regional and local newspapers and broadcast
media, and learn their deadlines. Get to know the editor and
environmental reporter who might cover the issue. Determine what
sorts of information will be useful to them.
3. Contact related organizations to ensure coordination. For
instance, permitting agencies should contact other regulatory agencies
on the federal, state, and local levels to ensure that all facts and
procedures are coordinated and correct before releasing any statement
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or other materials. If your organization is local, you should
coordinate with national or state-wide chapters. You may want to
consider discussing the news release with other interested
stakeholders (e.g., through a briefing). However, draft news releases
should not be shared - they are internal documents.
4. Select the information to be communicated. For the press release,
place the most important and newsworthy elements up front and
present additional information in descending order of importance.
Use supporting paragraphs to elaborate on other pertinent
information. Mention opportunities for public participation (i.e.,
public meetings, etc.) and contact persons and cite factors that might
contribute to earlier implementation or delays in the corrective action
or permit processing. Note the location of the information repository
(if applicable) or other sources for relevant documents. If you are
presenting study findings or other technical information, present it in
layman's terms along with any important qualifying information (e.g.,
reliability of numbers or risk factors).
The press kit should contain materials that elaborate on the
information in the press release. Basic summaries of the RCRA
program, the permitting process, and public participation activities are
helpful materials. Background reports or studies may also be useful.
Enclose the name and phone number of a contact person and invite
the reporter to call him or her with any questions.
5. The news release should be brief. Limit it to essential facts and
issues.
6. Use simple language. Avoid the use of professional jargon, overly
technical words, and acronyms.
7. Identify who is issuing the news release. The top of the sheet
should include:
• Name and address of your organization;
• Release time ("For Immediate Release" or "Please Observe
Embargo Until") and date;
• Name and phone number of the contact person for further
information; and
• Headline summarizing the activity of interest.
8. In some cases, send copies of the release and the press kit to other
stakeholders at the same time you give them to the news media.
Coordinate with the public affairs office to determine appropriateness.
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When to Use
Accompanying
Activities
Advantages and
Limitations
The press kit and the news release can be complementary activities, though
you may choose to use either one separately. Some of the occasions when
you may want to issue a news release or a press kit include:
• When significant findings are made at the site, during the
process, or after a study;
• When program milestones are reached or when schedules are
delayed;
• In response to growing public or media interest or after your
organization takes a new policy stance;
• When you are trying to increase public interest in a facility;
• Before a public meeting to announce subject, time, place; and
• A news release should not be issued at times when it may be
difficult to get in touch with responsible officials (e.g., Friday
afternoons, or the day before a holiday).
The press kit is useful as a complement to a news release. News releases
and press kits can accompany any formal public hearings or public
meetings. They commonly accompany news conferences . They should
provide the name of the contact person whom interested reporters can
contact if they want more information.
A news release to the local media can reach a large audience quickly and
inexpensively. Press kits allow reporters to put the issue in context. If a
reporter is trying to meet a deadline and cannot contact you, he or she can
turn to the press kit as an authoritative source of information. If the name,
address, and phone number of a contact person are included, reporters and
possibly interested community members can raise questions about the
information in the release.
Because news releases must be brief, they often exclude details in which
the public may be interested. A news release should therefore be used in
conjunction with other methods of communication that permit more
attention to detail. A news release is not an appropriate vehicle for
transmitting sensitive information. In some cases, a news release can call
unwarranted attention to a situation; a mailing to selected individuals
should be considered instead. Frequent use of news releases to announce
smaller actions may reduce the impact of news releases concerning larger
activities.
One potential drawback of a press kit is that reporters may ignore it or use
the information incorrectly when writing a story.
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News releases and press kits cannot be used in lieu of a public notice.
Certain activities, such as the preparation of a draft permit, are subject to
public notice requirements. See the section on "Public Notices" earlier in
this Chapter for more details.
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Checklist for News Releases and Press Kits
Coordinate with public affairs staff
_ Determine purpose of news release and/or press kit
Coordinate writing and distribution of release or press kit with the public affairs staff
_ Verify that media mailing list is up-to-date
Request mailing labels
_ Write draft news release
Type and double space news release
_ Indicate the source of the news release (i.e., in the upper-left-hand corner, put the name
and phone number of the person writing the release, along with the agency or department
name and address)
_ Provide release instructions (i.e., "For Immediate Release")
Date the news release
_ Write concisely; avoid technical terms and jargon
Number pages; if more than one page is needed, put" — more --" at the center bottom of
the page that is to be continued; succeeding pages should be numbered and "slugged" with
an identifying headline or reference (i.e., "EPA ~ 2"); when you come to the end of the
news release, indicate the end with one of the following: ~ 30 —, ####, or ~ END —.
_ Prepare materials for the press kit
Collect short descriptions of the RCRA program, permitting, and public participation
processes
Include other pertinent information, such as reports, studies, and fact sheets
_ Coordinate internal review
Prepare final matierals based on review comments
_ Distribute news release and press kit to local media
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News Conferences
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
News conferences are information sessions or briefings held for
representatives of the news media and may be open to the general public.
News conferences provide all interested local media and members of the
public with accurate information concerning important developments
during a RCRA-regulated process. If your organization has public outreach
personnel, you will probably want to coordinate news conferences with
them.
Allow one to two days to prepare for, rehearse, and conduct a news
conference.
To conduct news conferences:
1. Coordinate all media activity through your outreach staff. Public
outreach personnel will assure that you adhere to organization policy
on news conferences. They will help arrange location and equipment,
etc.
2. Evaluate the need for a news conference. Use this technique
carefully because statements made during a news conference may be
misinterpreted by the media. For reporting the results of site
inspections, sampling, or other preliminary information other public
involvement techniques (e.g., fact sheets, news releases, or public
meetings) may be more appropriate. A news conference announcing
preliminary results of technical studies may add unnecessarily to
public concerns about the facility.
3. Notify members of the local and regional media of the time,
location, and topic of the news conference. Local officials also
may be invited to attend, either as observers or participants,
depending upon their interest. Including local officials at a news
conference will underscore your organization's commitment to a
community's interests and concerns.
4. Anticipate reporters' questions and have your answers ready.
5. Present a short, official statement, both written and spoken,
about developments and findings. Explain your organization's
decisions by reviewing the situation and identifying the next steps.
Use visual aids, if appropriate. Live conferences leave no room for
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When to Use
Accompanying
Activities
Advantages and
Limitations
mistakes, so preparation and rehearsal is very important.
Open the conference to questions, to be answered by your staff, local
officials, and any other experts present. Have technical staff on hand
to answer any technical questions. Decide ahead of time who will
answer certain types of questions.
News conferences can be used:
• When time-sensitive information needs to reach the public, and
a news release may not be able to address key issues for the
community;
• When staff are well-prepared to answer questions; and
• During any phase of the permit application or corrective action.
News conferences can be held before or after formal public hearings or
public meetings. They are usually accompanied by news releases.
Exhibits, telephone contacts , briefings, and mailing lists would
contribute to the planning and effectiveness of a news conference.
News conferences provide a large public forum for announcing plans,
findings, policies, and other developments. They also are an efficient way
to reach a large audience. A written news release can help ensure that the
facts are presented accurately to the media. During the question and
answer period, your spokesperson(s) can demonstrate knowledge of the
facility and may be able to improve media relations by providing thorough,
informative answers to all questions.
A news conference can focus considerable attention on the situation,
potentially causing unnecessary local concern. Residents may not welcome
the increased attention that such media coverage is apt to bring. News
releases or lower-profile means of disseminating information should be
considered as alternatives.
A risk inherent in news conferences is that the media can take comments
out of context and create false impressions. This risk is heightened when
staff are unprepared or when the conference is not properly structured or
unanticipated questions are asked.
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Checklist for News Conferences
Coordinate news conference with public affairs staff
Determine purpose of news conference
Identify staff to make presentations/answer questions at news conference
_ Prepare visual materials (i.e., exhibits) and handout materials (i.e., fact sheets)
Prepare responses to "anticipated" questions from the media
_ Coordinate a rehearsal of all presenters
Determine date, time, location, and equipment needs of news conference
_ Is the location large enough to accommodate the media?
Notify local media of news conference in advance of news conference
_ Call the local media the day before the news conference as a reminder
Conduct the news conference
_ Set up room with a speakers table, chairs for the audience
Have handout materials available when media arrive
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Community
Interviews
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
Community interviews are informal, face-to-face or telephone interviews
held with local residents, elected officials, community groups, and other
individuals to acquire information on citizen concerns and attitudes about a
facility. The interviews may be conducted by facility staff, the permitting
agency, or public interest groups as part of the community assessment.
Chapter 2 provides more information on community assessments in the
section titled "Assessing the Situation."
Community interviews can play an important role in the community
assessment, which usually takes place at the beginning of the permitting
process, or before major modifications and significant corrective actions.
Community interviews will not be necessary in every community. For
instance, in routine or non-controversial situations, there may be no need
for community interviews. However, if a facility is controversial or has the
potential to receive high levels of public interest, then EPA recommends a
broad range of community interviews. Permitting situations that fall
between the preceding cases may require some interviews, beginning with a
survey of community representatives and group leaders (see "Assessing the
Situation" in Chapter 2).
Community interviews allow agencies, facility owners, and public interest
groups to tailor regulatory requirements and additional activities to fit the
needs of particular communities. Information obtained through these
interviews is typically used to assess the community's concerns and
information needs and to prepare a public participation plan , which
outlines a community-specific strategy for responding to the concerns
identified in the interview process.
Community interviews are a time-intensive activity because of the large
amount of organization required and time needed for interviews. While
level of effort will vary, interviewers should schedule at least one hour per
interview for research and preparation, the interview itself, and follow-up
activities. If time and/or resources are limited, interviewers may want to
conduct interviews by phone and focus on community leaders.
Permitting agencies, facility owners, and public interest groups who plan to
conduct community interviews should follow the steps below, adjusting
them as necessary to suit the situation at hand:
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1. Identify potential people to interview. If a mailing list is not
available, begin by reviewing available files and other documents
(e.g., newspaper articles) to identify local residents, key state and
local officials, and citizen organizations that have been involved with
or expressed concern about the facility. Agency staffer other groups
in the community (e.g., existing facility owners and operators, public
interest organizations, civic groups, local government agencies) may
also be able to suggest individuals or groups to interview. Develop a
list of individuals and groups that provides the greatest variety of
perspectives. Make sure to include individuals who tend to be less
vocal to balance the views of those who are more outspoken. Your
contact list may include:
• state agency staff, such as officials from health, environmental,
or natural resources departments;
• local agency staff and elected officials, such as county health
department officials, county commissioners, mayor or township
administrator, and officials on environmental commissions,
advisory committees, and planning boards;
• representatives of citizens' groups organized to address issues at
the facility or in the area;
• non-affiliated area residents and individuals;
• local business representatives (e.g., from the Chamber of
Commerce or Council of Governments);
• local civic groups, neighborhood associations, educational and
religious organizations;
• local chapters of public interest groups (e.g., environmental
organizations); and
• nearby landowners and businesses.
2. Determine how many interviews to conduct. Conduct interviews
with the goal of obtaining a broad range of perspectives and gathering
sufficient information to develop an effective public participation
plan. However, the actual number of interviews is likely to depend on
available time and resources as well as the community's level of
interest and concern about the facility. It is generally desirable to
conduct more extensive interviews in communities where the level of
concern is high. Alternatively, where the level of interest is low or
there has already been significant interaction with community, fewer
interviews may be appropriate.
3. Prepare for the interviews. Before conducting the interviews, learn
as much as possible about the community and community concerns
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regarding the facility. Review any available news clippings,
documents, letters, and other sources of information relevant to the
facility. Determine whether the community has any particular
language, geographic, or economic characteristics that should be
addressed. Prepare a list of questions that can serve as a general
guide when speaking with residents and local officials. Questions
should be asked in a way that stimulates discussion on a variety of
topics, including:
• General knowledge of the facility. Find out what sort of
information the community has received about the facility and if
what level of involvement the community has had with the
facility.
• Specific concerns about the technical and regulatory aspects of
activities at the facility. Determine what the community's
concerns are and what types of information would be most
appropriate to address these concerns.
• Recommended methods of communicating with the community
and receiving community input. Determine which
communications tools are likely to be most effective ~ e.g.,
mailings, meetings, broadcast media ~ and what public
participation events could best serve the community. Learn
about special information needs that the community may have
(e.g., the level of literacy, the percentage of non-English
speakers).
• The best public meeting facilities, most relied-upon media
outlets, and the best times to schedule activities.
• Other groups or individuals to contact for more information.
4. Arrange the interviews. Telephone prospective interviewees and
arrange a convenient time and place to meet. Ideally, the meeting
place should promote candid discussions. While government and
media representatives are likely to prefer meeting in their offices
during business hours, local residents and community groups may be
available only in non-business hours. Meetings at their homes may be
most convenient.
During the interviews:
1. Provide background information. Briefly describe the permitting
activity or corrective action at hand.
2. Assure interviewees that their specific comments will remain
confidential. At the beginning of each interview, explain the purpose
of the interviews ~ to gather information to assess community
concerns and develop an appropriate public participation strategy.
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Explain that while the public participation plan will be part of the
administrative record, the plan will not attribute specific statements or
information to any individual. Ask interviewees if they would like
their names, addresses, and phone numbers on the mailing list.
3. If community members do not feel comfortable with interviewers
from your organization, consider using a third-party. Some
citizens may not be entirely forthcoming with their concerns or issues
if they are uncomfortable with the interview. If sufficient resources
are available, inciter hiring a contractor to perform interviews. Some
civic or community organizations may be willing to help in the
interview process. If these options are not available, then consider
distributing anonymous surveys or convening focus groups, where a
number of citizens can give their input together.
4. Identify other potential contacts . During the discussions, ask for
names and telephone numbers of other persons who are interested in
activities at the facility.
5. Gather information on past citizen participation activities .
Determine the interviewee's perceptions of past outreach activities by
your organization.
6. Identify citizens' concerns about the facility . When identifying
concerns, consider the following factors:
• Threat to health ~ Do community residents believe their health
is or has been affected by activities at the facility?
• Economic concerns - How does the facility affect the local
economy and the economic well-being of community residents?
• Agency/Facility/Interest Group credibility ~ Does the public
have confidence in the capabilities of the agency? What are the
public's opinions of the facility owner/operator and involved
environmental/public interest organizations
• Involvement ~ What groups or organizations in the community
have shown an interest in the facility? Is there a leader who has
gained substantial local following? How have interested groups
worked with the agency or facility in the past? Have
community concerns been considered in the past?
• Media ~ Have events at the facility received substantial
coverage by local, state, or national media? Do local residents
believe that media coverage accurately reflects the nature and
intensity of their concerns?
• Number affected ~ How many households or businesses
perceive themselves as affected by the facility (adversely or
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When to Use
Accompanying
Activities
Advantages and
Limitations
positively)?
Assess how citizens would like to be involved in the RCRA
permitting or corrective action process . Briefly explain the RCRA
public participation process and ask the interviewees how they would
like to be involved and informed of progress made and future
developments at the facility. Ask what is the best way to stay in
contact with the interviewee. Ask the interviewee to recommend
convenient locations for setting up the information repository or
holding public meetings. Keep a list of those who wish to be kept
informed.
Community interviews should be conducted:
• As part of a community assessment by facility owners who are
applying for a permit, seeking a major permit modification, or
beginning significant corrective action.
• By the permitting agency to find out about community concerns at the
outset of a major permitting or corrective action process.
• Before revising a public participation strategy, because months, or
perhaps years, may have elapsed since the first round of interviews,
and community concerns may have changed.
As the level of community concern increases, so does the need to conduct
more extensive assessments. If there has been a lot of interaction with the
community and interested parties, information on citizen concerns may be
current and active. In such situations, it may be acceptable to conduct only
a few informal discussions in person or by telephone with selected,
informed individuals who clearly represent the community to verify,
update, or round out the information already available.
As stated above, community interviews are conducted to gather information
to develop an appropriate public participation plan for the facility. A
mailing list may or may not be in place at the time interviews are
conducted. If there is one, it can be used to identify individuals to
interview. If one has not yet been established, the interviews themselves
can provide the basis for the list.
Community interviews can be a valuable source of opinions, expectations,
and concerns regarding RCRA facilities and often provide insights and
views that are not presented in the media. In addition, these interviews
may lead to additional information sources. The one-on-one dialogue that
takes place during community interviews provides the basis for building a
good working relationship, based on mutual trust, between the community
and other stakeholders. Therefore, although its primary purpose is to gather
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information, the community interview also serves as an important public
outreach technique.
The major disadvantages of community interviews are that they may be
time-consuming and resource-intensive for your staff; they could cause
unnecessary fear of the situation among the public; and, they are not very
useful if you do not talk with the right people ~ the people who have not
identified themselves as well as the more vocal ones who have.
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Checklist for Community Interviews
Determine number of interviews to be conducted:
Determine dates for interviews:
Identify team to conduct interviews:
Identify individuals to interview
Review facility background files for names of people who have expressed interest
_ Identify community leaders to contact
Identify city/state/county officials to contact
Prepare interview questions
Review background information available about the facility and community
Set up interviews
Confirm interviews by mail or phone
Conduct interviews
Ask for additional people to contact
_ Gather information using prepared interview questions
Follow-Up
Follow-up interview with a thank you letter
Notify the interviewee when the public participation strategy is available in the repository
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Focus Groups
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
None.
Some organizations use focus groups as a way of gathering information on
community opinion. The advertizing industry developed focus groups as an
alternative to expensive market research (which relies heavily on polling).
Focus groups are small discussion groups selected either to be random or to
approximate the demographics of the community. The group is usually led
by a trained moderator who draws out people's reactions to an issue.
Facility owners may want to consider focus groups as a complement to
interviews during the community assessment or at important activities
during the life of a facility. The permitting agency may want to consider
focus groups to gauge public opinion before controversial permitting
activities or corrective actions.
Focus groups can be resource-intensive, depending on the number of groups
you convene. This method will be more expensive if you need to provide
for a moderator, meeting space, or transportation.
To prepare for focus groups:
1. Determine whether or not a focus group can help the process.
Community interviews serve much the same purpose as focus groups.
Will gathering members of the community together provide more
comfort? Will it be a more effective means of gauging public
opinion?
2. Select your focus groups. Contact other stakeholders and
community leaders to get input on who to include in your focus
groups.
3. Use community interview techniques to get input from the focus
group. You can follow the guidance in "Community Interviews"
above in this Chapter to learn about the types of questions to ask your
focus groups.
4. Use the information in forming a public participation plan.
Facility owners may want to use focus groups as a complement to
community interviews; permitting agencies may want to consider focus
groups in situations where there is a high degree of public interest in a
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permitting activity. Focus groups provide a quick means of feedback from
a representative group and can be a good supplementary activity, especially
if such group discussions will make some members of the public feel more
comfortable.
Accompanying ^se f°cus §rouPs as a complement to community interviews . You may
. . . . want to hold a presentation or provide the groups with information such as
fact sheets.
Advantages and Focus groups allow you to get an in-depth reaction to permitting issues.
T . . . They can help to outline a public participation plan and give an indication
Limitations r., ,, .,• -,, ,, , •
oi how the public will react to certain issues.
The reactions of a focus group cannot, in all cases, be counted on to
represent the greater community. Some people may perceive focus groups
as an effort to manipulate the public.
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Checklist for Focus Groups
Determine number of focus groups to be conducted:
Determine dates for focus groups:
_ Identify moderator to conduct focus groups:
Identify individuals for focus groups
Review facility background files for names of people who have expressed interest
_ Identify community leaders to contact
Identify city/state/county officials to contact
Prepare discussion questions
Review background information available about the facility and community
Set up focus groups
Confirm participation by mail or phone
Conduct focus groups
Ask for additional people to contact
_ Gather information using prepared interview questions
Follow-Up
Follow-up interview with a thank you letter
Notify the interviewee when the public participation plan is available
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Door-to-Door
Canvassing
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
Door-to-door canvassing is a way to collect and distribute information by
calling on community members individually and directly. Public interest
groups have long used such techniques, and they may also be useful for
facility owners as a way to gauge public interest during the community
assessment stage. The permitting agency may consider using this technique
to interact with the community in situations where public interest is very
high, such as emergency cleanups, or in other situations where direct
contact with citizens is essential. See the section on "When to Use" below
for more details.
During these interactions, canvassers can field questions about the
permitting activity, discuss concerns, and provide fact sheets or other
materials. Some citizens may want to find out more about the activity by
signing up for mailing lists or by attending an upcoming event.
Door-to-door canvassing is a very time-intensive activity because of the
number of staff needed to conduct the canvassing and the amount of time
you will need to plan for the canvassing. Canvassers should travel in pairs
in areas where there may be a lot of contention or in high crime areas.
Planning for the door-to-door canvassing will require at least a day. This
includes identifying the area to be canvassed, determining the amount of
staff needed, and notifying area residents. The amount of time spent
canvassing will depend on the size of the area to be canvassed.
A door-to-door canvass involves training staff to gather information,
answer questions, and to communicate with a possibly irate or suspicious
public.
Procedures to follow in preparing a door-to-door canvass include:
1. Identify the area where canvassing is necessary or desirable.
Determine the area where special information must be given or
collected. This area may range from just a few streets to several
neighborhoods. Determine if there is a need for a translator or
materials in languages other than English. Also determine when it is
likely that people will be at home; the canvassing may have to be
conducted in the evening.
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2. If time permits, notify residents (e.g., by distributing a flyer) that
canvassers will be calling door-to-door in the area. Tell residents
what time the canvassers will be in the neighborhood and explain the
purpose of the canvassing program. Advance notice will reduce the
suspicions of residents and encourage their cooperation. Also, notify
local officials so they are aware of the door-to-door canvassing.
3. Provide canvassers with the information they will need to respond
to questions. Residents will want to know what is happening at the
facility and may have questions about possible health effects
associated with various activities. If appropriate, you should
distinguish between the types of questions that a canvasser may
answer (i.e., questions concerning the schedule of activity) and the
types of questions that should be referred to technical staff (e.g.,
highly technical questions concerning hazardous waste or agency
policies). Provide canvassers with fact sheets or other written
materials for distribution.
4. Canvass the designated area. Note the name, address, and
telephone number of residents requesting more information. Note
also the names of those who were especially helpful in giving
information. Be prepared to tell residents when they will next be
contacted and how (i.e., by telephone, by letter, or in person). All
canvassers should have an official badge to identify themselves to
residents.
5. Send a thank-you letter after the canvass to all residents in the
canvassed area. If possible, provide information concerning recent
developments and any results or pertinent information gathered by the
canvass. Respond to special requests for information either in the
thank-you letter or by telephone.
When to Use Door-to-door canvassing may be used:
When there is a high level of concern about the site, but
meetings cannot be scheduled;
When there is a need to notify citizens about a certain event or
an upcoming permitting issue;
When you need to reach a specific group of people for a specific
purpose, such as getting signatures to allow access to properties
adjacent to the facility;
When the community has a low literacy rate and written
materials aren't useful;
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Accompanying
Activities
Advantages and
Limitations
When the area consists of a population whose primary language
is not English, but it is important to pass information to the area;
and
When there is an emergency situation that the community needs
to know about.
Telephone contacts and community interviews may help to identify
appropriate areas for canvassing efforts. Canvassers should add to the
mailing list names of individuals who either requested additional
information or provided particularly useful information.
This activity involves face-to-face contact, thereby ensuring that citizens'
questions can be directly and individually answered. Canvassing
demonstrates a commitment to public participation, and is a very effective
means of gathering accurate, detailed information, while determining the
level of public concern.
This technique is very time-consuming and costly, even in a small area.
Furthermore, trained people that can answer questions at the necessary
level of detail are often not available for this activity. This activity is not
recommended for the dissemination of information except in an emergency.
This high level of direct contact can raise more concerns rather than allay
them.
The safety and security of the canvassers also should be taken into account
when planning this activity. Additional staff may be need so that people
can work in teams to two or three; in extreme situations, security staff may
be necessary .
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Checklist for Door-to-Door Canvassing
Identify area where canvassing will be conducted
_ Prepare maps for each team of canvassers
Send a letter to residents announcing canvassing
Prepare mailing list using the city directory (section listing residences by street
address)
_ Prepare letter; coordinate internal review
Determine security needs of canvassing team
_ Prepare any information (i.e., fact sheets) that canvassing team may provide to interested
residents
_ Identify staff to conduct canvassing and have official badges made to identify them
Brief staff on canvassing effort
_ Provide staff with a copy of letter sent to residents
Tell staff what kinds of questions they may answer and provide them with information
(i.e., questions concerning the schedule of activity)
_ Tell staff what kinds of questions they should refer to a specialist (i.e., technical questions)
Provide staff with prepared maps
_ Canvass designated areas
Note the name, address, and telephone number of residents requesting more information
_ Send thank you letter to all residents in the canvassed area
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Public Comment
Periods
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
Accompanying
Activities
Public comment periods are required whenever the permitting agency
issues a draft permit or an intent to deny a permit (§ 124.10). Comment
periods are also mandatory on requests for Class 2 and 3 permit
modifications under § 270.42, for agency-initiated modifications under §
270.41, and during closure and post-closure for interim status facilities
under §§ 265.112(d)(4) and 265.118(f).
A public comment period is a designated time period in which citizens can
formally review and comment on the agency's or facility's proposed course
of action or decision. Comment periods for RCRA permits must be at least
45 days.
There is no specific level of effort for a public comment period. Estimates
of the time required to conduct activities associated with the public
comment period (public notice, public hearing, etc.) are found elsewhere in
this chapter. The time required to receive, organize, and determine how to
respond to comments will vary depending on the number of comments
received and the complexity of the proposed action (see the section on
"Response to Comments" earlier in this chapter).
Announce the public comment period in a local newspaper of general
circulation and on local radio stations. Public notices must provide the
beginning and ending dates of the public comment period and specify
where interested parties should send their comments and/or requests for a
public hearing. Refer to the section about "Public Notices" earlier in this
chapter for further information.
A minimum 45-day public comment period is required for RCRA permits,
including modifications to permits initiated by the agency as well as Class 2
and 3 modifications requested by the facility.
Public comment periods cannot begin until notice of the permitting activity
is given. RCRA requires that the agency conduct a public hearing if
requested by a member of the public during the public comment period.
Announce the hearing through a public notice and through a fact sheet, if
one is prepared in advance. Public comment periods cannot begin until
notice is given.
Comments received during the public comment period must be discussed in
a written response to comments .
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Advantages and Public comment periods allow citizens to comment on agency and facility
T imitations proposals and to have their comments incorporated into the formal public
record.
However, public comment periods provide only indirect communication
between citizens and agency officials because, in some cases, the formal
responses to the comments may not be prepared for some time. Also, in
some cases, the agency may not individually respond to every comment. A
public participation program should provide other activities that allow
dialogue between agency officials and the community.
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Checklist for Public Comment Periods
Determine dates of public comment period (minimum of 45 days)
Dates:
Determine contact person within the agency who will answer citizens' questions regarding the
public comment period
Announce public comment period through a public notice
If requested by a member of the public during the comment period, schedule a public hearing
Document with a memo to the file any comments that were not received in written form
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Unsolicited
Information and
Office Visits
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None.
EPA encourages permitting agencies, public interest groups, and facility
owners/operators to seek input from interested citizens and other
stakeholders. At times, this information may arrive in the form of phone
calls, letters, and meetings. While this type of information is not always
asked for, it can be helpful.
Citizens or stakeholders from other groups may want to visit the agency's
office or the facility. In this situation, the visiting stakeholders will want to
meet with the person who works most directly with their concerns.
Depends entirely on the type of unsolicited information provided by the
public. Office visits will also command varying amounts of time.
Members of the public will come to the agency, the facility, or another
organization with information and requests. Public outreach staff should be
available for discussion and information when visitors come.
Unsolicited information can be very helpful. First, it can provide an idea of
the level of public concern over a facility. Second, members of the public
often provide information that is essential to making good technical,
economic, and policy decisions. Local citizens often have the most
knowledge and insight about the conditions of the land and the people
surrounding a facility.
If interested people come to the office, they should be received by a staff
member who can relate well with the public and knows the overall mission
of your organization. If feasible, he or she should introduce the visitors to
members of the staff who can discuss specific issues. Staff people should
listen to the citizens' concerns and provide feedback where possible. They
should be candid when they do not know the answer to a question. They
should also be cordial, avoid jargon and overly technical language, and try
to solve the visitor's problem. (See the section on "Informal Meetings
With Other Stakeholders" in this Chapter for more information).
If citizens send a letter or call by phone, the receiving organization should
respond as soon as possible. If the response will be delayed, a
representative of the organization should write a letter or call to explain.
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When to Use
Accompanying
Activities
Advantages and
Limitations
The receiving organization should consider all relevant comments as
informal input into the permitting process and let citizens know how they
can submit formal comments.
Unsolicited information is a constant in community participation. You can
improve (or maintain) the credibility of your organization by giving due
weight to citizens' concerns and by replying promptly to citizen input.
Fact sheets, project reports, and other mailings can answer questions or
reply to citizen inquiries. Offer to put concerned citizens on the mailing
list. Consider holding an availability session , open house, or informal
meetings if you detect a high level of public interest.
A good outreach program can increase your organization's credibility.
Unsolicited information can alert you to issues of high public concern and
allow you to identify involved groups in the community. Visitors to your
organization can get to know the staff, while the staff gains a better
understanding of the visitors' concerns.
Unsolicited information is, at best, a supplement to more formal
information-gathering. It may be misleading since it does not always
reflect the overall level of public concern. Good handling of unsolicited
information takes good communication and cooperation within your
organization.
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Checklist for Unsolicited Information and Office Visits
For office visits:
Appoint a member of your staff to act as a liaison for public visits
_ The liaison should answer questions and introduce stakeholders to members of your organization
who are involved in the issue
Invite visitors to put their names on your mailing list
_ Follow up quickly on any questions that you could not answer during the visit
For phone calls and written requests:
_ Keep a log of calls and letters from other stakeholders
Respond quickly to questions; inform the questioner if your response will not be timely
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Surveys and
Telephone Polls
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None.
If public participation is to be a dialogue, citizens need ways to provide
feedback to facilities, public interest organizations, and permitting
agencies. Surveys and polls are designed to solicit specific types of
feedback from a targeted audience, such as public opinion about a
permitting activity, the effectiveness of public participation activities, or
what could be done to improve distributed materials. Surveys may be
either oral or written; used in person or by mail; and distributed either to
specific segments of the community or to representative samples. We
discuss telephone polls in this section, but you may want to consider door-
to-door polling or other methods.
Facility owners may want to consider using surveys and polls during the
community assessment to gauge public sentiment about constructing or
expanding a facility, or as a complement to direct community interviews.
The permitting agency can use surveys and polls in a similar fashion,
especially during major projects and at facilities that raise controversy. The
agency, public interest groups, and the facility owner may also want to use
surveys and polls to find out if citizens are receiving enough information
about the RCRA activity and are being reached by public notices or other
outreach methods.
On-paper surveys distributed at meetings or by mail are relatively easy and
inexpensive, aside from postage. Surveys done in person or by telephone
can be very time-consuming.
To prepare for surveys or telephone polls:
1. Specify the information that you need to gather. Construct
specific questions to include in the survey or poll. For written
surveys, consider which questions should be multiple choice or
"check one box" ~ formats that people are more likely to answer.
Ensure that oral questions are not too long or confusing and be wary
of the factors that can bias your surveying method (e.g., the wording
of the question).
Survey questions do not have to be highly detailed in every case. You
may use surveys to allow people to submit general impressions after a
meeting or a hearing.
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Design the survey or poll. For written surveys, you should leave
plenty of room for people to write. Give clear instructions and
explain how you will be using the information. Always include the
name and number of a contact person. Provide multi-lingual surveys
where appropriate. Follow these same guidelines for oral surveys and
polls. For oral surveys, you may want to provide a business card to
the interviewee when your discussion is over
Distribute the surveys and questionnaires. As we mentioned
earlier, you may distribute written surveys in person or via mail. You
may also leave them for people to pick up after a meeting; or you may
decide to distribute them by hand to peoples' homes. If people will
need to mail the survey, consider including pre-stamped, pre-
addressed envelopes.
If you are seeking out specific information, you may want to
distribute the surveys to a representative sample of the community. In
some cases, you may want to do a "blanket" distribution to all homes
and businesses within a certain distance of the facility.
If you choose to do an oral survey, follow the information in the
section on "Community Interviews" earlier in this Chapter.
For telephone polls, you will have to decide whom to call and whether
you will address the poll to a random sample, a representative sample,
or a targeted segment of the community. If you are attempting one of
the latter two options, you may want to contact community leaders
and local officials to determine the demographics of the area.
When to Use ^se surveYs and telephone polls when:
you are seeking specific information from a targeted community or
audience; or
you are trying to provide people with a means of giving anonymous
feedback during the permitting process.
AcconiDanvins Always include the name and number of a contact person on a survey or a
. . . . questionnaire. Surveys and questionnaires can be useful for gathering
general impressions about specific permitting activities or public
participation events, such as availability sessions or public hearings.
They may also complement community interviews by allowing people,
who may have been uncomfortable or pressured during the interview, to
submit anonymous thoughts and comments.
Advantages and Written surveys and questionnaires are relatively inexpensive and simple
T . ., ,. ways to solicit information. They can provide feedback loops for many
Limitations .... .. ... , , , c _. U1 ... :,
permitting activities and some people may be more comfortable with the
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anonymity that written surveys can ensure. Oral surveys and polls allow
you to interact directly with members of the public and to solicit their
immediate feedback on permitting issues.
Surveys conducted in-person can be very time-consuming and expensive.
Written surveys may not present viewpoints that are representative of the
community because people who fill out the surveys tend to have stronger
feelings in favor, or against, the proposed activity. Surveys conducted by
mail have the additional weaknesses of undependable response rates and
questionable response quality.
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Checklist for Surveys and Telephone Polls
_ Determine what type of information is needed
Determine what format will work best for gathering the information
Written surveys:
Determine if you will need to provide the survey in a multilingual format or you will need to
provide for other special communication needs in the community (e.g., persons who are illiterate)
_ Prepare interview questions
Design the survey sheet; leave adequate writing room and make sure the instructions are clear and
easy to understand
_ Provide the name of a contact person on the survey
Decide how you will distribute the survey, based on the public participation plan, community
interviews, and background information on the facility and the community
Telephone polls or an oral surveys:
Identify a team to conduct the survey or the telephone poll
_ Identify how you will target the polling group
Consult a polling firm or a consultant if you are conducting your survey with a representative
sample
Determine if you need to conduct a multilingual poll or survey and whether there are other special
communication needs in the community (e.g., persons who are hearing impaired)
_ Prepare the questions for the poll or survey
Write a script you can use to give background information to people before the questions
_ When you conduct the survey, provide the name of a contact person, either over the phone, or by
handing out business cards in person
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Contact
Persons/Offices
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
EPA regulations require the permitting agency to designate a contact office
in most public notices. This requirement applies to draft permits, notices of
intent to deny a permit, and modifications initiated by the permitting
agency (§§ 124.10(d) and 270.41), as well as to the notice of application
submittal (§ 124.32(b)). In these cases, the permitting agency will also
provide a contact for the permit applicant. When a permit applicant holds a
pre-application meeting under § 124.31, the applicant must provide public
notice that includes a contact person for the facility. Similarly, the facility
must provide public notice, including a contact at the agency and the
facility, when requesting a Class 2 or 3 permit modification (§ 270.42 (b)
and (c)). Permitting agencies must also provide contacts and telephone
numbers (for the facility and the agency) during the trial burn stage at
permitted and interim status combustion facilities (§ 270.62(b) and (d);
270.66(d)(3) and (g)).
The contact person is a designated staff member who is responsible for
responding to questions and inquiries from the public and the media. Some
organizations may want to consider distributing lists of contact persons who
are responsible for answering questions in certain topic areas.
The amount of time that the contact person spends responding to citizen
concerns and questions will depend on the level of community interest in a
facility's permit or corrective action activities. A contact person may spend
a few hours a day responding to citizen inquiries if there is high to
moderate interest in the facility's RCRA activities.
For each permit or corrective action, designate a contact who will respond
to citizens' requests for information, answer their questions, and address
their concerns on any aspect of the permit or cleanup process. Although
permitting agencies are only required to designate a contact office,
specifying a person and keeping the same person as the contact throughout
the process may engender more public trust and confidence.
When a contact person is assigned:
1. Send out a news release announcing the contact person to all local
newspapers, radio stations, and television stations. Include the
contact person's telephone number and mailing address in all news
releases, fact sheets, and mailings. Include in publications a self-
mailer, which can be a separate flyer or a designated cut-a-way
section of the fact sheet that is addressed to the contact person and
leaves room for interested people to request more information or
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When to Use
Accompanying
Activities
Advantages and
Limitations
write their comments.
2. Give the name, address, and phone number of the contact person
to all involved staff in your organization and other stakeholders.
Let staff members know that the contact person may be approached
for information and that your staff should coordinate the release of
information with the contact person. Inform other stakeholders that
the contact person will be available for questions and information-
sharing.
3. Keep a log book of all citizen requests and comments received by the
contact person, and how each one was handled. This will help to
assure that incoming requests are not filed and forgotten. This log
book also provides another record of issues and concerns.
A contact person should be designated for every facility at the outset of the
RCRA process.
Designation of the contact person should be announced in news releases
and fact sheets, and public notices. The contact person also should be
responsible for making sure that the facility's information repository , if
required, is kept up-to-date.
A contact person can assure citizens that your organization is actively
listening to their concerns and can provide the community with consistent
information from a reliable source.
The contact person may not have the authority to resolve all of the concerns
raised by citizens and other stakeholders; his or her role may be limited to
providing information and facilitating communication between your staff,
citizens, and other stakeholders. If, for any reason, the identity of the
contact person changes, it is important to inform the community, media
contacts, and other stakeholders about this change quickly. You should
designate a replacement as soon as possible.
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Checklist for Contact Persons
Designate a contact person for the facility:
Notify media of the name, mailing address, and phone number of the contact person
Inform your staff and other stakeholders who are involved with the facility
Have contact person maintain a log book of all stakeholder requests and comments received
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Telephone Contacts
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
Accompanying
Activities
None.
Advantages and
Telephone contacts can be used to gather information about the community
and to update State and local officials and other interested parties on the
status of permitting or corrective action activities. See the section on
"Surveys and Telephone Polls" earlier in this Chapter for related activities.
Telephone contacts can be a time-intensive activity, depending on the
nature of the call. Allow several hours per call when gathering
information.
In making telephone contacts:
1. Know exactly what information to request or give out. Plan
carefully what you want to say or what information you would like to
obtain from these individuals. Refer to the section on "Community
Interviews" earlier in this chapter for information on how to conduct
these interviews.
2. Conduct telephone calls and take notes for your files.
Telephone contacts may be used:
• In the early stages of the RCRA actions to identify key officials,
citizens, and other stakeholders who have a high interest in the
facility;
• To gather information when face-to-face community interviews
are not possible;
• When new and time-sensitive material becomes available; and
• When there is a high level of community interest in the facility,
and it is important to keep key players informed.
Telephone contacts are usually made to arrange or conduct community
interviews, develop mailing lists and arrange for other public participation
activities such as news briefings, informal meetings , and presentations.
Telephone calls can be an inexpensive and expedient method of acquiring
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Limitations initial information about the facility. Once the initial information has been
gathered, telephone contacts are a quick means of informing key people
about facility activities and for monitoring any shifts in community
concerns.
Residents initially may feel uncomfortable discussing their concerns and
perceptions over the telephone with a stranger. Once residents have met
your staff in person, however, they may be more open and willing to
discuss their concerns during follow-up telephone calls.
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Checklist for Telephone Contacts
Initial telephone contacts:
_ Identify individuals to contact:
State officials
_ Local officials
Regulatory agency officials
_ Concerned citizens
_ Media
_ Environmental groups, civic organizations, public interest groups
Prepare information to discuss on telephone
_ Prepare questions for individuals to answer
Prepare information that you can give them
_ Keep a log book of information received/given
On-going contacts:
_ Maintain up-to-date telephone contact list
Prepare information to discuss on telephone before each set of calls
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Telephone Hotlines
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
None.
A hotline is a toll-free (or local) telephone number people can call to ask
questions and obtain information promptly about RCRA activities. Some
hotlines allow people to order documents.
The amount of time spent on the telephone hotline responding to citizen
concerns and questions will depend on the level of concern the community
has regarding the facility's permit or corrective action activities. You may
spend several hours a day responding to inquiries if there is high to
moderate interest in the facility's RCRA activities.
To install a telephone hotline, either as a semi-permanent fixture (available
throughout the permit review or corrective action process) or as a
temporary measure (installed at the time of major community feedback,
such as the public comment period):
1. Assign one or more staff members to handle the hotline calls.
Consider installing more than one line to minimize busy signals. If
staff are not available throughout the day, install an answering
machine directing people to leave their name, number, and brief
statement of concern, and informing them that someone in your
organization will return their call promptly. If a voice mail system is
available, provide information on commonly requested information
such as meeting dates and locations and the permit status. Check the
answering machine for messages at least once a day. If the level of
concern is high, check for messages more frequently.
2. Announce the telephone hotline in news releases to local
newspapers, radio stations, and television stations, and in fact sheets,
publications, and public notices.
3. Keep a record of each question , when it was received, from whom,
and how and when it was answered. All questions and inquiries
should be responded to promptly (within 24 hours) if an answer
cannot be given immediately. Be diligent in following up requests for
information and tracking down accurate, direct responses.
A telephone hotline may be used:
• When community interest or concern is moderate to high;
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When emergencies or unexpected events occur, or when a
situation is changing rapidly;
When there is a high potential for complaints (e.g., about dust or
noise);
Where literacy rates are low and written information must be
supplemented; and
Where the community is isolated and has little opportunity for
face-to-face contact with project staff (e.g., rural areas, areas far
from Regional offices).
Accompanying The hotline can supplement all other public participation activities.
Activities
Advantages and A hotline can provide interested people with a relatively quick means of
T imitations expressing their concerns directly to your organization and getting their
questions answered. This quick response can help reassure callers that their
concerns are heard. A telephone hotline also can help monitor community
concerns. A sudden increase in calls could indicate that additional public
participation efforts may be warranted.
You must respond quickly to questions or concerns; otherwise callers may
become frustrated. If the number of calls is large, responding quickly to
each inquiry could prove burdensome to your staff. Furthermore, dialing a
hotline number and receiving a recorded message could irritate or alienate
some members of the public.
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Checklist for Telephone Hotlines
Determine need for telephone hotline
_ Identify staff responsible for answering calls
Have staff maintain a log of all calls and responses
Install telephone hotlines/answering machines
Notify interested people about the hotline
_ Public notice
Fact sheet
Mailing to facility mailing list
Coordinate staffing of hotline
_ Follow-up on calls to hotline
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On-Scene
Information Offices
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
None.
An on-scene information office is a trailer, small building, or office space
on or near the facility site, depending on what is more convenient and
accessible for the affected community. The office is staffed by a full-time
or part-time person(s) who responds to inquiries and prepares information
releases.
An on-scene information office is a time-intensive activity. You may have
staff in the office up to 40 hours a week. Short Cut: Hire a contractor to
staff the office; however, always ensure that a representative is there for
some specified period during the week.
To provide an on-scene information office:
1. Establish the office. You may have to rent a trailer, arrange with the
owner of the facility to designate space in the facility, or rent office
space in a town to be used as an office and launching area. If you will
be establishing the office off-site, then you should find an area in the
vicinity of the facility or in the nearest town or village.
2. Install a telephone and an answering machine to respond to inquiries
and publicize the number in local newspapers and your public
participation publications.
3. Assign someone to staff the office. Establish regular hours,
including some during the weekend and weekday evenings. Publicize
the trailer's hours and the services it offers.
4. Equip the office with the same materials normally contained in an
information repository, if possible. At a minimum, include key
documents and summaries of other documents that are not available.
Provide a copy machine so that the public can make copies of
documents in the information repository.
An on-scene information office may be used:
• When community interest or concern is high;
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Accompanying
Activities
Advantages and
Limitations
• During corrective actions;
• When cleanup involves complex technologies or processes;
• When the community perceives a high level of risk to health;
• When activities may disrupt the area surrounding the facility
(e.g., traffic patterns); and
• When the area near the facility is densely populated.
The on-scene staff person can conduct meetings and question and answer
sessions to inform citizens about the status of the corrective actions or other
facility operations. Staff may also prepare and distribute fact sheets and
newsletters to local residents, conduct facility tours, and support the
telephone hotline. With the telephone contacts they make, they can add
to and update mailing lists and revise public participation plans . An on-
scene information office may also be a good location for the information
repository.
Individuals staffing an on-scene information office for an extended period
of time will necessarily have a special role in the community. Involvement
in other public participation activities may represent a large part of their
function. In addition to distributing information to local residents, on-site
staff may be responsible for maintaining data bases of residents' addresses,
the status of access to property, and a daily log of inquiries. It is important
that on-site staff monitor public perceptions and concerns daily. On-scene
staff often can make useful recommendations regarding stakeholder
concerns. Finally and perhaps most importantly, on-site staff members will
frequently serve as a liaison with the public.
An on-scene information office can be an effective activity for ensuring
that other stakeholders are adequately informed about permitting activities
and that their concerns are addressed immediately.
An information office can be very expensive since it requires, at a
minimum, a part-time staff person and a telephone. Hence, it should be
used only when community concerns are currently high or may be high in
the future.
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Checklist for On-Scene Information Offices
Determine need for an on-scene information office
Identify staff to work in information office
Rent a trailer or office space for the information office
_ Equip the office with a telephone, office equipment (i.e., copier), and all materials contained in
an information repository.
Notify interested people of availability of on-scene information office
Public Notice
Fact sheet
Mailing to facility mailing list
Maintain on-scene information office
_ Have staff conduct the following:
Maintain the mailing list
Review media coverage
_ Respond to calls from citizens and stakeholder groups
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Question and
Answer Sessions
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
Accompanying
Activities
None.
A question and answer session makes knowledgeable staff available to
stakeholders to discuss permitting and corrective action issues. Question
and answer sessions typically accompany a presentation, briefing, or
meeting. Anyone at the event who needs more information will have the
opportunity to speak with officials after the event. These sessions can be
informal or formal.
Answering questions will add a small amount of staff time to other public
participation activities.
To conduct a question and answer session:
1. Announce that someone will be available for questions after the
event. Pick an area where people can meet a knowledgeable staff
person for questions and answers.
2. Be responsive, candid, and clear. Ensure that all questions are
answered. If staff cannot answer the question on the spot, they should
not be afraid to say "I don't know" and offer to answer the question
after getting more information. The staffer should write down the
question, discuss it with other staff, and respond - as soon as possible
- by phone or letter. Try to avoid using jargon that people will not
understand.
3. Consider brainstorming ahead of time to develop potential
questions and to prepare responses.
Question and answer sessions are appropriate whenever people at an event
need more information or the presenting organization needs more feedback.
Question and answer sessions are also appropriate when people may feel
more comfortable asking questions in a one-on-one situation. If a
particular issue, raised by one person at a meeting, is preventing other
issues from making the floor at a meeting, you may want to offer to discuss
the issue one-on-one after the meeting.
Hold question and answer sessions after exhibits, presentations, meetings,
facility tours, or on observation decks . Some events, such as open
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houses, have built-in question and answer sessions. In responding to
inquiries, you may want to provide written information, such as fact sheets,
or refer the questioner to a contact person .
Advantages and Question and answer sessions provide direct communication between your
T . . . organization and citizens. They are a useful, easy, and inexpensive way of
Limitations ... , '. • • c , ^ • Z
providing one-on-one explanations in an informal setting. One-on-one
discussions may attract people who are intimidated from raising issues
during a meeting. Such interactions may also increase public comfort and
trust in your organization.
Citizens may not be pleased if you cannot answer a question on the spot;
they will certainly not be pleased if your response is slow. Be sure to
respond to all unanswered questions as soon as you can.
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Checklist for Question and Answer Sessions
Brainstorm potential questions and prepare responses
If you are planning a Q&A session after a meeting or other event, let people know where it will
be held by mentioning it during the meeting
Be candid and avoid jargon in your answers. If you cannot answer a question, take the
questioner's phone number or address and respond to the question as soon as you can.
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Information Tables
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
None.
Information tables are simple public participation tools that you can use to
interact with interested stakeholders. An information table consists of a
table or booth set up at a meeting, hearing, or other event (e.g., a
community fair or civic gathering). It is staffed by at least one member of
your organization who is available to answer questions. Pamphlets, fact
sheets, and brochures are available on the table, along with a sign-up sheet
for interested people to add their names to the facility mailing list.
This activity is time-intensive, with at least one staff person staying at the
table during the entire event. The information table is less of a drain on
other resources since the materials should already be available.
To prepare for an information table:
1. Learn from community interviews which local events are most
frequented by citizens during the year.
2. Decide whether the table will be sufficient to address community
concerns. The information table may not be effective in highly-
charged environments.
3. Set up the table. Include important fact sheets, answers to common
questions, general descriptions of the RCRA program, contact names,
and hotline numbers. Allow people to sign up for the facility mailing
list. Use exhibits if appropriate.
Use information tables when:
• You need to provide a feedback loop after a public event;
• The RCRA activity has raised significant public interest or technical
issues may raise many questions among the public;
• You are gathering names for the facility mailing list;
• A local event, where tables are available, will attract a significant
portion of the community.
Information tables may be useful in connection with a public hearing or
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Accompanying
Activities
Advantages and
Limitations
meeting. EPA recommends using information tables as part of availability
sessions and open houses. Fact sheets, newsletters, project reports and
other information should be available at the table. People who come to the
table should have the opportunity to sign up for the mailing list. Exhibits
and diagrams can be helpful for explaining the process or technical issues.
Provide the name of a contact person (or a list of contact people) for
interested people to take with them. Information tables provide a good
opportunity to distribute questionnaires and surveys.
An information table can provide a feedback loop that complements other
events in the permitting process. Information tables at availability sessions
and open houses can provide a comfortable way for people to approach
project staff and ask questions. At county fairs or other events, they allow
project staff to interact with the community and spread information about
important permitting activities.
People who approach the information table may ask questions that staff
cannot answer. To avoid any negative reactions, staff should record the
question and contact the person with an answer by a certain date.
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Checklist for Information Tables
(As appropriate):
Determine a location for the information table
_ Facility name, location
Contact person at location
_ Confirm availability of location for information tables
Discuss guidelines for information tables with the event planner
_ Assign staff to cover the information table
Collect materials for the information table
_ Table and chairs
Table skirt
_ A sign that identifies your organization
Exhibits, time-lines, surveys
Mailing list sign-up sheet
Name tags for your staff
_ Pens and notepads
Fact sheets, reports, pamphlets, and other documents that people can take
_ Business cards with the name of a contact person at your organization
Reference documents for your use
_ Keep a record of comments and questions for your files
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Informal Meetings
with Other
Stakeholders
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None. (This type of informal meeting is distinct from the pre-application
meeting required under § 124.31 (and discussed under "Public Meetings" in
this Chapter) which EPA has stated should be an informal discussion open
to the public).
Informal meetings are meetings your organization holds with individual
stakeholder groups that have particular interest in a permitting activity.
These meetings are held in an informal setting, such as a resident's home or
a local meeting place. Informal meetings allow interested citizens and
local officials to discuss issues and concerns. Staff responsible for the
facility receive first-hand information from interested community
members, special interest groups, and elected officials, while citizens have
the opportunity to ask questions and explore topics of interest regarding the
facility in question.
Public meetings, which are distinct from public hearings, are a special
form of informal meetings where the entire community can participate.
Public meetings allow all interested parties to discuss issues regarding the
facility with each other as well as the regulatory agency. Public meetings
can be especially useful for allowing discussion before a public hearing and
can be scheduled immediately before the hearing. Comments made during
a public meeting do not become part of the official administrative record as
they do during a hearing. (See the sections on "Public Meetings" and
"Public Hearings" in this Chapter for more details.)
An informal meeting will take two to three days to plan and conduct. This
includes about three hours to set up and schedule the meeting, five hours
for preparation, four hours to conduct the meeting, and four hours to follow
up on any issues raised during the meeting.
To conduct informal meetings:
1. Identify interested citizens and officials. Contact each group and
local agency that is directly affected by the facility, or contact
individuals who have expressed concern regarding the facility.
Interested citizen/public interest groups may also want to contact the
agency or the facility to set up a meeting. Offer to discuss the permit
or corrective action plans at a convenient time, taking into
consideration the following elements that will affect levels of
community interest and concern: for facilities at which emergency
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actions are required, schedule the meeting after the agency has
accurate information to share with the participants; for a corrective
action, determine first when community concerns may be highest and
schedule meetings accordingly. For instance, it may be appropriate to
hold an informal meeting when the risk assessment report is released.
Holding informal meetings early in the permit process can help
prevent potentially volatile situations from developing by providing
citizens with one-on-one attention.
2. Limit attendance. To increase effectiveness, restrict attendance to
between five and 20 individuals or specify attendance by invitation
only. The larger the group, the less likely it is that some people will
candidly express their concerns. It is difficult to establish rapport
with individuals in a large group. If a greater number of stakeholders
are interested, you should schedule additional small meetings. If a
greater number of participants appears than are expected at an
informal meeting, divide the group into smaller groups to allow more
one-on-one discussion to take place.
3. Select a meeting date, time, and place convenient to attendants.
The meeting place should have chairs that can be arranged into a
circle, or some other informal setting conducive to two-way
communication. A private home, public library meeting room,
community center, or church hall may be more likely to promote an
exchange of ideas than a large or formal public hall. When
scheduling the meeting, make sure that the date and time do not
conflict with other public meetings that citizens may want to attend,
such as town council meetings, or with holidays or other special
occasions. Permitting agencies should be sure that the meeting
location does not conflict with state "sunshine laws." In selecting a
public meeting place, be attentive to the special needs of handicapped
individuals (e.g., access ramps or elevators). Be aware that meetings
will frequently have to be scheduled during evening hours to
accommodate work schedules.
4. Begin the meeting with a brief overview. This short presentation
should include a summary of the permit review schedule and how
stakeholders can be involved in the decision. These opening remarks
should be kept brief and informal (no more than a few minutes) to
allow maximum opportunity for open discussion with meeting
attenders. Cover whatever topics the public is interested in
discussing, these may include:
• Extent of the activity;
• Safety and health implications;
• Factors that might speed up or delay the regulatory and technical
process; and
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• How community concerns are considered in making decisions
on permits and corrective actions.
5. Identify the regulatory decision-makers (major agencies and
individuals responsible for enacting and enforcing RCRA
regulations.) Citizens and other stakeholders will then know where to
direct further questions or voice new ideas or suggestions.
6. Gear the discussion to the audience. Be sensitive to the level of
familiarity that the citizens have with the more technical aspects of
the activities discussed.
7. Listen and take notes. Find out what the meeting attendees want
done. Some concerns may be addressed by making minor changes in
a proposed action. Discuss the possibility for accommodating these
concerns or explain the reasons why citizen requests appear to be
unworkable or conflict with program or legal requirements.
8. Promptly follow-up on any major concerns. Stay in touch with the
groups and contact any new groups that have formed, so that new or
increasing concerns can be dealt with before problems develop.
9. Write up brief minutes for your files.
When to Use Informal meetings can be used:
When there is widely varying level of knowledge among
community members;
When the level of tension is high and large meetings may not be
appropriate;
When the community needs more personal contact to have trust
in your organization or the process;
When groups want to discuss specific issues in which the
community as a whole isn't interested.
Accompanying Community interviews or calls to telephone contacts usually precede
A rtivitipQ these meetings, since it is during these interviews that concerned citizens
groups are identified and contacted. Possible meeting locations also can be
identified during the community interviews.
Distributing fact sheets at these meetings also may be appropriate,
depending on when they are held.
Advantages and The primary benefit of informal meetings is that they allow two-way
interaction between citizens, local officials, the permitting agency, and the
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Limitations facility. Not only will citizens be informed about the developments, but the
facility owner/operator and officials responsible for the site can learn how
citizens view the site.
Informal meetings also add a personal dimension to what might otherwise
be treated as a purely technical problem. Informal meetings offer citizens,
facility staff, and officials a chance to increase their familiarity with how
the process works, increase awareness of each other's point of view, and
actively promote public participation. Informal meetings also may diffuse
any tension between stakeholders.
Some groups may perceive your efforts to restrict the number of attenders
as a "divide and conquer" tactic to prevent large groups from exerting
influence on potential actions and to exclude certain individuals or groups.
One way to prevent this perception is to hold informal meetings with those
organizations who express concern about being left out of the process.
Irate groups or individuals also may accuse your staff of telling different
stories to different groups at these small meetings. You can avoid this
criticism by inviting a cross-section of interests to each small meeting or by
having a large public meeting. Alternatively, you can keep a written record
of the informal discussions and make it available upon request or include it
in the information repository. A record of discussions is required for any
legally-required meetings held during the public comment period.
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Checklist for Informal Meetings with Other Stakeholders
Determine purpose of meeting
Determine number of attenders:
Determine location(s) for meeting (complete for each available facility)
_ Facility name, location
Contact person at facility
Phone number
Occupancy size
_ Handicap accessibility
Features:
Restrooms
_Public telephones
_Adequate parking
Determine date, time of meeting:
Date:
Time:
_ Identify interested citizens and officials
Contact citizen groups, invite a representative to the meeting
_ Prepare meeting agenda
Overview of project
_ Identify decision-makers
Allow time for discussion, question/answers
_ Follow-up
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Public Meetings
Regulatory
Requirements
Description of Activity
Level of Effort
The pre-application meeting that a permit applicant is required to conduct
under § 124.31 is a type of public meeting, though it need not be restricted
to the type of meetings described in this section. In some cases, different
meeting formats will fulfill the requirements (see "The Pre-Application
Meeting" in Chapter 3). Permit holders are also required to hold public
meetings when requesting a class 2 or 3 permit modification under §
270.42(b) or (c).
Public meetings are not public hearings . Public hearings are regulatory
requirements that provide a formal opportunity for the public to present
comments and oral testimony on a proposed agency action. Public
meetings, on the other hand, are less formal: anyone can attend, there are
no formal time limits on statements, and the permitting agency and/or the
facility usually answers questions. The purpose of the meeting is to share
information and discuss issues, not to make decisions. Due to their
openness and flexibility, public meetings are preferable to hearings as a
forum for discussing complex or detailed issues.
Public meetings sometimes complement public hearings. Public meetings
can be especially useful for allowing discussion before a public hearing and
can be scheduled immediately before the hearing ( workshops, see below,
can also fulfill this need). Comments made during a public meeting do not
become part of the official administrative record as they do during a
hearing. Public meetings provide two-way communication, with
community members asking questions and the permitting agency providing
responses. Unlike the activity in the section above ("Informal Meetings
with Other Stakeholders"), public meetings are open to everyone.
While public meetings are usually called and conducted by the permitting
agency (e.g., before public hearings) or the facility (e.g., during permit
modification procedures), it is common for civic, environmental, and
community organizations to hold public meetings where ideas can be
discussed freely.
EPA's regulations require several specific public meetings. Section 124.31
calls on prospective permit applicants to announce and hold an informal
public meeting prior to submitting a permit application. The permitting
agency is not required to attend the meeting. See Chapter 3 for more
information about the pre-application meeting. Permittees are required to
hold public meetings when requesting a class 2 or 3 modification under §
270.42.
While a public meeting should require less planning than a public hearing,
it may take several days to a week to arrange the location and logistics. See
Chapter 5: Public Involvement Activities
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the "Public Notice" section above in this chapter to determine the resources
you will need to announce the meeting. Other activities include preparing
and copying materials for distribution. You may be able to distribute some
of the same materials at the meeting and the public hearing (if applicable).
How to Conduct the ^° ^°^ a Pu^nc meeting, you will follow many of the same steps as for a
. . . public hearing (see Chapter 3 for specific guidance regarding pre-
^ application meetings under § 124.31):
1. Anticipate the audience and the issues of concern. Identify the
audience's objectives, expectations, and desired results. With this
information you will know what topics to spend time on and what
materials and exhibits to provide. If a part of your audience does not
speak English, arrange for a translator.
2. Schedule the meeting location and time so that citizens (particularly
handicapped individuals) have easy access. Ensure the availability of
sufficient seating, microphones, lighting, and recorders. Hold the
meeting at a time and place that will accommodate the majority of
concerned citizens.
3. Announce the meeting at least 30 days before the meeting date.
Provide notice of the hearing in local newspapers, broadcast media,
signs, and mailings to interested citizens (you can find requirements
for pre-application meetings in § 124.31(d)). Choose communication
methods that will give all segments of the community an equal
opportunity to participate. Use multilingual notices where
appropriate. Make follow-up phone calls to interested parties to
ensure that the notice has been received. Provide the name of a
contact person.
4. Make relevant documents available for public review. If you are a
permittee requesting a class 2 or 3 permit modification, you must
place a copy of the modification request and supporting documents in
a location that is publicly accessible and in the vicinity of the facility
(see § 270.42(b)(3) and (c)(3)). Announce the location in the public
notice for the meeting. For other public meetings, you should
consider making important documents available prior to the meeting.
5. Provide an opportunity for people to submit written questions
and comments. Not all individuals will want, or be able, to attend
the meeting. Announce in public notices and mailings that written
comments and questions can be submitted to the contact person. You
may want to raise some of these written comments and questions at
the public meeting.
6. Post a sign-up sheet so that attendees can voluntarily provide their
names and addresses. If you are a permit applicant holding a pre-
application meeting under § 124.31, you can use this sheet to produce
ChapterS: Public Involvement Activities Page 5-118
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When to Use
Accompanying
Activities
Advantages and
Limitations
and submit an attendee list as part of your part B application (as
required under § 124.31© and § 270.14(b)(22)). The permitting
agency will use the attendee list to help generate the facility mailing
list.
7. Take notes about the major issues of concern and prepare a
summary of all oral and written comments. If you are a permit
applicant holding a pre-application meeting under § 124.31, you must
submit a summary of the meeting as part of your part B permit
application (as required under § 124.31© and § 270.14(b)(22)). For
other public meetings, you should make a summary available for
public review and announce where it is available.
Some permitting agencies have had success in holding public meetings
prior to a public hearing. Public hearings are often "staged" events with
little opportunity for new input or discussion. Some participants have
criticized them as opportunities for grandstanding. Public meetings, on the
other hand, allow interested parties to ask questions and raise issues in an
informal setting. A public meeting can provide a useful means of two-way
communication at any significant stage during the permitting or corrective
action process.
If you are a permit applicant required to hold a pre-application meeting
under § 124.31, the public meeting format is one option you can use. Refer
to the discussion in Chapter 3 for more information.
Provide public notice of the meeting and designate a contact person.
Fact sheets and exhibits can inform people about permitting issues at
public meetings. You may also consider establishing an information table
where people who may feel uneasy speaking during the meeting can ask
questions and pick up materials. Another option is to make your staff
available after in the meeting, in the same manner as an availability
session or an open house. Information repositories can complement the
meeting by making important documents available for public review.
A public meeting provides a forum where interested people can ask
questions and discuss issues outside of the formality of a public hearing.
They are flexible tools that are open to everyone.
Some citizens may be reluctant to speak up at public meetings. You can
address this concern by providing one-on-one access to your staff via an
information table or an open house, or by scheduling informal meetings.
Public meetings, like public hearings, could become adversarial.
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Checklist for Public Meetings
(As applicable):
Determine location for public meeting
_ Facility name, location
Contact person at location
Phone number
Occupancy size
_ Handicap accessibility
Features:
Restrooms
_ Public telephones
Adequate parking
Security
_ Determine date, time of public meeting:
Date:
Time:
_ Confirm availability at location (if location is not available, determine new location or new date)
Announce the public meeting. (Pre-application meetings under § 124.31 must be announced
through a display advertizement in a newspaper of general circulation, over a broadcast medium,
and through a sign posted on or near the site of the facility or proposed facility).
Contact local officials
_ Notify key agencies and other stakeholder groups
Provide an opportunity, in the notice, for people to submit written comments
_ Determine whether a translator is needed
Determine presentation requirements (depending upon the specific requirements of your
presentation, some of these items may be optional)
_ Electrical outlets
Extension cords
Chapter 5: Public Involvement Activities Page 5-120
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Checklist for Public Meetings (continued)
_ Accessible lighting control panel
Podium
_ Stage
Table(s) and chairs for panel
_ Table skirt
Sign-up sheet for the mailing list. (If you are conducting a pre-application meeting under §
124.31, you are required to provide a sign-up sheet or another means for people to add their
names to the facility mailing list. You must provide the sheet to the permitting agency as a
component of your part B permit application).
Water pitcher and glasses
_ Sound system
Microphones (stand, tabletop)
_ Cables
Speakers
Technician/engineers available for hearing
Visual aids
_ Slides
Slide projector
_ Extra projector bulbs
Flip chart
_ Flip chart markers
Overhead transparencies
_ Overhead machine
VCR and monitor
_ Screen
Table for projection equipment
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Checklist for Public Meetings (continued)
_ Security personnel (if necessary)
Table for meeting recorder (who will produce a meeting transcript or summary)
_ Registration table
Registration cards
Writing pens
Signs
_ Miscellaneous supplies:
Scissors
_ Tape (masking, transparent)
Thumbtacks
_ Public information materials (fact sheets, etc.)
Prepare meeting agenda. (Facility owners/operators conducting a pre-application meeting under
§ 124.31 should refer to chapter 3 of this manual for information on the subjects they should
cover during the meeting).
Arrange contingency planning. Decide what to do if:
• more people show up than capacity
• equipment malfunctions
Prepare the meeting summary/transcript and make it available to the public. (Facility
owners/operators conducting a pre-application meeting under § 124.31 must provide the summary
to the permitting agency as a component of the part B application).
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Public Hearings
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
Public hearings are required if requested (§ 124.11) by the public during the
draft permit stage, during an agency-initiated modification under § 270.41,
or a Class 3 permit modification under § 270.42(c)(6). The agency will
also hold a public hearing at the draft permit stage when there is a high
level of public interest (based on requests), or when the agency thinks that
the hearing might clarify relevant issues (§ 124.12). The agency will also
hold a hearing if these conditions apply during closure or post-closure at
interim status facilities (§§ 265.112(d)(4) and 265.118(f)).
Public hearings provide an opportunity for the public to provide formal
comments and oral testimony on proposed agency actions. Occasionally
the agency will present introductory information prior to receiving
comments. All testimony received becomes part of the public record.
In contrast to a public hearing, a public meeting (see above in this
Chapter) is intended to provide two-way discussion and is not always
recorded for the public record.
Permittees and facility staff have no official role during a hearing. The
hearing is a regulatory requirement of the permitting agency.
Several days to a week may be required to arrange for a public hearing,
including the location, hearing logistics, and agenda preparation. Other
activities include preparing the notice for the hearing, conducting a dry-run
of the hearing, and preparing and copying materials.
To conduct public hearings:
1. Anticipate the audience and the issues of concern. Identify the
audience's objectives, expectations, and desired results. With this
information you can determine whether the hearing is likely to be
confrontational, or if the audience will need more detailed
information about a permit or corrective action. If a part of your
audience does not speak English, arrange for a translator.
2. Schedule the hearing location and time so that citizens (particularly
handicapped individuals) have easy access. Identify and follow any
procedures established by the local and state governments for public
hearings. Ensure the availability of sufficient seating, microphones,
lighting, and recorders. Hold the hearing at a time and place that will
accommodate the majority of concerned citizens.
3. Arrange for a court reporter to record and prepare a transcript of
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the hearing.
4. Announce the public hearing at least 30 days before the hearing
date. Provide notice of the hearing in local newspapers and mailings
to interested citizens. Under § 124.10(b), you may combine the
hearing notice with the draft permit notice. Make follow-up phone
calls to interested parties to ensure that the notice has been received.
5. Provide an opportunity for people to submit written comments.
Not all individuals will want to provide oral testimony. Publicize
where written comments can be submitted and how they will be
reviewed.
6. Prepare a transcript of all oral and written comments. Announce
where the transcript will be available for public review.
The following are general tips on conducting public hearings:
Be clear and up front with meeting format and logistics. Public
hearings are very limited in the amount of information that is exchanged
and the extent to which responses are given. Participants should not expect
the question and answer format found in public meetings.
Establish meeting format. Public hearings should be managed by a
hearings officer or moderator, whose responsibility it is to ensure that all
comments are taken for the public record.
• Establish a speakers list. A moderator should develop a list of
speakers from the list of respondents to public notices (e.g., those
responding to a notice saying, "those wishing to be placed on the list
of commenters should contact...") and/or by asking those wishing to
speak to identify themselves on a sign-up list on the way into the
hearing. While limiting commenters to a pre-developed list may be
inappropriate, such lists serve as valuable management tools in
bringing forward commenters in an orderly and expeditious manner.
• Establish time limits for commenters . A moderator should establish a
set time limit for an individual to make comments. Typically the
limit is five minutes or less. Those wishing to make more detailed
comments should be encouraged to submit their comments in writing.
• Establish time limits (if any) for the hearing . Based on your speakers
list, and assuming a limited speaking time for individual commenters,
the moderator may establish time limits (if any) on the hearing. Most
hearings last between two and five hours. However, for very
controversial topics, public hearings have been known to extend over
a period of days.
• Interacting with commenters . Because comments become part of the
public record, the moderator should ask all commenters to give their
Chapter 5: Public Involvement Activities Page 5-124
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When to Use
names and addresses. If there is doubt about spelling, the moderator
should ask the commenters to spell names or street names. In cases
where there may be litigation, it is common practice to further request
that anyone legally representing any party as part of the permit
process or decision identify that fact.
When giving the floor to a commenter, the moderator should also note
the person's name, so that he/she can thank the commenters by name
at the conclusion of the comment (e.g., "Thank you for those
comments, Ms. Smith.").
Speakers from the permitting agency . There are no set rules for who
should participate or speak at a public hearing. In the spirit of the
law, the participants from the agency should be those who will be
most involved with making the actual decision ~ that is, the permit
writer, and senior staff who will weigh all information, including
these public comments, prior to reaching a final decision. Speakers
from the agency should be limited to explaining briefly the decision
being made (e.g., "We are here to discuss a proposed modification to
the facilities permit to conduct the following activities...").
When requested by a member of the public during a public comment
period on a permit, closure, or corrective action. Once requested,
hearings require a minimum 30-day advance notice.
Public hearings are usually conducted during the public comment
period following the issuance of a draft permit, major permit
modification, or at the selection of a proposed corrective measure.
Public hearings may be appropriate at other times during the process,
especially if the level of community concern warrants a formal record
of communication.
Accompanying
Activities
Public notices distributed to the mailing list and published in local
newspapers are used to announce hearings to the public. If a hearing is
held to solicit comments on either a draft permit decision or proposed
corrective measure, the agency must prepare a response to comments .
The response to comments documents all submitted public comments and
includes the agency's responses. An educational workshop or public
meeting may be useful shortly before the public hearing to explain key
issues of the proposed decision or corrective measure and respond to citizen
concerns.
Advantages and
Limitations
A hearing provides a record of communication so citizens can be sure that
their concerns and ideas reach the permitting agency. Public hearings gen-
erally should not serve as the only forum for citizen input. They occur at
the end of a process that should have provided earlier public access to
information and opportunities for involvement. Earlier opportunities
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should answer most questions and arguments that are based on curiosity,
emotion, sensationalism, or a lack of knowledge about the situation, thereby
freeing the hearing for factually-based questions. Meet citizens' needs for
information before a formal hearing with techniques such as fact sheets,
small-group meetings, and one-on-one briefings.
The formality of a public hearing often creates an atmosphere of "us versus
them." There may be little opportunity to interact with citizens. This may
be frustrating to some; however, informal gatherings and question and
answer sessions are often effective ways to interact with the public on an
interpersonal level. A variety of informal techniques, ranging from talking
to citizens groups to holding workshops, are discussed throughout this
chapter.
Public hearings can easily become adversarial. One way to avoid hostility
or confrontation is to make sure the community has had an opportunity to
express concerns in a less formal setting prior to the hearing. More
frequent contact with concerned citizens before a formal public hearing will
reduce the likelihood of a confrontation.
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Checklist for Public Hearings
(As appropriate):
Determine location(s) for public hearing
_ Facility name, location
Contact person at facility
Phone number
Occupancy size
_ Handicap accessibility
Features:
Restrooms
_ Public telephones
_ Adequate parking
Security
Determine date, time of public hearing:
Date:
Time:
Confirm hearing facility availability (if facility not available, determine new facility or new
hearing date)
_ Announce the public hearing through a public notice in at least one newspaper 30 days prior to
the hearing
Contact local officials
_ Notify key agencies
Determine presentation requirements (depending upon the specific requirements of your
presentation, some of these items may be optional)
_ Electrical outlets
Extension cords
_ Accessible lighting control panel
Chapter 5: Public Involvement Activities Page 5-127
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Checklist for Public Hearings (continued)
_ Podium
Stage
_ Table(s) and chairs for panel
Table skirt
_ Water pitcher and glasses
Sound system
_ Microphones (stand, tabletop)
Cables
_ Speakers
Technician/engineers available for hearing
_ Visual aids
Slides
_ Slide projector
Extra projector bulbs
_ Flip chart
Flip chart markers
_ Overhead transparencies
Overhead machine
VCR and monitor
Screen
_ Table for projection equipment
Security personnel
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Checklist for Public Hearings (continued)
_ Table for court reporter
Registration table
_ Registration cards
Writing pens
_ Signs
Miscellaneous supplies:
_ Scissors
Tape (masking, transparent)
_ Thumbtacks
Public information materials (fact sheets, etc.)
Prepare meeting agenda
Determine hearing participants/speakers
Prepare opening comments for hearing officer
_ Arrange contingency planning, decide what to do if:
• more people show up than capacity
• the crowd becomes disruptive
_ Coordinate with public involvement coordinator on notification of the media
Set date and time for debriefing following the hearing
Chapter 5: Public Involvement Activities Page 5-129
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Availability
Sessions/Open
Houses
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
None. (In some cases, an availability session or an open house may fulfill
the pre-application meeting requirement under § 124.31, as long as the
meeting achieves the standards of that section. See "The Pre-Application
Meeting" in Chapter 3 for more detail.)
Availability sessions/open houses are informal meetings in a public location
where people can talk to involved officials on a one-to-one basis. The
meetings allow citizens to ask questions and express their concerns directly
to project staff. This type of gathering is helpful in accommodating
individual schedules.
Availability sessions and open houses can be set up to allow citizens to talk
with representatives from all interested organizations. Citizens can find out
more about all sides of a permitting issue through conversations with
agency officials, facility staff, and representatives of involved interest
groups and civic organizations.
An availability session/open house may take two to three days to plan and
conduct. Allow sufficient time to select a date, time, and location for the
meeting, plan for the session, prepare supporting materials, and meet with
and brief your staff who will attend the meeting. You should plan for about
five hours for the actual session.
To conduct an availability session/open house:
1. Select a date, time, and location for the availability session/open
house that encourages attendance. Evening hours usually are
preferable. The location should be in an easily accessible building
familiar to residents (such as a public library, school, or local meeting
room).
2. Anticipate the number of attenders and plan accordingly. If a
large number of people is expected, consider the possibility of holding
two availability session/open houses to enable staff to meet and talk
with each attender. Alternatively, you can increase the number of
staffer the length of the availability session/open house. As a general
rule, planning for one staff member per 15-20 attenders should foster
an informal atmosphere for conversation, and thereby avoid the
situation where a staff member has to speak to a "crowd."
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3. Develop or gather together appropriate explanatory materials.
These materials may include poster boards, handouts, or fact sheets.
4. Publicize the availability session/open house at least two weeks
ahead of time, if possible. Send announcements to newspapers,
television and radio stations, citizens on the mailing list, and any
interested community organizations that publish newsletters.
5. Ensure that appropriate staff attend, so that citizens can meet
those who will be responsible for facility activities. The staff present
should be able to answer both technical and policy questions.
6. Meet with and brief staff and rehearse for the session. Anticipate
questions that may be asked during the session and prepare answers.
When to Use An availability session/open house is most appropriate:
• When scheduling of meetings is difficult because of community
members' schedules;
• When new information is available on several different
technical or regulatory issues that would make explaining it in
its entirety would be too long for a more formal meeting;
• When community members have widely varying interests or
levels of knowledge;
• When an informal setting is appropriate to enhance your
credibility with the community;
• When staff is available;
• When larger crowds will make it difficult for certain members
of the public to raise questions; and
• In some cases, to fulfill the pre-application meeting
requirements in § 124.31 (see "Regulatory Requirements" above
in this section).
Accompanying Exhibits and fact sheets can provide background information that enables
A rtivitipQ citizens to ask more informed questions about the facility during the
availability session/open house.
Advantages and ^he one-to-one conversations during an availability session/open house can
T imitatinns ^elp ^^ trust and establish a rapport between citizens and project staff.
An informal, neutral setting will keep officials and the public relaxed and
make communications smoother. Citizens can find out more about all
viewpoints concerning a permitting action if public interest groups, civic
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organizations, agency officials, and facility staff are present at the session.
Planning and conducting an availability session/open house can require a
significant amount of staff time. A low turnout may not justify the effort.
Hence, community interest in the site should be significant before an
availability session/open house is planned.
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Checklist for Availability Sessions/Open Houses
(* If you are conducting this activity to fulfill the requirements of § 124.31, the activity must meet the
standards of that section. See Chapter 3 for more information).
(As appropriate):
Determine location(s) for meeting (complete for each available facility)
_ Facility name, location
Contact person at facility
Phone number
Occupancy size.
_ Handicap accessibility.
Features:
Restrooms
_ Public telephones
_ Adequate parking
Determine date, time of meeting:
Date:
Time:
_ Prepare draft notice (public notice, flier)
Coordinate internal review of notice
_ Prepare final notice
Determine what officials will attend availability session/open house
_ If applicable, coordinate with other organizations that will be available at the session
Notify citizens of availability session/open house
Direct mailing to citizens on facility mailing list
Verify that mailing list is up-to-date
_ Request mailing labels
Public notice in local newspaper(s)
_ Prepare handouts, other informational material for availability session/open house
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Workshops
Regulatory
Requirements
None.
Description of Activity
Level of Effort
How to Conduct the
Activity
Workshops are seminars or gatherings of small groups of people (usually
between 10 and 30), led by a small number of specialists with technical
expertise in a specific area. In workshops, participants typically discuss
hazardous waste issues where citizens comment on proposed response
actions and receive information on the technical issues associated with the
permitting process and the RCRA program in general. Experts may be
invited to explain the problems associated with releases of hazardous
substances and possible remedies for these problems. Workshops may help
to improve public understanding of permit conditions or hazardous waste
problems at a facility and to prevent or correct misconceptions. Workshops
also may identify citizen concerns and encourage public input.
A one-day workshop may take about three days to a week to plan and
execute. Another day will probably be required to follow up on any issues
that arise during the workshop.
To conduct a workshop:
1. Determine the focus of the workshop. Decide what topic or topics
will be covered in either one or more workshops. Suggested topics
include: purpose of RCRA; description of the permit process or
corrective action program; proposed remedies; risk assessment;
identified health or environmental problems; and/or method and
format for receiving citizen comments on the proposed or ongoing
actions. Determine what staff will be needed at each workshop and
whether any outside experts will be needed.
2. Plan the workshop. Decide ahead of time on a minimum and
maximum number of participants. If there are too few, consider
holding an informal meeting and postpone the workshop until
additional interest develops. Identify a convenient location and time
for the workshop, and set a date that does not conflict with other
important meetings or interests (for example, town council meetings,
high school sporting events).
3. Announce the workshop by publishing a notice well in advance (at
least 3 weeks) in the local newspapers. Send a notice of workshops
with mailings to all citizens on the facility mailing list and distribute
posters around town. Send out invitations and registration forms to
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When to Use
Accompanying
Activities
Advantages and
Limitations
concerned citizens. Provide for multiple registrations on each form to
accommodate friends who also might be interested in the workshop.
Emphasize that the number of participants is limited, and provide a
deadline for registration.
Workshops are appropriate:
• When the RCRA process needs to be explained to community
members interested in participating in the process;
• When specific topics needs to be discussed in detail, especially
health or risk assessment issues; and
• When technical material needs to be explained and feedback
from the community is important to make sure that citizens
understand the material.
Workshops can be conducted before formal public hearings or during
public comment periods to give citizens some ideas on developing and
presenting testimony. Fact sheets and exhibits can complement the
workshop.
Workshops provide more information to the public than is possible through
fact sheets or other written materials. Workshops have proven successful
in familiarizing citizens with key technical terms and concepts before a
formal public meeting. Workshops also allow two-way communication,
making them particularly good for reaching opinion leaders, interest group
leaders, and the affected public.
If only a limited number are held, workshops can reach only a small
segment of the affected population.
When planning a workshop, you should make sure that it is announced in
local newspapers, to help ensure that it will be well-attended. In addition, it
may be helpful to specifically invite all residents who have expressed an
interest in the site.
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Checklist for Workshops
(As appropriate):
_ Determine purpose of workshop
Determine number of attenders
Plan the workshop
Identify topics to be presented
_ Identify agency officials to present topics, handle registration
Prepare handouts, other informational materials
_ Determine location(s) for workshop (complete for each available facility)
Facility name, location
_ Contact person at facility
Phone number
_ Occupancy size
Handicap accessibility
_ Features:
_ Restrooms
Public telephones
Adequate parking
_ Determine date, time of workshop:
Date:
Time:
Prepare draft notice announcing workshop (public notice, flier)
_ Coordinate internal review of notice
Prepare final notice
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Checklist for Workshops (continued)
Notify citizens of workshop
Direct mailing to citizens on facility mailing list
Verify that mailing list is up-to-date
_ Request mailing labels
Public notice in local newspaper(s)
_ Determine presentation requirements
Electrical outlets
_ Extension cords
Accessible lighting control panel
Window covers
Podium
_ Stage
Table(s) and chairs for panel
_ Water pitcher and glasses
Sound system
_ Microphones (stand, tabletop, lavaliere)
Cables
_ Speakers
Technician/engineers available for hearing
_ Visual aids
Slides
_ Slide projector
Chapter 5: Public Involvement Activities Page 5-137
-------
Checklist for Workshops (continued)
Extra projector bulbs
_ Flip chart
Flip chart markers
_ Overhead transparencies
Overhead machine
VCR and monitor
Screen
_ Table for projection equipment
Registration table
_ Registration cards
Writing pens
_ Signs
Miscellaneous supplies:
_ Scissors
Tape (masking, transparent)
_ Thumbtacks
Public information materials (fact sheets, etc.)
_ Arrange and conduct at least one rehearsal
Chapter 5: Public Involvement Activities Page 5-138
-------
Attending Other
Stakeholder
Meetings and
Functions
Regulatory
Requirements
Description of Activity
Level of Effort
How to Conduct the
Activity
When to Use
None. (The permitting agency may need to attend public meetings held by
the permittee under § 270.42 in order to respond to public comments on the
modification request. Agencies may also want to attend the applicant's
pre-application meeting held under § 124.31. See the section on the "Pre-
Application meeting" in Chapter 3 for more detail.)
Permitting agencies, facilities, local governments, environmental
organizations, religious and civic groups may all hold meetings or other
gatherings during the permitting process. Some may be required by
regulation and others may be informational meetings or discussions of
important issues. As an involved stakeholder, you can learn more about the
views of other stakeholders by attending their meetings. You can join in
important discussions and provide information. Some groups may invite
you to give a presentation or a briefing.
The time you commit to attending other stakeholder meetings or functions
will depend on the level of your participation. Meetings can vary in length;
your resource commitment will be more substantial if you agree to give a
briefing or a presentation (see those sections of this chapter for more
information). You will need a few hours to prepare notes for your file after
the meeting.
If you decide to attend a meeting, you may want to inform the host
organization that you plan to attend the meeting. If you choose to identify
yourself at the meeting, be prepared to answer questions. You may want to
bring fact sheets or other information you can provide upon request. In any
case, be prepared to listen to the discussion and prepare notes for your files.
The host organization may ask you to provide a briefing or a presentation.
See those sections of this chapter for more information.
You may want to attend other stakeholders' meetings when the meetings
are open and you want to learn more about the views held by other
stakeholders. In some cases, a group may invite your organization to attend
a meeting to provide input or answer questions. In such cases, you should
be prepared to answer questions or present the views of your organization.
If appropriate, you may want to make fact sheets available upon request at
Chapter 5: Public Involvement Activities
Page 5-139
-------
the meeting. Provide the name of a contact person . If you are
/YCCOmpanymg representing the permitting agency, let participants know about how to put
Activities their names on the facility mailing list.
Advantages and Attending meetings or functions held by other stakeholders can provide
T . . . useful insight to other opinions and concerns. This information can help
Limitations , ., U1. .. . .. , , . , . .,
you plan other public participation events and complement data you gather
from community interviews.
This activity should not be used in place of informal meetings or other
activities that may be more appropriate. If your attendance has the
potential to cause problems, make sure to contact the host before the
meeting.
Chapter 5: Public Involvement Activities Page 5-140
-------
Citizen Advisory
Groups
Regulatory
Requirements
None.
Description of Activity
A Citizen Advisory Group (CAG) provides a public forum for
representatives of diverse community interests to present and discuss their
needs and concerns with government and/or the facility. Although CAGs
may come in many different forms and have different responsibilities and
roles, they are generally composed of a board of stakeholders that meets
routinely to discuss issues involving a particular facility. The purpose of a
CAG is usually to advise a facility owner/operator or the permitting agency
on permitting or corrective action activities.
CAGs can be a good way to increase active community participation in
environmental decision-making and provide a voice for affected
community members and groups. They promote direct, two-way
communication among the community, the permitting agency, and the
facility.
The make-up and mission of a CAG may vary ~ there is no set formula
governing the make-up or responsibilities of the group. The best type of
CAG to use will depend on the situation. For instance, a citizen
organization may create a CAG of affected community members to provide
an official voice from the community. Facility owner/operators may create
a CAG of affected community members to provide informal or formal
advice. A permitting agency may form a CAG that includes stakeholders
from the facility, the community, and the agency.
In establishing a CAG, it is important to bear in mind that the size of a
group can often have an impact on its effectiveness — for example, too
large of a group can inhibit how efficiently it can work and come to
consensus on issues, and too small of a group may not be adequate to
represent diverse community concerns.
Forming a CAG does not necessarily mean that there will be universal
agreement about permitting or corrective action issues. Nor does having a
CAG mean there will be no controversy during the process. However,
when decisions made by the facility or the permitting agency differ from
the stated preferences of a CAG, the facility or the agency should accept
the responsibility of explaining its decision to CAG members.
RCRA regulations do not require the use of advisory groups; however, EPA
regulations do contain standards for advisory groups if EPA decides to
require them under 40 CFR. These standards are located in 40 CFR 25.7.
Chapter 5: Public Involvement Activities
Page 5-141
-------
Although these standards may not apply to all types of advisory groups used
in conjunction with RCRA permitting, they provide useful guidance for
agencies, facilities, and public interest groups who may want to use
advisory groups. A copy of the part 25 regulations is available Appendix F.
Level of Effort
How to Conduct the
Activity
When to Use
EPA's Office of Emergency and Remedial Response has issued guidance
on the use of CAGs at Superfund sites (see Appendix E). Although there
are many differences between the Superfund and RCRA programs (most
notably that Superfund often deals with abandoned sites while RCRA
typically deals with existing or potential facilities), a large part of the
Superfund CAG guidance discusses CAG development, membership, and
training that may be applicable to some RCRA CAGs. Superfund
terminology and process aside, the guidance contains some very useful,
concise advice on various aspects of CAGs.
Although CAGs are a useful tool in many situations, they may not always
be appropriate. See the section "When to Use" below for a list of factors
you should consider before forming a CAG.
CAGs can be a time-consuming and expensive endeavor. Membership
selection, meeting preparation and follow-up, information dissemination,
and training all take a lot of resources. Unlike the Superfund program,
agencies that implement RCRA cannot provide Technical Assistance
Grants (TAGs) to help defray the costs of CAGs.
See EPA's Guidance for Community Advisory Groups at Superfund Sites
and 40 CFR § 25.7 (in Appendices E and F) for information on how to set
up CAGs. Keep in mind that CAGs under the RCRA program will differ
from CAGs under Superfund. You may want to obtain a copy of the
reference list of public participation and risk communication literature
(available through the RCRA Hotline or the RCRA Information Center in
Docket Number F-95-PPCF-FFFFF) to look for additional information
sources on this topic.
A CAG can be formed at any point in the permitting or corrective action
process, and may be most effective in the early stages. Generally, the
earlier a CAG is formed, the more members can participate in and impact
decision-making.
CAGs may not be appropriate in every situation. If you are considering use
of a CAG, you should consider the following factors:
• the level of community interest and concern;
• community interest in forming a CAG;
• the existence of groups with competing agendas in the community;
Chapter 5: Public Involvement Activities
Page 5-142
-------
environmental justice issues or concerns regarding the facility;
the history of community involvement with the facility, or with
environmental issues in general; and
the working relationship between the facility, the community, and the
permitting agency.
Accompanying
Activities
Depending on the make-up and the purpose of the CAG, you may want to
provide public notice, hold a public meeting, and issue a news release
before forming the CAG. The CAG may choose to provide public
participation activities (such as meetings, newsletters, or availability
sessions) as part of its mission.
Advantages and
Limitations
CAGs can increase active community participation in environmental
decision-making and provide a voice for affected community members and
groups. They promote direct, two-way communication among the
community, the permitting agency, and the facility and can highlight your
organization's commitment to inclusive stakeholder input.
CAGs can be time- and resource-intensive. CAGs that do not accurately
reflect or account for public concerns may lose support in the community.
In addition, uncertainty about the group's charter may cause conflict and
hard feelings. If you plan to use a CAG, the mission and responsibilities of
the CAG must be made clear from the start. Finally, CAGs can spend so
much time agreeing on procedures that they drive away people who are
concerned with substance. The need for elaborate procedures can be
sharply reduced if an advisory group agrees to work on a consensus basis
rather than by majority vote.
-------
&EPA
United States
Environmental Protection
Agency
Office of Water
(4204)
Washington, DC 20460
EPA 832-F-98-001
March 1998
Cleaning Up Polluted Runoff with the
Clean Water State Revolving Fund
What's In It For You?
Based on the serious threats to water sources across the
country, EPA would like to see the SRF become a major
source of funding to address polluted runoff (nonpoint
source) problems. The 51 Clean Water State Revolving
Fund (CW-SRF) programs currently issue approximately
$3 billion in loans annually. SRF loans are issued at
below market rates (0% to less than market), offering
borrowers significant savings over the life of the loan.
History
In creating the CW-SRF, Congress ensured that it
would be able to fund virtually any type of water quality
project, including nonpoint source, wetlands, estuary,
and other types of watershed projects, as well as more
traditional municipal wastewater treatment systems. The
SRF provisions in the Clean Water Act give no more
preference to one category or type of project than any
other.
CW-SRF Buying Power
The CW-SRF will invest 10% of its fund on
polluted runoff projects by 2001
—Clean Water Action Plan
Capacity of the CW-SRF
The 51 SRF programs work like banks (each state and
Puerto Rico has one). Federal and state contributions are
used to capitalize or set-up the programs. These assets
are used to make low-interest loans for important water
quality projects. Repaid funds are then recycled to fund
other important water quality projects.
The CW-SRFs have in excess of $24 billion in assets.
Currently, the SRFs are funding approximately $3 billion
in water quality projects each year. The funding of
polluted runoff projects with the SRF is gaining
momentum. Since 1989 the SRF program has funded
900 projects, investing more than $650 million in
polluted runoff projects.
Nonpoint
Source
Grants
Wetlands
Grants
CW-SRF Loan
Activity
Loans vs. Grants
Many people believe they would rather have a grant
than a loan. Most state and local water quality officials
are more familiar with grants and, consequently, many
misconceptions persist. In fact, a loan may be a better
deal. Why?
•First, No Cash Up-Front. Most grant programs
require significant cost shares (as much as 40% or
more). An SRF loan can cover 100% of project costs
with no cash up-front.
•Second, Significant Cost Savings. SRF loans provide
significant cost savings over the life of the loan. The
total cost of a 0% SRF loan will be approximately 50%
less than the same project financed by a commercial loan
at 7.5%. Additionally, a 0% SRF loan is equivalent to
receiving a 50% grant (where the matching 50% is
financed at market rate).
•Third, Streamlined Federal Requirements.
Financing a project with an SRF loan means fewer
federal requirements than with a federal grant. Plus, the
51 CW-SRF programs are experienced in helping
applicants through the loan application process and
providing a variety of technical assistance. Also, it may
be possible to combine an SRF loan with grant dollars
from other sources. Check with your state.
-------
United States Office of Water (WH-585)
Environmental EPA-821-F-93-002
Protection Agency June 1993
SERA Protecting
Our Nation's
Waters from
Industrial
ischarges
-A.™ ^ SSjpJW^-t,. -***, ,*»(.Ł
ilSfc&J*ia --r_*>»fc---:i»?P*T"
-------
Backgiound
In 1972 Congress established, as part of the
Clean Water Act, a landmark program
to control the discharge of pollutants from
industries into the waters of the United States.
EPA uses complementary approaches to
ensure this protection of our valuable water
resources: technology-based effluent guide-
lines and water quality-based controls,
Effluent guidelines set national standards
for regulated industries. They ensure that
wastewaters discharged, either directly into
surface waters or indirectly into sewage
treatment plants, will achieve levels of pollut-
ants based on the best technology that is
economically ^^^^^^^^^^^^^^
Developing Guidelines
Developing a guideline for any industrial
category is a complex process, It begins with
a study of the industry and of the actual
performance of technologies already in
place, including pollution prevention, reuse,
recycling, and wastewater treatment. EPA
gathers information on manufacturing pro-
cesses, costs, waste reduction and treatment
technologies, and the contents of waste-
water discharges from many facilities in the
industrial category under consideration, EPA
analyzes wastewater samples, and prepares
an economic analysis to help assess the
potential impact of any proposed guideline.
" "Bcjdnornlc
Statistical Analyses
operating* dosts
•» treatment costs'
possible. Water
quality-based
controls are devel-
oped by individual
states when even
more stringent
measures are
needed to protect
specific bodies of
water within their
boundaries.
The Environ-
mental Protection
Agency has already developed many tech-
nology-based guidelines, regulating over fifty
industrial categories (such as oil and gas
extraction, and pulp and paper manufactur-
ing). They regulate conventional pollutants,
such as oil and suspended solids; pollutants
that are identified as toxic (like lead and
benzene); and nonconventional pollutants,
including many pesticides. Each guideline is
developed by EPA with the help of scientists,
the industries under consideration, environ-
mental groups, and other interested parties.
Environmental
Consideratipns /
* air emissiorris \-~
^f solid' waste / —' \
f disposal / \
•' \
• wastewxater into
ground waters
This combination of economic, engineering,
and wastewater databases enables EPA to
develop guideline options for the industrial
category being considered.
The Regulation Process
The CWA of 1972 required EPA to publish
effluent guidelines for both direct and indirect
industrial dischargers and provided specific
factors to be considered for conventional
pollutants (BPT, BCD, toxic pollutants (BAT),
and new sources (NSPS). EPA
factors in developing regulatory options.
Since conventional pollutants are considered
compatible with the operation of the munici-
pal wastewater treatment plant, they are not
regulated for indirect dischargers. In addition,
for toxic pollutants, EPA must show that the
Best Available Technology
onomically Achievable.
Best Practicable Control Technology
— Best Conventional Pollutant
Control Technology
NSPS— New Source
Performance
Standards
pollutant "passes through" the municipal
system before it is regulated for indirect
dischargers. For each industry, EPA defines
the levels of pollutants that are technically
and economically achievable, and describes
how these levels can be met and at what
cost. The industry may use any technology
that allows it to meet the guideline levels.
- Pretreatment Standards
for Existing Sources
PSNS — Pretreatment Standards
for New Sources
-------
The most suitable option is published in the
Federal Register Q$ a proposed regulation for
public review and comment. It may contain a
specific request for comments on controversial
or difficult issues. The public comment period,
an integral part of the guidelines development
process, gives everyone the opportunity to
provide support or opposition and to submit
constructive and helpful suggestions. At the
close of this period, EPA evaluates all the
comments and again reviews the alternative
options. In some cases the comments are so
substantial that EPA decides on further study
or evaluation.
After consideration of the comments and
any subsequent research or analysis, the final
guideline is published. Generally, industry has
a maximum of three years to comply with the
new regulations.
Future Activities
The 1987 Amendments to the Clean
Water Act require EPA to publish a biennial
plan to review and revise existing guidelines
and to develop new ones for dischargers of
toxic or nonconventional pollutants. As
wastewater treatment technologies continue
to advance, earlier guidelines will need to
be revised to take into account improved
treatment methods and pollution prevention
activities. In addition, national concern will
focus on new pollutants, more stringent
discharge limits, and industries not presently
regulated.
EPA has developed an effective national
effluent guidelines program that is ato widely
recognized and used by other countries. This
program has been essential to meeting the
commitment that the Clean Water Act
represents: the protection of our nation's
water for the benefit of us all.
For additional Information on effluent
guidelines or other Office of Water
programs, you may contact;
U.S. Environmental Protection Agency
Water Resource Center (RC-4100)
401 M Street, SW, Washington, D.C. 20460
(202) 260-7786
-------
Published (or existing) Guidelines
INDUSTRIES
Aluminum Forming
Asbestos Manufacturing
Battery Manufacturing
Builder's Paper and Board Mills
Carbon Black Manufacturing
Cement Manufacturing
Coal Mining
Coil Coating
Copper Forming
Dairy Products Processing
Electroplating
Electrical and Electronic Components
Explosive Manufacturing
Feedlots
Ferroalloy Manufacturing
Fertilizer Manufacturing
Fruits and Vegetables Processing
Glass Manufacturing
Grain Mills Manufacturing
Gum and Wood Chemicals Manufacturing
Hospitals
Ink Formulating
Inorganic Chemicals
Iron and Steel Manufacturing
Leather Tanning and Finishing
Meat Products
Metal Finishing
Metal Molding and Casting (Foundries)
Mineral Mining and Processing
Nonferrous Metals Forming and Metal Powders
Nonferrous Metals Manufacturing
Oil and Gas Extraction
Ore Mining and Dressing
Organic Chemicals, Plastics and Synthetic Fibers
Paint Formulating
Paving and Roofing Materials (Tars & Asphalts)
Pesticide Chemicals
Petroleum Refining
Pharmaceutical Manufacturing
Phosphate Manufacturing
Photographic Processing
Plastics Molding and Forming
Porcelain Enameling
Pulp, Paper, and Paperboard
Rubber Manufacturing
Seafood Processing
Soap and Detergent Manufacturing
Steam Electric Power Generating
Sugar Processing
Textile Mills
Timber Products Processing
40CFR
467
427
461
431
458
411
434
465
468
405
413
469
457
412
424
418
407
426
406
454
460
447
415
420
425
432
433
464
436
471
421
435
440
414
446
443
455
419
439
422
459
463
466
430
428
408
417
423
409
410
429
YEAR
1983
1974
1984
1982
1978
1974
1985
1982
1983
1974
1981
1983
1976
1974
1974
1974/79
1974
1974/86
1974
1976
1976
1975
1982
1982
1982
1974/76
1983
1985
1977
1985
1984
1993
1982/88
1987
1975
1975
1993
1982
1983
1976
1976
1984
1982
1982
1974
1974
1975
1982
1974
1982
1981
New and Revised Effluent Guidelines
Under Development*
CATEGORY
Organic Chemicals (Remand)
Pulp, Paper, & Paperboard
Pesticide Formulating & Packaging
Waste Treatment, Phase 1
Pharmaceutical Manufacturing
Metal Products & Machinery, Phase 1
(formerly Machinery Manufacturing & Rebuilding)
Coastal Oil & Gas
Waste Treatment, Phase 2
Industrial Laundries
Transportation Equipment Cleaning
Metal Products & Machinery, Phase 2
8 additional categories
PROPOSED
1991
1993
1994
1994
1994
1994
1995
1995
1996
1996
1997
1998-2001
FINAL
1993
1995
1995
1996
1996
1996
1996
1997
1998
1998
1999
2000-2003
* From the Effluent Guidelines Plan in the Federal Register, Septembers,
1992, Vol. 57, No. 174, pp. 41000-41004
Industry Studies
EPA has tentatively identified the following industries for study to determine
whether existing regulations should be revised. Findings will be published as
Preliminary Data Summaries and discussed in future Effluent Guidelines Plans.
CATEGORY
Petroleum Refinina
Metal Finishina
Textile Mills
Inoraanic Chemicals
7 additional categories
40CFR
419
433
410
415
YEAR
1993
1993
1996
1994
1 995-97
40 CFR: Code of Federal Regulations
Part Number (under Title 40)
-------
AMERICAN
WETLANDS
A Reason to Celebrate
"To increase public awareness of the
values and productivity of wetlands,
encourage people to enjoy them, and
to protect, recognize, enhance,
commemorate, and restore our
-------
Celebrate American Wetlands. Appreciate the values and functions of our wetlands.
etlands, the vegetated aquatic ecosystems that include such areas as bogs, marshes, swamps, and prairie potholes, are now recognized as some of the most productive natural areas
in the world. They're habitat for waterfowl and other wildlife, fish and shellfish. Humans, also, use wetlands for recreation, erosion control, and water quality control.
But we've only begun to recognize their irreplaceable ecological values: wetlands have long been misunderstood and abused. Historically, Americans, perceivih'g"
wetlands as useless swamps, drained, filled, channeled, and polluted them — destroying more than half the original 200 million acres of wetlands in "
lower 48 States. In response to these losses, the National Wetlands Policy Forum set two goals for protecting and managing the Nation's wetlands^
(1) to achieve no overall net loss of the Nation's remaining wetlands; and (2) to increase the quality and quantity of the Nation's wetlands
, help control flood waters by absorbing water during heavy
rainfall then s|owly releasing it downstream.
*„•*••.Ł;•*'
T»«fR*
Erosion Control: Because they're
often located between water 1
and high ground, wetlands 1
shorelands against erosion. Wetlands
plants also bind soil with their roots and
help to absorb impacts from wave actian.,
is ' i I
l:|tWfef
Boating: Wetlands are some of our
t>W*i«^;m«»'«rt,(a./attracting canoeists
kayakers to their pristine environments.
Quality of life:
fef
'is as naturaTbuffers~"4*
between land uses, as water
features, to create diversity u
within the development.
• Water quality and availability: Like giant
kidneys, wetlands help purify water by processing
nutrients, suspended materials, and other pollutants.
Wetlands also increase the availability of water by
absorbing and adding water in wet seasons, then
gradually releasing it during dry periods.
cish and wildlife habitat: Most fish and
shellfish we eat live in wetlands when they are
young. Wildlife also migrate through wetlands'
^"linear corridors"—and many endangered species
live there, as do birds and mammals of all j
from the mouse to the moose.
• Forestry: Carefuly'yar&ffics in
wetlands can be a valuable source of wood products.
• Recreation: Wetlands are wonderlands^^.
People hunt, fish, crab, hike, walk, and boat
there—and those 50 million who observe and
photograph birds in wetlands spend nearly
r $10 billion a year on their hobby.
• Hunting: V\fetta«!s stippblrViin a'hnual commercial fur
and hide harvest of $300-$400 million. Migratory birds and
waterfowl use these ecosystems for food and shelter, and
for breeding and wintering grounds.
> fine arts and
ture Over the
(jr centuries na
lanfiiieape painters, f
"photographers, and writers
, ^ . -have expressed apprecia:
f he-values" — both
_
~of "America's wettarid
ghlng: Nearly all the ffiffartl^ghelliSn harvested
nerciafly—and halt of the recreational catch—depend on
etlands lar food and habitat during part of their life cycle.
For more information on American Wetlands
Month, contact the Terrene Institute
Tel: 202/833-8317 Fax: 202/296-4071
-------
AMERICAN
WETLANDS MONTH
te in May ...
and all year through
Throughout much of history,
wetlands have been little
regarded and often feared. They
have been used as dump sites
and valued only when drained
and developed. In fact, less than
50 percent of the United States'
original wetlands remain—that
translates into some 100 million
acres destroyed.
In the last several decades,
we have only begun to
understand that wetlands are a
fertile and precious nursery—
some even call them the "cradle
of life." Besides nurturing
millions of species—many
endangered—wetlands replenish
the earth's water supply, blunt
the ravages of nature and
provide sanctuary and serenity
for humans, often in urban areas.
The goal of American
Wetlands Month continues to be
educating and involving the
public through a multitude of
local activities—from field
trips, to educational displays,
to television public service
announcements. American
Wetlands Month provides the
spark—individual and group
enthusiasm and creativity
provide the power—
spread the message
about wetlands.
Franck, 1., and D. Brownstoneri
The Green Encyclopedia. Prentice
•' " ew York, N.Y.
Celebrate American Wetlands
— ivhat you can do —
Develop resolutions recognizing American
Wetlands Month: Encourage your government
• • '• officials to recognize the values of wetlands by
\, issuing a resolution declaring May as American
Wetlands Month.
Enjoy wetlands: Plan a "walk in the wetlands"
for your community—visit nearby wetlands in a
National Wildlife Refuge, a state park, or
estuary—to appreciate their beauty and values.
Organize a local group: Encourage others in
your community to form a group to help protect
• ' wetlands in your area.
Read about wetlands: Learn more about the spe- »
cial qualities and functions of wetlands by reading
about them. Call the Terrene Institute for ft list of edu- >'
cational materials. 202/833-8317.
!; Talk to elected officials: Visit your city/town/
.' ' county council and your state legislature to talk
>', about the need to protect wetlands. Invite them to
I'isit a nearby wetlands with you.
Look into government programs: Contact
State and Federal wetlands protection agencies to
find out what laws, programs, and projects protect
wetlands. Call the Terrene Institute for a list of
suggested contacts and activities. 202/833-8327.
" Publicize American Wetlands Month: Encour-
t age your local newspaper and radio/TV stations to run
, stories on wetlands protection. Contact the Terrene In-
stitute for a wetlands fact sheet. 202J833-8317
for more information, contact
Terrene Institute
(before 4/30/96)
1717 K Street, NW, Suite 801
Washington, DC 20006
(after 4/30/96)
4-B Herbert Street
-------
CHAPTER TEN
SAMPLING METHODS
Prior to employing the methods in this chapter, analysts are advised to consult the disclaimer
statement at the front of this manual and the information in Chapter Two for guidance on the allowed
flexibility in the choice of apparatus, reagents, and supplies. In addition, unless specified in a
regulation, the use of SW-846 methods is not mandatory in response to Federal testing
requirements. The information contained in each procedure is provided by EPA as guidance to be
used by the analyst and the regulated community in making judgements necessary to meet the data
quality objectives or needs for the intended use of the data.
The following methods are found in Chapter Ten:
Method 0010:
Appendix A:
Appendix B:
Method 0011:
Method 0020:
Method 0023A:
Method 0030:
Method 0031:
Method 0040:
Method 0050:
Method 0051:
Method 0060:
Method 0061:
Method 0100:
Modified Method 5 Sampling Train
Preparation of XAD-2 Sorbent Resin
Total Chromatographable Organic Material Analysis
Sampling for Selected Aldehyde and Ketone Emissions from
Stationary Sources
Source Assessment Sampling System (SASS)
Sampling Method for Polychlorinated Dibenzo-p-Dioxins and
Polychlorinated Dibenzofuran Emissions from Stationary
Sources
Volatile Organic Sampling Train
Sampling Method for Volatile Organic Compounds (SMVOC)
Sampling of Principal Organic Hazardous Constituents from
Combustion Sources Using Tedlar® Bags
Isokinetic HCI/CI2 Emission Sampling Train
Midget Impinger HCI/CI2 Emission Sampling Train
Determination of Metals in Stack Emissions
Determination of Hexavalent Chromium Emissions from
Stationary Sources
Sampling for Formaldehyde and Other Carbonyl Compounds
in Indoor Air
CD-ROM
TEN- 1
Revision 2
December 1996
-------
CHAPTER NINE
SAMPLING PLAN
9.1 DESIGN AND DEVELOPMENT
The initial -- and perhaps most critical -- element in a program designed
to evaluate the physical and chemical properties of a solid waste is the plan
for sampling the waste. It is understandable that analytical studies, with
their sophisticated instrumentation and high cost, are often perceived as the
dominant element in a waste characterization program. Yet, despite that
sophistication and high cost, analytical data generated by a scientifically
defective sampling plan have limited utility, particularly in the case of
regulatory proceedings.
This section of the manual addresses the development and implementation
of a scientifically credible sampling plan for a solid waste and the
documentation of the chain of custody for such a plan. The information
presented in this section is relevant to the sampling of any solid waste, which
has been defined by the EPA in its regulations for the identification and
listing of hazardous wastes to include solid, semisolid, liquid, and contained
gaseous materials. However, the physical and chemical diversity of those
materials, as well as the dissimilarity of storage facilities (lagoons, open
piles, tanks, drums, etc.) and sampling equipment associated with them,
preclude a detailed consideration of any specific sampling plan. Consequently,
because the burden of responsibility for developing a technically sound
sampling plan rests with the waste producer, it is advisable that he/she seek
competent advice before designing a plan. This is particularly true in the
early developmental stages of a sampling plan, at which time at least a basic
understanding of applied statistics is required. Applied statistics is the
science of employing techniques that allow the uncertainty of inductive
inferences (general conclusions based on partial knowledge) to be evaluated.
9.1.1 Development of Appropriate Sampling Plans
An appropriate sampling plan for a solid waste must be responsive to both
regulatory and scientific objectives. Once those objectives have been clearly
identified, a suitable sampling strategy, predicated upon fundamental
statistical concepts, can be developed. The statistical terminology associated
with those concepts is reviewed in Table 9-1; Student's "t" values for use in
the statistics of Table 9-1 appear in Table 9-2.
9.1.1.1 Regulatory and Scientific Objectives
The EPA, in its hazardous waste management system, has required that
certain solid wastes be analyzed for physical and chemical properties. It is
mostly chemical properties that are of concern, and, in the case of a number
of chemical contaminants, the EPA has promulgated levels (regulatory
thresholds) that cannot be equaled or exceeded. The regulations pertaining to
the management of hazardous wastes contain three references regarding the
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TABLE 9-1. BASIC STATISTICAL TERMINOLOGY APPLICABLE TO SAMPLING PLANS FOR SOLID WASTES
Termi nology
Symbol
Mathematical Equation
(Equati on)
Variable (e.g.
or endrin)
ban' urn
• Individual measurement
of variable
. Mean of possible
measurements of variable
(population mean)
N
Z <
?'-l
N
with N - number of (1)
possible measurements
Mean of measurements
generated by sample
(sample mean)
Simple random sampling and
systematic random sampling
n
Z
f-1
n
with n - number of (2a)
sample measurements
Stratified random sampling
Ar=l
with xk - stratum (2b)
mean and Wk - frac-
tion of population
represented by Stratum
k (number of strata
[k] range from 1 to r)
Variance of sample
Simple random sampling and
svstemaic random sampling
s2 -
n n
Z *? ~ (Z *,)Vn
T -1 / =1
n - I
(3a)
Stratified random sampling
r
Z
Ar-l
s
•*
with s\ - stratum (3b)
variance and H, -
fraction of population
represent by Stratum k
(number of strata [k]
ranges from 1 to r)
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TABLE 9-1. (continued)
Termi nology
Symbol
Mathematical Equation
(Equation)
Standard deviation of
sample
(4)
Standard error
(also standard error
of mean and standard
deviation of mean)
of sample
Confidence
for a
interval
(5)
CI
CI
with t 20
obtained from
Table 2 for
appropri ate
degrees of freedom
(6)
Regulatory threshold3 RT
Appropriate number of
samples to collect from n
a solid waste (financial
constraints not considered)
Degrees of freedom df
Square root transformation
Arcsin transformation —
Defined by EPA (e.g., 100 ppm for
barium in elutriate of EP toxicity)
tjo s2 with A - RT - x
df = n - 1
Arcsin p; if necessary, refer to any
text on basic statistics;
measurements must be con-
verted to percentages (p)
(7)
(8)
(9)
(10)
(11)
aThe upper limit of the CI for p is compared with the applicable regulatory threshold
(RT) to determine if a solid waste contains the variable (chemical contaminant) of
concern at a hazardous level. The contaminant of concern is not considered to be
present in the waste at a hazardous level if the upper limit of the CI is less than the
applicable RT. Otherwise, the opposite conclusion is reached.
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TABLE 9-2. TABULATED VALUES OF STUDENT'S "t" FOR EVALUATING
SOLID WASTES
Degrees of
freedom (n-l)a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
40
60
120
Tabu! ated
"t" Value5
3.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
.078
.886
.638
.533
.476
.440
.415
.397
.393
.372
.363
.356
.350
.345
.341
.337
.333
.330
.328
.325
.323
.321
.319
.318
.316
.315
.314
.313
.311
.310
.303
.296
.289
.282
Degrees of freedom (df) are equal to the number of samples (n) collected from a
solid waste 1 ess one.
b Tabulated "t" values are for a two-tailed confidence
of 0.20 (the same values are applicable to a one-tailed
probability of 0.10).
interval and a probability
confidence interval and a
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sampling of solid wastes for analytical properties. The first reference, which
occurs throughout the regulations, requires that representative samples of
waste be collected and defines representative samples as exhibiting average
properties of the whole waste. The second reference, which pertains just to
petitions to exclude wastes from being listed as hazardous wastes, specifies
that enough samples (but in no case less than four samples) be collected over
a period of time sufficient to represent the variability of the wastes. The
third reference, which applies only to ground water monitoring systems,
mandates that four replicates (subsamples) be taken from each ground water
sample intended for chemical analysis and that the mean concentration and
variance for each chemical constituent be calculated from those four subsamples
and compared with background levels for ground water. Even the statistical
test to be employed in that comparison is specified (Student's t-test).
The first of the above-described references addresses the issue of
sampling accuracy, and the second and third references focus on sampling
variability or, conversely, sampling precision (actually the third reference
relates to analytical variability, which, in many statistical tests, is
indistinguishable from true sampling variability). Sampling accuracy (the
closeness of a sample value to its true value) and sampling precision (the
closeness of repeated sample values) are also the issues of overriding
importance in any scientific assessment of sampling practices. Thus, from both
regulatory and scientific perspectives, the primary objectives of a sampling
plan for a solid waste are twofold: namely, to collect samples that will allow
measurements of the chemical properties of the waste that are both accurate and
precise. If the chemical measurements are sufficiently accurate and precise.
they will be considered reli able estimates of the chemical properties of the
waste.
It is now apparent that a judgment must be made as to the degree of
sampling accuracy and precision that is required to estimate reliably the
chemical characteristics of a solid waste for the purpose of comparing those
characteristics with applicable regulatory thresholds. Generally, high
accuracy and high precision are required if one or more chemical contaminants
of a solid waste are present at a concentration that is close to the applicable
regulatory threshold. Alternatively, relatively low accuracy and low precision
can be tolerated if the contaminants of concern occur at levels far below or
far above their applicable thresholds. However, a word of caution is in order.
Low sampling precision is often associated with considerable savings in
analytical, as well as sampling, costs and is clearly recognizable even in the
simplest of statistical tests. On the other hand, low sampling accuracy may
not entail cost savings and is always obscured in statistical tests (i.e., it
cannot be evaluated). Therefore, although it is desirable to design sampling
plans for solid wastes to achieve only the minimally required precision (at
least two samples of a material are required for any estimate of precision),
it is prudent to design the plans to attain the greatest possible accuracy.
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The roles that inaccurate and imprecise sampling can play in causing a
solid waste to be inappropriately judged hazardous are illustrated in Figure
9-1. When evaluating Figure 9-1, several points are worthy of consideration.
Although a sampling plan for a solid waste generates a mean concentration (x)
and standard deviation (s, a measure of the extent to which individual sample
concentrations are dispersed around x) for each chemical contaminant of
concern, it is not the variation of individual sample concentrations that is
of ultimate concern, but rather the variation that characterizes x itself.
That measure of dispersion is termed the standard deviation of the mean (also,
the standard error of the mean or standard error) and is designated as s^.
Those two sample values, x and S^ , are used to estimate the interval (range)
within which the true mean (p) of the chemical concentration probably occurs,
under the assumption that the individual concentrations exhibit a normal (bell-
shaped) distribution. For the purposes of evaluating solid wastes, the
probability level (confidence interval) of 80% has been selected. That is, for
each chemical contaminant of concern, a confidence interval (CI) is described
within which p occurs if the sample is representative, which is expected of
about 80 out of 100 samples. The upper limit of the 80% CI is then compared
with the appropriate regulatory threshold. If the upper limit is less than the
threshold, the chemical contaminant is not considered to be present in the
waste at a hazardous level; otherwise, the opposite conclusion is drawn. One
last point merits explanation. Even if the upper limit of an estimated 80% CI
is only slightly less than the regulatory threshold (the worst case of chemical
contamination that would be judged acceptable), there is only a 10% (not 20%)
chance that the threshold is equaled or exceeded. That is because values of
a normally distributed contaminant that are outside the limits of an 80% CI are
equally distributed between the left (lower) and right (upper) tails of the
normal curve. Consequently, the CI employed to evaluate solid wastes is, for
all practical purposes, a 90% interval.
9.1.1.2 Fundamental Statistical Concepts
The concepts of sampling accuracy and precision have already been
introduced, along with some measurements of central tendency (x) and
dispersion (standard deviation [s] and sx) for concentrations of a chemical
contaminant of a solid waste. The utility of x and sx in estimating a
confidence interval that probably contains the true mean (p) concentration of
a contaminant has also been described. However, it was noted that the validity
of that estimate is predicated upon the assumption that individual
concentrations of the contaminant exhibit a normal distribution.
Statistical techniques for obtaining accurate and precise samples are
relatively simple and easy to implement. Sampling accuracy is usually achieved
by some form of random sampling. In random sampling, every unit in the
population (e.g., every location in a lagoon used to store a solid waste) has
a theoretically equal chance of being sampled and measured. Consequently,
statistics generated by the sample (e.g., x and, to a lesser degree, S^ ) are
unbiased (accurate) estimators of true population parameters (e.g., the CI
for p). In other words, the sample is representative of the population. One
of the commonest methods of selecting a random sample is to divide the
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ACCURATE AND PRECISE SAMPLE
(Waste Appropriately Judged Nonhazardous)
0.4-
True Mean (pi and Sample Mean (x)
ACCURATE AND IMPRECISE SAMPLE
(Waste Inappropriately Judged Hazardous)
M and x
0.3-
u.
O
0.2-
O
0.1-
I I I I
65 70 75 80 85 90 95 100 105 110
CONCENTRATION OF BARIUM (ppm)
INACCURATE AND PRECISE SAMPLE
(Waste Inappropriately Judged Hazardous)
I
r
65 70 75 80 85 90 95 100 105 110
CONCENTRATION OF BARIUM (ppm)
INACCURATE AND IMPRECISE SAMPLE
(Waste Inappropriately Judged Hazardous)
65
70 75 80 85 90 95 100 105 110
CONCENTRATION OF BARIUM (ppm)
1 I I I I T
65 70 75 80 85 90 95 100 105 110
CONCENTRATION OF BARIUM (ppm)
NOTE: In All Cases, Confidence Interval for n - x ± t 20 >x.
Figure 9-1. - Important theoretical relationships between sampling
accuracy and precision and regulatory objectives for a chemical contaminant
of a solid waste that occurs at a concentration marginally less than its
regulatory threshold. In this example, barium is the chemical contaminant.
The true mean concentration of barium in the elutriate of the EP toxicity
test is 85 ppm, as compared to a regulatory threshold of 100 ppm. The
upper limit of the confidence interval for the true mean concentration,
which is estimated from the sample mean and standard error, must be less
than the regulatory threshold if barium is judged to be present in the
waste at a nonhazardous level.
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population by an imaginary grid, assign a series of consecutive numbers to the
units of the grid, and select the numbers (units) to be sampled through the use
of a random-numbers table (such a table can be found in any text on basic
statistics). It is important to emphasize that a haphazardly selected sample)
is not a suitable substitute for a randomly selected sample. That is because
there is no assurance that a person performing undisciplined sampling will not
consciously or subconsciously favor the selection of certain units of the
population, thus causing the sample to be unrepresentative of the population.
Sampling precision is most commonly achieved by taking an appropriate
number of samples from the population. As can be observed from the equation
for calculating S^ precision increases ( S^ and the CI for p decrease) as the
number of samples (n) increases, although not in a 1:1 ratio. For example, a
100% increase in the number of samples from two to four causes the CI to
decrease by approximately 62% (about 31% of that decrease is associated with
the critical upper tail of the normal curve). However, another 100% increase
in sampling effort from four to eight samples results in only an additional 39%
decrease in the CI. Another technique for increasing sampling precision is to
maximize the physical size (weight or volume) of the samples that are
collected. That has the effect of minimizing between-sample variation and,
consequently, decreasing s^. Increasing the number or size of samples taken
from a population, in addition to increasing sampling precision, has the
secondary effect of increasing sampling accuracy.
In summary, reliable information concerning the chemical properties of a
solid waste is needed for the purpose of comparing those properties with
applicable regulatory thresholds. If chemical information is to be considered
reliable, it must be accurate and sufficiently precise. Accuracy is usually
achieved by incorporating some form of randomness into the selection process
for the samples that generate the chemical information. Sufficient precision
is most often obtained by selecting an appropriate number of samples.
There are a few ramifications of the above-described concepts that merit
elaboration. If, for example, as in the case of semiconductor etching
solutions, each batch of a waste is completely homogeneous with regard to the
chemical properties of concern and that chemical homogeneity is constant
(uniform) over time (from batch to batch), a single sample collected from the
waste at an arbitrary location and time would theoretically generate an
accurate and precise estimate of the chemical properties. However, most wastes
are heterogeneous in terms of their chemical properties. If a batch of waste
is randomly heterogeneous with regard to its chemical characteristics and that
random chemical heterogeneity remains constant from batch to batch, accuracy
and appropriate precision can usually be achieved by simple random sampling.
In that type of sampling, all units in the population (essentially all
locations or points in all batches of waste from which a sample could be
collected) are identified, and a suitable number of samples is randomly
selected from the population. More complex stratified random sampling is
appropriate if a batch of waste is known to be nonrandomly heterogeneous in
terms of its chemical properties and/or nonrandom chemical heterogeneity is
known to exist from batch to batch. In such cases, the population is
stratified to isolate the known sources of nonrandom chemical heterogeneity.
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After stratification, which may occur over space (locations or points in a
batch of waste) and/or time (each batch of waste), the units in each stratum
are numerically identified, and a simple random sample is taken from each
stratum. As previously intimated, both simple and stratified random sampling
generate accurate estimates of the chemical properties of a solid waste. The
advantage of stratified random sampling over simple random sampling is that,
for a given number of samples and a given sample size, the former technique
often results in a more precise estimate of chemical properties of a waste (a
lower value of s^) than the latter technique. However, greater precision is
likely to be realized only if a waste exhibits substantial nonrandom chemical
heterogeneity and stratification efficiently "divides" the waste into strata
that exhibit maximum between-strata variability and minimum within-strata
variability. If that does not occur, stratified random sampling can produce
results that are less precise than in the case of simple random sampling.
Therefore, it is reasonable to select stratified random sampling over simple
random sampling only if the distribution of chemical contaminants in a waste
is sufficiently known to allow an intelligent identification of strata and at
least two or three samples can be collected in each stratum. If a strategy
employing stratified random sampling is selected, a decision must be made
regarding the allocation of sampling effort among strata. When chemical
variation within each stratum can be estimated with a great degree of detail,
samples should be optimally allocated among strata, i.e., the number of samples
collected from each stratum should be directly proportional to the chemical
variation encountered in the stratum. When detailed information concerning
chemical variability within strata is not available, samples should be
proportionally allocated among strata, i.e., sampling effort in each stratum
should be directly proportional to the size of the stratum.
Simple random sampling and stratified random sampling are types of
probability sampling. Which, because of a reliance upon mathematical and
statistical theories, allows an evaluation of the effectiveness of sampling
procedures. Another type of probability sampling is systematic random
sampling, in which the first unit to be collected from a population is randomly
selected, but all subsequent units are taken at fixed space or time intervals.
An example of systematic random sampling is the sampling of a waste lagoon
along a transect in which the first sampling point on the transect is 1 m from
a randomly selected location on the shore and subsequent sampling points are
located at 2-m intervals along the transect. The advantages of systematic
random sampling over simple random sampling and stratified random sampling are
the ease with which samples are identified and collected (the selection of the
first sampling unit determines the remainder of the units) and, sometimes, an
increase in precision. In certain cases, for example, systematic random
sampling might be expected to be a little more precise than stratified random
sampling with one unit per stratum because samples are distributed more evenly
over the population. As will be demonstrated shortly, disadvantages of
systematic random sampling are the poor accuracy and precision that can occur
when unrecognized trends or cycles occur in the population. For those reasons,
systematic random sampling is recommended only when a population is essentially
random or contains at most a modest stratification. In such cases, systematic
random sampling would be employed for the sake of convenience, with little
expectation of an increase in precision over other random sampling techniques.
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Probability sampling is contrasted with authoritative sampling, in which
an individual who is well acquainted with the solid waste to be sampled selects
a sample without regard to randomization. The validity of data gathered in
that manner is totally dependent on the knowledge of the sampler and although
valid data can sometimes be obtained, authoritative sampling is not recommended
for the chemical characterization of most wastes.
It may now be useful to offer a generalization regarding the four sampling
strategies that have been identified for solid wastes. If little or no
information is available concerning the distribution of chemical contaminants
of a waste, simple random sampling is the most appropriate sampling strategy.
As more information is accumulated for the contaminants of concern, greater
consideration can be given (in order of the additional information required)
to stratified random sampling, systematic random sampling, and, perhaps,
authoritative sampling.
The validity of a CI for the true mean (p) concentration of a chemical
contaminant of a solid waste is, as previously noted, based on the assumption
that individual concentrations of the contaminant exhibit a normal
di stri buti on. This is true regardless of the strategy that is employed to
sample the waste. Although there are computational procedures for evaluating
the correctness of the assumption of normality, those procedures are meaningful
only if a large number of samples are collected from a waste. Because sampling
plans for most solid wastes entail just a few samples, one can do little more
than superficially examine resulting data for obvious departures from normality
(this can be done by simple graphical methods), keeping in mind that even if
individual measurements of a chemical contaminant of a waste exhibit a
considerably abnormal distribution, such abnormality is not likely to be the
case for sample means, which are our primary concern. One can also compare the
mean of the sample (x) with the variance of the sample (s2). In a normally
distributed population, x would be expected to be greater than s2 (assuming
that the number of samples [n] is reasonably large). If that is not the case,
the chemical contaminant of concern may be characterized by a Poi son
distribution (x is approximately equal to s2) or a negative binomial
di stri buti on (x is less than s2). In the former circumstance, normality can
often be achieved by transforming data according to the square root
transformation. In the latter circumstance, normality may be realized through
use of the arcsine transformation. If either transformation is required, all
subsequent statistical evaluations must be performed on the transformed scale.
Finally, it is necessary to address the appropriate number of samples to
be employed in the chemical characterization of a solid waste. As has already
been emphasized, the appropriate number of samples is the least number of
samples required to generate a sufficiently precise estimate of the true mean
(p) concentration of a chemical contaminant of a waste. From the perspective
of most waste producers, that means the minimal number of samples needed to
demonstrate that the upper limit of the CI for \i is less than the applicable
regulatory threshold (RT). The formula for estimating appropriate sampling
effort (Table 9-1, Equation 8) indicates that increased sampling effort is
generally justified as s2 or the "t 20" value (probable error rate) increases
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and as A(RT - x) decreases. In a wel1-designed sampling plan for a solid
waste, an effort is made to estimate the values of x and s2 before sampling is
initia ted. Such preliminary estimates, which may be derived from information
pertaining to similar wastes, process engineering data, or limited analytical
studies, are used to identify the approximate number of samples that must be
collected from the waste. It is always prudent to collect a somewhat greater
number of samples than indicated by preliminary estimates of x and s2 since
poor preliminary estimates of those statistics can result in an underestimate
of the appropriate number of samples to collect. It is usually possible to
process and store the extra samples appropriately until analysis of the
initially identified samples is completed and it can be determined if analysis
of the additional samples is warranted.
9.1.1.3 Basic Sampling Strategies
It is now appropriate to present general procedures for implementing the
three previously introduced sampling strategies (simple random sampling,
stratified random sampling, and systematic random sampling) and a hypothetical
example of each sampling strategy. The hypothetical examples illustrate the
statistical calculations that must be performed in most situations likely to
be encountered by a waste producer and, also, provide some insight into the
efficiency of the three sampling strategies in meeting regulatory objectives.
The following hypothetical conditions are assumed to exist for all three
sampling strategies. First, barium, which has an RT of 100 ppm as measured in
the EP elutriate test, is the only chemical contaminant of concern. Second,
barium is discharged in particulate form to a waste lagoon and accumulates in
the lagoon in the form of a sludge, which has built up to approximately the
same thickness throughout the lagoon. Third, concentrations of barium are
relatively homogeneous along the vertical gradient (from the water-sludge
interface to the sludge-lagoon interface), suggesting a highly controlled
manufacturing process (little between-batch variation in barium concen-
trations). Fourth, the physical size of sludge samples collected from the
lagoon is as large as practical, and barium concentrations derived from those
samples are normally distributed (note that we do not refer to barium levels
in the samples of sludge because barium measurements are actually made on the
elutriate from EP toxicity tests performed with the samples). Last, a
preliminary study of barium levels in the elutriate of four EP toxicity tests
conducted with sludge collected from the lagoon several years ago identified
values of 86 and 90 ppm for material collected near the outfall (in the upper
third) of the lagoon and values of 98 and 104 ppm for material obtained from
the far end (the lower two-thirds) of the lagoon.
For all sampling strategies, it is important to remember that barium will
be determined to be present in the sludge at a hazardous level if the upper
limit of the CI for \i is equal to or greater than the RT of 100 ppm (Table 9-1,
Equations 6 and 7).
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9.1.1.3.1 Simple Random Sampling
Simple random sampling (Box 1) is performed by general procedures in which
preliminary estimates of x and s2, as well as a knowledge of the RT, for each
chemical contaminant of a solid waste that is of concern are employed to
estimate the appropriate number of samples (n) to be collected from the waste.
That number of samples is subsequently analyzed for each chemical contaminant
of concern. The resulting analytical data are then used to conclude
definitively that each contaminant is or is not present in the waste at a
hazardous concentration or, alternatively, to suggest a reiterative process,
involving increased sampling effort, through which the presence or absence of
hazard can be definitively determined.
In the hypothetical example for simple random sampling (Box 1),
preliminary estimates of x and sz indicated a sampling effort consisting of six
samples. That number of samples was collected and initially analyzed
generating analytical data somewhat different from the preliminary data (sz was
substantially greater than was preliminarily estimated). Consequently, the
upper limit of the CI was unexpectedly greater than the applicable RT,
resulting in a tentative conclusion of hazard. However, a reestimation of
appropriate sampling effort, based on statistics derived from the six samples,
suggested that such a conclusion might be reversed through the collection and
analysis of just one more sample. Fortunately, a resampling effort was not
required because of the foresight of the waste producer in obtaining three
extra samples during the initial sampling effort, which, because of their
influence in decreasing the final values of x, S^, t 20, and, consequently, the
upper limit of the CI -- values obtained from all nine samples -- resulted in
a definitive conclusion of nonhazard.
9.1.1.3.2 Stratified Random Sampling
Stratified random sampling (Box 2) is conducted by general procedures that
are similar to the procedures described for simple random sampling. The only
difference is that, in stratified random sampling, values of x and s2 are
calculated for each stratum in the population and then integrated into overall
estimates of those statistics, the standard deviation (s), sx, and the
appropriate number of samples (n) for all strata.
The hypothetical example for stratified random sampling (Box 2) is based
on the same nine sludge samples previously identified in the example of simple
random sampling (Box 1) so that the relative efficiencies of the two sampling
strategies can be fully compared. The efficiency generated through the process
of stratification is first evident in the preliminary estimate of n (Step 2 in
Boxes 1 and 2), which is six for simple random sampling and four for stratified
random sampling. (The lesser value for stratified sampling is the consequence
of a dramatic decrease in s2 which more than compensated for a modest increase
in A.) The most relevant indication of sampling efficiency is the value of Ss,
which is directly employed to calculate the CI. In the case of simple random
sampling, S^ is calculated as 2.58 (Step 9 in Box 1), and, for stratified
random sampling, S^ is determined to be 2.35 (Steps 5 and 7 in Box 2).
Consequently, the gain in efficiency attributable to stratification is
approximately 9% (0.23/2.58).
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BOX 1. STRATEGY FOR DETERMINING IF CHEMICAL CONTAMINANTS OF SOLID WASTES
ARE PRESENT AT HAZARDOUS LEVELS - SIMPLE RANDOM SAMPLING
Step General Procedures
1. Obtain preliminary estimates of x and s2 for each chemical contaminant of
a solid waste that is of concern. The two above-identified statistics are
calculated by, respectively, Equations 2a and 3a (Table 9-1).
2. Estimate the appropriate number of samples (n^ to be collected from the
waste through use of Equation 8 (Table 9-1) and Table 9-2. Derive
individual values of n: for each chemical contaminant of concern. The
appropriate number of samples to be taken from the waste is the greatest
of the individual r\1 values.
3. Randomly collect at least r\1 (or n2 - n 1 , n3 - n 2, etc., as will be
indicated later in this box) samples from the waste (collection of a few
extra samples will provide protection against poor preliminary estimates
of x and sz). Maximize the physical size (weight or volume) of all
samples that are collected.
4. Analyze the r\1 (or n 2 - n lt n 3 - n 2 etc.) samples for each chemical
contaminant of concern. Superficially (graphically) examine each set of
analytical data for obvious departures from normality.
5. Calculate x, s2, the standard deviation (s), and SR for each set of
analytical data by, respectively, Equations 2a, 3a, 4, and 5 (Table 9-1).
6. If x for a chemical contaminant is equal to or greater than the applicable
RT (Equation 7, Table 9-1) and is believed to be an accurate estimator of
p, the contaminant is considered to be present in the waste at a hazardous
concentration, and the study is completed. Otherwise, continue the study.
In the case of a set of analytical data that does not exhibit obvious
abnormality and for which x is greater than s2, perform the following
calculations with nontransformed data. Otherwise, consider transforming
the data by the square root transformation (if x is about equal to s2) or
the arcsine transformation (if x is less than s 2) and performing all
subsequent calculations with transformed data. Square root and arcsine
transformations are defined by, respectively, Equations 10 and 11 (Table
9-1).
7. Determine the CI for each chemical contaminant of concern by Equation 6
(Table 9-1) and Table 9-2. If the upper limit of the CI is less than the
applicable RT (Equations 6 and 7, Table 9-1), the chemical contaminant is
not considered to be present in the waste at a hazardous concentration and
the study is completed. Otherwise, the opposite conclusion is tentatively
reached.
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If a tentative conclusion of hazard is reached, reestimate the total
number of samples (n2) to be collected from the waste by use of Equation
8 (Table 9-1) and Table 9-2. When deriving n2, employ the newly
calculated (not preliminary) values of x and s2. If additional n2 - r\
samples of waste cannot reasonably be collected, the study is completed,
and a definitive conclusion of hazard is reached. Otherwise, collect
extra n2 - nl samples of waste.
Repeat the basic operations described in Steps 3 through 8 until the waste
is judged to be nonhazardous or, if the opposite conclusion continues
to be reached, until increased sampling effort is impractical.
Hypothetical Example
The preliminary study of barium levels in the elutriate of four EP
toxicity tests, conducted with sludge collected from the lagoon several
years ago, generated values of 86 and 90 ppm for sludge obtained from the
upper third of the lagoon and values of 98 and 104 ppm for sludge from the
lower two-thirds of the lagoon. Those two sets of values are not judged
to be indicative of nonrandom chemical heterogeneity (stratification)
within the lagoon. Therefore, preliminary estimates of x and s2 are
calculated as:
n
E x
7=1
+ 90 + 98 + 104
4
= 94.50 , and
(Equation 2a)
n
E x/
7=1
n
- (E
7=1
xf)2/n
n - 1
(Equation 3a)
35,916.00 - 35,721.00
3
= 65.00.
Based on the preliminary estimates of x and s2 as well as the knowledge
that the RT for barium is 100 ppm,
(1.6382) (65.00)
5.502
= 5.77.
(Equation 8)
As indicated above, the appropriate number of sludge samples (n^ to be
collected from the lagoon is six. That number of samples (plus three
extra samples for protection against poor preliminary estimates of x and
s2) is collected from the lagoon by a single randomization process (Figure
9-2). All samples consist of the greatest volume of sludge that can be
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WASTE
1
18
35
52
69
86
103
TX
—
239
409
113
^
87
•^'*lt+
~
>
/
r
90
PCl^oeA
1 93
—
93
~~
WASTE LAGOON
—
E
91
_
—
OUTFALL
\
«Ce.Ofj
89
L
_
— -
*
>$
I
DZ
_
OVERFLOW PIPE
J-
H&^
\+*
90
''
96
S
17
34
255
425
U
0
L(
O
'PER THIRD
: LAGOON
3WER TWO-THIRDS
: LAGOON
V
IMAGINARY SAMPLING GRID
LEGEND
1—425 Units in Sampling Grid
S Barium Concentrations (ppm)
Associated with Nine Samples of Sludge
Figure 9-2. Hypothetical sampling conditions in waste lagoon containing
sludge contaminated with barium. Barium concentrations associated with samples
of sludge refer to levels measured in the elutriate of EP toxicity tests
conducted with the samples.
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practically collected. The three extra samples are suitably processed and
stored for possible later analysis.
4. The six samples of sludge (n^ designated for immediate analysis generate
the following concentrations of barium in the EP toxicity test: 89, 90,
87, 96, 93, and 113 ppm. Although the value of 113 ppm appears unusual
as compared with the other data, there is no obvious indication that the
data are not normally distributed.
5. New values for x and s2 and associated values for the standard deviation
(s) and s-x are calculated as:
n
E xr
- Ill = 89 + 90+87 + 96 + 93 + 113 = ^^ (Equation 2a)
n n
E xf2 - (E xf)2/n
7=1 7=1
n _ i (Equation 3a)
= 54,224.00 - 53,770.67 = gQ ^
5 ' '
, (Equation 4)
s = fs7 = 9.52, and
s- = sljn = 9.52/,/S = 3.89. (Equation 5)
6. The new value for x (94.67) is less than the RT (100). In addition, x is
greater (only slightly) than s2 (90.67), and, as previously indicated, the
raw data are not characterized by obvious abnormality. Consequently, the
study is continued, with the following calculations performed with
nontransformed data.
7- CI = ~± t 2Q s- = 94.67 + (1.476X3.89) (Equation 6)
= 94.67 + 5.74.
Because the upper limit of the CI (100.41) is greater than the applicable
RT (100), it is tentatively concluded that barium is present in the sludge
at a hazardous concentration.
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8. n is now reestimated as:
(1.4762) (90.6_7^ = 6 95 (Equation 8)
A2 5.332
The value for n2 (approximately 7) indicates that an additional (n2 -
nl = 1) sludge sample should be collected from the lagoon.
The additional sampling effort is not necessary because of the three extra
samples that were initially collected from the lagoon. All extra samples
are analyzed, generating the following levels of barium for the EP toxicity
test: 93, 90, and 91 ppm. Consequently, x, s2 the standard deviation (s),
and s^ are recalculated as:
86+ 90 +...+ 91 _ 93 56 (Equation 2a)
n n
E X2 - (E x.)2/n ,r . . 0 .
1 ' (Equation 3a)
7=1 7=1
n - 1
79,254.00-78,773.78 __ 6Q
s = vs = 7.75, and . r . . ..
v (Equation 4)
s- = s/Jn = 7.757/9 = 2.58.
(Equation 5)
The value for x (93.56) is again less than the RT (100), and there is no
indication that the nine data points, considered collectively, are
abnormally distributed (in particular, x is now substantially greater than
s2). Consequently, CI, calculated with nontransformed data, is determined
to be:
CI = ~± t .. s- = 93.56 + (1.397) (2.58) ,r . . r,
•20 x (Equation 6)
= 93.56 + 3.60.
The upper limit of the CI (97.16) is now less than the RT of 100.
Consequently, it is definitively concluded that barium is not present in the
sludge at a hazardous level.
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BOX 2. STRATEGY FOR DETERMINING IF CHEMICAL CONTAMINANTS OF SOLID WASTES ARE
PRESENT AT HAZARDOUS LEVELS - STRATIFIED RANDOM SAMPLING
Step General Procedures
1. Obtain preliminary estimates of x and sz for each chemical contaminant of
a solid waste that is of concern. The two above-identified statistics are
calculated by, respectively, Equations 2b and 3b (Table 9-1).
2. Estimate the appropriate number of samples (fij) to be collected from the
waste through use of Equation 8 (Table 9-1) and Table 9-2. Derive
individual values of n1 for each chemical contaminant of concern. The
appropriate number of samples to be taken from the waste is the greatest of
the individual n1 values.
3. Randomly collect at least n1 (or n2 - nl, n3 - n2, etc., as will be indicated
later in this box) samples from the waste (collection of a few extra samples
will provide protection against poor preliminary estimates of x and s2).
If sk for each stratum (see Equation 3b) is believed to be an accurate
estimate, optimally allocate samples among strata (i.e., allocate samples
among strata so that the number of samples collected from each stratum is
directly proportional to sk for that stratum). Otherwise, proportionally
allocate samples among strata according to size of the strata. Maximize the
physical size (weight or volume) of all samples that are collected from the
strata.
4. Analyze the n1 (or n 2 - n 1 , n3 - n2 etc.) samples for each chemical
contaminant of concern. Superficially (graphically) examine each set of
analytical data from each stratum for obvious departures from normality.
5. Calculate x, s2, the standard deviation (s), and xs for each set of
analytical data by, respectively, Equations 2b, 3b, 4, and 5 (Table 9-1).
6. If x for a chemical contaminant is equal to or greater than the applicable
RT (Equation 7, Table 9-1) and is believed to be an accurate estimator of
p, the contaminant is considered to be present in the waste at a hazardous
concentration, and the study is completed. Otherwise, continue the study.
In the case of a set of analytical data that does not exhibit obvious
abnormality and for which x is greater than s2, perform the following
calculations with nontransformed data. Otherwise, consider transforming the
data by the square root transformation (if x is about equal to s2) or the
arcsine transformation (if x is less than s2) and performing all subsequent
calculations with transformed data. Square root and arcsine transformations
are defined by, respectively, Equations 10 and 11 (Table 9-1).
7. Determine the CI for each chemical contaminant of concern by Equation 6
(Table 9-1) and Table 9-2. If the upper limit of the CI is less than the
applicable RT (Equations 6 and 7, Table 9-1), the chemical contaminant is
not considered to be present in the waste at a hazardous concentration, and
the study is completed. Otherwise, the opposite conclusion is tentatively
reached.
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8. If a tentative conclusion of hazard is reached, reestimate the total number
of samples (n2) to be collected from the waste by use of Equation 8 (Table
9-1) and Table 9-2. When deriving n2, employ the newly calculated (not
preliminary) values of x and s2. If additional n2 - r\ samples of waste
cannot reasonably be collected, the study is completed, and a definitive
conclusion of hazard is reached. Otherwise, collect extra n2 - r\1 samples
of waste.
9. Repeat the basic operations described in steps 3 through 8 until the waste
is judged to be nonhazardous or, if the opposite conclusion continues to be
reached, until increased sampling effort is impractical.
Hypothetical Example
1. The preliminary study of barium levels in the elutriate of four EP toxicity
tests, conducted with sludge collected from the lagoon several years ago,
generated values of 86 and 90 ppm for sludge obtained from the upper third
of the lagoon and values of 98 and 104 ppm for sludge from the lower two-
thirds of the lagoon. Those two sets of values are not judged to be
indicative of nonrandom chemical heterogeneity (stratification) within the
lagoon. Therefore, preliminary estimates of x and sz are calculated as:
r
- — (1X88.00) (2X101.00) 0, ,7 , (Equation 2b)
x= E Uk xk = + = 96.67 , and
o o
k-l
r
2 v // 2 (1X8.00) (2X18.00) r, ,7
5 = E uk sk = 3 + 3 = 14-67 • (Equation 3b)
k=l
2. Based on the preliminary estimates of x and s2 as well as the knowledge that
the RT for barium is 100 ppm,
(1.3682) (14.67) 0 cc (Equation 8)
— = 3.00.
A2 3.332
As indicated above, the appropriate number of sludge samples (r^) to be
collected from the lagoon is four. However, for purposes of comparison with
simple random sampling (Box 1), six samples (plus three extra samples
for protection against poor preliminary estimates of x and s2) are
collected from the lagoon by a two-stage randomization process
(Figure 2). Because sk for the upper (2.12 ppm) and lower (5.66 ppm) strata
are not believed to be very accurate estimates, the nine samples to be
collected from the lagoon are not optimally allocated between the two
strata (optimum allocation would require two and seven samples to be
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collected from the upper and lower strata, respectively). Alternatively,
proportional allocation is employed: three samples are collected from the
upper stratum (which represents one-third of the lagoon), and six samples
are taken from the lower stratum (two-thirds of the lagoon). All samples
consist of the greatest volume of sludge that can be practically collected.
4. The nine samples of sludge generate the following concentrations of barium
in the EP toxicity test: upper stratum -- 89, 90, and 87 ppm; lower stratum
-- 96, 93, 113, 93, 90, and 91 ppm. Although the value of 113 ppm appears
unusual as compared with the other data for the lower stratum, there is no
obvious indication that the data are not normally distributed.
5. New values for x and s2 and associated values for the standard deviation (s)
and s; are calcul ated as:
r
,, ~ (1X88.67) (2X96.00) n~ cc
Ukxk= - - - + - - - = 93.56 , (Equation 2b)
k=l
2 y ,, 2 (1)(2.33) ^ (2)(73.60) ,q R4
s - 2. w^ s^. - + 4y.b4 , (Equation 3b)
k=l
s = /s7 = 7.06, and (Equation 4)
s- = s/v/n = 7.06/V/9 = 2.35. (Equation 5)
6. The new value for x (93.56) is less than the RT (100). In addition, x is
greater than s2 (49.84), and, as previously indicated, the raw data are not
characterized by obvious abnormality. Consequently, the study is continued,
with the following calculations performed with nontransformed data.
7. Cl = ~± t/M s- = 93.56 + (1.397X2. 35) (Equation 6)
= 93.56 + 3.28.
The upper limit of the CI (96.84) is less than the applicable RT (100).
Therefore, it is concluded that barium is not present in the sludge at a
hazardous concentration.
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9.1.1.3.3 Systematic Random Sampling
Systematic random sampling (Box 3) is implemented by general procedures
that are identical to the procedures identified for simple random sampling.
The hypothetical example for systematic random sampling (Box 3) demonstrates
the bias and imprecision that are associated with that type of sampling when
unrecognized trends or cycles exist in the population.
9.1.1.4 Special Considerations
The preceding discussion has addressed the major issues that are critical
to the development of a reliable sampling strategy for a solid waste. The
remaining discussion focuses on several "secondary" issues that should be
considered when designing an appropriate sampling strategy. These secondary
issues are applicable to all three of the basic sampling strategies that have
been identified.
9.1.1.4.1 Composi te Sampli ng
In composite sampling, a number of random samples are initially collected
from a waste and combined into a single sample, which is then analyzed for the
chemical contaminants of concern. The major disadvantage of composite
sampling, as compared with noncomposite sampling, is that information
concerning the chemical contaminants is lost, i.e., each initial set of samples
generates only a single estimate of the concentration of each contaminant.
Consequently, because the number of analytical measurements (n) is small, sx
and t 20 are large, thus decreasing the likelihood that a contaminant will be
judged to occur in the waste at a nonhazardous level (refer to appropriate
equations in Table 9-1 and to Table 9-2). A remedy to that situation is to
collect and analyze a relatively large number of composite samples, thereby
offsetting the savings in analytical costs that are often associated with
composite sampling, but achieving better representation of the waste than would
occur with noncomposite sampling.
The appropriate number of composite samples to be collected from a solid
waste is estimated by use of Equation 8 (Table 9-1), as previously described
for the three basic sampling strategies. In comparison with noncomposite
sampling, composite sampling may have the effect of minimizing between-sample
variation (the same phenomenon that occurs when the physical size of a sample
is maximized), thereby reducing somewhat the number of samples that must be
collected from the waste.
9.1.1.4.2 Subsampling
The variance (s2) associated with a chemical contaminant of a waste
consists of two components in that:
2 sa2 (Equation 12)
s = s + ,
m
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BOX 3. STRATEGY FOR DETERMINING IF CHEMICAL CONTAMINANTS OF SOLID WASTES
ARE PRESENT AT HAZARDOUS LEVELS - SYSTEMATIC RANDOM SAMPLING
Step General Procedures
1. Follow general procedures presented for simple random sampling of solid
wastes (Box 1).
yi Hypothetical Example
The example presented in Box 1 is applicable to systematic random sampling,
with the understanding that the nine sludge samples obtained from the lagoon
would be collected at equal intervals along a transect running from a
randomly selected location on one bank of the lagoon to the opposite bank.
If that randomly selected transect were established between Units 1 and 409
of the sampling grid (Figure 9-2) and sampling were performed at Unit 1 and
thereafter at three-unit intervals along the transect (i.e., Unit 1, Unit
52, Unit 103, ... , and Unit 409), it is apparent that only two samples
would be collected in the upper third of the lagoon, whereas seven samples
would be obtained from the lower two-thirds of the lagoon. If, as suggested
by the barium concentrations illustrated in Figure 9-2, the lower part of
the lagoon is characterized by greater and more variable barium
contamination than the upper part of the lagoon, systematic random sampling
along the above-identified transect, by placing undue (disproportionate)
emphasis on the lower part of the lagoon, might be expected to result in an
inaccurate (overestimated) and imprecise characterization of barium levels
in the whole lagoon, as compared with either simple random sampling or
stratified random sampling. Such inaccuracy and imprecision, which are
typical of systematic random sampling when unrecognized trends or cycles
occur in the population, would be magnified if, for example, the randomly
selected transect were established solely in the lower part of the lagoon,
e.g., between Units 239 and 255 of the sampling grid.
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where s2s = a component attributable to sampling (sample) variation, | = a
component attributable to analytical (subsample) variation, and m = number of
subsamples. In general, s2, should not be allowed to exceed one-ninth of szs. If
a preliminary study indicates that s2a exceeds that threshold, a sampling
strategy involving subsampling should be considered. In such a strategy, a
number of replicate measurements are randomly made on a relatively limited
number of randomly collected samples. Consequently, analytical effort is
allocated as a function of analytical variability. The efficiency of that
general strategy in meeting regulatory objectives has already been demonstrated
in the previous discussions of sampling effort.
The appropriate number of samples (n) to be collected from a solid waste
for which subsampling will be employed is again estimated by Equation 8 (Table
9-1). In the case of simple random sampling or systematic random sampling with
an equal number of subsamples analyzed per sample:
n
~ = E x.ln,
7=1
(Equation 13)
where xt = sample mean (calculated from values for subsamples) and n = number
of samples. Also,
n n
EI~2 - (E~)2/n
7=1 7=1
n - 1
(Equation 14)
The optimum number of subsamples to be taken from each sample (mopt ) is
estimated as:
m
(Equation 15)
when cost factors are not considered. The value for sa is calculated from
available data as:
/ j / J S\ ,• -: \ / -> S\ • • j
' , / / /
n (m - 1)
(Equation 16)
and ss, which can have a negative characteristic, is defined as:
(Equation 17)
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with s2 calculated as indicated in Equation 14.
In the case of stratified random sampling with subsampling, critical
formulas for estimating sample size (n) by Equation 8 (Table 9-1) include:
x = E lflk xk
/c=l
(Equation 2b)
where xk = stratum mean and W k = fraction of population represented by Stratum
K (number of strata, k, ranges from 1 to r). In Equation 2b, xk for each
stratum is calculated as the average of all sample means in the stratum (sample
means are calculated from values for subsamples). In addition, sz is
calculated by:
s'
= Ł w,
k=l
S,
(Equation 3b)
with s \ for each stratum calculated from all sample means in the stratum. The
optimum subsampling effort when cost factors are not considered and all
replication is symmetrical is again estimated as:
— , with
(Equation 15)
S =
E E E xL< - (E Xt..)z/m
rn (m - 1)
and
(Equation 18)
\
s -
(Equation 17)
with s2 derived as shown in Equation 3b.
9.1.1.5 Cost and Loss Functions
The cost of chemically characterizing a waste is dependent on the
specific strategy that is employed to sample the waste. For example, in the
case of simple random sampling without subsampling, a reasonable cost function
might be:
C
(Equation 19)
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where C(n) = cost of employing a sample size of n, C0 = an overhead cost (which
is independent of the number of samples that are collected and analyzed), and
Cj = a sample-dependent cost. A consideration of Qn) mandates an evaluation
of L(n), which is the sample-size-dependent expected financial loss related to
the erroneous conclusion that a waste is hazardous. A simple loss function is:
/.(n) = —, (Equation 20)
with a = a constant related to the cost of a waste management program if the
waste is judged to be hazardous, s2 = sample variance, and n = number of
samples. A primary objective of any sampling strategy is to minimize C(n) +
L(n). Differentiation of Equations 19 and 20 indicates that the number of
samples (n) that minimize C(n) + L(n) is:
n =
(Equation 21)
As is evident from Equation 21, a comparatively large number of samples (n) is
justified if the value of a or sz is large, whereas a relatively small number
of samples is appropriate if the value of C1 is large. These general
conclusions are valid for any sampling strategy for a solid waste.
9.2 IMPLEMENTATION
This section discusses the implementation of a sampling plan for the
collection of a "solid waste," as defined by Section 261.2 of the Resource
Conservation and Recovery Act (RCRA) regulations. Due to the uniqueness of
each sampling effort, the following discussion is in the general form of
guidance which, when applied to each sampling effort, should improve and
document the quality of the sampling and the representativeness of samples.
The following subsections address elements of a sampling effort in a
logical order, from defining objectives through compositing samples prior to
analysis.
9.2.1 Definition Of Objectives
After verifying the need for sampling, those personnel directing the
sampling effort should define the program's objectives. The need for a
sampling effort should not be confused with the objective. When management,
a regulation, or a regulatory agency requires sampling, the need for sampling
is established but the objectives must be defined.
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The primary objective of any waste sampling effort is to obtain
information that can be used to evaluate a waste. It is essential that the
specific information needed and its uses are defined in detail at this stage.
The information needed is usually more complex than just a concentration of a
specified parameter; it may be further qualified (e.g., by sampling location
or sampling time.) The manner in which the information is to be used can also
have a substantial impact on the design of a sampling plan. (Are the data to
be used in a qualitative or quantitative manner? If quantitative, what are the
accuracy and precision requirements?)
All pertinent information should be gathered. For example, if the
primary objective has been roughly defined as "collecting samples of waste
which will be analyzed to comply with environmental regulations," then ask the
following questions:
1. The sampling is being done to comply with which environmental
regulation? Certain regulations detail specific or minimum
protocols (e.g., exclusion petitions as defined in §260.22 of the
RCRA regulations); the sampling effort must comply with these
regulatory requirements.
2. The collected samples are to be analyzed for which parameters?
Why those and not others? Should the samples be analyzed for more
or fewer parameters?
3. What waste is to be sampled: the waste as generated? The waste
prior to or after mixing with other wastes or stabilizing
agents? The waste after aging or drying or just prior to
disposal? Should waste disposed of 10 years ago be sampled to
acquire historical data?
4. What is the end-use of the generated data base? What are the
required degrees of accuracy and precision?
By asking such questions, both the primary objective and specific
sampling, analytical, and data objectives can be established.
Two sampling efforts could have identical primary objectives but
different specific objectives. For example, consider two situations in which
the primary objective is to determine if the concentration of barium is less
than the regulatory threshold of 100 ppm. The specific objectives will vary
and have a substantial effect on sampling. (This situation is presented
graphically in Figures 9-3 and 9-4.) In Figure 9-3, under the assumption that
the true distribution of barium concentrations throughout the waste of interest
is as shown, limited information has indicated that the average concentration
is approximately 50 ppm. In Figure 9-4, assume that historical data indicated
an average concentration of 90 ppm and the true distribution of barium
concentrations is as shown. Therefore, the specific data objective for the
latter case is to generate a data base that can discriminate between 90 and 100
ppm, whereas in the former case the data objective is to discriminate between
50 and 100 ppm. Greater accuracy and precision are required to discriminate
between 90 and 100 ppm; this fact will affect the number, size, and degree of
compositing of samples collected and analyzed.
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1 0.3-
"o
Ł0.2-
«
§.
Ł
LL
0.1-
Sampl<
/-
Confidence /
Interval /
Lower \ /
(LL)*y
y
• Mean = True Mean
\
\
\
\ Upper
\ Limit Rpgnlfltory
M(UL) Threshold (RT)
i
•
25 50 75
Concentration of Barium (ppm)
100
Distance of true value from regulatory threshold
requires less accuracy and precision.
Figure 9 - 3.
threshold.
Distribution of barium concentration removed from a regulatory
0.4-J
Sample Mean Ł True Mean
>
3
0.3-
0.2.
0.1-
Upper
i Limit
! (UL)
! | Regulatory
! Threthold (RT)
85 OO OS 10O
Concentration of Barium (ppm)
Proximity of true value from regulatory threshold
requires more accuracy and precision.
Figure
threshold.
Distribution of barium concentration near a regulatory
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The form in Figure 9-5 can be used to document primary and specific
objectives prior to development of a sampling plan. Once the objectives of a
sampling effort are developed, it is important to adhere to them to ensure that
the program maintains its direction.
9.2.2 Sampling Plan Considerations
The sampling plan is usually a written document that describes the
objectives and details the individual tasks of a sampling effort and how they
will be performed. (Under unusual circumstances, time may not allow for the
sampling plan to be documented in writing, e.g., sampling during an emergency
spill. When operating under these conditions, it is essential that the person
directing the sampling effort be aware of the various elements of a sampling
plan.) The more detailed the sampling plan, the less the opportunity for
oversight or misunderstanding during sampling, analysis, and data treatment.
To ensure that the sampling plan is designed properly, it is wise to have
all aspects of the effort represented. Those designing the sampling plan
should include the following personnel:
1. An end-user of the data, who will be using the data to attain
program objectives and thus would be best prepared to ensure that
the data objectives are understood and incorporated into the
sampling pi an.
2. An experienced member of the field team who will actually collect
samples, who can offer hands-on insight into potential problems
and solutions, and who, having acquired a comprehensive
understanding of the entire sampling effort during the design
phase, will be better prepared to implement the sampling plan.
3. An analytical chemist, because the analytical requirements for
sampling, preservation, and holding times will be factors around
which the sampling plan will be written. A sampling effort cannot
succeed if an improperly collected or preserved sample or an
inadequate volume of sample is submitted to the laboratory for
chemical, physical, or biological testing. The appropriate
analytical chemist should be consulted on these matters.
4. An engineer should be involved if a complex manufacturing process
is being sampled. Representation of the appropriate engineering
discipline will allow for the optimization of sampling locations
and safety during sampling and should ensure that all waste-stream
variations are accounted for.
5. A statistician, who will review the sampling approach and verify
that the resulting data will be suitable for any required
statistical calculations or decisions.
6. A quality assurance representative, who will review the
applicability of standard operating procedures and determine the
number of blanks, duplicates, spike samples, and other steps
required to document the accuracy and precision of the resulting
data base.
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Sampli ng Si te:
Address:
Description of Waste to be Sampled:
Primary Objective:
Specific Sampling Objectives:
Specific Analysis Objectives:
Specific Data Objectives:
Figure 9-5. Form for Documenting Primary and Specific Objectives
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At least one person should be familiar with the site to be sampled. If
not, then a presampling site visit should be arranged to acquire site-specific
information. If no one is familiar with the site and a presampling site visit
cannot be arranged, then the sampling plan must be written so that it can
address contingencies that may occur.
Even in those cases in which a detailed sampling plan is authored and a
comprehensive knowledge of the site exists, it is unusual for a sampling plan
to be implemented exactly as written. Waste-stream changes, inappropriate
weather, sampling equipment failure, and problems in gaining access to the
waste are some reasons why a sampling plan must be altered. Thus it is always
necessary to have at least one experienced sampler as a member of a sampling
team.
The sampling plan should address the considerations discussed below.
9.2.2.1 Statistics
A discussion of waste sampling often leads to a discussion of statistics.
The goals of waste sampling and statistics are identical, i.e., to make
inferences about a parent population based upon the information contained in
a sample.
Thus it is not surprising that waste sampling relies heavily upon the
highly developed science of statistics and that a sampling/analytical effort
usually contains the same elements as does a statistical experiment.
Analogously, the Harris pollster collects opinions from randomly chosen people,
whereas environmental scientists collect waste at randomly chosen locations or
times. The pollster analyzes the information into a useable data base;
laboratories analyze waste samples and generate data. Then the unbiased data
base is used to draw inferences about the entire population, which for the
Harris pollster may be the voting population of a large city, whereas for the
environmental scientist the population may mean the entire contents of a
landfill.
During the implementation of a waste sampling plan or a statistical
experiment, an effort is made to minimize the possibility of drawing incorrect
inferences by obtaining samples that are representative of a population. In
fact, the term "representative sample" is commonly used to denote a sample that
(1) has the properties and chemical composition of the population from which
it was collected, and (2) has them in the same average proportions as are found
in the population.
In regard to waste sampling, the term "representative sample" can be
misleading unless one is dealing with a homogeneous waste from which one sample
can represent the whole population. In most cases, it would be best to
consider a "representative data base" generated by the collection and analysis
of more than one sample that defines the average properties or composition of
the waste. A "representative data base" is a more realistic term because the
evaluation of most wastes requires numerous samples to determine the average
properties or concentrations of parameters in a waste. (The additional samples
needed to generate a representative data base can also be used to determine the
variability of these properties or concentrations throughout the waste
populati on . )
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Statisticians have developed a number of strategies to obtain samples
that are unbiased and collectively representative of a population. A detailed
discussion of these strategies is presented in Section 9.1 of this chapter.
The following discussion of statistical considerations is a less technical
summary of these strategies. It was written to complement Section 9.1 and will
be most useful after Section 9.1 is read and studied.
Section 9.1 describes three basic sampling strategies: simple random,
stratified random, and systematic random sampling. It should be noted that the
word random has more than one meaning. When used in statistical discussions,
it does not mean haphazard: it means that every part of a waste has a
theoretically equal chance of being sampled. Random sampling, which entails
detailed planning and painstaking implementation, is distinctly different from
haphazard sampling, which may introduce bias into the collection of samples and
the resulting data.
Systematic random sampling and authoritative sampling strategies require
a substantial knowledge of the waste to ensure that: (1) a cycle or trend in
waste composition does not coincide with the sampling locations: or (2) in the
case of authoritative sampling, all or most of the assumptions regarding waste
composition or generation are true. Because the variabilities of waste
composition and the waste generation process are often unknown, systematic
random and authoritative sampling strategies are usually not applicable to
waste evaluation.
Therefore, for waste sampling, the usual options are simple or stratified
random sampling. Of these two strategies, simple random sampling is the option
of choice unless: (1) there are known distinct strata divisions) in the waste
over time or in space: (2) one wants to prove or disprove that there are
distinct time and/or space strata in the waste of interest; or (3) one is
collecting a minimum number of samples and desires to minimize the size of a
hot spot (area of high concentration) that could go unsampled. If any of these
three conditions exists, it may be determined that stratified random sampling
would be the optimum strategy. To explain how these strategies can be
employed, a few examples follow:
Example 1: Simple Random Sampling of Tanks
A batch manufacturing process had been generating a liquid waste over a
period of years and storing it in a large open-top tank. As this tank
approached capacity, some of the waste was allowed to overflow to a smaller
enclosed tank. This smaller tank allowed for limited access through an
inspection port on its top.
Because the on-site tank storage was approaching capacity, it was
determined that the waste would have to be disposed of off-site.
The operators of the facility had determined that the waste was a
nonhazardous solid waste when the RCRA regulations were first promulgated.
However, upon recent passage of more stringent state regulations and concerns
of potential liability, the operators determined that they should perform a
more comprehensive analysis of the waste.
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Because the waste was generated in a batch mode over a period of years,
the operators were concerned that the waste composition might have varied
between batches and that stratification might have occurred in the tank at
unknown and random depths. Based on their knowledge, the operators knew that
a grab sample would not suffice and that a sampling program would have to be
designed to address the heterogeneity of the waste.
Because the operators intended to dispose of the entire contents of the
tank and lacked any specific information regarding stratification and
variability of the waste, it was decided that a simple random strategy would
be employed. (If the operators had treated portions of the waste differently
or had been aware of distinct strata, then stratified random sampling might
have been more appropriate.)
The large, unenclosed tank had a diameter of 50 ft, a height of 20 ft,
and an approximate volume of 295,000 gal allowed. It was encircled and
traversed by catwalks (refer to Figure 9-6), which allowed access to the entire
waste surface. The smaller tank had a diameter of 10 ft, a height of 10 ft,
and an approximate volume of 6,000 gal: an inspection port located on the top
allowed limited access. It was determined that the different construction of
the two tanks would require different simple random sampling approaches.
In the case of the large tank, it was decided that vertical composite
samples would be collected because the operators were interested in the average
composition and variability of the waste and not in determining if different
vertical strata existed. It was decided to select points randomly along the
circumference (157 ft) and along the radius (25 ft). These numbers, which
would constitute the coordinates of the sampling locations, were chosen from
a random-number table by indiscriminately choosing a page and then a column on
that page. The circumference coordinates were then chosen by proceeding down
the column and listing the first 15 numbers that are greater than or equal to
0, but less than or equal to 157. The radius coordinates were chosen by
continuing down the column and listing the first 15 numbers that are greater
than or equal to 0, but less than or equal to 25. These numbers were paired
to form the coordinates that determined the location of the 15 randomly chosen
sampling points. These coordinates were recorded in the field notebook (refer
to Table 9-3). Because no precision data on waste composition existed prior
to sampling, the number of samples (15) was chosen as a conservative figure to
more than allow for a sound statistical decision.
The actual samples were collected by employing a sampling device, which
was constructed on site from available materials, and a weighted bottle. This
device, which was used to access more remote areas of the tank, consisted of
a weighted bottle, a rope marked off at 1-ft increments, and a discarded spool
that originally contained electrical wire (refer to Figure 9-7).
Samples were collected by a three-person team. The person controlling
the weighted bottle walked to the first circumference coordinate (149 ft),
while the two persons holding the ropes attached to the spool walked along
opposing catwalks toward the center of the tank. The person controlling the
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15
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TABLE 9-3. RANDOM COORDINATES FOR 295,000-GAL TANK
Sampling Point Circumference Radius
1 149 4
2 86 22
3 94 13
4 99 0
5 23 10
6 58 2
7 52 22
8 104 16
9 23 25
10 51 4
11 77 14
12 12 5
13 151 15
14 83 23
15 99 18
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Trip Cord
Rope to circumference catwalk
Rope to radial catwalk
Rope to opposite radial catwalk
Figure 9-7. Device used to collect sample from the open tank.
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weighted bottle measured off the radius coordinate (4 ft). The spool was then
centered in the quadrant, the weighted bottle was lowered to the surface, and
a sample was collected from the first 2 ft of waste. This sample was then
transferred into a large, labeled sample container, which was used for
compositing. This same process was repeated nine more times at the same
location at different 2-ft depth intervals, resulting in the collection of a
total of 10 component depth samples that were compiled in the field into one
sample for that sampling point. This process was repeated at the remaining 14
sampling points, resulting in the collection of 15 vertical composite samples.
These vertical composite samples were taken to address any vertical
stratification that may have occurred.
The samples were properly preserved and stored, chain-of-custody
procedures were completed, and the samples were submitted to the laboratory.
A cost/benefit decision was made to composite aliquots of the samples into five
composite samples that were submitted for analysis. (Following analysis,
Equation 8 of Section 9.1 of this chapter was employed to determine if enough
samples were analyzed to make a statistically sound decision. If the number
of samples analyzed was not sufficient, then the samples would be recomposited
to a lesser degree or analyzed individually.)
Because there was no information to prove that the waste in the smaller
tank was the same as that in the larger tank, the operators decided that the
smaller tank must also be sampled. The different construction of the smaller,
enclosed tank mandated that a different sampling plan be designed. The only
access to the tank was through a small inspection port on the top of the tank.
This port would allow sampling only of a small portion of the tank contents;
thus, to make a decision on the entire contents of the tank, one would have to
assume that the waste in the vicinity of the inspection port was representative
of the remainder of the tank contents. The operators were not willing to make
this assumption because they determined that the liability of an incorrect
decision overrode the convenience of facilitating the sampling effort.
To randomly sample the entire contents of the tank, a different plan was
designed. This plan exploited the relatively small volume (approximately 6,000
gal) of the tank. A decision was made to rent two tank trucks and to sample
the waste randomly over time as it drained from the tank into the tank trucks.
It was calculated that at a rate of 20 gal/min, it would take 300 min to
drain the tank. From the random-number tables, 15 numbers that were greater
than or equal to 0, but less than or equal to 300, were chosen in a manner
similar to that employed for the larger tank. These numbers were recorded in
the field notebook (refer to Table 9-4) at the time that they were encountered
in the random-number table and were then assigned sampling point numbers
according to their chronological order.
The 15 samples were collected at the previously chosen random times as
the waste exited from a drainage hose into the tank trucks. These samples were
collected in separate labeled containers, properly preserved and stored; chain-
of-custody procedures were employed for transferral of the samples to the
1 aboratory.
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TABLE 9-4. RANDOM TIMES FOR 6,000-GAL TANK
Sampling point Time (min)
11 153
10 122
8 85
6 55
5 46
15 294
12 195
1 5
13 213
9 99
2 29
4 41
7 74
3 31
14 219
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The above example employed simple random sampling to determine the
average composition and variance of the waste contained in the two tanks. The
contents of the large tank were sampled randomly in space, whereas the contents
of the smaller tank were sampled randomly over time.
The following example will involve the use of stratified random sampling,
which is used when: (1) distinct strata are known to exist or (2) it is not
known whether different strata exist, but an objective of the sampling effort
is to discover the existence or nonexistence of strata.
A variation of this second reason for employing stratified random
sampling is when cost considerations limit the number of samples that can be
collected (e.g., when the budget allows for the collection of only six samples
in a 40-acre lagoon). In this situation, where little is known about the
composition of the waste, a concern exists that an area of the lagoon may be
highly contaminated and yet may not be sampled. The smaller the number of
samples, the greater the probability that an area of high contamination (a
distinct stratum) could be missed, and the greater the probability that the
sampling accuracy will suffer. Under such circumstances, a sampling plan may
employ stratified random sampling to minimize the size of a highly contaminated
area that could go unsampled.
For example, consider the situation where the budget allows only for the
collection of six samples in a 40-acre lagoon. If simple random sampling is
employed with such a small number of samples, there is a certain probability
that large areas of the lagoon may go unsampled. One approach to minimizing
the size of areas that may go unsampled is to divide the lagoon into three
strata of equal size and randomly sample each stratum separately. This
approach decreases the size of an area that can go unsampled to something less
than one-third of the total lagoon area.
The following example details more traditional applications of stratified
random sampli ng.
Example 2: Stratified Random Sampling of Effluents and Lagoons
A pigment manufacturing process has been generating wastes over a number
of years. The pigment is generated in large batches that involve a 24-hr
cycle. During the first 16 hr of the cycle, an aqueous sludge stream is
discharged. This waste contains a high percentage of large-sized black
particulate matter. The waste generated during the remaining 8 hr of the
manufacturing cycle is an aqueous-based white sludge that consists of much
smaller-sized particles than those found in the sludge generated in the first
16 hr of the batch process. This waste has been disposed of over the years
into a 40-acre settling lagoon, allowing the particulate matter to settle out
of solution while the water phase drains to an NPDES outfall at the opposite
end of the lagoon. The smaller white pigment particles released in the last
8 hr of the batch process settle more slowly than the much larger black
particles generated in the previous 16 hr. This settling pattern is quite
apparent from the distinct colors of the wastes. The sludge in the quadrant
closest to the waste influent pipe is black; the next quadrant is a light gray
color, resulting from settling of both waste streams. The last two quadrants
contain a pure white sludge, resulting from the settling of the small pigment
parti cles.
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Eventually, the facility operators decided that the settled participate
matter had to be removed to keep the settling lagoon functioning. In the past,
this residual lagoon waste was found to be a hazardous waste due to its
Teachable barium content. Further studies determined that the source of the
barium was a certain raw material that was released during the first 16 hr of
batch process.
To minimize present disposal costs, the operators wanted to determine if
the white sludge in the last two quadrants and the light gray waste were
nonhazardous. Also, the operators had recently changed raw materials, with the
intention of removing the source of barium in an attempt to minimize future
disposal costs. Thus, the operators were interested in determining whether the
currently generated waste was hazardous. If the altered waste stream was not
hazardous, future lagoon sludge could be disposed of more economically as a
solid waste. If the waste generated during the first 16 hr of the process
remained hazardous but the waste generated during the following 8 hr was
nonhazardous, the operators were willing to shift this latter waste to a second
lagoon reserved for nonhazardous wastes. By sequestering the waste streams in
this manner, the operators intended to decrease the amount of hazardous waste
by precluding generation of additional amounts of hazardous waste under the
"mixture rule."
To decide how the lagoon sludge should be handled, the operators arranged
to have the lagoon sludge sampled. The objectives of sampling the lagoon
sludge were to determine the average concentration and variance of Teachable
barium for the sludge in the entire lagoon and for each of the different
siudges.
The dimensions of the 40-acre square lagoon were calculated to be 1,320
ft on a side, with the black and the gray sludge each covering a quadrant
measuring 1,320 ft by 330 ft, and the white sludge covering the remaining area
of the lagoon, which measured 1,320 ft by 660 ft (refer to Figure 9-8). The
sludge had settled to a uniform thickness throughout the lagoon and was covered
with 2 ft of water.
Because the Teachable barium was assumed to be associated with the black
sludge, which was concentrated in the first quadrant, a stratified random
sampling approach was chosen. (Because of the obvious strata in the lagoon
sludge, the stratified sampling strategy was expected to give a more precise
estimate of the Teachable barium, in addition to giving information specific
to each stratum.)
When the actual sampling was being planned, it was decided that the
hazards presented by the lagoon waste were minimal, and, that if proper
precautions were employed, a stable and unsinkable boat could be used to
collect samples. The samples were collected with a core sampler at random
locations throughout each stratum. Because the cost of collecting samples was
reasonable and no historical data were available to help determine the optimum
number of samples, the operators decided to collect a total of 10 samples from
each of the smaller strata and a total of 20 samples from the larger strata.
They had confidence that this number of samples would allow them to detect a
small significant difference between the mean concentration of Teachable barium
and the applicable regulatory threshold.
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CJ
g
CO
CO
o
Overflow Pipe
Figure 9-8. Schematic of the 40-acre settling lagoon displaying strata
generated by a waste stream.
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The locations of the random sampling points were determined by selecting
length and width coordinates from a random-number table. This was done by
indiscriminately choosing a page from the random-number tables and then a
column on that page. The width coordinates of the two smaller quadrants were
then chosen by proceeding down the column and listing the first 20 numbers that
were greater than or equal to 0, but less than or equal to 330. The width
coordinate for the third and largest stratum was chosen by proceeding down the
column and selecting the first 20 numbers that were greater than or equal to
0, but less than or equal to 660. Because the lengths of the three quadrants
were all 1,320 ft, the length coordinates were chosen by listing the first 40
numbers that were greater than or equal to 0 but less than or equal to 1,320.
These coordinates were recorded in the field notebook (refer to nable 9-5).
The samples were collected by a four-person team. Two people remained
onshore while two maneuvered the boat and collected the samples. The first
sample in the first quadrant was collected by launching the boat at a distance
of 41 ft from the corner, which was designated the origin, 0 ft. The boat
proceeded out into the lagoon perpendicular to the long side of the quadrant.
The person onshore released 134 ft of a measured rope, which allowed the boat
to stop at the first sampling point (41, 134). The sample was then collected
with a core sampler and transferred to a sample container. This process was
repeated for all sampling points in the three strata. The samples were
properly preserved and stored, and the chain-of-custody records documented the
transfer of samples to the laboratory.
Aliquots of the samples were composited into five composite samples for
each stratum. The mean and variance of each stratum were calculated by
Equations 2(a) and 3(a), respectively. The mean and variance for the total
lagoon were calculated by using Equations 2(b) and 3(b), respectively.
Equation 6 was used to calculate a confidence interval for the Teachable barium
concentration, and the upper limit of this interval was compared with the
regulatory threshold. (See Table 9-1, Section 9.1 of this chapter, for
equati ons.)
As previously mentioned, the operators had recently changed their raw
materials and were also interested in discovering if the currently generated
waste was nonhazardous or if portions of this waste stream were nonhazardous.
As described above, the waste effluent for the first 16 hr of the day was
different from that discharged during the last 8 hr. However, because the same
large plumbing system was used for both waste streams, there were two 2-hr
periods during which the discharged waste was a mixture of the two different
wastes.
With the above objectives in mind, the operators decided to employ
stratified random sampling with four strata occurring over time, as opposed to
the strata in space that were employed for sampling the lagoon. The four time
strata were from 6:00 to 8:00 hr, from 8:00 to 20:00 hr, from 20:00 to 22:00
hr, and from 22:00 to 6:00 hr the following day. The two 2-hr strata were
those time periods during which the waste was a mixture of the two different
waste streams. The 12-hr stratum was the time period during which the large-
sized particulate black waste was being discharged. The smaller particulate
white waste was being discharged during the 8-hr stratum.
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TABLE 9-5.RANDOM COORDINATES FOR EACH STRATUM
IN THE 40-ACRE SETTLING LAGOON
Sampl i ng
Point
Stratum #1 1
(Black) 2
3
4
5
6
7
8
9
10
Stratum #2 1
(Gray) 2
3
4
5
6
7
8
9
10
Stratum #3 1
(White) 2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Length
(ft)
41
271
968
129
472
1,198
700
286
940
151
1,173
277
438
780
525
50
26
1,207
1,231
840
54
909
1,163
1,251
1
1,126
717
1,155
668
66
462
213
1,220
1,038
508
1,293
30
114
1,229
392
Width
(ft)
134
51
32
228
137
56
261
8
26
121
109
2
302
5
135
37
127
149
325
32
374
434
390
449
609
140
235
148
433
642
455
305
541
644
376
270
38
52
570
613
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The flow rate was constant throughout the 24-hr period, and there were
no precision data available for the waste. Therefore, it was decided that the
number of samples collected in the 8- and 12-hr strata would be proportional
to time. Because the 2-hr periods were times during which the composition of
the waste was changing, it was decided to collect more samples to get a more
precise estimate of the average composition of the waste during these time
strata. Thus a total of 28 samples was collected.
The samples were collected at randomly chosen times within each time
stratum. The random sampling times were chosen by employing a random-number
table. After indiscriminately selecting a starting point, the first four
numbers greater than or equal to 0, but less than or equal to 120 were selected
for the 120-min strata from 6:00 to 8:00 hr. These minutes were then added to
the starting time to determine when the four samples would be collected. In
similar fashion, the remaining 24 sampling times were chosen. The random-
number data were recorded in a laboratory notebook (refer to Table 9-6).
The samples were collected from the waste influent pipe with a wide-mouth
bottle at the randomly chosen sampling times. The samples were properly
preserved and stored and shipped to the laboratory, along with chain-of-custody
records. The samples were subjected to analysis, and the data were evaluated
in a manner similar to that employed for the samples of sludge collected in the
different strata of the lagoon.
The sampling plan must address a number of factors in addition to
statistical considerations. Obviously, one of the most important factors is
the waste itself and its properties. The following waste properties are
examples of what must be considered when designing a sampling plan:
1. Physical state: The physical state of the waste will affect most
aspects of a sampling effort. The sampling device will vary
according to whether the sample is liquid, gas, solid, or
multiphasic. It will also vary according to whether the liquid is
viscous or free-flowing, or whether the solid is hard or soft,
powdery, monolithic, or clay-like.
Wide-mouth sample containers will be needed for most solid samples
and for sludges or liquids with substantial amounts of suspended
matter. Narrow-mouth containers can be used for other wastes, and
bottles with air-tight closures will be needed for gas samples or
gases adsorbed on solids or dissolved in liquids.
The physical state will also affect how sampling devices are
deployed. A different plan will be developed for sampling a soil-
like waste that can easily support the weight of a sampling team
and its equipment than for a lagoon filled with a viscous sludge
or a liquid waste.
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TABLE 9-6. RANDOM TIMES FOR THE WASTE EFFLUENT
Stratum #1
(6:00 to 8:00
hours )
Stratum #2
(8:00 to 20:00
hours)
Stratum #3
(20:00 to 22:00
hours )
Stratum #4
(22:00 to 6:00
hours)
Sampl i ng
Point
1
2
3
4
1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
1
2
3
4
5
6
7
8
Random
Mi nute
28
62
99
112
11
107
156
173
296
313
398
497
555
600
637
706
13
52
88
108
48
113
153
189
227
290
314
474
Time
6:28
7:02
7:39
7:52
8:11
9:47
10:36
10:53
12:56
13:13
14:38
16:17
17:15
18:00
18:37
19:46
20:13
20:52
21:28
21:48
22:48
23:53
24:33
1:09
1:47
2:49
3:14
5:44
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The sampling strategy will have to vary if the physical state of
the waste allows for stratification (e.g., liquid wastes that vary
in density or viscosity or have a suspended solid phase),
homogenization or random heterogeneity.
2. Volume: The volume of the waste, which has to be represented by
the samples collected, will have an effect upon the choice of
sampling equipment and strategies. Sampling a 40-acre lagoon
requires a different approach from sampling a 4-sq-ft container.
Although a 3-ft depth can be sampled with a Coliwasa or a drum
thief, a weighted bottle may be required to sample a 50-ft depth.
3. Hazardous properties: Safety and health precautions and methods
of sampling and shipping will vary dramatically with the toxicity,
ignitabi1ity , corrosivity, and reactivity of the waste.
4. Composi ti on: The chosen sampling strategy will reflect the
homogeneity, random heterogeneity, or stratification of the waste
in time or over space.
9.2.2.3 Site
Site-specific factors must be considered when designing a sampling plan.
A thorough examination of these factors will minimize oversights that can
affect the success of sampling and prevent attainment of the program
objectives. At least one person involved in the design and implementation of
the sampling plan should be familiar with the site, or a presampling site visit
should be arranged. If nobody is familiar with the site and a visit cannot be
arranged, the sampling plan must be written to account for the possible
contingencies. Examples of site-specific factors that should be considered
fol1ow:
1. Accessibi1ity: The accessibility of waste can vary substantially.
Some wastes are accessed by the simple turning of a valve; others
may require that an entire tank be emptied or that heavy equipment
be employed. The accessibility of a waste at the chosen sampling
location must be determined prior to design of a sampling plan.
2. Waste generation and handling: The waste generation and handling
process must be understood to ensure that collected samples are
representative of the waste. Factors which must be known and
accounted for in the sampling plan include: if the waste is
generated in batches; if there is a change in the raw materials
used in a manufacturing process; if waste composition can vary
substantially as a function of process temperatures or pressures;
and if storage time after generation may vary.
3. Transitory events: Start-up, shut-down, slow-down, and
maintenance transients can result in the generation of a waste
that is not representative of the normal waste stream. If a
sample was unknowingly collected at one of these intervals,
incorrect conclusions could be drawn.
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4. C1imate: The sampling plan should specify any clothing needed for
personnel to accommodate any extreme heat or cold that may be
encountered. Dehydration and extensive exposure to sun, insects,
or poisonous snakes must be considered.
5. Hazards: Each site can have hazards -- both expected and
unexpected. For example, a general understanding of a process may
lead a sampling team to be prepared for dealing with toxic or
reactive material, but not for dealing with an electrical hazard
or the potential for suffocation in a confined space. A thorough
sampling plan will include a health and safety plan that will
counsel team members to be alert to potential hazards.
9.2.2.4 Equipment
The choice of sampling equipment and sample containers will depend upon
the previously described waste and site considerations. For the following
reasons, the analytical chemist will play an important role in the selection
of sampling equipment:
1. The analytical chemist is aware of the potential interactions
between sampling equipment or container material with analytes of
interest. As a result, he/she can suggest a material that
minimizes losses by adsorption, volatilization, or contamination
caused by leaching from containers or sampling devices.
2. The analytical chemist can specify cleaning procedures for
sampling devices and containers that minimize sample contamination
and cross contamination between consecutive samples.
3. The analytical chemist's awareness of analyte-specific properties
is useful in selecting the optimum equipment (e.g., choice of
sampling devices that minimize agitation for those samples that
will be subjected to analysis for volatile compounds).
The final choice of containers and sampling devices will be made jointly
by the analytical chemist and the group designing the sampling plan. The
factors that will be considered when choosing a sampling device are:
1. Negative contamination: The potential for the measured analyte
concentration to be artificially low because of losses from
volatilization or adsorption.
2. Positive contamination: The potential for the measured analyte to
be artificially high because of leaching or the introduction of
foreign matter into the sample by particle fallout or gaseous air
contami nants.
3. Cross contamination: A type of positive contamination caused by
the introduction of part of one sample into a second sample during
sampling, shipping, or storage.
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4. Required sample volume: For physical and/or chemical analysis.
5. "Ease of use" of the sampling device and containers under the
conditions that will be encountered on-site. This includes the
ease of shipping to and from the site, ease of deployment, and
ease of cleaning.
6. The degree of hazard associated with the deployment of one
sampling device versus another.
7. Cost of the sampling device and of the labor for its deployment.
This section describes examples of sampling equipment and suggests
potential uses for this equipment. Some of these devices are commercially
available, but others will have to be fabricated by the user. The information
in this section is general in nature and therefore limited.
Because each sampling situation is unique, the cited equipment and
applications may have to be modified to ensure that a representative sample is
collected and its physical and chemical integrity are maintained. It is the
responsibility of those persons conducting sampling programs to make the
appropriate modifications.
Table 9-7 contains examples of sampling equipment and potential
applications. It should be noted that these suggested sampling devices may not
be applicable to a user's situation due to waste- or site-specific factors.
For example, if a waste is highly viscous or if a solid is clay-like, these
properties may preclude the use of certain sampling devices. The size and
depth of a lagoon or tank, or difficulties associated with accessing the waste,
may also preclude use of a given device or require modification of its
deployment.
The most important factors to consider when choosing containers for
hazardous waste samples are compatibility with the waste, cost, resistance to
breakage, and volume. Containers must not distort, rupture, or leak as a
result of chemical reactions with constituents of waste samples. Thus, it is
important to have some idea of the properties and composition of the waste.
The containers must have adequate wall thickness to withstand handling during
sample collection and transport to the laboratory. Containers with wide mouths
are often desirable to facilitate transfer of samples from samplers to
containers. Also, the containers must be large enough to contain the optimum
sample volume.
Containers for collecting and storing hazardous waste samples are usually
made of plastic or glass. Plastics that are commonly used to make the
containers include high-density or linear polyethylene (LPE), conventional
polyethylene, polypropylene, polycarbonate, Teflon FEP (fluorinated ethylene
propylene), polyvinyl chloride (PVC), or polymethylpentene. Teflon FEP is
almost universally usable due to its chemical inertness and resistance to
breakage. However, its high cost severely limits its use. LPE, on the other
hand, usually offers the best combination of chemical resistance and low cost
when samples are to be analyzed for inorganic parameters.
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TABLE 9-7. EXAMPLES OF SAMPLING EQUIPMENT FOR PARTICULAR WASTE TYPES
Waste Location or Container
Sacks Open-
Waste and bed
Type Drum Bags Truck
Free- Coliwasa N/A N/A
f 1 owi ng
liquids
and
si urries
Sludges Trier N/A Trier
Moist Trier Trier Trier
powders
or
granul es
Dry Thief Thief Thief
powders
or
granul es
Sand or Auger Auger Auger
packed
powders
and
granules
Large- Large Large Large
grained Trier Trier Trier
solids
Closed- Storage Ponds,
Bed Tanks Waste Lagoons, Convey-
Truck or Bins Piles & Pits or Belt Pipe
Coliwasa Weighted N/A Dipper N/A Dipper
bottle
Trier Trier a a
Trier Trier Trier Trier Shovel Dipper
Thief a Thief Thief Shovel Dipper
Auger Thief Thief a Dipper Dipper
Large Large Large Large Trier Dipper
Trier Trier Trier Trier
a This type of sampling situation can present significant logistical sampling problems, and
sampling equipment must be specifically selected or designed based on site and waste conditions.
No general statement about appropriate sampling equipment can be made.
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Glass containers are relatively inert to most chemicals and can be used
to collect and store almost all hazardous waste samples, except those that
contain strong alkali and hydrofluoric acid. Glass soda bottles are suggested
due to their low cost and ready availability. Borosilicate glass containers,
such as Pyrex and Corex, are more inert and more resistant to breakage than
soda glass, but are expensive and not always readily available. Glass
containers are generally more fragile and much heavier than plastic containers.
Glass or FEP containers must be used for waste samples that will be analyzed
for organic compounds.
The containers must have tight, screw-type lids. Plastic bottles are
usually provided with screw caps made of the same material as the bottles.
Buttress threads are recommended. Cap liners are not usually required for
plastic containers. Teflon cap liners should be used with glass containers
supplied with rigid plastic screw caps. (These caps are usually provided with
waxed paper liners.) Teflon liners may be purchased from plastic specialty
supply houses (e.g., Scientific Specialties Service, Inc., P.O. Box 352,
Randal 1stown, Maryland 21133). Other liners that may be suitable are
polyethylene, polypropylene, and neoprene plastics.
If the samples are to be submitted for analysis of volatile compounds,
the samples must be sealed in air-tight containers.
Prior to sampling, a detailed equipment list should be compiled. This
equipment list should be comprehensive and leave nothing to memory. The
categories of materials that should be considered are:
1. Personnel equipment, which will include boots, rain gear,
disposable coveralls, face masks and cartridges, gloves, etc.
2. Safety equipment, such as portable eyewash stations and a first-
aid kit.
3. Field test equipment, such as pH meters and Draeger tube samplers.
4. An ample supply of containers to address the fact that once in the
field, the sampling team may want to collect 50% more samples than
originally planned or to collect a liquid sample, although the
sampling plan had specified solids only.
5. Additional sampling equipment for use if a problem arises, e.g.,
a tool kit.
6. Shipping and office supplies, such as tape, labels, shipping
forms, chain-of-custody forms and seals, field notebooks, random-
number tables, scissors, pens, etc.
Composite Liquid Waste Sampler (Coliwasa)
The Coliwasa is a device employed to sample free-flowing liquids and
slurries contained in drums, shallow tanks, pits, and similar containers. It
is especially useful for sampling wastes that consist of several immiscible
liquid phases.
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The Coliwasa consists of a glass, plastic, or metal tube equipped with
an end closure that can be opened and closed while the tube is submerged in the
material to be sampled (refer to Figure 9-9).
Weighted Bottle
This sampler consists of a glass or plastic bottle, sinker, stopper, and
a line that is used to lower, raise, and open the bottle. The weighted bottle
samples liquids and free-flowing slurries. A weighted bottle with line is
built to the specifications in ASTM Methods D270 and E300. Figure 9-10 shows
the configuration of a weighted-bottle sampler.
Dipper
The dipper consists of a glass or plastic beaker clamped to the end of
a two- or three-piece telescoping aluminum or fiberglass pole that serves as
the handle. A dipper samples liquids and free-flowing slurries. Dippers are
not available commercially and must be fabricated (Figure 9-11).
A thief consists of two slotted concentric tubes, usually made of
stainless steel or brass. The outer tube has a conical pointed tip that
permits the sampler to penetrate the material being sampled. The inner tube
is rotated to open and close the sampler. A thief is used to sample dry
granules or powdered wastes whose particle diameter is less than one-third the
width of the slots. A thief (Figure 9-12) is available at laboratory supply
stores.
A trier consists of a tube cut in half lengthwise with a sharpened tip
that allows the sampler to cut into sticky solids and to loosen soil. A trier
samples moist or sticky solids with a particle diameter less than one-half the
diameter of the trier. Triers 61 to 100 cm long and 1.27 to 2.54 cm in
diameter are available at laboratory supply stores. A large trier can be
fabricated (see Figure 9-13).
An auger consists of sharpened spiral blades attached to a hard metal
central shaft. An auger samples hard or packed solid wastes or soil. Augers
are available at hardware and laboratory supply stores.
Scoops and Shovels
Scoops and shovels are used to sample granular or powdered material in
bins, shallow containers, and conveyor belts. Scoops are available at
laboratory supply houses. Flat-nosed shovels are available at hardware stores.
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2.86 cm (1 1/8")
1 —
1
Tapered i
Stopper '
T^~
fi-
ll
II
II
II
II
II
II
II
II
II
II
II
II
II
II
II
II
II
i l
II
II
II
II
Bf
=,]
-^
t
T-Handle >
~ 6.35 cm (2 %") Locking J
Block ' |
1
1
1
1
1
1
1
1
1
1
1
1.52m(5'-0") 1
1
1
1
1
1
1
1
1
1
L i
T
17.8cm (7")
1
1
1 Stopper Rod, PVC
1 0.95 cm (3/8") 0. D.
1
1 + Pipe, PVC, 4.13 cm (1 5/8") 1. D.
| ' 4.26cm (1 7/8") 0. D.
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
_j ..__
I
"1 Stopper, Neoprene, No. 9 with
TH 3/8" S. S. or PVC Nut and Washer
SAMPLING POSITION
CLOSE POSITION
Figure 9-9. Composite liquid waste sampler (Coliwasa).
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Washer
Pin
Nut
Figure 9-10. Weighted bottle sampler.
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i-
0)
a.
o.
i
en
=1
01
CO O
\a
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60-100 cm
-HI*-
1.27-2.54 cm
Figure 9-12. Thief sampler.
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I
5.08-7.62 cm
122-183 cm
(48-72")
60-100 cm
\
\
1.27-2.54 cm
Figure 9-13. Sampling triers.
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Bailer
The bailer is employed for sampling well water. It consists of a
container attached to a cable that is lowered into the well to retrieve a
sample. Bailers can be of various designs. The simplest is a weighted bottle
or basally capped length of pipe that fills from the top as it is lowered into
the well. Some bailers have a check valve, located at the base, which allows
water to enter from the bottom as it is lowered into the well. When the bailer
is lifted, the check valve closes, allowing water in the bailer to be brought
to the surface. More sophisticated bailers are available that remain open at
both ends while being lowered, but can be sealed at both top and bottom by
activating a triggering mechanism from the surface. This allows more reliable
sampling at discrete depths within a well. Perhaps the best known bailer of
this latter design is the Kemmerer sampler.
Bailers generally provide an excellent means for collecting samples from
monitoring wells. They can be constructed from a wide variety of materials
compatible with the parameter of interest. Because they are relatively
inexpensive, bailers can be easily dedicated to an individual well to minimize
cross contamination during sampling. If not dedicated to a well, they can be
easily cleaned to prevent cross contamination. Unfortunately, bailers are
frequently not suited for well evacuation because of their small volume.
Suction Pumps
As the name implies, suction pumps operate by creating a partial vacuum
in a sampling tube. This vacuum allows the pressure exerted by the atmosphere
on the water in the well to force water up the tube to the surface.
Accordingly, these pumps are located at the surface and require only that a
transmission tube be lowered into the well. Unfortunately, their use is
limited by their reliance on suction to depths of 20 to 25 ft, depending on the
pump. In addition, their use may result in out-gassing of dissolved gases or
volatile organics and is therefore limited in many sampling applications. In
spite of this, suction methods may provide a suitable means for well evacuation
because the water remaining in the well is left reasonably undisturbed.
A variety of pumps that operate on this principle are available, but the
ones most commonly suggested for monitoring purposes are the centrifugal and
peristaltic pumps. In the centrifugal pump, the fluid is displaced by the
action of an impeller rotating inside the pump chamber. This discharges water
by centrifugal force. The resulting pressure drop in the chamber creates a
suction and causes water to enter the intake pipe in the well. These pumps can
provide substantial yields and are readily available and inexpensive. The
disadvantages are that they require an external power source and may be
difficult to clean between sampling events. In addition, the materials with
which these pumps are constructed may frequently be incompatible with certain
sample constituents. However, their substantial pumping rates make them
suitable for well evacuation.
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Peristaltic pumps operate in a manner similar to centrifugal pumps but
displace the fluid by mechanical peristalsis. A flexible transmission line is
mounted around the perimeter of the pump chamber, and rotating rollers compress
the tubing, forcing fluid movement ahead (the peristaltic effect) and inducing
suction behind each roller. This design isolates the sample from the moving
part of the pump and allows for easy cleaning by removal and replacement of the
flexible tubing. Unfortunately, peristaltic pumps are generally capable of
providing only relatively low yields. They are, therefore, not ideally suited
to wel1 evacuation.
Positive Displacement Pumps
A variety of positive displacement pumps are available for use in with-
drawing water from wells. These methods utilize some pumping mechanism, placed
in the well, that forces water from the bottom of the well to the surface by
some means of positive displacement. This minimizes the potential for aerating
or stripping volatile organics from the sample during removal from the well.
The submersible centrifugal pump is one common example of a positive
displacement pump. It works in a manner similar to the centrifugal suction
lift pump previously described, except that, in this case, both the pump and
electric motor are lowered into the well. As the impeller rotates and fluid
is brought into the pump, fluid is displaced up the transmission line and out
of the well. These pumps are capable of providing a high yield. However, they
require an external source of power and are frequently constructed with
materials and contain lubricants incompatible with certain sample constituents,
particularly organics. They also require considerable equipment and effort to
move from well to well. Cleaning between sampling events is difficult as well,
and, until recently, they have not been available for well diameters smaller
than 3 in.
Piston-driven or reciprocating piston pumps are another example of common
positive displacement pumps. These pumps consist of a piston in a submerged
cylinder operated by a rod connected to the drive mechanism at the surface.
A flap valve or ball-check valve is located immediately above or below the
piston cylinder. As the piston is lowered in the cylinder, the check valve
opens, and water fills the chamber. On the upstroke, the check valve closes,
and water is forced out of the cylinder, up into the transmission line, and to
the surface. The transmission line or piston contains a second check valve
that closes on the downstroke, preventing water from re-entering the cylinder.
These pumps are capable of providing high yields. However, moving these pumps
from well to well is difficult, and their use in monitoring programs may
require that a pump be dedicated to each well. Many of these pumps may not be
constructed with materials compatible with monitoring certain constituents.
A special adaptation of this pump has recently become available for use
in ground water monitoring. These piston pumps use compressed gas, rather than
a rod connected to a driving mechanism at the surface, to drive the pistons.
This provides a much more convenient and portable means for collecting samples
from monitoring wells. Compressed-gas pumps provide good yields and can be
constructed with materials compatible with many sampling programs.
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Another positive displacement pump applicable for monitoring purposes is
the gas-operated squeeze pump. This pump was originally developed by R. F.
Middleburg of the U.S.G.S. and consequently is referred to as the Middleburg
pump. It consists principally of a collapsible membrane inside a long, rigid
housing, a compressed gas supply, and appropriate control valves. When the
pump is submerged, water enters the collapsible membrane through the bottom
check valve. After the membrane has filled, gas pressure is applied to the
annular space between the rigid housing and membrane, forcing the water upward
through a sampling tube. When the pressure is released, the top check valve
prevents the sample from flowing back down the discharge line, and water from
the well again enters the pump through the bottom check valve.
Gas-operated squeeze pumps offer a number of advantages for use in ground
water monitoring programs. They can be constructed in diameters as small as
1 in. and from a wide variety of materials. They are also relatively portable
and are capable of providing a fair range of pumping rates. Most important,
the driving gas does not contact the water sample, so that possible
contamination or gas stripping does not occur. However, they do require a gas
source, and withdrawal of water from substantial depths may require large gas
volumes and long pumping cycles.
Jet pumps, a common type of submersible pump used in small domestic water
wells, may in some cases be suggested for use in monitoring wells. These pumps
operate by injecting water through a pipe down into the well. A venturi device
is located at the intake portion of the pump. As the water injected from the
surface passes through the constricted portion of the venturi, the velocity
increases and pressures decrease according to Bernoulli's principle. If the
discharge velocity at the nozzle is great enough, the pressure at this point
will be lowered sufficiently to draw water into the venturi assembly through
the intake and to bring it to the surface with the original water injected into
the well. This additional increment of water is then made available at the
surface as the pump's output. Because jet pumps require priming with water and
because the water taken from the well mixes with water circulating in the
system, they are clearly not applicable to collecting samples for monitoring
purposes. For similar reasons, their use is not recommended for well
evacuati on.
Pressure-Vacuum Lvsimeters
The basic construction of pressure-vacuum lysimeters (Wood, 1973), shown
in Figure 9-14, consists of a porous ceramic cup, with a bubbling pressure of
1 bar or greater, attached to a short piece of PVC pipe of suitable diameter.
Two tubes extend down into the device, as illustrated. Data by Silkworth and
Grigal (1981) indicate that, of the two commercially available sampler sizes
(2.2 and 4.8 cm diameter), the larger ceramic cup sampler is more reliable,
influences water quality less, and yields samples of suitable volume for
analysi s.
Detailed installation instructions for pressure-vacuum lysimeters are
given by Parizek and Lane (1970). Significant modification may be necessary
to adapt these instruments to field use when heavy equipment is used. To
prevent channelling of contaminated surface water directly to the sampling
device, the sampler may be installed in the side wall of an access trench.
Because random placement procedures may locate a sampler in the middle of an
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.c
CN
TUBING TO SURFACE
CONNECTORS
PIPE-THREAD SEALANT
PVC PIPE CAP
PVCPIPE
PVCCEMENT
POLYETHYLENE TUBING
BRANCH"T"
FEMALE ELBOW
POPPET CHECK VALVE
CONNECTORS
EPOXY CEMENT
POLYETHYLENE TUBING
POROUS CUP 3-8 m pore size
Figure 9-14. One example of a pressure-vacuum lysimeter Wood, 1973).
Reprinted by permission of the American Geophysical Union.
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active area, the sample collection tube should be protected at the surface from
heavy equipment by a manhole cover, brightly painted steel cage, or other
structure. Another problem associated with such sampler placement is that its
presence may alter waste management activities (i.e., waste applications,
tilling, etc., will avoid the location): therefore, the sampler may not yield
representative leachate samples. This problem may be avoided by running the
collection tube horizontally underground about 10 m before surfacing.
For sampling after the unit is in place, a vacuum is placed on the system
and the tubes are clamped off. Surrounding soil water is drawn into the
ceramic cup and up the polyethylene tube. To collect the water sample, the
vacuum is released, and one tube is placed in a sample container. Air pressure
is applied to the other tube, forcing the liquid up the tube and into the
sample container. Preliminary testing should ensure that waste products can
pass into the ceramic cup. If sampling for organics, an inert tubing, such as
one made of Teflon, should be substituted for the polyethylene pipe to prevent
organic contamination.
The major advantages of these sampling devices are that they are easily
available, relatively inexpensive to purchase and install, and quite reliable.
The major disadvantage is the potential for water quality alterations due to
the ceramic cup; this possible problem requires further testing. For a given
installation, the device chosen should be specifically tested using solutions
containing the soluble hazardous constituents of the waste to be land treated.
This device is not recommended for volatiles unless a special trap device is
used (Hazardous Waste Land Treatment, SW-874).
Vacuum Extractor
Vacuum extractors were developed by Duke and Haise (1973) to extract
moisture from soils above the ground water table. The basic device consists
of a stainless steel trough that contains ceramic tubes packed in soil. The
unit is sized not to interfere with ambient soil water potentials (Corey,
1974); it is installed at a given depth in the soil with a slight slope toward
the collection bottle, which is in the bottom of an adjacent access hole. The
system is evacuated and moisture is moved from the adjacent soil into the
ceramic tubes and into the collection bottle, from which it can be withdrawn
as desired. The advantage of this system is that it yields a quantitative
estimate of leachate flux as well as provides a water sample for analysis. The
volume of collected leachate per unit area per unit time is an estimate of the
downward movement of leachate water at that depth. The major disadvantages to
this system are: it is delicate; it requires a trained operator; it estimates
leachate quantity somewhat lower than actual field drainage; and it disturbs
the soil above the sampler. Further details about the use of the vacuum
extractor are given by Trout et al . (1975). Performance of this device when
installed in clay soils is generally poor.
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Trench Lvsimeters
Trench lysimeters are named for the large access trench, or caisson,
necessary for operation. Basic installation, as described by Parizek and Lane
(1970), involves excavating a rather large trench and shoring up the side
walls, taking care to leave open areas so that samplers can be placed in the
side walls. Sample trays are imbedded in the side walls and connected by
tubing to sample collection containers. The entire trench area is then covered
to prevent flooding. One significant danger in using this system is the
potential for accumulation of hazardous fumes in the trench, possibly
endangering the health and safety of the person collecting the samples.
Trench lysimeters function by intercepting downward-moving water and
diverting it into a collection device located at a lower elevation. The
intercepting agent may be an open-ended pipe, sheet metal trough, pan, or other
similar device. Pans 0.9 to 1.2 m in diameter have been successfully used in
the field by Tyler and Thomas (1977). Because there is no vacuum applied to
the system, only free water in excess of saturation is sampled. Consequently,
samples are plentiful during rainy seasons but are nonexistent during the dry
season.
Another variation of this system is to use a funnel filled with clean
sand inserted into the sidewall of the trench. Free water will drain into a
collection chamber, from which a sample is periodically removed by vacuum. A
small sample collection device such as this may be preferable to the large
trench because the necessary hole is smaller, so that installation is easier
(Figure 9-15).
9.2.2.5 Quality Assurance and Quality Control
Quality assurance (QA) can briefly be defined as the process for ensuring
that all data and the decisions based on these data are technically sound,
statistically valid, and properly documented. Quality control (QC) procedures
are the tools employed to measure the degree to which these quality assurance
objectives are met.
A data base cannot be properly evaluated for accuracy and precision
unless it is accompanied by quality assurance data. In the case of waste
evaluation, these quality assurance data result from the implementation of
quality control procedures during sampling and analysis. Quality control
requirements for specific analytical methods are given in detail in each method
in this manual: in this subsection, quality assurance and quality control
procedures for sampling will be discussed.
Quality control procedures that are employed to document the accuracy and
precision of sampling are:
1. Trip Blanks: Trip blanks should accompany sample containers to
and from the field. These samples can be used to detect any
contamination or cross-contamination during handling and
transportation.
2. Field Blanks: Field blanks should be collected at specified
frequencies, which will vary according to the probability of
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SOIL SURFACE
.•- SAND • - -• - *
* U-»* «*•••*•
'' ' - •- .••>•••.
VACUUM
SOURCE
Figure 9-15. Schematic diagram of a sand filled funnel used to collect
leachate from the unsaturated zone.
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contamination or cross-contamination. Field blanks are often
metal- and/or organic-free water aliquots that contact sampling
equipment under field conditions and are analyzed to detect any
contamination from sampling equipment, cross contamination from
previously collected samples, or contamination from conditions
during sampling (e.g., airborne contaminants that are not from the
waste bei ng sampled).
3. Field Duplicates: Field duplicates are collected at specified
frequencies and are employed to document precision. The precision
resulting from field duplicates is a function of the variance of
waste composition, the variance of the sampling technique, and the
variance of the analytical technique.
4. Field Spikes: Field spikes are infrequently used to determine the
loss of parameters of interest during sampling and shipment to the
laboratories. Because spiking is done in the field, the making of
spiked samples or spiked blanks is susceptible to error. In
addition, compounds can be lost during spiking, and equipment can
be contaminated with spiking solutions. To eliminate these and
other problems, some analysts spike blanks or matrices similar to
the waste in the laboratory and ship them, along with sample
containers, to the field. This approach also has its limitation
because the matrix and the handling of the spike are different
from those of the actual sample. In all cases, the meaning of a
low field-spike recovery is difficult to interpret, and thus,
field spikes are not commonly used.
In addition to the above quality control samples, a complete quality
assurance program will ensure that standard operating procedures (SOPs) exist
for all essential aspects of a sampling effort. SOPs should exist for the
following steps in a sampling effort:
1. Definition of objectives (refer to Section 9.2.1).
2. Design of sampling plans (refer to Section 9.2.2).
3. Preparation of containers and equipment (refer to the specific
analytical methods).
4. Maintenance, calibration, and cleaning of field equipment (refer
to instrument manuals or consult a chemist for cleaning
protocols).
5. Sample preservation, packaging, and shipping (refer to the
analytical methods and to Section 9.2.2.7).
6. Health and safety protocols (refer to Section 9.2.2.6).
7. Chain-of-custody protocols (refer to Section 9.2.2.7).
In addition to the above protocols, numerous other QA/QC protocols must
be employed to document the accuracy of the analytical portion of a waste
evaluation program.
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9.2.2.6 Health and Safety
Safety and health must also be considered when implementing a sampling
plan. A comprehensive health and safety plan has three basic elements: (1)
monitoring the health of field personnel; (2) routine safety procedures; and
(3) emergency procedures.
Employees who perform field work, as well as those exposed to chemicals
in the laboratory, should have a medical examination at the initiation of
employment and routinely thereafter. This exam should preferably be performed
and evaluated by medical doctors who specialize in industrial medicine. Some
examples of parts of a medical examination that ought to be performed are:
documentation of medical history; a standard physical exam; pulmonary functions
screening; chest X-ray: EKG; urinalysis; and blood chemistry. These procedures
are useful to: (1) document the quality of an employee's health at the time of
matriculation: (2) ensure the maintenance of good health; and (3) detect early
signs of bodily reactions to chemical exposures so they can be treated in a
timely fashion. Unscheduled examinations should be performed in the event of
an accident, illness, or exposure or suspected exposure to toxic materials.
Regarding safety procedures, personnel should be aware of the common
routes of exposure to chemicals (i.e., inhalation, contact, and ingestion) and
be instructed in the proper use of safety equipment, such as Draeger tube air
samplers to detect air contamination, and in the proper use of protective
clothing and respiratory equipment. Protocols should also be defined stating
when safety equipment should be employed and designating safe areas where
facilities are available for washing, drinking, and eating.
Even when the utmost care is taken, an emergency situation can occur as
a result of an unanticipated explosion, electrical hazard, fall, or exposure
to a hazardous substance. To minimize the impact of an emergency, field
personnel should be aware of basic first aid and have immediate access to a
first-aid kit. Phone numbers for both police and the nearest hospital should
be obtained and kept by each team member before entering the site. Directions
to the nearest hospital should also be obtained so that anyone suffering an
injury can be transported quickly for treatment.
9.2.2.7 Chain of Custody
An essential part of any sampling/analytical scheme is ensuring the
integrity of the sample from collection to data reporting. The possession and
handling of samples should be traceable from the time of collection through
analysis and final disposition. This documentation of the history of the
sample is referred to as chain of custody.
Chain of custody is necessary if there is any possibility that the
analytical data or conclusions based upon analytical data will be used in
litigation. In cases where litigation is not involved, many of the chain-of-
custody procedures are still useful for routine control of sample flow. The
components of chain of custody -- sample seals, a field logbook, chain-of-
custody record, and sample analysis request sheet -- and the procedures for
their use are described in this section.
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A sample is considered is considered to be under a person's custody if
it is (1) in a person's physical possession, (2) in view of the person after
taking possession, and (3) secured by that person so that no one can tamper
with it, or secured by that person in an area that is restricted to authorized
personnel. A person who has samples in custody must comply with the following
procedures.
(The material presented here briefly summarizes the major aspects of
chain of custody. The reader is referred to NEIC Policies and Procedures, EPA-
330/9/78/001-R [as revised 1/82], or other manual, as appropriate, for more
i nformati on . )
Sample labels (Figure 9-16) are necessary to prevent mi sidentification
of samples. Gummed paper labels or tags are adequate and should include at
least the following information:
Sample number.
Name of col 1ector.
Date and time of collection.
PI ace of col 1ecti on.
Labels should be affixed to sample containers prior to or at the time of
sampling and should be filled out at the time of collection.
Sample seals are used to detect unauthorized tampering of samples
following sample collection up to the time of analysis. Gummed paper seals may
be used for this purpose. The paper seal should include, minimally, the
following information:
Sample number. (This number must be identical with the number on the
sample 1abel.)
Name of col 1ector.
Date and time of sampling.
PI ace of col lection.
The seal must be attached in such a way that it is necessary to break it
in order to open the sample container. (An example of an official sample seal
is shown in Figure 9-17.) Seals must be affixed to containers before the
samples leave the custody of sampling personnel.
All information pertinent to a field survey or sampling must be recorded
in a logbook. This should be bound, preferably with consecutively numbered
pages that are 21.6 by 27.9 cm (8-1/2 by 11 in.). At a minimum, entries in the
logbook must include the following:
Location of sampling point.
Name and address of field contact.
Producer of waste and address, if different from location.
Type of process producing waste (if known).
Type of waste (e.g., sludge, wastewater).
Suspected waste composition, including concentrations.
Number and volume of sample taken.
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Collector Sample No.
Place of Collection
Date Sampled Time Sampled
Field Information
Figure 9-16. Example of Sample Label
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NAME AND ADDRESS OF ORGANIZATION COLLECTING SAMPLES
Person Collecting Sample
Date Collected
PI ace Col 1ected
Sample No.
(signature)
Time Collected
Figure 9-17. Example of Official Sample Seal
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Purpose of sampling (e.g., surveillance, contract number).
Description of sampling point and sampling methodology.
Date and time of collection.
Collector's sample identification number(s).
Sample distribution and how transported (e.g., name of laboratory, UPS,
Federal Express).
References, such as maps or photographs of the sampling site.
Field observations.
Any field measurements made (e.g., pH, f1ammabi1ity, explosivity).
Signatures of personnel responsible for observations.
Sampling situations vary widely. No general rule can be given as to the
extent of information that must be entered in the logbook. A good rule,
however, is to record sufficient information so that anyone can reconstruct the
sampling without reliance on the collector's memory. The logbook must be
stored safely.
To establish the documentation necessary to trace sample possession from
the time of collection, a chain-of-custody record should be filled out and
should accompany every sample. This record becomes especially important if the
sample is to be introduced as evidence in a court litigation. (A chain-of-
custody record is illustrated in Figure 9-18.)
The record should contain, minimally, the following information:
Sample number.
Signature of collector.
Date and time of collection.
Place and address of collection.
Waste type.
Signature of persons involved in the chain of possession.
Inclusive dates of possession.
The sample analysis request sheet (Figure 9-19) is intended to accompany
the sample on delivery to the laboratory. The field portion of this form is
completed by the person collecting the sample and should include most of the
pertinent information noted in the logbook. The laboratory portion of this
form is intended to be completed by laboratory personnel and to include,
minimally:
Name of person receiving the sample.
Laboratory sample number.
Date and time of sample receipt.
Sample allocation.
Analyses to be performed.
The sample should be delivered to the laboratory for analysis as soon as
practicable -- usually within 1 or 2 days after sampling. The sample must be
accompanied by the chain-of-custody record (Figure 9-18) and by a sample
analysis request sheet (Figure 9-19). The sample must be delivered to the
person in the laboratory authorized to receive samples (often referred to as
the sample custodian).
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SAMPLING ANALYSIS REQUEST
Part I: Field Section
Collector Date Sampled Time hours
Affiliation of Sampler
Address
number street city state zip
Telephone ( ) Company Contact
LABORATORY
SAMPLE COLLECTOR'S TYPE OF
NUMBER SAMPLE NO. SAMPLE* FIELD INFORMATION**
Analysis Requested
Special Handling and/or Storage
PART II: LABORATORY SECTII
Received by Title Date
Analysis Required
* Indicate whether sample is soil, sludge, etc.
** Use back of page for additional information relative to sample location.
Figure 9-19. Example of hazardous waste sample analysis sheet.
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Any material that is identified in the DOT Hazardous Material Table (49
CFR 172.101) must be transported as prescribed in the table. All other
hazardous waste samples must be transported as follows:
1. Collect sample in a 16-oz or smaller glass or polyethylene
container with nonmetallic Teflon-lined screw cap. For liquids,
allow sufficient air space, approximately 10% by volume) so that
the container is not full at 54°C (130 °F). If collecting a solid
material, the container plus contents should not exceed 1 Ib net
weight. If sampling for volatile organic analysis, fill VOA
container to septum but place the VOA container inside a 16-oz or
smaller container so that the required air space may be provided.
Large quantities, up to 3.785 liters (1 gal), may be collected if
the sample's flash point if 23°C (75°F) or higher. In this case,
the flash point must be marked on the outside container (e.g.,
carton or cooler), and shipping paper should state that "Flash
point is 73°F or higher."
2. Seal sample and place in a 4-mi 1-thick polyethylene bag, one
sample per bag.
3. Place sealed bag inside a metal can with noncombustible, absorbent
cushioning material (e.g., vermiculite or earth) to prevent
breakage, one bag per can. Pressure-close the can and use clips,
tape, or other positive means to hold the lid securely.
4. Mark the can with:
Name and address of originator.
"Flammable Liquid, N.O.S. UN 1993."
(or, "Flammable Solid, N.O.S. UN 1325".)
NOTE: UN numbers are now required in proper shipping names.
5. Place one or more metal cans in a strong outside container such as
a picnic cooler or fiberboard box. Preservatives are not used for
hazardous waste site samples.
6. Prepare for shipping: The words "Flammable Liquid, N.O.S. UN
1993" or "Flammable Solid, N.O.S. UN 1325"; "Cargo Aircraft Only"
(if more than 1 qt net per outside package); "Limited Quantity" or
"Ltd. Qty."; "Laboratory Samples"; "Net Weight " or "Net Volume
" (of hazardous contents) should be indicated on shipping
papers and on the outside of the outside shipping container. The
words "This Side Up" or "This End Up" should also be on container.
Sign the shipper certification.
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7. Stand by for possible carrier requests to open outside containers
for inspection or to modify packaging. (It is wise to contact
carrier before packing to ascertain local packaging requirements.)
Remain in the departure area until the carrier vehicle (aircraft,
truck, etc.) is on its way.
At the laboratory, a sample custodian should be assigned to receive the
samples. Upon receipt of a sample, the custodian should inspect the condition
of the sample and the sample seal, reconcile the information on the sample
label and seal against that on the chain-of-custody record, assign a laboratory
number, log in the sample in the laboratory logbook, and store it in a secured
sample storage room or cabinet until it is assigned to an analyst for analysis.
The sample custodian should inspect the sample for any leakage from the
container. A leaky container containing a multiphase sample should not be
accepted for analysis. This sample will no longer be a representative sample.
If the sample is contained in a plastic bottle and the container walls show
that the sample is under pressure or releasing gases, the sample should be
treated with caution because it may be explosive or release extremely poisonous
gases. The custodian should examine whether the sample seal is intact or
broken, because a broken seal may mean sample tampering and would make analysis
results inadmissible as evidence in court. Any discrepancies between the
information on the sample label and seal and the information that is on the
chain-of-custody record and the sample analysis request sheet should be
resolved before the sample is assigned for analysis. This effort might require
communication with the sample collector. Results of the inspection should be
noted on the sample analysis request sheet and on the laboratory sample
logbook.
Incoming samples usually carry the inspector's or collector's
identification numbers. To identify these samples further, the laboratory
should assign its own identification numbers, which normally are given
consecutively. Each sample should be marked with the assigned laboratory
number. This number is correspondingly recorded on a laboratory sample log
book along with the information describing the sample. The sample information
is copied from the sample analysis request sheet and cross-checked against that
on the sample 1abel .
In most cases, the laboratory supervisor assigns the sample for analysis.
The supervisor should review the information on the sample analysis request
sheet, which now includes inspection notes recorded by the laboratory sample
custodian. The technician assigned to analysis should record in the laboratory
notebook the identifying information about the sample, the date of receipt, and
other pertinent information. This record should also include the subsequent
testing data and calculations. The sample may have to be split with other
laboratories in order to obtain all the necessary analytical information. In
this case, the same type of chain-of-custody procedures must be employed while
the sample is being transported and at the other laboratory.
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Once the sample has been received in the laboratory, the supervisor or
his/her assignee is responsible for its care and custody. That person should
be prepared to testify that the sample was in his/her possession or secured in
the laboratory at all times, from the moment it was received from the custodian
until the analyses were performed.
9.2.3 Sample Plan Implementation
Prior to implementing a sampling plan, it is often strategic to walk
through the sampling plan mentally, starting with the preparation of equipment
until the time when samples are received at the laboratory. This mental
excursion should be in as much detail as can be imagined, because the small
details are the ones most frequently overlooked. By employing this technique,
items not included on the equipment list may be discovered, as well as any
major oversight that could cause the sampling effort to fail. During this
review of the sampling plan, an attempt should be made to anticipate what could
go wrong. A solution to anticipated problems should be found, and, if
necessary, materials needed for solving these problems should be added to the
equipment list.
The remainder of this section discusses examples of sampling strategies
for different situations that may be encountered.
Contai ners
Prior to discussing the sampling of containers, the term must be defined.
The term container, as used here, refers to receptacles that are designed for
transporting materials, e.g., drums and other smaller receptacles, as opposed
to stationary tanks. Weighted bottles, Coliwasas, drum thiefs, or triers are
the sampling devices that are chosen for the sampling of containers. (See
Section 9.2.2.4 for a full discussion of sampling equipment.)
The sampling strategy for containers varies according to (1) the number
of containers to be sampled and (2) access to the containers. Ideally, if the
waste is contained in several containers, every container will be sampled. If
this is not possible due to the large number of containers or to cost factors,
a subset of individual containers must be randomly selected for sampling. This
can be done by assigning each container a number and then randomly choosing a
set of numbers for sampling.
Access to a container will affect the number of samples that can be taken
from the container and the location within the container from which samples can
be taken. Ideally, several samples should be taken from locations displaced
both vertically and horizontally throughout the waste. The number of samples
required for reliable sampling will vary depending on the distribution of the
waste components in the container. At a minimum with an unknown waste, a
sufficient number and distribution of samples should be taken to address any
possible vertical anomalies in the waste. This is because contained wastes
have a much greater tendency to be nonrandomly heterogeneous in a vertical
rather than a horizontal direction due to (1) settling of solids and the denser
phases of liquids and (2) variation in the content of the waste as it enters
the container. Bags, paper drums, and open-headed steel drums (of which the
entire top can be removed) generally do not restrict access to the waste and
therefore do not limit sampling.
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When access to a container is unlimited, a useful strategy for obtaining
a representative set of samples is a three-dimensional simple random sampling
strategy in which the container is divided by constructing an imaginary three-
dimensional grid (see Figure 9-20), as follows. First, the top surface of the
waste is divided into a grid whose section either approximate the size of the
sampling device or are larger than the sampling device if the container is
large. (Cylindrical containers can be divided into imaginary concentric
circles, which are then further divided into grids of equal size.) Each
section is assigned a number. The height of the container is then divided into
imaginary levels that are at least as large as the vertical space required by
the chosen sampling device. These imaginary levels are then assigned numbers.
Specific levels and grid locations are then selected for sampling using a
random-number table or random-number generator. (an alternative means of
choosing random sampling locations using circumference and diameter dimensions
is discussed in Section 9.2.2.1.)
Another appropriate sampling approach is the two-dimensional simple
random sampling strategy, which can usually yield a more precise sampling when
fewer samples are collected. This strategy involves (1) dividing the top
surface of the waste into an imaginary grid as in the three-dimensional
strategy, (2) selecting grid sections for sampling using random-number tables
or random-number generators, and (3) sampling each selected grid point in a
vertical manner along the entire length from top to bottom using a sampling
device such as a drum thief or Coliwasa.
Some containers, such as drums with bung openings, limit access to the
contained waste and restrict sampling to a single vertical plane. Samples
taken in this manner can be considered representative of the entire container
only if the waste is known to be homogenous or if no horizontal stratification
has occurred. Precautions must be taken when sampling any type of steel drum
because the drum may explode or expel gases and/or pressurized liquids. An
EPA/NEIC manual, "Safety Manual for Hazardous Waste Site Investigation,"
addresses these safety precautions.
Tanks are essentially large containers. The considerations involved in
sampling tanks are therefore similar to those for sampling containers. As with
containers, the goal of sampling tanks is to acquire a sufficient number of
samples from different locations within the waste to provide analytical data
that are representative of the entire tank contents.
The accessibility of the tank contents will affect the sampling
methodology. If the tank is an open one, allowing unrestricted access, then
usually a representative set of samples is best obtained using the three-
dimensional simple random sampling strategy, as described for containers (see
also Section 9.2.2.1). This strategy involves dividing the tank contents into
an imaginary three-dimensional grid. As a first step, the top surface of the
waste is divided into a grid whose sections either approximate the size of the
sampling device or are larger than the sampling device if the tank is large.
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Figure 9-20. Container divided into an imaginary three-dimensional grid.
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(Cylindrical tanks can be divided into imaginary concentric circles, which are
then further divided into grids of equal size.) Each section is assigned a
number. The height of the tank is then divided into imaginary levels that are
at least as large as the vertical space required by the chosen sampling device.
These imaginary levels are assigned numbers. Specific levels and grid
locations are then selected for sampling using a random-number table or random-
number generator.
A less comprehensive sampling approach may be appropriate if information
regarding the distribution of waste components is known or assumed (e.g., if
vertical compositing will yield a representative sample). In such cases, a
two-dimensional simple random sampling strategy may be appropriate. In this
strategy, the top surface of the waste is divided into an imaginary grid; grid
sections are selected using random-number tables or random-number generators;
and each selected grid point is then sampled in a vertical manner along the
entire length from top to bottom using a sampling device such as a weighted
bottle, a drum thief, or Coliwasa. If the waste is known to consist of two or
more discrete strata, a more precise representation of the tank contents can
be obtained by using a stratified random sampling strategy, i.e., by sampling
each stratum separately using the two- or three-dimensional simple random
sampli ng strategy.
Some tanks permit only limited access to their contents, which restricts
the locations within the tank from which samples can be taken. If sampling is
restricted, the sampling strategy must, at a minimum, take sufficient samples
to address the potential vertical anomalies in the waste in order to be
considered representative. This is because contained wastes tend to display
vertical, rather than horizontal, nonrandom heterogeneity due to settling of
suspended solids or denser liquid phases. If access restricts sampling to a
portion of the tank contents (e.g., in an open tank, the size of the tank may
restrict sampling to the perimeter of the tank; in a closed tank, the only
access to the waste may be through inspection ports), then the resulting
analytical data will be deemed representative only of the accessed area, not
of the entire tank contents unless the tank contents are known to be
homogeneous.
If a limited access tank is to be sampled, and little is known about the
distribution of components within the waste, a set of samples that is
representative of the entire tank contents can be obtained by taking a series
of samples as the tank contents are being drained. This should be done in a
simple random manner by estimating how long it will take to drain the tank and
then randomly selecting times during drainage for sampling.
The most appropriate type of sampling device for tanks depends on the
tank parameters. In general, subsurface samples (i.e., pond samplers) are used
for shallow tanks, and weighted bottles are usually employed for tanks deeper
than 5 ft. Dippers are useful for sampling pipe effluents.
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Waste Piles
In waste piles, the accessibility of waste for sampling is usually a
function of pile size, a key factor in the design of a sampling strategy for
a waste pile. Ideally, piles containing unknown wastes should be sampled using
a three-dimensional simple random sampling strategy. This strategy can be
employed only if all points within the pile can be accessed. In such cases,
the pile should be divided into a three-dimensional grid system, the grid
sections assigned numbers, and the sampling points then chosen using random-
number tables or random-number generators.
If sampling is limited to certain portions of the pile, then the
collected sample will be representative only of those portions, unless the
waste is known to be homogenous.
In cases where the size of a pile impedes access to the waste, a set of
samples that are representative of the entire pile can be obtained with a
minimum of effort by scheduling sampling to coincide with pile removal. The
number of truckloads needed to remove the pile should be estimated and the
truckloads randomly chosen for sampling.
The sampling devices most commonly used for small piles are thiefs,
triers, and shovels. Excavation equipment, such as backhoes, can be useful for
sampling medium-sized piles.
Landfills and Lagoons
Landfills contain primarily solid waste, whereas lagooned waste may range
from liquids to dried sludge residues. Lagooned waste that is either liquid
or semisolid is often best sampled using the methods recommended for large
tanks. Usually, solid wastes contained in a landfill or lagoon are best
sampled using the three-dimensional random sampling strategy.
The three-dimensional random sampling strategy involves establishing an
imaginary three-dimensional grid of sampling points in the waste and then using
random-number tables or random-number generators to select points for sampling.
In the case of landfills and lagoons, the grid is established using a survey
or map of the area. The map is divided into two two-dimensional grids with
sections of equal size. (An alternative way of choosing random sampling
locations is presented in the second example described in Section 9.2.2.1)
These sections are then assigned numbers sequentially.
Next, the depth to which sampling will take place is determined and
subdivided into equal levels, which are also sequentially numbered. (The
lowest sampling depth will vary from landfill to landfill. Usually, sampling
extends to the interface of the fill and the natural soils. If soil
contamination is suspected, sampling may extend into the natural soil.) The
horizontal and vertical sampling coordinates are then selected using random-
number tables or random-number generators. If some information is known about
the nature of the waste, then a modified three-dimensional strategy may be more
appropriate. For example, if the landfill consists of several cells, a more
precise measurement may be obtained by considering each cell as a stratum and
employing a stratified three-dimensional random sampling strategy (see Section
9.1).
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Hollow-stem augers combined with split-spoon samplers are frequently
appropriate for sampling landfills. Water-driven or water-rinsed coring
equipment should not be used for sampling because the water can rinse chemical
components from the sample. Excavation equipment, such as backhoes, may be
useful in obtaining samples at various depths; the resulting holes may be
useful for viewing and recording the contents of the landfill.
9.2.4 Sample Compositing
The compositing of samples, is usually done for cost-saving reasons,
involves the combining of a number of samples or aliquots of a number of
samples collected from the same waste. The disadvantage of sample compositing
is the loss of concentration variance data, whereas the advantage is that, for
a given analytical cost, a more representative (i.e., more accurate) sample is
obtai ned.
It is usually most expedient and cost effective to collect component
samples in the field and to composite aliquots of each sample later in the
laboratory. Then, if after reviewing the data any questions arise, the samples
can be recomposited in a different combination, or each component sample can
be analyzed separately to determine better the variation of waste composition
over time and space, or to determine better the precision of an average number.
The fact that this recompositing of samples can occur without the need to
resample often results in a substantial cost savings.
To ensure that recompositing can be done at a later date, it is essential
to collect enough sample volume in the field so that, under normal
circumstances, enough component sample will remain following compositing to
allow for a different compositing scheme or even for an analysis of the
component samples themselves.
The actual compositing of samples requires the homogenization of all
component samples to ensure that a representative subsample is aliquoted. The
homogenization procedure, and the containers and equipment used for
compositing, will vary according to the type of waste being composited and the
parameters to be measured. Likewise, the composite sample itself will be
homogenized prior to the subsampling of analytical aliquots.
9.2.5 References
1. Corey, P.R., Soil Water Monitoring, Unpublished Report to Dept. of Agr.
Eng., Colorado State University, Fort Collins, Colorado, 1974.
2. Duke, H.R. and H.R. Haise, Vacuum Extractors to Assess Deep percolation
Losses and Chemical Constituents of Soil Water, Soil Sci, Soc, Am. Proc. 37.
963-4 (1973)
3. Parizek, R.R. and B.E. Lane, Soil-Water Sampling Using Pan and Deep
Pressure-Vacuum Lysimeters, J.Hydr. 11. 1-21 (1970).
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4. Silkworth, D.R. and D.F. Grigal, Field Comparison of Soil Solution
Samplers, Soil Sci . Soc. Am. J. 45., 440-442 (1981).
5. Trout, T.J., J.L. Smith, and D.B. McWhorter, Environmental Effects of Land
Application of Digested Municipal Sewage Sludge, Report submitted to City of
Boulder, Colorado, Dept. of Agr. Engr., Colorado State Univ., For Collins,
Colorado, 1975.
6. Tyler, D.D. and G.W. Thomas, Lysimeter Measurements of Nitrate and Chloride
Losses and No-tillage Corn, J. Environ. Qual . 6, 63-66 (1977).
7. U.S. Department of Transportation, Hazardous Materials Table, 49 CFR
172.101.
8. U.S. EPA, Office of Solid Waste and Emergency Response, Hazardous Waste
Land Treatment, Washington, D.C., SW-874, 1983.
9. U.S. EPA, NEIC Policies and Procedures, 330/9/78/001 -R, 1982.
10. Wood, W.W., A Technique Using Porous Cups for Water Sampling at Any Depth
in the Unsaturated Zone, Water Resources Research 9., 486-488 (1973).
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&EPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/600/R-92/088
May 1992
Facility Pollution
Prevention Guide
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EPA/600/R -92/083
May 1992
FACILITY POLLUTION PREVENTION GUIDE
Office of Solid Waste
U.S. Environmental Protection Agency
Washington, D.C. 20460
Risk Reduction Engineering Laboratory
Office of Research and Development
U.S. Environmental Protection Agency $$ Printed on Recycled paper
Cincinnati, Ohio 45268
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NOTICE
This Guide has been subjected to U.S. Environmental Protection Agency peer
and administrative review and approved for publication. Approval does not signify
that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names or commercial
products constitute endorsement or recommendation for use. This document is
intended as advisory guidance only in developing approaches for pollution
prevention. Compliance with environmental and occupational safety and health
laws is the responsibility of each individual business and is not the focus of this
document.
Users are encouraged to duplicate portions of this publication as needed to
implement a pollution prevention program. Organizations interested in reprinting
and distributing the entire Guide should contact the Pollution Prevention Research
Branch, Risk Reduction Engineering Laboratory, U.S. Environmental Protection
Agency, Cincinnati, Ohio, 45268, to obtain a reproducible master.
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FOREWORD
Today's rapidly changing technologies and industrial products and practices
carry the risk of generating materials that, if improperly managed, can threaten
public health and the environment. With the Pollution Prevention Act of 1990, the
U.S. Congress established pollution prevention as a "national objective" and the
most important component of the environmental management hierarchy. Thus,
national policy declares that the creation of potential pollutants should be prevented
or reduced during the production cycle whenever feasible.
In carrying out its program 10 encourage the adoption of Pollution Prevention,
the Risk Reduction Engineering Labc.ra.ton, and the Office of Solid Waste offer this
Facility Pollution Pre:er.r.on Guide. The Guide's predecessor, the H^-.v
Minimizaricn Opportune, Ass.essrr.er.: .Wj/iita.'. published in 19SS. concentrated
primarily on the waste types cohered in the Resource Co rise nation and Recovery
Act (RCRAj. In contrast, this edition deals with "multimedia" pollution prevention.
This reflects our national realization, as demonstrated in the 1990 legislation, thai
we must look at wastes more broadly if we are to protect the environment
adequately. That is. ii is important to minimize all pollutants, including air
emissions. wastewater discharges, and s-oi'.d wastes as well as energy ar.d water
consumption. In addition to controlling waste creation during the production
process, we need to design produce that wi.1; have less impact on the environment
while in use and after disposal.
This edition of the Guide is written for those individuals responsible for
implementing pollution prevention in their facilities. It is intended to help small- to
medium-sized production facilities develop broad-based, multimedia pollution
prevention programs. It describes how to identify, assess, and implement
opportunities for preventing pollution arid how to stimulate the ongoing search for
such opportunities. Companies thai adopt this approach typically find thai they
reduce both their operating costs and their potential liabilities, in addition to helping
to preserve the environment
This is not intended to be a prescriptive, comprehensive document. It is
necessarily a generalized approach, since it is intended for use by companies in all
business and geographic areas. You are in the 'DCS: position to judge how 10
develop a program that will fit your circumstances. We have addressed the basic
steps involved in developing an adequate pollution prevention program. The true
success of your efforts will be determined by the extent to which you are able to go
beyond these basics. Because we strongi; entourage you to go beyond a minimal
program, this Guide also provides references and information sources that will help
you expand your efforts.
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ABSTRACT
The U.S. Environmental Protection Agency (U.S. EPA) developed the Facility
Pollution Prevention Guide for those who are interested in and responsible for
pollution prevention in industrial or service facilities. It summarizes the benefits of
a company-wide pollution prevention program and suggests ways to incorporate
pollution prevention in company policies and practices.
The Guide describes how to establish a company-wide pollution prevention
program. It outlines procedures for conducting a preliminary assessment to identify
opportunities for waste reduction or elimination. Then, it describes how to use the
results of this preassessment to prioritize areas for detailed assessment, how to use
the detailed assessment to develop pollution prevention options, and how to
implement those options that withstand feasibility analysis.
Methods of evaluating, adjusting, and maintaining the program are described.
Later chapters deal with cost analysis for pollution prevention projects and with the
roles of product design and energy conservation in pollution prevention.
Appendices consist of materials that will support the pollution prevention
effort: assessment worksheets, sources of additional information, examples of
evaluative methods, and a glossary.
The draft information used for this Guide was
compiled and prepared by Battelle, Columbus, Ohio,
under Contract No. 68-CO-0003 for the U.S. EPA's
Office of Research and Development.
IV
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CONTENTS
Page
NOTICE ii
FOREWORD iii
ABSTRACT iv
ACKNOWLEDGEMENTS vii
CHAPTER 1 DECIDING ON POLLUTION PREVENTION 1
Benefits of a Pollution Prevention Program 1
The Environmental Management Hierarchy 4
What Is Pollution Prevention? 4
What Is Not Pollution Prevention? 7
Pollution Prevention Regulatory Framework 9
CHAPTER 2 DEVELOPING A POLLUTION PREVENTION PROGRAM 12
Establish the Pollution Prevention Program 12
Organize the Pollution Prevention Program 16
Do the Preliminary Assessment 18
Prepare the Program Plan 21
CHAPTER 3 DEVELOPING AND IMPLEMENTING POLLUTION PREVENTION
PROJECTS , 27
Detailed Assessment Phase 27
Define Pollution Prevention Options 34
Do Feasibility Analyses , 35
Write the Assessment Report , 40
Implement the Pollution Prevention Plan 42
CHAPTER 4 MEASURING POLLUTION PREVENTION PROGRESS 44
Acquiring Data , 44
Methods of Analyzing the Data 46
Measuring Economic Results 49
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Page
CHAPTER 5 MAINTAINING THE POLLUTION PREVENTION PROGRAM 50
Integrate Pollution Prevention Into Corporate Plan 50
Staff Education 52
Maintain Internal Communication 55
Employee Reward Program 57
Public Outreach and Education 57
CHAPTER 6 ECONOMIC ANALYSIS OF POLLUTION PREVENTION PROJECTS . . 58
Total Cost Assessment 58
Expanded Cost Inventory 59
Expanded Time Horizon . 62
Long-Term Financial Indicators 62
Direct Allocation of Costs 62
Summary 64
CHAPTER 1 DESIGNING ENVIRONMENTALLY COMPATIBLE PRODUCTS 65
Stages in Life-Cycle Assessment 65
Goals of Product Design or Redesign 66
CHAPTER 8 ENERGY CONSERVATION AND POLLUTION PREVENTION 69
Preventing Pollution b> Conserving En-erg) 69
Conserving Energy through Pollution Prevention ... . . , 70
APPENDICES
APPENDIX A POLLUTION PREVENTION WORKSHEETS 73
APPENDIX B INDUSTRY-SPECIFIC CHECKLISTS S3
APPENDIX C CUSTOMIZED POLLUTION PREVENTION WORKSHEETS 97
APPENDIX D TECHNICAL/FINANCIAL ASSISTANCE PROGRAMS 117
APPENDIX E OPTION RATING: WEIGHTED SUM METHOD 127
APPENDIX F ECONOMIC EVALUATION EXAMPLE 128
APPENDIX G POLLUTION PREVENTION REFERENCE MATERIAL 134
APPENDIX H GLOSSARY OF POLLUTION PREVENTION TERMS 141
VI
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ACKNOWLEDGEMENTS
This Guide was prepared under the
direction and coordination of Lisa Brown of
the U.S. Environmental Protection Agency
(U.S. EPA), Pollution Prevention Research
Branch, Risk Reduction Engineering
Laboratory, Cincinnati, Ohio.
Battelle compiled and prepared the
information used for this Guide under the
direction of Bob Olfenbuttel. Participating in
this effort for Battelle were Larry Smith, David
Evers, Lynn Copley-Graves, Carol Young, and
Sandra Clark.
Contributions were made by U.S. EPA's
Office of Research and Development, the U.S.
EPA Office of Solid Waste, the pollution
prevention organizations in the U.S. EPA
Regional Offices, state pollution prevention
organizations, and members of academia and
industry.
Specifically, the following people
provided significant assistance:
Patrick Pesacreta
Office of Solid Waste
U.S. Environmental Protection Agency
Gary Hunt
North Carolina Office of Waste Reduction
Deborah Hanlon & Martin Spitzer
Pollution Prevention Division
U.S. Environmental Protection Agency
Abby Swaine
Region I Pollution Prevention Program
U.S. Environmental Protection Agency
Thomasine Bayless
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Contributions to the development of this
Guide were also made by the following
people:
Alan Rimer
Alliance Technologies Corporation
Eugene B. Pepper
Office of Environmental Coordination
Slate of Rhode Island and Providence
Plantations
Harry W. Edwards
Colorado State University
David L, Thomas, Ph.D.
Hazardous Waste Research and Information
Center
Azita Yazdani
Pollution Prevention International
David M. Benforado
3M Corporation
R. Lee Byers
Aluminum Company of America
James R. Aldrich
University of Cincinnati
Henry W. Nowick
Envirocorp
James Edward
Pollution Prevention Division
U.S. Environmental Protection Agency
Chet McLaughlin
Region VII
U.S. Environmental Protection Agency
Marvin Fleischman & Clay Hansen
University of Louisville
vn
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Charles A. Pittinger, PhD
The Procter & Gamble Company
H. Lanier Hickman, Jr.
GRCDA/SWANA
Dent Williams
DIPEC
Charles Wentz
Argonne National Laboratory
Linda G. Pratt
San Diego County Department of Health
Services
Bruce Cranford
U.S. Department of Energy
L. M. Fischer
Allied-Signal
Thomas R. Mersey, Jr.
Erie County Pollution Prevention Program
Richard F. Nowina
Ontario Waste Management Corporation
David Hartley & Robert Ludwig
California Department of Toxic Substance
Control
Bob Carter
Waste Reduction Resource
Center — Southeast
Audun Amundsen
Stiftelsen 0stfoldforskning
Norway
Birgitte B. Nielsen
Rendan A/S
Denmark
Michel Suijkerbuijk
Innovatiecentrum Overijssel
Netherlands
Per Kirkebak
Peterson A-S
Norway
Han Brezet & Bas Kothuis
TME
Netherlands
Sybren de Hoo
NOTA
Netherlands
Special acknowledgement is given to all
members of the Pollution Prevention Research
Branch, especially;
Ruth Corn. Rita Bender,
Harry Freeman, Ivars Licis,
Paul Randall, Mary Ann
Cumin and Anne Robertson.
Terry Foecke
WRITAR
International contributions were made by:
Barbel Hegenbart & Stefan Millonig
IOW & VOW
Austria
Brian Pearson
Aspects International Ltd.
England
Thomas Gutwinski
BAUM
Austria
VIII
Acknowledgements
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CHAPTER 1
DECIDING ON
POLLUTION PREVENTION
Pollution prevention is the use of materials, processes, or
practices that reduce or eliminate the creation of pollutants or
wastes at the source. It includes practices that reduce the use of
hazardous and nonhazardous materials, energy, water, or other
resources as well as those that protect natural resources through
conservation or more efficient use.
A pollution prevention program is an ongoing, comprehensive
examination of the operations at a facility with the goal of mini-
mizing all types of waste products. An effective pollution preven-
tion program will:
* reduce risk of criminal and civil liability
• reduce operating costs
• improve employee morale and participation
• enhance company's image in the community
• protect public health and the environment.
This Guide is intended to assist you in developing a pollution
prevention program for your business. It will help you decide
which aspects of your operation you should assess and how de-
tailed this assessment should be.
This chapter provides background information on pollution
prevention. Specifically, it
• Summarizes the benefits you can obtain from a
company-wide pollution prevention program that
integrates raw materials, supplies, chemicals, energy,
and water use.
Describes the U.S. EPA's Environmental Manage-
ment Hierarchy.
Explains what pollution prevention is and what it is
not.
Provides an overview of federal and state legislation
on pollution control.
A pollution prevention program
addresses all types of waste.
Those companies "struggling to
maintain compliance today may
not be around by the end of the
'90s. Those toeing the compli-
ance line will survive. But those
viewing the environment as a
strategic issue will be leaders."
— Richard W, MacLean, chief
of environmental programs at
Arizona Public Service Co., as
quoted in Environmental Busi-
ness Journal, December, 1991,
BENEFITS OF A POLLUTION PREVENTION PROGRAM
In the case of pollution prevention, national environmental
goals coincide with industry's economic interests. Businesses have
strong incentives to reduce the toxicity and sheer volume of the
waste they generate. A company with an effective, ongoing
pollution prevention plan may well be the lowest-cost producer and
have a significant competitive edge. The cost per unit produced
will decrease as pollution prevention measures lower liability risk
-------
and operating costs. The company's public image will also be
enhanced.
Reduced Risk of Liability
You will decrease your risk of both civil and criminal liability
by reducing the volume and the potential toxicity of the vapor,
liquid, and solid discharges you generate. You should look at all
types of waste, not just those that are currently defined as hazard-
ous. Since toxicity definitions and regulations change, reducing
the volume of wastes in all categories is a sound long-term man-
agement policy.
Environmental regulations at the federal and state levels
require that facilities document the pollution prevention and recy-
cling measures they employ for wastes defined as hazardous.
Companies that produce excessive waste risk heavy fines, and their
managers may be subject to fines and imprisonment if potential
pollutants are mismanaged.
Civil liability is increased by generating hazardous waste and
other potential pollutants. Waste handling affects public health and
property values in the communities surrounding production and
disposal sites. Even materials not currently covered by hazardous
waste regulations may present a risk of civil litigation in the future.
Workers' compensation costs and risks are directly related to
the volume of hazardous materials produced. Again, it is unwise
to confine your attention to those materials specifically defined as
hazardous.
Reduced Operating Costs
An effective pollution prevention program can yield cost
savings that will more than offset program development and imple-
mentation costs. Cost reductions may be immediate savings that
appear directly on the balance sheet or anticipated savings based
on avoiding potential future costs. Cost savings are particularly
noticeable when the costs resulting from the treatment, storage, or
disposal of wastes are allocated to the production unit, product, or
service that produces the waste. Refer to Chapter 6 for more
information on allocating costs.
Materials costs can be reduced by adopting production and
packaging procedures that consume fewer resources, thereby creat-
ing less waste. As wastes are reduced, the percentage of raw
materials converted to finished products increases, with a propor-
tional decrease in materials costs.
Waste management and disposal costs are an obvious and
readily measured potential savings to be realized from pollution
prevention. Federal and state regulations mandate special in-plant
handling procedures and specific treatment and disposal methods
for toxic wastes. The costs of complying with these requirements
and reporting on waste disposition are direct costs to businesses.
There are also indirect costs, such as higher taxes for such public
"Above all, companies want to
pin down risk... Because the costs
can be so enormous, risk must
now be taken into account across
a wide range of business deci-
sions. "
— Bill Schwalm, senior man-
ager for environmental pro-
grams and manufacturing at
Polaroid, in an interview with
Environmental Business Jour-
nal, December. 1991.
Look beyond the wastes currently
defined as hazardous.
A comprehensive pollution preven-
tion program can reduce current
and future operating costs.
Chapter 1
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services as landfill management. The current trend is for these
costs to continue to increase at the same or higher rates. Some of
these cost savings are summarized in Box 1.
Waste management costs will decrease as pollution prevention measures are implemented:
• Reduced manpower and equipment requirements for on-site pollution control and
treatment
Less waste storage space, freeing more space for production
Less pretreatment and packaging prior to disposal
Smaller quantities treated, with possible shift from treatment, storage, and
disposal (TSD) facility to non-TSD status
Less need to transport for disposal
Lower waste production taxes
Reduced paperwork and record-keeping requirements, e.g.. less Toxic Release
Inventor.1 i.TRI") reporting when TRI-listed chemicals are eliminated or reduced.
Box 1
Production costs can be reduced through a pollution preven-
tion assessment. When a multi-disciplinary group examines
production processes from a fresh perspective, opportunities for
increasing efficiency are likely to surface that might not otherwise
have been noticed. Production scheduling, material handling.
inventory control, and equipment maintenance are all areas that can
be optimized to reduce the production of waste of all types and
also control the costs of production.
Energy costs will decrease as pollution prevention measures
are implemented in various production lines. In addition, energy
used to operate the overall facility can be reduced by doing a
thorough assessment of how various operations interact. Chapter 8
discusses energy conservation.
Facility cleanup costs may result from a need to comply with
future regulations or to prepare a production facility or off-site
waste storage or disposal site for sale. These future costs can be
minimized by acting now to reduce the amount of wastes of all
types that you generate.
Improved Company Image
As the quality of the environment becomes an issue of greater
importance to society, your company's policy and practices for
controlling waste increasingly influence the attitudes of your
employees and of the community at large.
Employees are likely to feel more positive toward their com-
pany when they believe that management is committed to provid-
ing a safe work environment and is acting as a responsible member
Optimixng processes and energy-
use reduces wasie and controls
production costs.
Corporate image is enhanced by a
demonstrated commitment to
pollution pre^-entron.
Deciding on Pollution Prevention
-------
of the community. By participating in pollution prevention activi-
ties, employees can interact positively with each other and with
management Helping to implement and maintain a pollution
prevention program should increase their sense of identity with
company goals. This positive atmosphere helps to retain a compet-
itive workforce and to attract high-quality new employees.
Community attitudes will be more positive toward companies
that operate and publicize a thorough pollution prevention pro-
gram. Most communities actively resist the siting of new waste
disposal facilities in their areas. In addition, they are becoming
more conscious of the monetary costs of treatment and disposal.
Creating environmentally compatible products and avoiding exces-
sive consumption and discharge of material and energy resources,
rather than concentrating solely on treatment and disposal, will
greatly enhance your company's image within your community and
with potential customers.
Public Health and Environmental Benefits
Reducing production wastes provides upstream benefits be-
cause it reduces ecological damage due to raw material extraction
and refining operations. Subsequent benefits are the reduced risk
of emissions during the production process and during recycling,
treatment, and disposal operations.
"We regard the environment as a
long-term strategic set of issues.
To have a strong, viable compa-
ny, the environment has to be
taken into account... by planning
for [consumer demand for more
environmental quality] we will be
more competitive in the market-
place. "
— Bill Riley, director of Envi-
ronment—Marketing at Clorox,
as quoted in Environmental
Business Journal, December,
1991.
THE ENVIRONMENTAL MANAGEMENT HIERARCHY
The Pollution Prevention Act of 1990 reinforces the U.S.
EPA's Environmental Management Options Hierarchy, which is
illustrated in Figure 1. The highest priorities are assigned to pre-
venting pollution through source reduction and reuse, or closed-
loop recycling.
Preventing or recycling at the source eliminates the need for
off-site recycling or treatment and disposal. Elimination of pollut-
ants at or near the source is typically less expensive than collect-
ing, treating, and disposing of wastes. It also presents much less
risk to your workers, the community, and the environment.
Source reduction and reuse pre-
vent pollution.
WHAT IS POLLUTION PREVENTION?
Pollution prevention is the maximum feasible reduction of all
wastes generated at production sites. It involves the judicious use
of resources through source reduction, energy efficiency, reuse of
input materials during production, and reduced water consumption.
There are two general methods of source reduction that can be
used in a pollution prevention program: product changes and
process changes. They reduce the volume and toxicity of produc-
tion wastes and of end-products during their life-cycle and at
disposal. Figure 2 provides some examples.
Change products and production
processes to reduce pollution at
the source.
Chapter 1
-------
Product changes in the composition or use of the intermediate
or end products are performed by the manufacturer with the pur-
pose of reducing waste from manufacture, use, or ultimate disposal
of the products. Chapter 7 in this Guide provides information on
designing products and packaging that have minimal environmental
impact.
Redesign products to minimize
their environmental impact.
Method Example Activities Example Applications
Source Reduction
(Highest Priority)
Recycling
Treatment
Disposal
• Environmentally
Friendly Design
• Product Changes
• Source Elimination
• Reuse
• Reclamation
• Stabilization
• Neutralization
• Precipitation
• Evaporation
• Incineration
• Scrubbing
• Disposal at a
Permitted Facility
• Modify Product to
Avoid Solvent Use
• Modify Product to
Extend Coating Life
• Solvent Recycling
• Metal Recovery From
a Spent Plating Bath
• Volatile Organic
Recovery
• Thermal Destruction
of Organic Solvent
• Precipitation of Heavy
Metal From a Spent
Plating Bath
• Land Disposal
Figure 1: Environmental Management Options Hierarchy
Deciding on Pollution Prevention
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Sou rte Reduction
Product Changes
Design for Less
Increase Product
Life
Process Changes
Input Material Changes
• Material Purtfcatcn
• Substitution of Less-Toxic
Technology Changes
• La/D^ Changes
• improved Operating
Conditions
• Improved Equipment
* New Teennotogy
improved Operating Practices
* Operating and Maintenance
Procedures
• Management Pradces
• Stream Segregation
* Material Handling
Improvements
• Production Scheduling
* Inventory Contfo4
* Training
« Waste Segregation
Figure 2. Source Reduction Methods
Process changes are concerned with hov» tiie product is made.
They include input maienal changes, technology changes, and
improved operating practices. All such changes reduce worker
exposure to pollutants cJunng the manufacturing process. Typical-
ly, improved operating practices can be implemented more quickly
and at less expense than input material and technology changes.
Box 2 provides examples of process changes.
Process changes may be imple-
mented more quickly than product
changes.
Chapter 1
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The following process changes are pollution prevention measures because they redyce
the amount of waste created during production.
Examples of input material changes:
» Stop using heavy metal pigment.
• Use a less hazardous or toxic solvent for cleaning or as coating.
• Purchase raw materials that are free of trace quantities of hazardous or toxic
impurities.
Examples of technology changes;
• Redesign equipment and piping to reduce the volume of material contained,
cutting losses during batch or color changes or when equipment is drained for
maintenance or cleaning.
Change to mechanical stripping/cleaning devices to avoid solvent use.
Change to a powder-coating system.
• Install a hard-piped vapor recovery system to capture and return vaporous
emissions.
Use more efficient motors.
* Install speed control on pump motors to reduce energy consumption.
Examples of improved operating practices:
Train operators.
Cover solvent tanks when not in use.
• Segregate waste streams to avoid cross-contaminating hazardous and nonhazard-
ous materials.
• Improve control of operating conditions (e.g., flow rate, temperature, pressure,
residence time, stoichiometry).
* Improve maintenance scheduling, record keeping, or procedures to increase
efficiency.
Optimize purchasing and inventory maintenance methods for input materials.
Purchasing in quantity can reduce costs and packaging material if care is taken to
ensure that materials do not exceed their shelf life. Reevaluate shelf life charac-
teristics to avoid unnecessary disposal of stable items.
• Stop leaks, drips, and spills.
• Turn off electrical equipment such as lights and copiers when not in use.
• Place equipment so as to minimize spills and losses during transport of parts or
materials.
• Use drip pans and splash guards.
Box 2
WHAT IS NOT POLLUTION PREVENTION?
There are a number of pollution control measures that are Waste treatment is not pollution
applied only after wastes are generated. They are, therefore, not prevention.
correctly categorized as pollution prevention. Box 3 provides
some examples of procedures that are waste handling, not pollution
prevention, measures.
Deciding on Pollution Prevention
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The following are not pollution prevention measures because they are taken after the
waste is created:
Off-site recycling:
Off-site recycling (e.g., solvent recovery at a central distillation facility) is
an excellent waste management option. However, it does create pollution
during transport and during the recycling procedure.
• Waste treatment:
Waste treatment involves changing the form or composition of a waste
stream through controlled reactions to reduce or eliminate the amount of
pollutant. Examples include detoxification, incineration, decomposition,
stabilization, and solidification or encapsulation,
Concentrating hazardous or toxic constituents to reduce volume:
Volume reduction operations, such as dewatering, are useful treatment
approaches, but they do not prevent the creation of pollutants. For
example, pressure filtration and drying of a heavy metal waste sludge
prior to disposal decreases the sludge water content and waste volume,
but it does not decrease the number of heavy metal molecules in the
sludge.
Diluting constituents to reduce hazard or toxicity:
Dilution is applied to a waste stream after generation and does not reduce
the absolute amount of hazardous constituents entering the environment.
Transferring hazardous or toxic constituents from one environmental
medium to another:
Many waste management, treatment, and control practices used to date
have simply collected pollutants and moved them from one environmental
medium (air, water, or land) to another. An example is scrubbing to
remove sulfur compounds from combustion process off-gas.
Box 3
Off-site recycling is vastly preferable to other forms of waste Off-site recycling carries some
handling because it helps to preserve raw materials and reduces the risk.
amount of material that will require disposal. However, compared
with closed-loop recycling (or reuse), performed at the production
site, there is likely to be more residual waste that will require
disposal. Further, waste transportation and the recycling process
itself carry the risks of worker exposure and of release into the
environment.
Transferring hazardous wastes to another environmental Transfer to another environmental
medium is not pollution prevention. Many waste management medium should be avoided in most
practices to date have simply collected pollutants and moved them cases.
from one environmental medium to another. For example, solvents
can be removed from wastewater by means of an activated carbon
Chapter 1
-------
adsorbers. However, regenerating the carbon requires the use of
another solvent or heating, which transfer the waste to the atmo-
sphere. In some cases, transfer is a valid treatment option. How-
ever, too often the purpose has been to shift a pollutant to a less-
tightly regulated medium. In either case, media transfers are not
pollution prevention.
Waste treatment prior to disposal reduces the toxicity and/or
disposal-site space requirements but does not eliminate all pollutant
materials. This includes such processes as volume reduction, dilu-
tion, detoxification, incineration, decomposition, stabilization, and
isolation measures such as encapsulation or embedding.
POLLUTION PREVENTION REGULATORY FRAMEWORK
Companies are required to have pollution prevention programs
for waste classified as hazardous. See Appendix D for points of
contact at U.S. and state agencies levels who can provide you with
information about regulations and with technical assistance for
pollution prevention.
Federal
Under the terms of the 1988 Resource Conservation and
Recovery Act (RCRA), "it shall be a condition of any permit
issued under this section for the treatment, storage, or disposal of
hazardous waste on the premises where such waste was generated
that the permittee certify, no less often than annually, that the
generator of the hazardous waste has a program in place to reduce
the volume or quantity and toxicity of such waste to the degree
determined by the generator to be economically practicable."
The 1990 Pollution Prevention Act (PPA) specifies that
facilities required to report releases to the U.S. EPA for the Toxic
Release Inventory (TRI) provide documentation of their proce-
dures for preventing the release of or for reusing these materials
(Box 4).
These acts, plus the Comprehensive Environmental Re-
sponse, Compensation, and Liability Act (CERCLA), require
generators of hazardous wastes to evaluate and document their
procedures for controlling the environmental impact of their
operations.
However, the PPA goes beyond wastes designated as hazard-
ous. It encourages the maximum possible elimination of wastes of
all types. It emphasizes that the preferred method of preventing
pollution is to reduce at the source the volume of waste generated
and that reuse (closed-loop recycling) should be performed when-
ever possible. In this way, it is fundamentally different from off-
site recycling, treatment, and disposal and is meant to reduce the
need for these measures. Treatment and disposal are ro be viewed
as last-resort measures.
Hazardous waste reduction pro-
grams are required under RCRA,
PPA, and CERCLA
The Pollution Prevention Act
encourages source reduction of all
wasti' types.
Deciding on Pollution Prevention
-------
Pollution Prevention Act of 1990 data reporting requirements for TRI chemicals:
Amount entering any waste stream (or otherwise released into the environ-
ment) before recycling, treatment, or disposal, and the percent change from
the previous year.
Amount recycled on site or off site during each calendar year, the
percent change for the previous year, and the recycling process used.
Source reduction practices used during each year.
Amount expected to be reported under the first two data items above
for the two calendar years right after the reporting year (reported as
percent change).
• Ratio of reporting year's production to previous year's production.
• Techniques used to identify source reduction opportunities.
• Amount released into the environment from a catastrophic event,
remedial action, or other one-time event and not associated with the
production process.
Box 4
State
A number of states have enacted legislation that requires Some states require pollution
pollution prevention or waste minimization. As of March, 1992, a prevention programs.
total of 26 states had passed such legislation (WRITAR Survey of
State Legislation, March 1992). (See Box 5.)
State legislation, if enacted, must address at a minimum those
substances defined as hazardous by RCRA, CERCLA, and the
Superfund Amendments and Reauthorization Act of 1986 (SARA).
Additional substances may be classified as hazardous by the
individual state. Most programs are aimed at large-quantity gener-
ators since they are the high-volume producers of pollution. Some
also apply to small-quantity generators or have special provisions
for these. Fifteen states require waste generators to submit plans
and/or progress reports on waste minimization or pollution preven-
tion efforts, while others make such reporting optional.
In many states, the legislation establishes pollution prevention
program offices, advisory- boards, or commissions to provide
technical assistance and to promote education, training, and re-
search.
JQ Chapter 1
-------
State legislation promoting pollution prevention as of March. 1992:
Alaska
Arizona
California
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
low-a
Kentucky
Louisiana
Maine
Massachusetts
Minnesota
Mississippi
New Jersey
New. York
North Carolina
Oregon
Rhode Island
Tennessee
Texas
Vermoni
Washington
Wisconsin
Solid and Hazardous Waste Management Act
Amendments to Arizona Hazardous Waste Management
Statutes
Hazardous Waste Reduction and Man-
agement Review Act
Environmental Assistance to Business Act
Waste Minimization/Pollution Prevention Act
Pollution Prevention Act
Amendment to Hazardous Waste Management Act
Toxic Pollution Prevention Act
.Amendment to Environmental Code
Toxics Pollution Prevention Act
(no title)
Waste Reduction Lav.
Reduction of Toxics Use, Waste and Release Act
Toxic Use Reduction Ac;
Toxic Pollution Prevention Act
Comprehensive Multimedia Waste Minimization
Act
Pollution Prevention Act
Hazardous Waste Management Act
Hazardous Waste Management Act
Toxic Use Reduction and Hazardous Waste
Reduction Act
Hazardous Waste Facility Planning Act
Hazardous Waste Reduction Act
Waste Reduction Poiic> Act
Hazardous Waste Management Act
Hazardous Waste and Substance Reduction Act
Hazardous Substances. Toxic Pollutants.
Hazardous Waste Use and Release Reduction
Colorado, Michigan, Missouri. Ohio, and South Carolina are expected to
enact pollution prevention regulations in !9v2.
Box 5
Deciding on Pollution Prevention
11
-------
CHAPTER 2
DEVELOPING A
POLLUTION PREVENTION PROGRAM
Pollution prevention planning is a comprehensive and continu-
al evaluation of how you do business, and the resulting program
will affect many functional areas within your company. Therefore,
it has much in common with the planning you already do for other
aspects of your business operations.
Figure 3 illustrates the major steps in the pollution prevention
program. These steps are described in this chapter and in Chapters
3 through 5.
This chapter considers the elements of pollution prevention
program design as they might be addressed by a small- or medi-
um-sized company. These elements include building support for
pollution prevention throughout the company, organizing the
program, setting goals and objectives, performing a preliminary
assessment of pollution prevention opportunities, and identifying
potential problems and their solutions.
Pollution prevention should be
integrated into your overall busi-
ness plan.
ESTABLISH THE POLLUTION PREVENTION PROGRAM
Executive Level Decision
In some companies, the initiative to investigate setting up a
pollution prevention program will be taken at the executive level.
In others, lower-level managers or employees will be the catalysts.
In either case, it may be necessary to gather information to demon-
strate that pollution prevention opportunities exist and should be
explored. This information will be used by company executives as
they weigh the potential value of pollution prevention and decide
whether to commit the resources necessary to develop and imple-
ment the program.
One way to gather this information is to perform a preliminary
assessment. A pre-assessment is part of the formal program design
effort and is, therefore, described later in this chapter. However, a
high-level pre-assessment of only one or two areas of the facility
can be done to gather information and, perhaps, even identify
several low-cost, quick-payoff pollution prevention techniques that
can be implemented readily.
Once senior managers have decided to establish a pollution
prevention program, they should convey this commitment to all
employees through a formal policy statement. This will establish a
framework for communicating the formal commitment throughout
the organization.
Pollution Prevention
Program
Executive Lsve< Decision
Policy Statement
Consensus Building
I Organize Progrim 1
• — —| Do Pf»Hmlniry A«u«»mwilI
I Writ* Progrim Plan
1
Do DeUlled AiMt
Define Pollution Prevention Option*
I Do Feasibility Analyiaa
Writ* Aisesiment Report
Implement the Plan |
Measure Progreta
[Maintain Pollution Prevention Program)
12
Chapter 2
-------
ist*btlsh the Pollution Prevention Program
• Executive Level Decision
• Policy Statement
• Consensus Building
Organize Program
« Name Task Fores
• State Goals
Do Preliminary Assessment
• Collect Data
* Review Sites
• Establish Priorities
Wrl!» Program Plan
Consider External Groups
Define Objectives
Identity Potential Obstacles
Develop Schedule
Do Detailed Assessment
Name Assessment Team^s)
Review Data and Site(s)
Organize and Document Information
Define Pollution Prevention Options
• Propose Options
• Screen Options
Do Fusibility Analyse*
« Technical
• Environmental
• Economic
Writs Assessment Report
implement the Plan
* Select ProjecB
• Obtain Funding
• Install
Measure ProgreM
« Acquire Data
• Analyze Results
[ Maintain Pollution Prevention Program |
Figure 3. Pollution Prevention Program Overview
Developing a Pollution Prevention Program
13
-------
Policv Statement
As with other policy statements your company develops, your
pollution prevention policy statement should state why a program
is being established, what is to be accomplished in qualitative
terms, and who will do it Two example policy statements are
given in Box 6. They differ in level of detail, but both answer
these key questions:
Why are we implementing pollution prevention?
We want to protect the environment.
What will be done to implement pollution prevention?
We will reduce or eliminate the amounts of all types of
waste, and we will improve energy efficiency.
Who will implement pollution prevention?
Everyone will be involved.
Consensus Building
After you have developed your pollution prevention policy
statement, consider how it should be presented to your employees
so that they will see it as an ongoing, company-wide commitment.
The policy statement is the foun-
dation of
program,
'.he pollution. pr
/.' 15 essential ihat employees
understand and suppor: :he pollu-
tion prevention program.
Everyone in your facility will be involved in some way.
14
Chapter 2
-------
POLICY STATEMENT EXAMPLE 1 - "(Your Company Name) is committed to
excellence and leadership in protecting the environment. In keeping with this
policy, our objective is to reduce waste and emissions. We strive to minimize
adverse impact on the air, water, and land through pollution prevention and energy
conservation. By successfully preventing pollution at its source, we can achieve
cost savings, increase operational efficiencies, improve the quality of our products
and services, maintain a safe and healthy workplace for our employees, and improve
the environment. (Your Company Name)'s environmental guidelines include the
following:
— Environmental protection is everyone's responsibility. It is valued and
displays commitment to (Your Company Name).
— We will commit to including pollution prevention and energy conservation
in the design of all new products and services.
— Preventing pollution by reducing and eliminating the generation of waste
and emissions at the source is a prime consideration in research, process
design, and plant operations. (Your Company Name) is committed to
identifying and implementing pollution prevention opportunities through
encouraging and involving all employees.
— Technologies and methods which substitute nonhazardous materials and
utilize other source reduction approaches will be given top priority in
addressing all environmental issues.
— (Your Company Name) seeks to demonstrate its responsible corporate
citizenship by adhering to all environmental regulations. We promote
cooperation and coordination between industry, government, and the public
toward the shared goal of preventing pollution at its source."
POLICY STATEMENT EXAMPLE 2 - "At (Your Company Name), protecting
the environment is a high priority. We are pledged to eliminate or reduce our use
of toxic substances and to minimize our use of energy and generation of all wastes,
whenever possible. Prevention of pollution at the source is the preferred alternative.
When waste cannot be avoided, we are committed to recycling, treatment, and
disposal in ways that minimize undesirable effects on air, water, and land."
(Adapted from: Waste Reduction Institute for Training and Applications Research, Inc.
[WRITAR], Survey and Summaries, 1991, and Minnesota Office of Waste Management, Feb.
1991, Minnesota Guide to Pollution Prevention Planning)
Box 6
While executives and managers will assign priorities and set the
tone for the pollution prevention program, the attitude of produc-
tion-level employees will have a significant effect on its success.
Since it is their daily activities that generate waste, their support of
the program is essential.
Developing a Pollution Prevention Program 15
-------
How you publicize the policy depends on the size and the
culture of your company. You may decide to call a general
meeting or to hold several meetings with smaller groups. There
may be other types of publicity that you have found effective.
You might offer bonuses or other awards to employees who
suggest ways to prevent pollution. Announcing awards in newslet-
ters or on bulletin boards provides additional incentive to employ-
ees and further publicizes the program. Pollution prevention might
be included in job objectives and performance evaluations for
managers and other appropriate employees.
In any case, it is important to emphasize your company's
commitment to pollution prevention and encourage employee
participation. This will help to establish a positive atmosphere and
reassure employees who might be concerned about the changes that
will result. This approach will also elicit worthwhile pollution
prevention suggestions.
Encourage employee participation.
A positive atmosphere produces
best results.
Employees fee! committed to pollution prevention when they are encouraged to:
• Help define company goals and objectives.
• Review processes and operations to determine where and how toxic substances
are used and hazardous wastes are generated.
« Recommend ways to eliminate or reduce waste production at the source.
» Design or modify forms and records to monitor materials used and waste.
Find ways to involve suppliers and customers.
• Think of ways to acknowledge and reward employee contributions to the
pollution prevention effort.
Box 7
ORGANIZE THE POLLUTION PREVENTION PROGRAM
The program will be directed by the Pollution Prevention Task
Force. Their first task will be to delineate program goals.
Name the Pollution Prevention Task Force
The people who will direct the pollution prevention program
should be selected carefully. They will have overall responsibility
for developing the plan and directing its implementation. Their
capabilities and their attitudes toward the effort will be major
determinants of how successful it is. As with other areas of your
operation, successful program execution will require integration
and continuity of the planning, implementation, modification, and
maintenance stages. Therefore, all individuals named to this task
force should have substantial technical, business, and communica-
tion skills as well as thorough knowledge of the company. The
responsibility and authority of each individual should be estab-
lished during this organizational stage.
. _J Eaubluti Ilia Pollution Pi»v«nUon
Program
Organist Program
• Nam0 Tftik Force
* State Goait
Do D«Utl*dAt*«Mm*ni
Do F«»tlbllily An»ir
I
* Program*
I
" i ^° ^r*^m'IMiry A*i*»mi*nlI
1 .
I Wfll« Program Pton |
D«nn« Pollution Pravamlon {
1
nt Report I
[Maintain Pollution Prronllon Program [
16
Chapter 2
-------
The program leader should be named from the highest level
practical. The leader must have the authority and the influence
necessary to keep the program on track and to ensure that pollution
prevention becomes an integral part of the overall corporate plan.
The role of the leader is to facilitate the flow of information
among all levels in the company. Therefore, the leader should
possess the personal qualities necessary to elicit broad-based
support from the company's employees.
The task force works together during planning and preassessment.
One or more pollution prevention champions should be
designated. The task of a "champion" is to overcome possible
resistance to proposed changes in operations. In a medium-sized
company, several champions may be assigned, perhaps according
to production area. In a very small company, the champion may
also be the program leader. Champions will be the team members
who are the most visible within the production areas and should be
respected and trusted at all levels in order to perform this liaison
role well.
Other team members might be selected tor their specific
technical or business expertise. Environmental and plant process
engineers, production supervisors, and experienced line-workers are
good candidates. Other potential sources include purchasing and
quality-assurance staff. In some cases, outside consultants may be
retained to work with the in-house team.
Once the task force has been established, they will be a valu-
able resource within the company. When plans are being made to
The task force will direct the
development and implementation
of the pollution prevention pro-
gram and help integrate its princi-
ples into all phases of corporate
planning.
Developing a Pollution Prevention Program
17
-------
expand the facility or to design or redesign products, they can
review the plans to determine whether waste generation has been
evaluated thoroughly.
State Goals
The program leaders will need to establish goals that state the
long-term direction for the pollution prevention program. Well-
defined goals will help to focus effort and build consensus. Goals
should be consistent with your company's pollution prevention
policy and, in fact, may have been stated in general terms in the
policy statement. Now, they need to be stated more specifically,
The goal-setting process will involve the program team and
company management. The size of the group needed to develop
the goals depends on the size and complexity of your facility. For
a small company, the group might be only two or three people.
Since success in pollution prevention may require basic chang-
es in the corporate culture, goals should be useful and meaningful
for every employee. Goals need to be challenging enough to
motivate but not unreasonable or impractical,
When beginning the goal-setting process, consider starting
from the zero-discharge perspective. This ideal situation would
involve 100% utilization of resources, eliminating disposal costs
and regulatory compliance needs. This is probably not a com-
pletely achievable goal in any industry, given current technology.
However, like zero-defect production goals, zero-discharge goals
encourage an attitude of continually striving for improvement.
Pollution prevention goals can be qualitative, such as, "achieve
a significant reduction of toxic substance emissions to the environ-
ment." Quantitative goals are more difficult to develop but are
worth the extra effort They spell out your pollution prevention
commitment and give all participants and observers a yardstick for
measuring progress.
Finally, goals should be flexible and adaptable. Conditions
change in actual practice. As your pollution prevention program
becomes more focused and the pollution-specific aspects of the
operation become better known, the goals can be refined. They
can be adjusted up or down as the program matures and lessons
are learned. Periodic goal-achievement review and adjustment will
keep your program active and visible within the company.
Your corporate pollution prevention policy and goals should
be integrated in a formal planning document.
Goals should be:
* well-defined
* meaningful to all employees
* challenging yet achievable
* flexible
* part of a program planning
document.
Polaroid's Toxic Use and Waste
Reduction Program...aims to
reduce toxic use at source and
waste per unit of production by
10% per year....
— From an interview with
Bill Schwalm, a senior manag-
er at Polaroid, Environmental
Business Journal, December,
1991,
DO THE PRELIMINARY ASSESSMENT
Even though you may have completed some aspects of the
preliminary assessment as input to the executive decision to devel-
op a pollution prevention program, a deeper examination will be
needed at this point. The data collection that is a part of this pre-
assessment will help the team review the data that are already
18
Chapter 2
-------
available and begin defining ways to process that daia. These data
and the site visits will enable ihe Task Force to establish priorities
and procedures for detailed assessments. Chapter 3 describes the
detailed assessment phase and the more in-depth data collection
and analyses that will be done at that stage.
Collect Data
The extent and complexity of the system for collecting pollu-
tion prevention data should be consistent with the needs of your
company. Keep in mind that the goal of the program is to prevent
pollution, not to collect data — the simplest system that fits your
needs is the best. Depending on the nature and size of your firm.
much of the data needed for a pollution prevention program may
be collected as a normal pan of plant operations or in response to
existing regulatory requirements. iSee Box 8.j The worksheets in
Appendix A can be used for the pre-assessment: you may decide to
modify them to fit your particular industry.
An all-media approach, which deals with ail air, water, and
solid waste emissions and releases, will be the most effective.
This involves considering all waste streams, identifying their
sources and quantifying the true costs of pollution control, treat-
ment, and waste disposal. There are a number of information
sources to consider.
Regulatory reports — National Pollutant Discharge Elimina-
tion System (NPDES) and SARA Tide III reports document the
volume, composition, and degree of toxicity of wastewater dis-
charged. The toxic substance release inventories required by
SARA Title III. Section 313 may provide information on emissions
into all environmental media.
Engineering and operating data — Shipping manifests will
provide quantities of hazardous waste shipped during a given
period, but may lack chemical analysis, specific source, and the
time period dunng which the waste was generated. The plant
design documents and equipment operating manuals and proce-
dures may yield specific data for streams inside of the plant.
Plant business records — Records available from inventory
control, purchasing, records management, accounting, marketing.
and training can provide data needed for the pre-assessment and
may themselves present opportunities for pollution prevention. For
example, improved inventory control and judicious purchasing can
significantly reduce the volume of raw materials that must be
disposed of because they become outdated. In reviewing existing
data, you may find that current accounting practices are not appro-
priate for placing the burden of pollution and pollution control at
the point of generation. These findings should be taken into
account when costs of pollution control measures are analyzed.
(See Chapter 6.)
Establish Ins Pollution Prevention
Program
Organize Program
,
Do Preliminary Assessment
• Collect Data
• Remew Sites
• Estabtaft Pnontei
Wrile Program Plan
Do Detailed Assessment
Define PoOutton Prevention Option*
Do Feasibility Analyses
Write Assessment Report
Implement the Plan
Measure Progress
I
j Maintain Pollution Prevention Program [
Review existing information re-
sources
Developing a Pollution Prevention Program
19
-------
Data sources for facility
information include:
Regulatory Information:
Waste shipment manifests
Emission inventories
Biennial hazardous waste reports
Waste, wastewater, and air emis-
sions analyses, including intermedi-
ate streams
Environmental audit reports
• Permits and/or permit applications
Form R for SARA Title III Section
313
Process Information:
Process flow diagrams
• Design and actual material and heat
balances for:
— production processes
— pollution control processes
Operating manuals and process
descriptions
Equipment lists
Equipment specifications and data
sheets
Piping and instrument diagrams
Plot and elevation plans
Equipment layouts and logistics
Raw Material/Production Information:
Product composition and batch sheets
Material application diagrams
Material safety data sheets
• Product and raw material inventory re-
cords
Operator data logs
Operating procedures
• Production schedules
Accounting Information:
Waste handling, treatment, and disposal
costs
Water and sewer costs, including sur-
charges
Costs for nonhazardous waste disposal,
such as
trash and scrap metal
Product, energy, and raw material costs
Operating and maintenance costs
Department cost accounting reports
Other Information:
Environmental policy statements
Standard procedures
Organization charts
Box 8
Visit Sites
In order to utilize resources of time, staff, and money wisely,
the task force will need to prioritize the processes, operations, and
wastes that will be addressed during the subsequent detailed assess-
ment phase. During that phase, they will target the most important
waste problems, moving on to lower-priority problems as resources
permit. The pre-assessment site visits will provide the information
needed to accomplish this prioritization and to designate the
detailed assessment teams, who will be selected for their expertise
in particular areas.
Site visits make it possible to:
prioritize areas
select detailed assessment
teams
20
Chapter 2
-------
Typical considerations for prioritizing waste streams for further study include:
compliance with current and anticipated regulations
costs of waste management (pollution control, 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 pollution prevention
• 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
• minimizing waste water discharges
• reducing energy use
Box 9
Establish Priorities
Assigning priorities (Box 9) to processes, operations, and
materials will focus the remainder of the pollution prevention plan
development effort. The priorities set in this stage will guide the
selection of areas for the detailed assessments. Areas may also be
targeted based on the volume of waste produced or the cost of
waste disposal. Regulatory concerns such as the RCRA land
disposal restrictions or SARA Title 313 chemicals may also guide
prioritization. The Option Rating Weighted Sum Method, which is
illustrated in Appendix E, can be used during the pre-assessment
phase as well as during detailed assessment.
PREPARE THE PROGRAM PLAN
With the information collected during the pre-assessment, the
Task Force can develop a detailed program plan. This plan will
address the extent to which external organizations will be involved,
define pollution prevention program objectives, identify potential
obstacles and solutions, and define the data collection and analysis
procedures that will be used. A summary of the points that should
be addressed in a program plan appears in Box 10.
Contacting External Groups
At this point, the Task Force should consider soliciting input
from outside the company. Including the surrounding community
in the pollution prevention planning process can create a new
The priorities established at this
point will guide subsequent effort.
Establish the Pollution Prevention
Program
i
progfam
I
_ _ _J Q0 ptalimlrtary Assessment 1
1
Write Progrim Plan
• Consider External Groups
* Define Objectives
• Identify Potential Obstacles
• Dsvelop Schedule
,
Do Dattllad As
i Define Pollution Prevention Options [
Do Fusibility Analyse* I
I Write AiMtsment Report
1
Implement the Plan
>
Measure Progress
| Maintain Pollution Proven lion Program!
Developing a Pollution Prevention Program
-------
forum for communication. Valuable technical information car. also
be exchanged with some organizations.
The formal written pollution prevention plan will include the following elements:
Corporate policy statement of support for pollution prevention
• Description of your pollution prevention planning team(sj makeup, authority, and
responsibility
« Descnption of how ail of :he groups i production, laboratory-, maintenance.
shipping, marketing, engineering, and others) will work together to reduce waste
production and energy consumption
• Plan for publicizing and gaining company-wide support for ihe pollution preven-
tion program
Plan for communicating ihe successes and failures of pollution prevention
programs within your company
• Description of the processes that produce, use. or release hazardous or toxic ma-
terials, including clear definition of the amounts and types of substances, materi-
als, and products under consideration
List of treatment disposal, and recycling facilities and transporters currently used
• Preliminary review of the cost of pollution control and waste disposal
Description of current and past pollution prevention activities at your facility
• Evaluation of the effectiveness of past and ongoing pollution prevention activities
* Criteria for prioritizing candidate facilities, processes, and streams for pollution
prevention projects.
Box 10
Legislative and executive officials can provide iheir perspec-
tives on environmental protection issues and information on their
planning processes. In return, they can gain information that will
help them make decisions on future public issues related to the
environment.
Community involvement is a good way 10 build credibility
and focus pollution prevention efforts on the discharge paths that
most concern your neighbors. However, it may be wise to wait
until Ihe program is established before seeking to involve the
community. Having a few pollution prevention projects underway
will demonstrate your good faith. Positive community involve-
ment can be encouraged through holding open meetings, granting
interviews to the media, advertising, direct-mail surveys and
opinion polls.
Other businesses can be a source of information on technical
issues and suppliers, either because they are in the same geograph-
ical area or because they have similar technical areas of interest.
Local business groups are a good way of locating resources in the
immediate area, while trade and professional associations can
provide contacts in other parts of the country- or :he world. Of
course, the companies with the most similar interests may be
and community
mutual benefits
,ith government
leaders vie Ids
Gir,ir businesses wiil have useful
information.
Chapter 2
-------
competitors, but it should be possible to interact without risking
disclosure of business-sensitive information.
Define Objectives
During the preliminary assessment phase, the program team
will have identified opportunities for pollution prevention and will
have worked with the executive group to establish priorities.
These will be the starting point for defining short- and long-range
objectives.
Objectives are the specific tasks that will be necessary to
achieve goals. For example, in order to reach a goal of reducing
waste, the objectives might be defined as reducing solvent, paper,
and packaging wastes by specific amounts over a stated period of
time.
Objectives can be defined at the facility- or the department-
level, depending on the size and diversity of your company. A
small company could decide to develop a single set of objectives
to cover all of its operations. A larger company with many facili-
ties or products might develop an overall corporate plan describing
goals and objectives, supplemented by facility- or product-specific
goals. In any case, the management at each location must under-
stand and support its objectives if the pollution prevention program
is to be successful.
Objectives should be stated in quantitative terms and should
have target dates. These two attributes make objectives effective
tools for directing effort and measuring progress.
Identify Potential Obstacles
As the pollution prevention program team begins to develop
and implement a pollution prevention program, they are likely to
encounter a number of factors that will complicate the process.
These need to be recognized, and the means for overcoming them
need to be defined. Apparent obstacles will be less likely to
impede the process if everyone understands that there is a mecha-
nism for addressing them in a later stage.
The mix of factors and the relative degree of difficulty each
presents will vary from company to company. Those that are
likely to be encountered by most businesses are discussed below.
They fall into four broad categories: economic, technical, regula-
tory, and institutional.
Economic Obstacles. The task force should recognize that some
complex economic factors may need to be addressed later. Broad-
ly defining procedures now for dealing with them will help prevent
economic concerns from stilling the creative process of defining
options.
Cost-benefit analysis procedures should be defined. Many
proposed pollution prevention options will have start-up costs. For
example, additional or replacement equipment may need to be
Clorox's environmental execu-
tives... want to integrate goals
already established by plants into
corporate-wide objectives that can
be quantified and measured to
assess progress.
— From an interview with
Michael Riley, Director of
Environmental Marketing at
Clorox. Environmental Busi-
ness Journal, December, 1991.
Anticipate obstacles and plan to
overcome them.
Potential economic obstacles
include relatively complex cost
analysis requirements and the
need for capital improvements
funding.
Developing a Pollution Prevention Program
23
-------
purchased, staff training may be required, or alternative raw mate-
rials may cost more. Some of these additional costs can be justi-
fied readily because they clearly will be cost-effective and will
Slave short pay-back times. However, many will not be so clear-
cut and will need more sophisticated analysis. Chapter 6 describes
the "Total Cost Assessment" (TCA) approach as it applies to
pollution prevention projects and discusses why it may be neces-
sary to look at longer payback times for pollution prevention
projects.
Limited financial resources for capital improvements may
also be a problem, even for options that will ultimately be profit-
able. The team should investigate the availability of and condi-
tions for funding assistance or low-interest loans from state or local
agencies. Appendix D provides information on whom to contact.
Technical Obstacles. Information will be needed on alternative
procedures that should be considered, how to integrate them in the
production process, and what side effects are possible.
Information resources could be a problem. As a small or
medium-sized business, you may not have ready access to a central
source of information on pollution prevention techniques. There
are several ways to deal with this problem. Contact appropriate
agencies listed in Appendix D for assistance. Encourage employ-
ees to watch for information in the technical journals and news-
letters they read and to pass it on to the task force. Those who
belong to professional societies may get ideas from other members.
Metropolitan or university library reference departments can
provide assistance in locating sources of published information as
well as names of people who might be able to provide information
in specific areas. If the scope of the technical problem and re-
sources permits, it may be appropriate to retain a consultant.
Limited flexibility in the manufacturing process may pose
another technical barrier. A proposed pollution prevention option
may involve modifying die work flow or the product or installing
new equipment; implementation could require a production shut-
down, with loss of production time. You might be concerned that
the new operation will not work as expected or might create a
bottleneck that slows production. In addition, the production
facility might not have space for pollution prevention equipment.
These technical barriers can be overcome by having design and
production personnel take part in the planning process and by
using tested technology or setting up pilot operations.
Product quality or customer acceptance concerns might
cause resistance to change. For example, in some printing and
publishing operations it is possible to minimize waste by substi-
tuting a water-based ink for a solvent-based ink. But for some
products, quality suffers when water-based ink is used. You
should plan to avoid potential product quality degradation by
verifying customer needs, testing the new process or product, and
increasing quality control during manufacture.
Possible technical obstacles:
* availability of information
• disruption of production
* product quality changes
Chapter 2
-------
There are a number of sources of technical assistance:
« Trade associations generally provide assistance and information about
environmental regulations and various available techniques for complying
with these regulations. Their information is especially valuable because it is
tailored to the specific industry.
• Published literature can be a valuable resource. Articles in technical
magazines, trade journals, government reports, and research briefs describe
pollution prevention technologies and applications.
• Federal, state, and local environmental agencies are expanding their pollution
prevention technical assistance programs. These programs make available
information on industry-specific pollution prevention techniques. (See Appendix
D for addresses and phone numbers of such resources.)
• Equipment vendors and sales literature are helpful in identifying and analyzing
potential equipment-oriented options.
* Consultants — Consultants with experience in pollution prevention in the specific
industry can usually be located.
* Other Companies.
Bo% 11
Regulatory Obstacles. Regulations may be a barrier to some
pollution prevention options. For example, changing to another
feed material may require changing the existing permits. In
addition, it may be necessary to learn what regulations might apply
to proposed alternative input materials.
Working with the appropriate regulatory bodies early in the
planning process will help overcome this barrier. The U.S. EPA
and the state environmental agencies have developed a number of
documents to facilitate pollution prevention efforts by industry;
some are listed in Appendix G. Points of contact at the appro-
priate agencies will be helpful; many are listed in Appendix D.
Your local health department and city and county waste dis-
posal and treatment offices can also provide assistance. Industry
task forces and consultants might also be contacted,
Institutional Obstacles. As with any other new program, general
resistance to change and friction among elements within the orga-
nization may arise. These can result from many factors, such as
lack of awareness of corporate goals and objectives, individual or
organizational resistance to change, lack of commitment, poor
internal communication, requirements of existing labor contracts,
or an inflexible organizational structure.
Analyze these barriers from different perspectives in order to
understand the concerns. Management is concerned with produc-
tion costs, efficiency, productivity, return on investment, and
present and future liability. Workers are concerned about job
security, pay, and workplace health and safety. The extent to
Working with regulatory bodies
will help resolve questions as to
requirements that pertain to pro-
posed changes.
Resistance to change and friction
among organizational elements
can he reduced by effective com-
munication.
Developing a Pollution Prevention Program
25
-------
which these issues are addressed in the pollution prevention pro-
gram will affect the success of the program.
Institutional barriers can be overcome with education and
outreach programs. As was pointed out earlier, it is vital to gain
the support of staff at all levels very early in the pollution preven-
tion effort.
Develop Schedule
The final aspect of planning your pollution prevention program
is to list the milestones within each of the stages from detailed
assessment through implementation and assign realistic target
dates. The execution of these stages (described in Chapter 3)
should follow this schedule closely. Significant deviations may
cause the program to falter because certain steps are not com-
pleted. Adherence to the schedule will also help control the
startup or implementation costs of the program.
26 Chapter 2
-------
CHAPTER 3
DEVELOPING AND IMPLEMENTING
POLLUTION PREVENTION PROJECTS
This chapter outlines how to execute the pollution prevention
program plan that resulted from the activities outlined in Chapter
2. The figure to the right illustrates the steps that will be dis-
cussed in this chapter and places them in the context of the overall
effort.
As with the other stages, the degree of formality should be
tailored to the size of the company and the diversity of its product
lines. Thus, a small company may need to do only one detailed
assessment and prepare one implementation plan, while a larger,
more diverse company might require several in order to address all
production processes. If multiple plans are developed, it will be
necessary to examine how they fit together, resolving any conflicts
and prioritizing them to fit available resources.
DETAILED ASSESSMENT PHASE
As part of your program design, you probably did a prelimi-
nary assessment of your facility to identify areas of opportunity for
pollution prevention. Now, detailed assessments will focus on
specific areas targeted by the preliminary assessment.
Assessment teams will be assigned to each operational area of
the facility to gather data for later analysis. As was the case
during the preliminary assessment, they will use existing written
materials and site evaluations. However, they will delve much
more deeply into each production process, interviewing workers
and compiling necessary data that may not have been collected
before.
During this process, the team may identify some options that
can be implemented quickly and with little cost or risk. It is
likely, however, that many options will be more complex and will
require in-depth analysis later.
Designate the Detailed Assessment Team(s)
The detailed assessment phase should be started by a member
of the pollution prevention task force, which was identified during
program design. Unless your company is small enough that the
task force and the detailed assessment team are the same, you will
need to name additional staff to comprise one or more detailed
assessment teams. The focus of each assessment team will be
relatively specific. It is likely that three to six people will prove to
Establish the Pollution Prevention
Program
1.— —•———» —
Organize Program
• — —4 Do Preliminary Assessment
Write Program Plan
Do Detailed Assessment
Name Assessment Tearn(s)
Review Oala and Srts(s)
Organize and Document information
Defins Pollution Prevention Options
* Propose Options
• Screen Options
Do Feasibility Analyses
« Technical
* Environmental
* EcOfEOFTtfC
Wrile Assessment Report
Implement Ihe Plan
• Select Projects
• Obtain FurxJifig
• Iristsril
Measure Progress
Maintain Pollution Prevention Program]
27
-------
be a workable number for an assessment team. Specialists can be Areas of expertise to consider for
consulted as needed. Ideally, one member of the task force will be detailed assessment teams:
included on each team; this will facilitate communication. The * Management
additional team members should be people with direct responsibili- * Engineering
ty for and knowledge of the waste streams and/or areas of the " &uallty contr°<
facility under consideration. A multidisciplinary team is likely to ' Produclion and maintenance
, .c. i • t_- • i- j * Accounting ana purchasing
be more successful in achieving a comprehensive assessment and .
providing the best input possible to the data analysis and option g ^eailh at ^ afetv
definition stages. To the extent practical, you should consider . Research and aeveiopment
engineers, supervisors, and production workers as well as finance
and accounting, purchasing, and administrative staff when selecting
the team members.
Aside from field of expertise, consider a candidate's ability to
work on a team, apparent interest in and commitment to the
program, and capacity for looking at situations from new perspec-
tives and for thinking creatively.
Examples of Detailed Assessment Teams:
Metal finishing department in a large defense contractor:
— Metal finishing department manager
— Process engineer responsible for metal finishing processes
* Facilities engineer responsible for metal finishing department
— Wastewater treatment department supervisor
— Staff environmental engineer
Small pesticide formula tor:
* Production supervisor
— Environmental engineer
— Maintenance engineer
Cyanide plating operation:
* Environmental engineer
— Electroplating facility engineering supervisor
— Plant chemist
Large offset printing facility:
Internal assessment team
* Environmental engineer
— Film processing supervisor
— Pressroom supervisor
Outside assessment team (possible alternative team)
* Engineer from within establishment
— Environmental scientist
— Printing industry technical consultant
* = Recommended team leader
Box 12
28 Chapter 3
-------
The box on the preceding page (Box 12) gives examples of
assessment teams that might be designated for facilities of various
sizes and in different industries. Note that for each team, the team
leader is someone who has day-to-day operations responsibility and
experience.
Review Data and Sites
Numerous data sources probably exist for a given site. Many Site reviews supplement and ex-
of these may have been identified during the preliminary assess- plain existing data.
ment. The detailed assessment team for that site will search for
additional sources of data that will be useful in studying the
targeted processes, operations, or waste streams.
However, most of their effort will be directed toward perform-
ing a thorough site review and interviewing workers. This will
help them understand the data already collected and identify factors
that are not well documented and for which data will need to be
collected. Site review guidelines are outlined in Box 13.
Site reviews should be well planned.
Prepare an agenda in advance that covers all points that still require clarifica-
tion. Provide staff contacts in the area being assessed with the agenda several
days before the inspection.
Schedule the inspection to coincide with the particular operation that is of
interest (e.g., makeup chemical addition, bath sampling, bath dumping, startup,
shutdown, etc.).
Monitor the operation at different times during all shifts, and if needed, during
all three shifts, especially when waste generation is highly dependent on human
involvement (e.g., in painting or parts cleaning operations).
Interview the operators, shift supervisors, and work leaders in the assessed area.
Discuss the waste generation aspects of the operation. Note their familiarity with
the impacts their operation may have on other operations.
Photograph or videotape the area of interest, if warranted. Pictures are valuable
in the absence of plant layout drawings. Many details can be captured in pictures
that otherwise could be forgotten or inaccurately recalled at a later date.
Observe the "housekeeping" aspects of the operation. Check for signs of spills
or leaks. Visit the maintenance shop and ask about problems in keeping the
equipment leak-free. Assess the overall cleanliness of the site. Pay attention to
odors and fumes.
Assess the organizational structure and level of coordination of environmental
activities between various departments.
• Assess administrative controls, such as cost accounting procedures, material
purchasing procedures, and waste collection procedures.
Box 13
Developing and Implementing Pollution Prevention Projects 29
-------
question and of how it fits into the overall facility operation. This
perspective is a prerequisite for thorough assessment of options in
later phases of the pollution prevention plan development cycle. If
consultants are on the assessment team, the site review enables
them to become familiar enough with the facility to utilize their
expertise effectively.
The site review should not be performed perfunctorily, even
though the assessment team members who are employed at the
facility will all be familiar to some extent with the work-site being
reviewed. Those who are not involved in the day-to-day operation
in that area will see factors that otherwise would be overlooked.
Furthermore, personnel assigned to that specific site will often see
it in a new light when performing a pollution prevention assess-
ment. Some of the information that can be gathered through site
reviews is summarized in Box 14.
Typical questions to ask during site reviews include:
What is the composition of the waste streams and emissions generated in the
company? What is their quantity?
From which production processes or treatments do these waste streams and
emissions originate?
Which waste materials and emissions fall under environmental regulations?
What raw materials and input materials in the company or production
process generate these waste streams and emissions?
How much of a specific raw or input material is found in each waste
stream?
What quantity of materials are lost in the form of volatile emissions?
How efficient is the production process and the various steps of that pro-
cess?
Are any unnecessary waste materials or emissions produced by mixing
materials — which could otherwise be reused with other waste materials?
Which good housekeeping practices are already in force in the company to
limit the generation of waste materials?
What process controls are already in use to improve process efficiency?
Box 14
Site visits should be well-planned to ensure that maximum Good planning is essential for
benefit is obtained without excessive expenditures of time. While efficient site reviews.
multiple visits to check or supplement data will usually be re-
quired, good planning can minimize such repetitions. Several
-------
it is worthwhile to predetermine the boundaries and bases for
calculating the energy and material balances that will be worked
out during that stage. Doing a preliminary balance during the data
collection phase can help identify data gaps and determine sam-
pling requirements. The worksheets in Appendix A can be used
for data collection, or you may decide to customize them or create
entirely new ones to conform to the nature of the specific site.
Appendices B and C may be helpful in developing new work-
sheets. Photographs are an excellent means of capturing exten-
sive detail quickly and accurately.
Prepare an agenda and make sure that all team members and
supervisors at the site receive it in advance.
Schedule site visits by contacting the staff in the area to be
visited. Ask when they will be performing the operations you are
particularly interested in assessing.
Observe operations as they are actually performed by differ-
ent shifts and under various circumstances. Process units may be
operated differently from the methods described in their operating
manuals, or the equipment may have been modified without being
so documented in the flow diagrams or equipment lists.
Interview workers and supervisors to determine how aware
they are of what wastes are generated by their operation. They
may have suggestions on reducing these wastes.
Follow the process from beginning to end, from the point
where input materials enter the work-site to the point where prod-
ucts and wastes exit. This will help identify all suspected sources
of waste. Waste sources to inspect include the production process;
piping; maintenance operations; storage areas for raw materials,
finished product, and work-in-process. Examine housekeeping
practices and the waste treatment area, as well.
Make follow-up visits as missing or unclear data are identi-
fied during the analysis stage.
Organize and Document Process Information
Analyzing process information involves preparing material and
energy balances as a means of analyzing pollution sources and
opportunities for eliminating them. Such a balance is an organized
system of accounting for the flow, generation, consumption, and
accumulation of mass and energy in a process. In its simplest
form, a material balance is drawn up according to the mass conser-
vation principle:
Mass in = Mass out - Generation
+ Consumption + Accumulation
If no chemical or nuclear reactions occur and the process progress-
es in a steady state, the material balance for any specific com-
pound or constitutent is as follows:
Mass out = Mass in
Look at procedures as they are
performed in the production envi-
ronment.
Identify waste sources.
A material and energy balance for
a given substance will reveal
quantities lost to emission or to
accumulation in equipment.
Developing and Implementing Pollution Prevention Projects
31
-------
Data collection and review take many forms.
The first step in preparing a balance is to draw a process
diagram, which is a visual means of organizing the data on the
energy and material flows and on the composition of the streams
entering and leaving the system. Such a diagram shows the system
boundaries, all streams entering and leaving the process, and points
at which wastes are generated. An example of a flow diagram
appears as Figure 4.
A process diagram organizes data
graphically.
32
Chapter 3
-------
Air Emission
Catalyst
Heat Out
Product
Waste
Catalyst
*• By-Product
Waste
-------
A material balance should be calculated for each component
entering and leaving the process. When chemical reactions take
place in a system, there is an advantage to performing the material
balance on the elements involved.
The limitations of material and energy balances should be
understood. They are useful for organizing and extending pollu-
tion prevention data and should be used whenever possible. How-
ever, the user should recognize that most balance diagrams will be
incomplete, approximate, or both.
Most processes have numerous process streams, many of
which affect various environmental media.
The exact composition of many streams is unknown and
cannot be easily analyzed.
Phase changes occur within the process, requiring multi-
media analysis and correlation.
• Plant operations or product mix change frequently, so the
material and energy flows cannot be accurately character-
ized by a single balance diagram.
Many sites lack sufficient historical data to characterize
all streams.
These are examples of the complexities that will recur in analyzing
real world processes.
Despite the limitations, material balances are essential to
organize data, identify gaps, and permit estimation of missing
information. They can help calculate concentrations of waste
constituents where quantitative composition data are limited. They
are particularly useful if there are points in the production process
where it is difficult or uneconomical to collect or analyze samples.
Data collection problems, such as an inaccurate reading or an
unmeasured release, can be revealed when "mass in" fails to equal
"mass out." Such an imbalance can also indicate that fugitive
emissions are occurring. For example, solvent evaporation from a
parts cleaning tank can be estimated as the difference between
solvent put into the tank and solvent removed by disposal, recy-
cling, or d ragout.
DEFINE POLLUTION PREVENTION OPTIONS
Once the sources and nature of wastes generated have been
described, the assessment team enters the creative phase. In a two-
step procedure, they will propose and then screen pollution preven-
tion options. Their objective is to generate a comprehensive set of
options, ranked as to priority, that merit detailed feasibility assess-
ment.
Propose Options
As with other planning efforts, the best results will be
achieved in an environment that encourages creativity and inde-
pendent thinking by each assessment team member. Brainstorming
Each component should have a
material balance calculated.
Material and energy balances
have some limitations.
Imbalances indicate that the data
are inaccurate and should be
reviewed or that fugitive emissions
of waste are occurring.
EsUbllfth lh« Pollution Prevention
Program
i
Qrganii* Progr»m
, —J Do Preliminary Asa***miMil I
I Writ* Program Plan 1
T .
» Do Detailed Ai«e««rnent
Define Pollution Prevention Option*
• Propose Opttoni
* Screen Options
I Da Feasibility Analyse* I
Write
nt Report I
I Implement the Plan I
Measure Progreea
I Maintain Pollution Prevention Pro
grant]
34
Chapter 3
-------
sessions are useful for encouraging creative thought because they
provide a nonjudgmental, synergistic atmosphere in which ideas
can be shared. Then, these ideas can be developed by means of
group decision-making techniques.
This approach will enable the assessment team to identify
options that the individual members might not have come up with
on their own. Worksheet 7 in Appendix A is a suggested format
for describing each option as it is proposed.
Structuring option definition sessions according to the U.S.
EPA hierarchy (Chapter 1, Figure 1) will encourage the team to
look first at true source reduction options, such as improved
operating procedures and changes in technology, materials, and
products. Then, options that involve reuse, or closed-loop recy-
cling, would be examined. Finally, the team would consider off-
line and off-site recycling and alternative treatment and disposal
methods.
Screen Options
Many proposed options may result from the previous step.
Since detailed technical, economic, and environmental feasibility
analysis can be costly, the proposed options should be screened by
the assessment team. Some options will be found to have no cost
or risk attached; these can be implemented immediately. Others
will be found to have marginal value or to be impractical; these
will be dropped from further consideration. The remaining options
will generally be found to require feasibility assessment.
This screening does not require detailed and costly study.
Screening procedures can range from an informal review with a
decision made by either the program manager or a vote of the
team members, to the use of quantitative decision-making tools.
Box 15 on the next page shows questions to be considered in
option screening.
The informal review is a procedure by which, the assessment
team selects the optioas that appear best after discussing and
examining each option. As is the case when the team is proposing
options, their approach to screening should employ group decision-
making techniques whenever possible.
In more complicated situations, the team may need to use the
weighted sum method (see Appendix E) or another, similar
technique designed for use in complex decision-making situations.
DO FEASIBILITY ANALYSES
The final product of the option definition phase is a prioritized
list of pollution prevention options. These options now should be
examined to determine which are technically, environmentally, and
economically feasible and to prioritize them for implementation.
Encourage creativity in option
definition sessions.
Categorize proposed options as:
* no risk or cost: implement
immediately
« marginal value or impractical:
drop
• complex: perform feasibility
analysis
Establish lh« Pollution Prevention
Program
I
I Organize Program I
• — —* Do Preliminary AssessmentI
I WrlH Program Plan
Do Detailed Assessment
I D*fln* Pollution Prevention Options 1
Do Feasibility Analyse*
• Technical
* Environmental
- Economic
Write A
ssesamenl Report I
Implement the Plan I
Measure Progress
[Maintain Pollution Prevention Program
Developing and Implementing Pollution Prevention Projects
35
-------
Option screening should consider these questions:
• Which options will best achieve the goal of waste reduction?
What are the main benefits to be gained by implementing this option (e.g.,
financial, compliance, liability, workplace safety, etc.)?
• Does the necessary technology exist to develop the option?
• How much does it cost? Does it appear to be cost-effective, meriting in-depth
economic feasibility assessment?
« Can the option be implemented within a reasonable amount of time without dis-
rupting production?
• Does the option have a good "track record"? If not, is there convincing evidence
that the option will work as required?
What other areas will be affected?
Box 15
Depending on the resources currently available, it may be neces-
sary to postpone feasibility assessments for some options. Howev-
er, all options should be evaluated eventually.
Technical Evaluation
The assessment team will perform a technical evaluation to
determine whether a proposed pollution prevention option is likely
to work in a specific application. Technical evaluation for a given
option may be relatively quick or it may require extensive investi-
gation. The list in Box 16 suggests some criteria that could be
used in a technical evaluation. Some of these are more detailed
versions of questions asked during the option screening phase.
All groups in the facility that will be affected directly if the
option is adopted should contribute to the technical evaluation.
This might include people from production, maintenance, QC/QA,
and purchasing. In some cases, customers may need to be con-
sulted and their requirements verified. Prior consultation and
review with these groups will ensure the viability and acceptance
of an option. If the option calls for a change in production meth-
ods or input materials, carefully assess the likely effects on the
quality of the final product. If after the technical evaluation the
option appears impractical or can be expected to lower product
quality, drop it.
For options that do not involve a significant capital expendi-
ture, the team can use a "fast-track" approach. For example,
procedural or housekeeping changes can often be implemented
quickly, after the appropriate review, approvals, and training have
been accomplished. Material substitutions also can be accom-
plished relatively quickly if there are no major production rate,
product quality, or equipment changes involved.
Technical evaluations require the
expertise of a variety of people.
Some options can be implemented
right away.
36
Chapter 3
-------
Typical technical evaluation criteria:
Will it reduce waste?
• Is the system safe for our workers?
• Will our product quality be improved or maintained?
• Do we have space available in our facility?
* Are the new equipment, materials, or procedures compatible with our production
operating procedures, work flow, and production rates?
Will we need to hire additional labor to implement the option?
Will we need to train or hire personnel with special expertise to operate or main-
tain the new system?
Do we have the utilities needed to run the equipment? Or, must they be installed
at increased capital cost?
How long will production be stopped during system installation?
• Will the vendor provide acceptable service?
• Will the system create other environmental problems?
Box 16
Equipment-related options or process changes are more expen-
sive and may affect production rate or product quality. Therefore,
such options require more study. The assessment team will want
to determine whether the option will perform in the field under
conditions similar to the planned application. In some cases, they
can arrange, through equipment vendors and industry contacts,
visits to existing installations. Experienced operators' comments
are especially important and should be compared with vendors'
claims. A bench-scale or pilot-scale demonstration may be needed.
It may also be possible to obtain scale-up data using a rental test
unit for bench-scale or pilot-scale experiments. Some vendors will
install equipment on a trial basis, with acceptance and payment
after a prescribed time, if the user is satisfied.
Environmental Evaluation
In this step, the pollution prevention assessment team will
weigh the advantages and disadvantages of each option with regard
to the environment. Often the environmental advantage is obvious
— the toxicity of a waste stream wiE be reduced without generating
a new waste stream. Most housekeeping and direct efficiency
improvements have this advantage. With such options, the envi-
ronmental situation in the company improves without new environ-
mental problems arising.
Unfortunately, the environmental evaluation is not always so
clearcut Some options require a thorough environmental evalua-
tion, especially if they involve product or process changes or the
substitution of raw materials.
Options that can affect production
or quality need careful study.
Environmental considerations:
* effect on number and toxicity
of waste streams
• risk of transfer to other media
* environmental impact of alter-
nate input materials
* energy consumption
Developing and Implementing Pollution Prevention Projects
37
-------
The technical feasibility evaluation is done to determine
if a pollution prevention option will work.
For example, the engine rebuilding industry is dropping
solvent and alkaline cleaners to remove grease and dirt from
engines prior to disassembly. Instead, they are using high-temper-
ature baking followed by shot blasting. This shift eliminates waste
cleaner but presents a risk of atmospheric release because small
quantities of components from the grease can vaporize.
To make a sound evaluation, the team should gather informa-
tion on the environmental aspects of the relevant product, raw
material or constituent part of the process. This information would
consider the environmental effects not only of the production phase
and product life cycle but also of extracting and transporting the
alternative raw materials and of treating any unavoidable waste.
Energy consumption should also be considered. To make a
sound choice, the evaluation should consider the entire life cycle of
Consider energy requirements.
38
Chapter 3
-------
both the product and the production process. Energy conservation
is discussed in Chapter 8.
Economic Evaluation
Estimating the costs and benefits of some proposed pollution
prevention projects is straightforward, while others prove to be
complex. Despite the ease with which the cost calculations may
be done for some options, it is advisable to document all that are
adopted and to estimate the economic effects of each. This will
help ensure that these real accomplishments of your pollution
prevention program will not be overlooked when you measure the
program's progress, as discussed in Chapter 4.
Document cost calculations so that
the full benefit of the pollution
prevention program can be quanti-
fied.
The economic feasibility needs to be
checked and rechecked.
If a project has no significant capital costs, the decision is
relatively simple. Its profitability can be judged by whether or not
it reduces operating costs and/or prevents pollution. If it does, it
can be implemented quickly. Installation of flow controls and
improvement of operating practices, for example, probably will not
require extensive analysis before they are adopted. Worksheet 9
(in Appendix A) can be used to document analysis of this type.
Operational changes usually can
be installed quickly.
Developing and Implementing Pollution Prevention Projects
39
-------
Projects with significant capital costs attached will require
more detailed analysis. Worksheet 9 may be a good starting point,
but an in-depth evaluation like the example that appears as Appen-
dix F will be required.
There are a number of factors that make pollution prevention
costs and benefits difficult to calculate for many proposed projects.
The total costs of continuing to pollute are not discernible in most
corporate accounting systems. Furthermore, many of these costs
are probabilistic — although the risks are real, it is difficult to
predict the cost and even the occurrence date from past experience.
The long-term need to avoid the spiraling costs of waste treatment,
storage, and disposal as well as future regulatory and liability
entanglements are likely to be major elements of your pollution
prevention project economic evaluation
Chapter 6 describes the Total Cost Analysis approach and
gives an overview of the types of cost and benefit factors that
should be examined when studying proposed pollution prevention
projects. It suggests some approaches to calculating indirect and
probabilistic costs so that their full impact can be included in
economic feasibility assessments. It also discusses ways to track
the economic effects of pollution prevention projects after they are
implemented.
Most accounting systems do not
reveal the total costs of continuing
to pollute.
Total Cost Analysis is a useful
mechanism for understanding the
financial impact of pollution
prevention projects.
WRITE THE ASSESSMENT REPORT
The task force should write a report that summarizes the
results of the pollution prevention assessment at the company level.
Box 17 shows the report contents. The report will provide a
schedule for implementing prevention projects and will be the
basis for evaluating and maintaining the pollution prevention
program. It may also be needed to secure internal funding for
projects that require capital investment, if the members of the
pollution prevention assessment task force do not have the authori-
ty to commit funds.
You may be tempted to omit this step if your company has an
owner-manager and only a few employees. A summary assess-
ment report may not be needed to resolve pollution prevention
project conflicts among different areas, and your funding approvals
probably are not a formal procedure requiring cost justifications.
However, an assessment report will help you focus subsequent pol-
lution prevention efforts and will be useful as a record of what
aspects of your business you examined for pollution prevention
opportunities.
Input of the Assessment Teams
In a company that has several assessment teams, the task force
will need to evaluate the results and resolve any conflicts that
might exist among the teams as to approach and resources required
for the projects they propose.
Establish the Pollution Prevention
Program
'
Organize Program
,
[ Do Preliminary Aaaeeament
•
Write Program Plan
•
[ Do Detailed Assessment
I
Define Pollution Prevention Options
,
Do Feasibility Analyses
-
| Write Assessment Report |
,
•
Implement the Plan
1 Measure Progress
i
Maintain Pollution Prevention Program |
40
Chapter 3
-------
The report on each proposed project should discuss:
Its pollution prevention potential
The maturity of the technology and a discussion of successful applications
The overall project economics
The required resources and how they will be obtained
The estimated time for installation and startup
Possible performance measures to allow the project to be evaluated after it is
implemented
Box 17
As input to this integration effort, each assessment team
should prepare a summary report, presenting the results of their
investigations and listing the options they screened. Each report
should describe in some detail the options that the team has deter-
mined are feasible and propose a schedule for implementing them.
The options recommended for immediate implementation should
then be described in detail as proposed projects.
These proposals should evaluate each project under different
scenarios. For example, the profitability of each could be esti-
mated under both optimistic and pessimistic assumptions. Where
appropriate, sensitivity analyses indicating the effect of key vari-
ables on profitability should be included. Each should outline a
plan for adjusting and fine-tuning the initial projects as knowledge
and experience increases. The proposals should include a schedule
for addressing those areas and waste streams with lower priorities
than the ones selected for the initial effort.
Preparing and Reviewing the Assessment Report
The task force will use the assessment teams' reports and
project proposals to prepare the summary assessment report and
implementation plan. The report should include a qualitative
evaluation of the indirect and intangible costs and benefits to your
company and employees of a pollution prevention plan. It will
provide the basis for obtaining funding of pollution prevention
projects. Pollution prevention projects should not be sold on their
technical merits alone; a clear description of both tangible and
intangible benefits can help a proposed project obtain funding.
Before the report is issued in final form, managers and other
experienced people in the production units that will be affected by
the proposed projects should be asked to review the report. Their
review will help to ensure that the projects proposed are well-
defined and feasible from their perspectives. While they probably
were involved in the site reviews and other early efforts of the task
force, they may spot inaccuracies or misunderstandings on the part
of the assessment teams that were not apparent before.
Each assessment learn summariz-
es:
• results of assessment effort
• options proposed
• results of option screening
• results of feasibility analysis
• project proposal for each
selected option
Evaluate the project under various
scenarios.
The summary assessment report is
used for:
• QA of implementation plan
• funding decisions
• building support for plan
Developing and Implementing Pollution Prevention Projects
41
-------
In addition to ensuring the quality of the assessment report and
implementation plan, this review will help ensure the support of
the people who will be responsible for the success of the project.
IMPLEMENT THE POLLUTION PREVENTION PLAN
Select Projects for Implementation
Final decisions on which projects will be implemented and
what the schedule will be are made at this point. If the task force
or company executives question aspects of some projects, the
assessment teams or pollution prevention program champions may
be asked to produce additional data. They should be flexible
enough to develop alternatives or modifications. They should also
be willing to do background and support work, and they should
anticipate potential problems in implementing the options. Above
all, they should keep in mind that an idea will not sell if the
marketers are not convinced.
Obtain Funding
The task force will seek to secure funding for those projects
that will require expenditures. There will probably be other
projects, such as expanding production capacity or moving into
new product lines, that will compete with the pollution prevention
program for funding. If the task force is part of the overall budget
decision-making procedure, it can make an informed decision that
a given pollution prevention project should be implemented right
away or that it can wait until the next capital budgeting period.
The task force will need to ensure that the project is reconsidered
at that time.
Some companies will have difficulty raising funds internally
for capital investment. If this applies to your company, look to
outside financing. Private sector financing includes bank loans and
other conventional sources of financing. Financial institutions are
becoming more cognizant of the sound business aspects of pollu-
tion prevention.
Government financing is available in some cases. It may be
worthwhile to contact your state's department of commerce or U.S.
Small Business Administration for information regarding loans for
pollution control. Some states can provide financial assistance.
Appendix D includes a list of states providing this assistance and
addresses where you can write for information.
Install the Selected Projects
Many pollution prevention projects will require changes in
operating procedures, purchasing methods, or materials inventory
control. Company policies and procedures documents and employ-
ee training will also be affected by the changes.
E»tabll*ri the Pollution Prevention
Program
Organ! z* Program
Do Preliminary Assessment I
[ Write Program Plan I
i
M Do Datalted Aeisaumant 1
1 .
Define Pollution Prevention Option* I
i .
[ Oc Feasibility Analyse* I
Writ* Assessment Report
Implement the Plan
• Select Projects
• Obtain Funding
• Install
I
Measure Progrwa I
(Maintain Pollution Prevention Program I
In 1989, the Bank of Boston
started a unit focused strictly on
environmental lending.
— Environmental Business
Journal, October, 1991.
42
Chapter 3
-------
For projects that involve equipment modification or new
equipment, the installation of a pollution prevention project is
essentially the same as any other capital improvement project. The
phases of the project include planning, design, procurement,
construction, and operator training. As with other equipment
acquisitions, it is important to get warranties from vendors prior to
installation of the equipment
Training and incentive programs may be needed to get em-
ployees used to the new pollution prevention procedures and
equipment.
Review and Adjust
The pollution prevention process does not end with implemen-
tation. After the pollution prevention plan is implemented, track
its effectiveness versus the claims made — technical, economic, etc.
Options that do not meet your original performance expectations
may require rework or modifications. Above all, reuse the knowl-
edge gained by continuing to evaluate and fine-tune pollution
prevention projects. Chapter 4 provides details on measuring prog-
ress after implementation and evaluating it against goals. Chapter
5 deals with ways to maintain and enhance a program after it is
implemented.
Installing a pollution prevention
project generally involves the
same considerations as for other
capital improvement projects.
Reiteration of the process will
yield maximum success.
Developing and Implementing Pollution Prevention Projects
43
-------
CHAPTER 4
MEASURING POLLUTION
PREVENTION PROGRESS
You will want to measure your progress against your goals.
By reviewing the program's successes and failures, managers at all
levels can assess the degree to which pollution prevention goals at
the facility and production unit levels are being met and what the
economic results have been. The comparison identifies pollution
prevention techniques that work well and those that do not. This
information will help guide future pollution prevention assessment
and implementation cycles.
Quantitative evaluation also enables you to compare your unit
with similar units in your company and with data from other
companies. You will need this knowledge to plan enhancements
of your current pollution prevention program, to select technologies
for transfer from other operations, and to help identify new pollu-
tion prevention options.
ACQUIRING DATA
You will need to select a quantity (e.g., waste volume or
toxicity), measure that quantity, and normalize the data as neces-
sary to correct for factors not related to the pollution prevention
method being reviewed. Although the process is simple in theory,
complexities arise in practice. There are a number of factors to
consider when defining what data you will track.
First, the quantity selected to track performance must accurate-
ly reflect the waste(s) of interest. Second, the quantity must be
measurable with the resources available to you. As in the Detailed
Assessment Phase, material and energy balances will be helpful in
organizing data and can help fill in some gaps in data.
After deciding what data should be tracked, you will need to
determine how to collect it and what normalization may be re-
quired for each category of data.
Regulatory Reporting Data
Depending on the type of business your company engages in,
you may have a considerable volume of data already collected for
regulated waste streams. However, there can be gaps and discrep-
ancies in this data. For example, RCRA wastes are characterized
by waste type and total amount, but not by individual components.
Therefore, this data may not be specific enough for your evalua-
tion. In addition, accurate measuring devices may not be available
for all waste streams (e.g., vaporous or fugitive emissions). In
E*ubll*n the Pollution Pr»Ą*nlion
Program
t
Organize Program
«-« —| Do Preliminary ABte
I Writ* Program Plan I
Do Detailed Atisxmmt
I Define Pollution Prevention Options I
I Do Feasibility Analyaea |
I Writ* Atttiimani Report
I Implement the Plan
Measure Pragma*
• Acquire Data
• Analyze Results
I Maintain Pollution Prevention Program)
Useful normalization factors
include:
units produced
• hours of labor
• hours of production
It may be necessary to supplement
regulatory data.
44
Chapter 4
-------
such cases, your regulatory compliance reports would have been
based on estimates; comparing estimates from one period to anoth-
er will not yield very reliable percent-of-change figures. Finally,
year-to-year comparisons may not be meaningful if the reporting
requirements changed sufficiently to cause differences in how
waste quantities were measured.
Wastes Shifted to Other Media
The pollution prevention option may eliminate part of the
target material but shift some of it to another plant stream, to
another environmental medium, or into the product.
It can be difficult to track the shift of a pollutant from one
medium to another or to determine what new pollutants may be
created by the new procedure. Transferring a given pollutant to
another medium or replacing it with a different pollutant is, in
principle, to be avoided. If you were to find that transfer was
occurring, you would need to evaluate very carefully the relative
impact on the environment.
Measuring Toxicity
The toxicity of the waste should be looked at, not just the
quantity produced. Reducing the sheer volume of a given waste
product while increasing its per-unit toxicity is a treatment option,
but it is not pollution prevention. For example, adding lime to a
waste stream to precipitate metals reduces the volume of waste but
does not prevent pollution since the total quantity of metal is not
changed. Since toxicity frequently is not measured as part of
production reporting, you may have to establish procedures for
doing so.
Normalizing for External Factors
Changes in quantity are straightforward, easily understood, and
relatively easy to calculate if data are available. Quantity compari-
sons from one period to the next can be useful input to a pollution
prevention program review. However, the data will have to be
normalized if there were major factors unrelated to pollution
prevention efforts that influenced the quantities produced.
There are a number of external factors that can cause the
quantities and/or mix of products and by-products to change. You
will need to look carefully to see whether there are external factors
for which you will need to normalize your data. Common ones to
consider are: total hours the process operated; total employee
hours; area, weight, or volume of product produced; number of
batches processed; area, weight, or volume of raw material pur-
chased; and profit from product. For continuous processes, the
product output or raw material input can be a good normalization
factor. Flow processes may be measured by volume or weight,
whereas plating or film-making may be better normalized by area.
Watch for shifts of wastes to other
media.
Toxicity measures may need to be
developed.
It may be necessary to normalize
quantity comparisons to adjust for
external factors.
Measuring Pollution Prevention Progress
45
-------
In batch processes, production volume usually is related to
waste production, but it may not be a linear relationship in all
cases. For example, the quantity of solvent used at a printing plant
is primarily a function of the total volume of stock printed and ink
used, but it is also significantly influenced by the number of color
changes made.
Another difficulty in comparing production and waste quanti-
ties arises when the relationship is inverse. This situation occurs
frequently when the production rate decreases to the point that age-
dated input materials in the inventory expire. For some production
processes, waste is generated during start-up and shut-down of
equipment. The volume of waste created in both situations is
inversely proportional to the production volume.
Revenue and profit factors can indicate the amount of activity
but may not be reliable indicators if market forces often cause
prices to change. Thus, monetary factors typically apply only to
products in stable markets.
Establishing a Baseline
When a pollution prevention option involves incremental
changes to a well-defined process, it is possible to derive a base-
line from historical performance. However, directly applicable
historical data would not be available for new facilities.
Establishing a baseline is further complicated by changes to
existing processes or equipment and by new facilities that are
radically different from older plants for reasons other than pollu-
tion prevention alone. In this case, the measure of success may be
the amount of pollution that was never generated. Thus, a project-
ed amount of pollution may serve as a baseline.
The...system monitors rates of
toxic use and waste genera-
tion...avoiding distortion of pro-
duction performance due to
changes in overall volume of
production.
— From an interview with
Bill Schwalm on Polaroid's
program, as reported in Envi-
ronmental Business Journal,
December, 1991.
Historical data may not be suffi-
cient to establish baselines.
METHODS OF ANALYZING THE DATA
As the above discussion indicates, measuring pollution preven-
tion progress is complex. Therefore, using a single measure to
summarize pollution prevention will be applicable only in the
simplest cases, if at all. The characteristics of several approaches
and their advantages and disadvantages are outlined in the follow-
ing paragraphs. Select the method or combination of methods that
best fits your data availability, facility characteristics, and corporate
goals.
Semi-Quantitative Process Description
The semi-quantitative process description measurement method
relies primarily on text, supplemented by a limited amount of
numerical data. This type of analysis is less costly to prepare in
terms of staff time and avoids many of the data collection prob-
lems discussed above. However, lack of quantitative data means
that it has negligible value in evaluating achievement of specific
Select the most useful analysis
method(s) for your situation.
Semi-quantitative methods are
easier to prepare but have less
utility.
46
Chapter 4
-------
goals. Lack of quantitative data also makes it difficult to compare
similar processes when looking at potential technology transfer.
Quantity of Waste Shipped off Site or Treated on Site
Data for analysis based on transfers should be easy to obtain.
Collecting such data for the SARA Title III chemicals is among
the reporting requirements of the Pollution Prevention Act of 1990.
Quantities of hazardous waste shipped off site are likely to be
accurately recorded in manifests, although some inaccuracy may be
introduced when partial barrels are shipped. In addition, the
compositions of RCRA wastes may not be available in exact
percentages. The amounts of trash and other nonhazardous wastes
can be estimated based on shipment costs,
The amount of waste going to on-site waste treatment plants
may be more difficult to obtain, but it should be possible to mea-
sure or estimate these quantities.
Quantity of Materials Received
Changes in the quantities of materials brought on site, as
determined from receiving records, can be used to measure pollu-
tion prevention progress. Most facilities keep detailed, accurate
records of material received from suppliers. These records provide
a source of data to track changes in the types and volumes of
materials brought into the facility. However, this method may be
difficult to apply at the process or project level. In addition, the
quantity input will not accurately reflect the amount of waste if
some of the material is destroyed during the process or is acquired
from other production units in the facility,
Quantity of Waste Generated or Used
This method is a combination of the two previous ones. It
essentially gives an overall material balance for each waste compo-
nent. It involves tracking the quantities of hazardous, toxic, and
other materials flowing into and out of the facility. It uses data on
the quantities of material purchased, produced and destroyed in the
production process, and incorporated in products and by-products,
as well as discharges to waste treatment and disposal.
This approach gives an overall picture of material use but re-
quires extensive data collection. Data on fugitive emissions are
particularly difficult to track but can sometimes be estimated by
calculating material balances.
Analysis of a Process
Pollution prevention can be measured on a process-by-process
basis by examining the production process in detail for changes
due to pollution prevention activities. If the process is carefully
selected and can be defined precisely, this approach yields an
Shipping manifests and compli-
ance reports provide data on
quantities transferred.
Quantity purchased is an impre-
cise measure because ii does not
account for loss during process-
in f>.
Looking at both inputs and outputs
provides a mare complete under-
standing of progress.
Analyses based strictly on process-
es will overlook facility-level
waste, such as lighting and con-
struction debris,
Measuring Pollution Prevention Progress
47
-------
accurate description of process-related waste. It also allows better
definition of a representative production or activity index for the
waste generation.
However, it can be difficult to select which process to focus
on in large facilities with complex, interconnected process units.
The approach requires extensive data collection and analysis. In
addition, many wastes may not be generated by a specific process.
These nonprocess-specific wastes can be missed in a strictly
process-based pollution prevention measurement system. Some
types of waste that can be missed include construction debris, area
lighting and utility support, and plant wastewater.
Analysis of a Pollution Prevention Project
This method focuses on measuring the results of each pollu-
tion prevention activity. It is suitable for facilities that produce
many products from the same production line or for facilities that
have a wide variety of production processes. As with the process
approach, the data requirements are extensive. It also assumes a
process orientation and thus is more applicable to product or
equipment changes than to behavioral changes, such as good
housekeeping or improved training,
Change in Amount of Toxic Constituents
Pollution prevention can be measured by the change in the
total amounts of toxic materials released. The data can be drawn
in directly from SARA Title 313 Form R reporting. This method,
obviously, does not apply to nonhazardous wastes.
Change in Material Toxieity
Testing for and eliminating the discharge of pollutants respon-
sible for aquatic toxicity is required under the Clean Water Act.
Pollutants causing aquatic toxicity may not be the pollutants on a
"toxic pollutants list." The first class are compounds that are toxic
to aquatic organisms and hence are assumed to be toxic to the
aquatic environment. The second class are pollutants that have
been tested on humans or other higher life forms and have been
demonstrated to have detrimental effects.
Whole effluent toxicity testing is required under the NPDES
permitting process. Standard methods are available to measure
toxicity to aquatic life forms. The source of the toxicity can be
identified by more detailed testing. Process streams contributing to
the plant waste effluents are sampled and, if needed, partitioned
into separate phases. This detailed toxicity testing allows identifi-
cation and tracking of the actual toxicity of wastes from the plant.
Toxicity testing requires sophisticated testing and data handling,
however, and may not be feasible for all applications.
Project analysis is mare useful for
production changes than for be-
havioral changes.
48
Chapter 4
-------
MEASURING ECONOMIC RESULTS
Aside from assessing its effectiveness in preventing pollution. Evaluate the cost effectiveness of
a project should be evaluated like any other new process or capital the program.
investment. Preliminary cost estimates for installing and operating
the system will be made prior to installing the system. More
detailed data can be collected during construction and operation.
The value of reduced waste production is estimated based on
volumes of waste and cost of waste treatment and disposal. The
economics of the process can then be evaluated by any of several
techniques such as payback, period, net present value, or return on
investment
Measuring Pollution Prevention Progress 49
-------
CHAPTER 5
MAINTAINING THE POLLUTION
PREVENTION PROGRAM
The task of maintaining a viable pollution prevention program
will made easier with the establishment of a pollution prevention
awareness program. Such a program is intended to promote
employee involvement in the prevention effort The objectives of
the pollution prevention awareness program are to:
raise awareness of environment-related activities at the
facility
inform employees of specific environmental issues
train employees in their pollution prevention responsibili-
ties
recognize employees for pollution prevention efforts
encourage employees to participate in pollution preven-
tion
publicize success stories
A summary of methods for accomplishing this appears in Box 18
on the next page.
INTEGRATE POLLUTION PREVENTION
INTO CORPORATE PLAN
Assign Accountability for Wastes
Operating units that generate wastes could be charged with the
full costs of controlling and disposing of the wastes they generate.
Cost accountability should also take into account indirect costs
such as potential liability, compliance reporting, and oversight.
Burying waste management costs in general overhead can lead to
the illusion that disposal is "free." Allocating the costs of waste
handling to the operating units that generate the waste reminds unit
managers that waste control and disposal are increasingly large
factors in the cost of doing business and motivates them to find
ways to cease generating the waste. Chapter 6 describes several
cost allocation methods.
Tracking and Reporting
Your information system should track and retain the data
necessary to measure pollution prevention program results. You
will need to ensure that these data are reviewed and reports pre-
pared at meaningful intervals.
Pollution prevention is an ongoing
effort that will be best maintained
by personnel in the production
area.
Establish the Pollution Prevention
Program
J
Organize Program
1 Do Preliminary Assessment
,
Write Program Plan
,
j Do Detailed Assessment
|
Define Pollution Prevention Options
-
Do Feasibility Analyse*
i
Write Assessment Report
-
t the Plan
-I Measure Progress
(Maintain Pollution Prevention Programj
50
Chapter 5
-------
Key ways to maintain and improve the pollution prevention program:
Integrate pollution prevention into corporate planning:
— Assign pollution prevention accountability to the operating units where
waste is generated
— Track and report program status
— Conduct an annual program evaluation at the corporate level
Provide ongoing staff education programs:
— Make pollution prevention awareness program a part of new employee orienta-
tion
— Provide advanced training
— Retrain supervisors and employees
Maintain internal communication:
— Encourage two-way communication between employees and management
— Solicit employees' pollution prevention suggestions
— Follow-up on suggestions
Reward personnel for their success in pollution prevention:
— Cite accomplishments in performance reviews
— Recognize individual and group contributions
— Grant material rewards
— Consider pollution prevention a job responsibility subject to review
Provide public outreach and education about pollution prevention efforts:.
— Submit press releases on innovations to local media and to industry journals
read by prospective clients.
— Arrange for employees to speak publicly about pollution prevention mea-
sures in schools and civic organizations.
Box 18
Reports should be prepared frequently enough to enable unit
managers to monitor and adjust their operations to adhere to the
schedule that was established during the planning stage. (See
Chapter 2.) In addition, they need this information to provide
feedback to their staff, as discussed below.
Annual Program Evaluation
Top management can demonstrate continuing commitment to
the program by conducting annual reviews of the program. The
results of these annual reviews should be communicated to all
employees through written announcements and meetings. Program
successes should be recognized and any changes in objectives or
policies announced and explained.
Maintaining the Pollution Prevention Program 51
-------
If these company-level reviews demonstrate chronic schedule
slippage, company executives and the pollution program task force
should meet to reevaluate the program. Some objectives or the
approach to achieving them may need to be adjusted. The purpose
is to maintain the same high profile the pollution prevention pro-
gram had initially.
Tracking and reporting are essential.
STAFF EDUCATION
One of the most important elements of the waste minimization
and pollution prevention awareness program is training. The
training program should include all levels of personnel within the
company. The goal is to make each employee aware of waste
generation, its impact on the site and the environment, and ways
waste can be reduced and pollution prevented.
52
Chapter 5
-------
Classroom interaction generates ideas.
New Employee Orientation
A pollution prevention awareness orientation can be incorpo-
rated in the general orientation program given to all new employ-
ees. The orientation program would include the elements illustrat-
ed in Box 19.
More detailed pollution prevention training should be provided
to new employees after they have been on the job for a few weeks.
This training will provide them with the skills they need to partici-
pate in pollution prevention. It also emphasizes the company's
commitment to prevention.
At many plants, employees in certain jobs must be trained and
examined on their knowledge of standard operating procedures
specific to the site prior to working there. Pollution prevention
training can be incorporated into this. It can also be incorporated
in the QA procedures qualification process.
Advanced Training
Specialized training sessions on pollution prevention policy,
procedures, and techniques should be provided to staff when their
job scope is expanded or when they transfer to other areas in the
company. These sessions should be considered part of the regular
training program, and managers should have funds allocated to
cover the costs.
If the progress of the pollution prevention program slows,
review the amount and type of pollution prevention training pro-
vided and consider increasing its frequency and audience.
Make sure new employees are
aware of the program.
Make pollution prevention part of
the QA process.
Keep long-term employees' knowl-
edge current.
Maintaining the Pollution Prevention Program
53
-------
Example Pollution Prevention Employee Orientation
Course: "Pollution Prevention — Description, Motivation, and Practice"
Description: This training course emphasizes your company's commitment to pollution
prevention. It gives instruction and practice in techniques for promotion, persuasion, and
encouragement of pollution prevention.
Goal: The goal of the training program is to explain:
• What is pollution prevention?
• What leads to successful implementation of pollution prevention?
What role can the individual play in promoting pollution prevention?
Lesson Plan for One-Day Orientation
Activities Objectives
Get acquainted Outline activities
Define terms and Begin definition of pollution prevention as a concept and an
introduce objectives activity
Group discussion Perform and discuss a pollution prevention assessment of a simple
process
Outline pollution prevention opportunities
Analyze implementation, possible barriers, and how to overcome
Hands-on exercise (1st half) Perform and discuss pollution prevention assessment of a
complex process
Form teams Experience pressures of business
Individuals assigned roles Experience importance of communication
Hands-on exercise (2nd half) Refine application
Reassign roles Develop teamwork
Repeat hands-on exercise Experience putting opportunities into priority list
(1st half) Discuss implementation, possible barriers, and how to overcome
Discussion Reinforce need for pollution prevention
Explain significance of individual contribution to pollution
prevention
Box 19
54 Chapter 5
-------
Retraining
Periodic retraining of employees may be necessary when your
policies and procedures change. Retraining employees also will
reiterate your commitment to pollution prevention.
MAINTAIN INTERNAL COMMUNICATION
Two-Way Communication
Your goal is to keep employees motivated (see Box 20). They
need to identify with and "buy in" to goals and objectives and
continuously have the opportunity to contribute to its success.
Employees will take their pollution prevention roles more seriously
when their managers keep them informed and encourage them to
submit pollution prevention ideas.
Make sure employees receive regularly scheduled status
reports that are clear and truthful. Objectives that are described in
vague terms and have poorly quantified results and reports that are
issued at odd intervals may give the impression of a reduced
priority for poDution prevention. Explain to the staff any schedule
slippage resulting from unexpected challenges and the need for
greater staff involvement, if applicable. Employees will work
more effectively when they know what management expects of
them. Cessation of reports or failure to show ongoing activities
gives employees the impression that little progress is being made
and/or that the overall program no longer is a priority.
Solicit and Follow up on Employees' Suggestions
Employees' ideas for pollution prevention projects should be
actively sought. Employees take their pollution prevention role
more seriously when management keeps them informed and
encourages them to submit pollution prevention ideas. Forums
such as breakfasts or informal pollution prevention review meet-
ings promote the exchange of information that will help generate
new ideas. You could run a contest to get and reward employee
input. For example, you could post a checklist of pollution pre-
vention ideas and offer cash awards for the best way to implement
an idea and for the best pollution prevention idea not included on
the checklist.
Suggestions should be evaluated promptly and put into prac-
tice if they are found to be feasible. Similarly, if an employee
submits an idea that is not implemented, explain why it was not
used and work with the employee to develop a feasible idea.
Prompt feedback is necessary to maintain employee interest.
Effective communication between
managers and employees is a
critical requirement for maintain-
ing a successful program.
Show employees their ideas are
welcome.
Maintaining the Pollution Prevention Program
55
-------
To motivate employees, managers can:
Provide feedback and reinforcement of employees' pollution prevention perfor-
mance.
Set an example by adhering to the pollution prevention program and actively
considering employee ideas.
Convey enthusiasm about meeting pollution prevention objectives.
When new pollution prevention measures are implemented, explain how they fit
in with the overall objectives.
Regularly reinforce the importance of each individual's contributions to pollution
prevention and their value to the overall objectives.
Demonstrate personal commitment to the objectives and praise the commitment
demonstrated by employees.
Announce pollution prevention innovations by calling a meeting for all individu-
als who will be affected to discuss the change.
— Open meeting to questions and comments.
— Pay attention to signs of animosity or resistance and address these
immediately.
— Gain cooperation by showing that you know and care how the employ-
ees feel.
Establish a "group identity" and work at building pride in adapting to the
pollution prevention innovation.
"Go to bat" for employees who have good pollution prevention ideas that have
been rejected or overlooked.
Establish quantifiable annual pollution prevention objectives:
— On a monthly basis, have employees chart their personal and the
company's progress against these objectives.
— Incorporate pollution prevention goals, objectives, and accomplishments
into annual job performance evaluations for people with direct process
pollution prevention responsibilities.
— Readjust objectives if they prove to be unattainable.
Box 20
56 Chapter 5
-------
EMPLOYEE REWARD PROGRAM
Performance Reviews
Progress in pollution prevention can be stated as an objective Good suggestions should he put
on which annual job performance evaluations are based, particular- into practice and recognized.
ly at the management level. This delineates their responsibility for
maintaining and enhancing the pollution prevention program.
Using the formal mechanism of the written annual report to recog-
nize efforts in this area raises the visibility of pollution prevention
as something that is important to the company.
Recognition Among Peers
Employees who suggest pollution prevention measures that
prove feasible and are slated for implementation should be publi-
cized in the company newsletter or on bulletin boards. The esti-
mated cost savings and/or other advantages that the company or
unit will derive should be included in this announcement. Periodic
group meetings may be a good forum for announcing individuals'
efforts to control pollution in the company's daily operations.
Material Rewards
Cash or merchandise can be awarded to individuals. Estab-
lishing the award as a set percentage of the estimated annual
savings to be realized by the company or production unit is one
way to highlight the concrete value of pollution prevention.
PUBLIC OUTREACH AND EDUCATION
Employees can speak at meetings of community organizations
and at schools to publicize the company's pollution prevention
progress. Interviews with local media are another way to enhance
corporate image and to further emphasize to employees the impor-
tance of the program.
Papers given at technical meetings and articles published in
trade and professional journals are additional forms of positive
publicity.
These measures all help to demonstrate that the company's
commitment to pollution prevention is real.
Maintaining the Pollution Prevention Program 57
-------
CHAPTER 6
ECONOMIC ANALYSIS OF
POLLUTION PREVENTION PROJECTS
Although businesses may invest in pollution prevention be-
cause it is the right thing to do or because it enhances their public
image, the viability of many prevention investments rests on sound
economic analyses. In essence, companies will not invest in a
pollution prevention project unless that project successfully com-
petes with alternative investments. The purpose of this chapter is
to explain the basic elements of an adequate cost accounting
system and how to conduct a comprehensive economic assessment
of investment options.
A proposed pollution prevention
option must compete with alterna-
tive investments.
TOTAL COST ASSESSMENT
In recent years industry and the EPA have begun to leam a
great deal more about full evaluation of prevention-oriented invest-
ments. In the first place, we have learned that business accounting
systems do not usually track environmental costs so they can be
allocated to the particular production units that created those
wastes. Without this sort of information, companies tend to lump
environmental costs together in a single overhead account or
simply add them to other budget line items where they cannot be
disaggregated easily. As a result, companies do not have the
ability to identify those parts of their operations that cause the
greatest environmental expenditures or the products that are most
responsible for waste production. This chapter provides some
guidance on how accounting systems can be set up to capture this
useful information better.
It has also become apparent that economic assessments typi-
cally used for investment analysis may not be adequate for pollu-
tion prevention projects. For example, traditional analysis methods
do not adequately address the fact that many pollution prevention
measures will benefit a larger number of production areas than do
most other kinds of capital investment Second, they do not
usually account for the full range of environmental expenses
companies often incur. Third, they usually do not accommodate a
sufficiently long time horizon to allow full evaluation of the
benefits of many pollution prevention projects. Finally, they
provide no mechanism for dealing with the probabilistic nature of
pollution prevention benefits, many of which cannot be estimated
with a high degree of certainty. This chapter provides guidance on
how to overcome these problems as well.
Standard accounting systems do
not track environmental costs well.
Economic analysis of pollution
prevention projects is complex
because they:
• affect multiple areas
• have long time horizons
• have probabilistic benefits
58
Chapter 6
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In recognition of opportunities to accelerate pollution pre-
vention, the U.S. EPA has funded several studies to demonstrate
how economic assessments and accounting systems can be modi-
fied to improve the competitiveness of prevention-oriented invest-
ments. EPA calls this analysis Total Cost Assessment (TCA).
There arc four elements of Total Cost Assessment: expanded cost
inventory, extended time horizon, use of long-term financial
indicators, and direct allocation of costs to processes and products.
The first three apply to feasibility assessment, while the fourth
applies to cost accounting. Together these four elements will help
you to demonstrate the true costs of pollution to your firm as well
as the net benefits of prevention. In addition, they help you show
how prevention-oriented investments compete with company-
defined standards of profitability. In sum, TCA provides substan-
tial benefits for pre-implementation feasibility assessments (see
Chapter 2 on preliminary assessments and Chapter 3 on feasibility
analysis) and for post-implementation project evaluation (see
Chapter 4 on measuring progress.)
The remainder of this chapter summarizes the essential char-
acteristics of TCA. Much of the information is drawn from a
report recently prepared for the U.S. EPA by Tellus Institute. (See
Appendix G for the full citation.) The Tellus report addresses
TCA methodology in much greater detail than can be provided
here and provides examples of specific applications from the pulp
and paper industry. The report also includes an extensive bibliog-
raphy on applying TCA to pollution prevention projects. In a
separate but related study for the New Jersey Department of
Environmental Protection, Tellus analyzed TCA as it applies to
smaller and more varied industrial facilities. A copy of this report
can be obtained from the N.J. Department of Environmental
Protection.
Elements of Total Cosi Assess-
ment:
• expanded cos! inventory
• extended time horizon
• use of long-term indicators
• allocation of costs by area
TCA methodology has been the
topic of several government stud-
ies.
EXPANDED COST INVENTORY
TCA includes not only the direct cost factors that are part of
most project cost analyses but also indirect costs, many of which
do not apply to other types of projects. Besides direct and indirect
costs, TCA includes cost factors related to liability and to certain
"less-tangible" benefits.
TCA is a flexible tool that can be adapted to your specific
needs and circumstances. A full-blown TCA will make more
sense for some businesses than for others. In either case it is
important to remember that TCA can happen incrementally by
gradually bringing each of its elements to the investment evalua-
tion process. For example, while it may be quite easy to obtain
information on direct costs, you may have more trouble estimating
some of the future liabilities and less tangible costs. Perhaps your
first effort should incorporate all direct costs and as many indirect
costs as possible. Then you might add those costs that are more
difficult to estimate as increments to the initial analysis, thereby
TCA analyzes
* direct costs
* indirect costs
* liability costs
* less tangible benefits
Economic Analysis of Pollution Prevention Projects
59
-------
highlighting to management both their uncertainty and their impor-
tance.
Direct Costs
For most capital investments, the direct cost factors are the
only ones considered when project costs are being estimated. For
pollution prevention projects, this category may be a net cost, even
though a number of the components of the calculation will repre-
sent savings. Therefore, confining the cost analysis to direct costs
may lead to the incorrect conclusion that pollution prevention is
not a sound business investment.
Indirect Costs
For pollution prevention projects, unlike more familiar capital
investments, indirect costs are likely to represent a significant net
savings. Administrative costs, regulatory compliance costs (such
as permitting, recordkeeping, reporting, sampling, preparedness,
closure/post-closure assurance), insurance costs, and on-site waste
management and pollution control equipment operation costs can
be significant. They are considered hidden in the sense that they
are either allocated to overhead rather than their source (production
process or product) or are altogether omitted from the project
financial analysis. A necessary first step in including these costs
in an economic analysis is to estimate and allocate them to their
source. See the section below on Direct Cost Allocation for
several ways to accomplish this.
Liability Costs
Reduced liability associated with pollution prevention invest-
ments may also offer significant net savings to your company.
Potential reductions in penalties, fines, cleanup costs, and personal
injury and damage claims can make prevention investments more
profitable, particularly in the long run.
In many instances, estimating and allocating future liability
costs is subject to a high degree of uncertainty. It may, for exam-
ple, be difficult to estimate liabilities from actions beyond your
control, such as an accidental spill by a waste hauler. It may also
be difficult to estimate future penalties and fines that might arise
from noncompliance with regulatory standards that do not yet
exist. Similarly, personal injury and property damage claims that
may result from consumer misuse, from disposal of waste later
classified as hazardous, or from claims of accidental release of
hazardous waste after disposal are difficult to estimate. Allocation
of future liabilities to the products or production processes also
presents practical difficulties in a cost assessment. Uncertainty,
therefore, is a significant aspect of a cost assessment and one that
top management may be unaccustomed to or unwilling to accept.
Direct Costs
Capital Expenditures
• Buildings
• Equipment and Installation
• Utility Connections
- Project Engineering
Operation and Maintenance
Expenses or Revenues
• Raw Materials
• Labor
• Waste Disposal
• Water and Energy
• Value of Recovered Material
Indirect Costs
Administrative Costs
Regulatory Compliance Costs
• Permitting
• Recordkeeping and Reporting
• Monitoring
' Manifesting
Insurance
Workman's Compensation
On-Site Waste Management
On-Site Pollution Control
Equipment Operation
Liability Costs
Penalties
Fines
Personal Injury
Property Damage
Natural Resources Damage Clean-
up Costs
• Superfund
• Corrective Action
60
Chapter 6
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Some firms have nevertheless found alternative ways to
address liability costs in project analysis. For example, in the
narrative accompanying a profitability calculation, you could
include a calculated estimate of liability reduction, cite a penalty or
settlement that may be avoided (based on a claim against a similar
company using a similar process), or qualitatively indicate without
attaching dollar value the reduced liability risk associated with the
pollution prevention project. Alternatively, some firms have
chosen to loosen the financial performance requirements of their
projects to account for liability reductions. For example, the
required payback period can be lengthened from three to four
years, or the required internal rate of return can be lowered from
15 to 10 percent. (See the U.S. EPA's Pollution Prevention
Benefits Manual, Phase //, as referenced in Appendix G, for sug-
gestions on formulas that may be useful for incorporating future
liabilities into the cost analysis.)
Less-Tangible Benefits
A pollution prevention project may also deliver substantial
benefits from an improved product and company image or from
improved employee health. These benefits, listed in the cost
allocation section of this chapter, remain largely unexamined in
environmental investment decisions. Although they are often
difficult to measure, they should be incorporated into the assess-
ment whenever feasible. At the very least, they should be high-
lighted for managers after presenting the more easily quantifiable
and allocatable costs.
Consider several examples. When a pollution prevention
investment improves product performance to the point that the new
product can be differentiated from its competition, market share
may increase. Even conservative estimates of this increase can
incrementally improve the payback from the pollution prevention
investment. Companies similarly recognize that the development
and marketing of so-called "green products" appeals to consumers
and increasingly appeals to intermediate purchasers who are inter-
ested in incorporating "green" inputs into their products. Again,
estimates of potential increases in sales can be added to the analy-
sis. At the very least, the improved profitability from adding these
less-tangible benefits to the analysis should be presented to man-
agement alongside the more easily estimated costs and benefits.
Other less tangible benefits may be more difficult to quantify, but
should nevertheless be brought to management's attention. For
example, reduced health maintenance costs, avoided future regula-
tory costs, and improved relationships with regulators potentially
affect the bottom line of the assessment.
In time, as the movement toward green products and compa-
nies grows, as workers come to expect safer working environ-
ments, and as companies move away from simply reacting to
regulations and toward anticipating and addressing the environmen-
tal impacts of their processes and products, the less tangible
Less-Tangible Benefits
Increased Sales Due to
• improved product quality
• enhanced company image
• consumer trust in green prod-
ucts
Improved Supplier-Customer
Relationship
Reduced Health Maintenance
Costs
Increased Productivity Due to
Improved Employee Relations
Improved Relationships with
Regulators
"We wanted to make a major
effort to show that industry in the
U.S. can simultaneously attack
and solve environmental problems
while improving both products
and profitability."
— John Dudek, value analysis
manager at Zytec, as quoted in
Perspectives on Minnesota
Waste Issues, January-Febru-
ary, 1992.
Economic Analysis of Pollution Prevention Projects
61
-------
aspects of pollution prevention investments will become more
apparent.
EXPANDED TIME HORIZON
Since many of the liability and less-tangible benefits of pollu-
tion prevention will occur over a long period of time, it is impor-
tant that an economic assessment look at a long time frame, not
the three to five years typically used for other types of projects.
Of course, increasing the time frame increases the uncertainty of
the cost factors used in the analysis.
Many of the benefits of pollution
prevention accrue over long peri-
ods of time.
LONG-TERM FINANCIAL INDICATORS
When making pollution prevention decisions, select long-term
financial indicators that account for:
* all cash flows during the project
the time value of money.
Three commonly used financial indicators meet these criteria; Net
Present Value (NPV) of an investment, Internal Rate of Return
(IRR), and Profitability Index (PI). Another commonly used
indicator, the Payback Period, does not meet the two criteria
mentioned above and should not be used.
Discussions on using these and other indicators will be found
in economic analysis texts.
Net Present Value, Internal Rate
of Return, and Profitability Index
are useful financial indicators.
DIRECT ALLOCATION OF COSTS
Few companies allocate environmental costs to the products
and processes that produce these costs. Without direct allocation,
businesses tend to lump these expenses into a single overhead
account or simply add them to other budget line items where they
cannot be disaggregated easily. The result is an accounting system
that is incapable of (1) identifying the products or processes most
responsible for environmental costs, (2) targeting prevention
opportunity assessments and prevention investments to the high
environmental cost products and processes, and (3) tracking the
financial savings of a chosen prevention investment. TCA will
help you remedy each of these deficiencies.
Like much of the TCA method, implementation of direct cost
allocation should be flexible and tailored to the specific needs of
your company. To help you evaluate the options available to you,
the discussion below introduces three ways of thinking about
allocating your costs: single pooling, multiple pooling, and service
centers. The discussion is meant as general guidance and explains
some of the advantages and disadvantages of each approach.
Please see other EPA publications (such as those listed in Appen-
Developing a pollution prevention
program may well provide the first
real understanding of the costs of
polluting.
Three methods of direct cost
allocation:
• single pooling
multiple pooling
m service centers
62
Chapter 6
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dix G), general accounting texts, and Financial specialists for more
detail.
Single Pool Concept
With the single pool method, the company distributes the
benefits and costs of pollution prevention across all of its products
or services. A general overhead or administrative cost is included
in all transactions.
Advantages. This is the easiest accounting method to put into
use. All pollution costs are included in the general or admin-
istrative overhead costs that most companies already have, even
though they may not be itemized as pollution costs. It may there-
fore not be a change in accounting methods but rather an adjust-
ment in the overhead rate. No detailed accounting or tracking of
goods is needed. Little additional administrative burden is incurred
to report the benefits of pollution prevention.
Disadvantages. If the company has a diverse product or
service line, pollution costs may be recovered from products or
services that do not contribute to the pollution. This has the effect
of inflating the costs of those products or services unnecessarily.
It also obscures the benefits of pollution prevention to the people
who have the opportunity to make it successful — the line manager
will not see the effect of preventing or failing to prevent pollution
in his area of responsibility.
Multiple Pool Concept
The next level of detail in the accounting process is the multi-
ple pool concept, wherein pollution prevention benefits or costs are
recovered at the department or other operating unit level.
Advantages. This approach ties the cost of pollution more
closely to the responsible activity and to the people responsible for
daily implementation. It is also easy to apply within an accounting
system that is already set up for departmentalized accounting.
Disadvantages. A disparity may still exist between respon-
sible activities and the cost of pollution. For example, consider a
department that produces parts for many outside companies. Some
customers need standard parts, while others require some special
preparation of the parts. This special preparation produces pollu-
tion. Is it reasonable to allocate the benefit or cost for this pollu-
tion prevention project across all of the parts produced?
Service Center Concept
A much more detailed level of accounting is the service center
concept. Here, the benefits or costs of pollution prevention are
allocated to only those activities that are directly responsible.
Advantages. Pollution costs are accurately tied to the genera-
tor. Theoretically, this is the most equitable to all products or
services produced. Pollution costs can be identified as direct costs
Single pool accounting is the
easiest method, but it does not
point up the effects of action
within a given area.
Multiple pool accounting comes
closer to tracking responsibility.
Service center accounting applies
costs or benefits to the activities
that are directly responsible.
Economic Analysis of Pollution Prevention Projects
63
-------
on the appropriate contracts and not buried in the indirect costs,
affecting competitiveness on other contracts. Pollution costs are
more accurately identified, monitored and managed. The direct
benefits of pollution prevention are more easily identified and
emphasized at the operational level.
Disadvantages. Considerable effort may be required to track
each product, service, job, or contract and to recover the applicable
pollution surcharges. Added administrative costs may be incurred
to implement and maintain the system. It may be difficult to
identify the costs of pollution when pricing an order or bidding on
a new contract. It may be difficult to identify responsible activities
under certain circumstances such as laboratory services where
many small volumes of waste are generated on a seemingly contin-
ual basis.
SUMMARY
Environmental costs have been rising steadily for many years
now. Initially, these costs did not seem to have a major impact on
production. For this reason, most companies simply added these
costs to an aggregate overhead account, if they tracked them at all.
The tendency of companies to treat environmental costs as over-
head and to ignore many of the direct, indirect, and less-tangible
environmental costs (including future liability) in their investment
decisions has driven the development of TCA.
Expanding your cost inventor}' pulls into your assessments a
much wider array of environmental costs and benefits. Extending
the time horizon, even slightly, can improve the profitability of
prevention investments substantially, since these investments tend
to have somewhat longer payback schedules. Choosing long-term
financial indicators, which consistently provide managers with
accurate and comparable project financial assessments, allows
prevention oriented investments to compete successfully with other
investment options. Finally, directly allocating costs to processes
and products enhances your ability to target prevention investments
to high environmental cost areas, routinely provides the informa-
tion needed to do TCA analysis, and allows managers to track the
success of prevention investments. Overall, the TCA method is a
flexible tool, to be applied incrementally, as your company's needs
dictate.
TCA is an increasingly valuable
tool as the business costs of pollu-
tion continue to rise.
64
Chapter 6
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CHAPTER 7
DESIGNING
ENVIRONMENTALLY
COMPATIBLE PRODUCTS
Environmentally compatible products minimize the adverse
effects on the environment resulting from their manufacture, use,
and disposal. The environmental impact of a product is to a large
extent determined during its design phase. By taking environmen-
tal considerations into account during product planning, design,
and development, your company can minimize the negative impact
of your products on the environment.
Design changes made to prevent pollution should be imple-
mented in such a manner that the quality or function of the product
is not affected adversely. Design for the environment can be
achieved by the people directly involved, within the framework of
company policy and with support from company management,
whether or not in response to incentives external to the company.
The process of looking at all aspects of product design from
the preparation of its input materials to the end of its use is life-
cycle assessment. A life-cycle assessment of the product design
evaluates the types and quantities of product inputs, such as ener-
gy, raw materials, and water, and of product outputs, such as atmo-
spheric emissions, solid and waterborne wastes, and the end-prod-
uct.
What are environmentally compat-
ible products?
Compatibility can be integrated
with other design concerns.
STAGES IN LIFE-CYCLE ASSESSMENT
In 1990, the U.S. EPA sponsored an international pollution
prevention conference on "clean" technologies and products. The
introduction to the published proceedings (see Appendix G) pro-
vides the following overview.
"Life-cycle assessment is a snapshot of inputs and outputs. It
can be used as an objective technical tool to identify and evaluate
opportunities to reduce the environmental impacts associated with
a specific product, process, or activity. This tool can also be used
to evaluate the effects of various resource management options
designed to create sustainable systems. Life-cycle assessment takes
a holistic approach by analyzing the entire life cycle ... encompass-
ing extraction and processing (of) raw materials; manufacturing,
transportation, and distribution; use/reuse/maintenance; recycling
and composting; and final disposal.
Life-cycle assessment looks at all
inputs and outputs of a product
during its life cycle.
65
-------
"The three components of a life-cycle assessment include (1)
the identification and quantification of energy and resource use and
waste emissions (inventory analysis); (2) the assessment of the
consequences those wastes have on the environment (impact
analysis); and (3) the evaluation and implementation of opportuni-
ties to effect environmental improvements (improvement analysis).
The life-cycle assessment is not necessarily a linear or stepwise
process. Rather, information from any of the components can
complement information from the other two. Environmental
benefits can be realized from each component of the assessment
process. For example, the inventory alone may be used to identi-
fy opportunities for reducing emissions, energy consumption, or
material use. Impact analysis typically identifies the activities
with greater and lesser environmental effects, while the improve-
ment analysis helps ensure that any potential reduction strategies
are optimized and that improvement programs do not produce
additional, unanticipated adverse impacts to human health and the
environment."
The three phases of life-cycle
assessment:
* Inventory analysis
• Impact analysis
* Improvement analysis
GOALS OF PRODUCT DESIGN OR REDESIGN
When beginning to look at product design or redesign to make
it environmentally compatible, the first step is to define the goals.
When redesigning an existing product, goals will involve modify-
ing those aspects of its performance that are judged environmental-
ly unacceptable and that can be improved. Aspects that should be
examined include whether it uses a scarce input material, contains
hazardous substances, uses too much energy, or is not readily
reused or recycled. These environmental criteria can be added to
the initial program of requirements for the product, such as quality,
customer acceptance, and production price.
The goals of new product design can be reformulation and a
rearrangement of the products' requirements to incorporate envi-
ronmental considerations. For example, the new product can be
made out of renewable resources, have an energy-efficient manu-
facturing process, have a long life, be non-toxic and be easy to
reuse or recycle. In the design of a new product, these environ-
mental considerations can become an integral part of the program
of requirements.
J. C. van Weenan describes product design and redesign from
the environmental impact perspective in his book Waste Preven-
tion: Theory and Practice. (See Appendix G for the full refer-
ence.)
In both the redesign of existing products and the design of
new products, the methods applied and the procedure followed win
be affected by additional environmental requirements. These new
environmental criteria will be added to the list of traditional crite-
ria. Box 21 lists some environmental criteria for product design.
Identify the aspects of a product
(hat have environmental impact.
66
Chapter 7
-------
Environmentally
L Compatible Product
Design
T—
Definition
Criteria
Prlorltlzatlon
Program
Requirements
Improve the
Influence of
the Product
Upon the
Environment
Minimize the
Influence of
the Product
Upon the
Environment
Internal
Company
Evaluation
Redesigned
Product
Newly Designed
Product
1
Environmentally
Compatible Product
•External Evaluation Factors:
• Product Policy
* Product Life Cycle Assessment
* Eco-Labe) Program
* Genera! Perception
* Market Conditions
* Consumer Organizations
* Design Organizations
Adapted From: Dr. J. C. van Weenan, IDES, University of Amsterdam, February 18,1991.
Figure 5. Schematic Representation of the "Eco-Product" Design Process
Designing Environmentally Compatible Products
67
-------
Environmental criteria to consider in designing products:
Use renewable natural resource materials.
• Use recycled material.
Use fewer toxic solvents or replace solvents with an alternative material (e.g., use
bead blasting instead of solvents for paint removal).
• Reuse scrap and excess material.
• Use water-based inks instead of solvent-based ones.
• Produce combined or condensed products that reduce packaging requirements.
Produce fewer integrated units (i.e., more replaceable component parts).
Minimize product filler and packaging.
• Produce more durable products.
• Produce goods and packaging reusable by the consumer.
Manufacture recyclable final products.
Box 21
The design process in Figure 5 shows a schematic representa-
tion of van Weenan's (1990) design of environmentally compatible
products.
68 Chapter 7
-------
CHAPTER 8
ENERGY CONSERVATION
AND POLLUTION PREVENTION
Energy conservation and pollution prevention are complemen-
tary activities. That is, actions that conserve energy reduce the
quantity of wastes produced by energy-generating processes, and
actions that reduce production process wastes lower the expendi-
ture of energy for waste handling and treatment.
Energy conservation goes hand-in-
hand with pollution prevention.
PREVENTING POLLUTION BY CONSERVING ENERGY
Nearly all energy used in the United States is generated by
processes that consume materials and create wastes that pollute the
environment if released directly. These wastes require treatment or
the even less satisfactory measure of long-term containment.
Wastes Produced by Energy Generation
Fossil fuel and nuclear power generation create a variety of
wastes. The gaseous and paniculate byproducts of fossil fuel
combustion include carbon dioxide, carbon monoxide, and nitrogen
and sulfur oxides. The processes used to treat these gases create
other wastes. The use of nuclear energy presents the risk of
accidental release of radioactive gases.
Water used in generating energy from fossil fuels is contami-
nated with the chemicals used to control scale and corrosion.
Before discharge, the water must be treated to remove these
contaminants. The water used in nuclear power plants can become
contaminated accidentally, requiring that it be disposed of in a
secure site.
Burning fossil fuels creates solid waste in the form of ash and
slag. In addition, the treatment of waste gases and water causes
the formation of solid waste. Waste nuclear fuel is another form
of solid waste resulting from energy production.
Ways to Conserve Electrical and Thermal Energy
Production facilities consume enormous amounts of electricity
in both their production processes and the operation of their
facilities. Aside from environmental considerations, the rapid
increase in the cost of electricity provides a strong motivation to
conserve its use. Box 22 lists several ways to conserve electricity.
Wastes are produced in almost all
energy-generating activities.
Consumption of electricity is a
major cost for most facilities.
69
-------
Your company can conserve electricity by;
Implementing housekeeping measures such as turning off equipment and
lights when not in use.
• Placing cool air intakes and air-conditioning units in cool, shaded locations.
• Using more efficient heating and refrigeration units.
Using more efficient motors,
• Eliminating leaks in compressed air supply lines.
Improving lubrication practices for motor-driven equipment.
Using energy-efficient power transfer belts.
Using fluorescent lights and/or lower wattage lamps or ballasts.
Installing timers and/or thermostats to better control heating and cooling.
Box 22
Combustion of fossil fuels in primary heat sources such as
boilers or fired heaters provides a major source of heat input to
industrial processes. Thermal energy can be conserved by taking
care to prevent its loss during transport from the combustion site to
the specific processes where it is used. Box 23 lists some mea-
sures that can be taken to conserve thermal energy as it is trans-
ported and used. It may also be possible to recover and use heat
generated by production processes.
You can reduce loss with thermal energy conservation by:
Adjusting burners for optimal air/fuel ratio.
* Improving or increasing insulation on heating or cooling lines.
Instituting regular maintenance to reduce leakage and stop steam trap bypass.
Improving the thermodynamic efficiency of the process by options such as:
— Using condensers or regenerative heat exchanger to recapture heat.
— Using heat pumps or similar equipment to recover heat at distilla-
tion columns.
— Using more efficient heat exchangers.
— Using cogeneration of electricity and steam.
Box 23
CONSERVING ENERGY THROUGH
POLLUTION PREVENTION
Energy consumption is reduced when waste generation is
controlled. Treating and transporting pollutants represents an
enormous drain on the energy reserves of the United States.
70 Chapter 8
-------
Pollution prevention activities result in improved efficiency of
resource use, with a consequent reduction in the amount of energy
required to process input materials. For example, reuse of metals
such as copper or aluminum requires considerably less energy than
is expended in extracting and processing the ores. Additional
savings in energy can be realized by reducing the amount of metal
used in a production process, thereby saving on energy required to
recover the metal.
Two books listed in Appendix G deal specifically with facility
energy conservation (Glasstone; Hu). They provide information on
conducting energy audits, identifying conservation alternatives, and
other topics related to improving the efficiency of energy use
within a facility.
Energy Conservation and Pollution Prevention 71
-------
APPENDIX A
POLLUTION PREVENTION
WORKSHEETS
The worksheets in this appendix were designed to be useful at various points in the development
of a pollution prevention program. Table A-l lists the worksheets and describes the purpose of each.
Since these worksheets are intentionally generic, you may decide to redesign some or all of them
to be more specific to your facility once you have your program underway. The checklists in
Appendix B contain information that you may find helpful in deciding how to customize these
worksheets to fit your situation. Appendix C contains examples of worksheets as they might be
customized for a pharmaceutical company.
Table A-l. List of Pollution Prevention Assessment Worksheets
Phase
Number and Title
Purpose/Remarks
1. Assessment Overview
Assessment Phase
2. Site Description
3. Process Information
4. Input Materials Summary
5. Products Summary
6. Waste Stream Summary
7. Option Generation
8. Option Description
Feasibility Analysis Phase
9. Profitability
Summarizes the overall program.
Lists background information about the facility, including location,
products, and operations.
This is a checklist of process information that can be collected before
the assessment effort begins.
Records input material information for a specific production or process
area. This includes name, supplier, hazardous component or prop-
erties, cost, delivery and shelf-life information, and possible substitutes.
Identifies hazardous components, production rate, revenues, and other
information about products.
Summarizes the information collected for several waste streams. This
sheet can be used to prioritize waste streams to assess.
Records options proposed during brainstorming or nominal group tech-
nique sessions. Includes the rationale for proposing each option.
Describes and summarizes information about a proposed option. Also
notes approval of promising options.
This worksheet is used to identify capital and operating costs and to
calculate the payback period.
73
-------
Firm _
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of
of Page .
of
WORKSHEET
1
ASSESSMENT OVERVIEW
E»tabll»h the Pollution Prevention Program
• Ewcutw Level Decition
• Policy Statement
• Contensus Bulking
Organize Program
• Name Task Force
• State Goals
Do Preliminary A»e*ament
• Collect Data
• Review Sites
• Establish Priorities
Write Program Plan
Consider External Groups
Define Objectives
' Identity Potential Obstacles
• Develop Schedule
Do Detailed AtMUment
1 Name Assessment Team(s)
1 Review Data and Site(s)
• Organize and Document Information
Define Pollution Prevention Optlona
• Propose Options
• Screen Options
Do Feasibility Analyaes
• Technical
• Environmental
• Economic
Write Asaeument Report
'
Implement the Plan
• Selecl Projects
• Obtain Fuming
- Install
Measure Progrea*
• Acquire Data
• Analyze Results
1
I Maintain Pollution Prevention Program J
74
Appendix A
-------
Firm _
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of Page of
WORKSHEET
2
SITE DESCRIPTION
Firm:
Plant:
Department:
Area:
Street Address:
City:
State/Zip Code:
Telephone: ( )
Major Products:
SIC Codes:
EPA Generator Number:
Major Unit:
Product or Service:
Operations:
Facilities/Equipment Age:
Pollution Prevention Worksheets
75
-------
Firm . A,
Site
Pollution Prevention
isessment Worksheets
Date Proi. No.
WORKSHEET PROCESS INFORMATION
Pre
Ch
Sh
oared Bv
ecked Bv
eet of Paae of
Process Unit/Operation:
Operation Type: D Continuous Q Dis
D Batch or Semi-Batch D Git*
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Process Description
Operating Manuals
Equipment List
Equipment Specifications
Piping and Instrument Diagrams
Plot and Elevation PJan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
crete
er
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Jsed in this
Report (Y/N)
Document
Number
.ocation
76
Appendix A
-------
p
Firm A««
Site
dilution Prevention
essmartt Worksheets
Date Proi. No.
Prepared Bv
Checked Bv
Sheet of Psae of
WORKSHEET INPUT MATERIALS SUMMARY
,
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode1
Shipping Container Size & Type2
Storage Mode3
Transfer Mode*
Empty Container Disposal Management8
Shelf Life
Supplier Would
— accept expired material? (Y/N)
— accept shipping containers? (V/N)
— revise expiration date? (Y/N)
Acceptable Substitute^, if any
Alternate Suppliers)
Description
Stream No.
Stream No.
Stream No.
Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g., 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g., outdoor, warehouse, underground, aboveground, etc.
4. e.g., pump, forklift, pneumatic transport, conveyor, etc.
5. e.g., crush and landfill, clean and recycle, return to supplier, etc.
Pollution Prevention Worksheets
77
-------
Pi
Firm a««
Site
jUutlon Prevention
Bjsment Worksheets
Date Proi. No.
Prepared By
Checked By
Sheet of Paae of
WORKSHEET PRODUCTS SUMMARY
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size & Type
Onsite Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
— relax specification (Y/N)
— accept larger containers !Y/N)
Description
Stream No,
Stream No,
Stream No.
78
Appendix A
-------
Pollut
Firm , A»*e*sr
Site
Date Proj. No.
on Prevention
nent Worksheets
Prepared Bv
Checked Bv
Sheet of Paae of
WORKSHEET WASTE STREAM SUMMARY
6. ,. ... .^_ ...... ..... ...
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units I
Overall
Component(s) of Concern
Cost of Disposal
Unit Cost (5 per: )
Overall (per year)
Method of Management1
Relative
Priority Rating Criteria2 Wt. (W)
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Priority Rank
Description
Stream No.
Rating
(R) R x W
I(RxW)
Stream No.
Rating
(R) R x W
I(RxW)
Stream No.
Rating
(R) R x W
I(RxW|
Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
Pollution Prevention Worksheets
79
-------
Pollution Prevention
Firm A«,of tmont w0rir
-------
Firm _
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj, No.
Prepared By
Checked By
Sheet of
of Page
of
WORKSHEET
8
OPTION DESCRIPTION
Option Name:
Briefly describe the option;
Waste Stream(s) Affected:
Input Material(s) Affected:
Produces) Affected:
Indicate Type: D Source Reduction
Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
D Recycling/Reuse
Onsite
Off site
Material reused for original purpose
Material used for a lower-quality purpose
Material sold
Originally proposed by:
Reviewed by:
Date:
Date:
Approved for study?
.Yes,
. no By:_
Reason for Acceptance or Rejection .
Pollution Prevention Worksheets
81
-------
Firm .
Site _
Date
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet of Page .
.of.
WORKSHEET
9
PROFITABILITY
Capita! Costs
Purchased Equipment
Materials
Installation
Utility Connections
Engineering
Start-up and Training
Other Capital Costs _
Total Capital Costs
Incremental Annual Operating Costs
Change in Disposal Costs
Change in Raw Material Costs ,
Change in Other Costs
Payback Period (in years)
Annual Net Operating Cost Savings
Total Capital Costs
Annual Net Operating Cost Savings
82
Appendix A
-------
APPENDIX B
INDUSTRY-SPECIFIC CHECKLISTS
This appendix tabulates information that may be helpful to you if you decide to customize the
worksheets in Appendix A for your own company's needs. Some ideas for achieving pollution
prevention through good operating practices are shown in Table 1. Approaches to pollution prevention
in material receiving, raw material and product storage, laboratories, and maintenance areas are shown
in Table 2. Information in these two tables can apply to a wide range of industries. Industry-specific
checklists for five example industries are presented in Tables 3 through 7. See Appendix G for a list
of publications that provide industry-specific information related to pollution prevention. The tables
contained within this appendix are as follows:
Table 1. Pollution Prevention Through Good Operating Practices
Table 2. Checklist for All Industries
Table 3. Checklist for the Printing Industry
Table 4. Checklist for the Fabricated Metal Industry
Table 5. Checklist for the Metal Casting Industry
Table 6. Checklist for the Printed Circuit Board Industry
Table 7. Checklist for the Coating Industry
83
-------
Table 1. Pollution Prevention Through Good Operating Practices
Good Operating Practice
Program Ingredients
Waste Segregation
Preventive Maintenance
Programs
Training/Awareness-
Building Programs
Effective Supervision
Employee Participation
Prevent mixing of hazardous wastes with nonhazardous wastes
Store materials in compatible groups
Segregate different solvents
Isolate liquid wastes from solid wastes
Maintain equipment history cards on equipment location, characteris-
tics, and maintenance
Maintain a master preventive maintenance (PM) schedule
Keep vendor maintenance manuals handy
Maintain a manual or computerized repair history file
Provide training for
- Operation of the equipment to minimize energy use and material
waste
- Proper materials handling to reduce waste and spills
- Emphasize importance of pollution prevention by explaining the
economic and environmental ramifications of hazardous waste
generation and disposal
- Detecting and minimizing material loss to air, land, or water
- Emergency procedures to minimize lost materials during acci-
dents
Closer supervision may improve production efficiency and reduce
inadvertent waste generation
Centralize waste management. Appoint a safety/waste management
officer for each department. Educate staff on the benefits of pollution
prevention. Establish pollution prevention goals. Perform pollution
prevention assessments.
"Quality circles" (free forums between employees and supervisors) can
identify ways to reduce waste
Solicit and reward employee suggestions for waste reduction ideas
84
Appendix B
-------
Table 1. (Continued)
Good Operating Practice Program Ingredients
Production Scheduling/Plan- Maximize batch size to reduce clean out waste
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency (light-to-dark
batch sequence, for example)
Cost accounting/ Charge direct and indirect costs of all air, land, and water discharges to
Allocation specific processes or products
Allocate waste treatment and disposal costs to the operations that
generate the waste
Allocate utility costs to specific processes or products
Industry-Specific Checklists 85
-------
Table 2. Checklist for All Industries
Waste Origin/Type
Pollution Prevention and Recycling Methods
Material Receiving/
Packaging materials, off-spec materi-
als, damaged container, inadvertent
spills, transfer hose emptying
Raw Material and Product Storage/
Tank bottoms; off-spec and excess
materials; spill residues; leaking
pumps, valves, tanks, and pipes; dam-
aged containers; empty containers
Use "Just-in-Time" ordering system.
Establish a centralized purchasing program.
Select quantity and package type to minimize packing
waste.
Order reagent chemicals in exact amounts.
Encourage chemical suppliers to become responsible
partners (e.g., accept outdated supplies).
Establish an inventory control program to trace
chemical from cradle to grave.
Rotate chemical stock.
Develop a running inventory of unused chemicals for
other departments' use.
Inspect material before accepting a shipment.
Review material procurement specifications.
Validate shelf-life expiration dates.
Test effectiveness of outdated material.
Eliminate shelf-life requirements for stable compounds.
Conduct frequent inventory checks.
Use computer-assisted plant inventory system.
Conduct periodic materials tracking.
Properly label all containers.
Set up staffed control points to dispense chemicals
and collect wastes.
Buy pure feeds.
Find less critical uses for off-spec material (that
would otherwise be disposed).
Change to reusable shipping containers.
Switch to less hazardous raw material.
Use rinsable/recyclable drums.
Establish Spill Prevention, Control, and Countermeasures
(SPCC) plans.
Use properly designed tanks and vessels only for their
intended purposes.
Install overflow alarms for all tanks and vessels.
Maintain physical integrity of all tanks and vessels.
Set up written procedures for all loading/unloading
and transfer operations.
Install secondary containment areas.
Instruct operators to not bypass interlocks, alarms, or
significantly alter setpoints without authorization.
Isolate equipment or process lines that leak or are not
in service.
Use sealless pumps.
86
Appendix B
-------
Table 2. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Raw Material and Product Storage/
(Continued)
Laboratories/
Reagents, off-spec chemicals, samples,
empty sample and chemical containers
Use bellows-seal valves.
Document all spillage.
Perform overall materials balances and estimate the
quantity and dollar value of all losses.
Use floating-roof tanks for VOC control.
Use conservation vents on fixed roof tanks.
Use vapor recovery systems.
Store containers in such a way as to allow for visual
inspection for corrosion and leaks.
Stack containers in a way to minimize the chance of
tipping, puncturing, or breaking.
Prevent concrete "sweating" by raising the drum off
storage pads.
Maintain Material Safety Data Sheets to ensure correct
handling of spills.
Provide adequate lighting in the storage area.
Maintain a clean, even surface in transportation areas.
Keep aisles clear of obstruction.
Maintain distance between incompatible chemicals.
Maintain distance between different types of chemicals to
prevent cross-contamination.
Avoid stacking containers against process equipment.
Follow manufacturers' suggestions on the storage and
handling of all raw materials.
Use proper insulation of electric circuitry and inspect
regularly for corrosion and potential sparking.
Use large containers for bulk storage whenever possible.
Use containers with height-to-diameter ratio equal to one
to minimize wetted area.
Empty drums and containers thoroughly before cleaning
or disposal.
Reuse scrap paper for note pads; recycle paper.
Use micro or semi-micro analytical techniques.
Increase use of instrumentation.
Reduce or eliminate the use of highly toxic chemicals in
laboratory experiments.
Reuse/recycle spent solvents.
Recover metal from catalyst.
Industry-Specific Checklists
87
-------
Table 2. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Laboratories (Continued)
Operation and Process Changes
Solvents, cleaning agents, degreasing
sludges, sandblasting waste, caustic,
scrap metal, oils, greases from equip-
ment cleaning
Operation and Process Changes
Sludge and spent acid from heat ex-
changer cleaning
Treat or destroy hazardous waste products as the last
step in experiments.
Keep individual hazardous waste streams segregated,
segregate hazardous waste from nonhazardous waste,
segregate recyclable waste from non-recyclable waste.
Assure that the identity of all chemicals and wastes is
clearly marked on all containers.
Investigate mercury recovery and recycling.
Maximize dedication of process equipment.
Use squeegees to recover residual fluid on product
prior to rinsing.
Use closed storage and transfer systems.
Provide sufficient drain time for liquids.
Line equipment to reduce fluid holdup.
Use cleaning system that avoid or minimize solvents
and clean only when needed.
Use countercurrent rinsing.
Use clean-in-place systems.
Clean equipment immediately after use.
Reuse cleanup solvent.
Reprocess cleanup solvent into useful products.
Segregate wastes by solvent type.
Standardize solvent usage.
Reclaim solvent by distillation.
Schedule production to lower cleaning frequency.
Use mechanical wipers on mixing tanks.
Use bypass control or pumped recycle to maintain
turbulence during turndown.
Use smooth heat exchange surfaces.
Use on-stream cleaning techniques.
Use high pressure water cleaning to replace chemical
cleaning where possible.
Use lower pressure steam.
Appendix B
-------
Table 3. Checklist for the Printing Industry
Waste Origin/Type
Pollution Prevention and Recycling Method
Image Processing/Empty containers,
used film packages, outdated material
Image Processing/
Photographic chemicals, silver
Plate Making/Damaged plates, developed film,
outdated materials
Plate Making/
Acids, alkali, solvents, plate coatings (may
contain dyes, photopolymers, binders, resins,
pigment, organic acids), developers (may
contain isopropanol, gum arabic, lacquers,
caustics), and rinse water
Finishing/Damaged products, scrap
Printing/
Lubricating oils, waste ink, cleanup solvent
(halogenated and nonhalogenated), rags
Recycle empty containers.
Recycle spoiled photographic film.
Use silver-free films, such as vesicular, diazo,
or electrostatic types..
Use water-developed litho plates.
Extend bath life.
Use squeegees to reduce carryover.
Employ countercurrent washing.
Recover silver and recycle chemicals.
Use electronic imaging, laser plate making.
Electronic imaging/laser print making.
Recover silver and recycle chemicals.
Use floating lids on bleach and developer
tanks.
Use countercurrent washing sequence.
Use squeegees to reduce carryover.
Substitute iron-EDTA for ferrocyanide.
Use washless processing systems.
Use better operating practices.
Remove heavy metals from wastewater.
Reduce paper use and recycle waste paper.
Prepare only the quantity of ink needed for a
press run.
Recycle waste ink and solvent.
Schedule runs to reduce color change over.
Use automatic cleaning equipment.
Use automatic ink leveler.
Use alternative solvents.
Use water-based ink.
Use UV-curable ink.
Install web break detectors.
Use automatic web splicers.
Store ink properly.
Standardize ink sequence.
Recycle waste ink.
Industry-Specific Checklists
89
-------
Table 3. (Continued)
Waste Origin/Type Pollution Prevention and Recycling Method
Printing/ Install web break detectors.
Test production, bad printings, empty ink Monitor press performance.
containers, used blankets. Use better operating practices.
Printing/ (Continued) Use alternative fountain solutions.
Use alternative cleaning solvents.
Use automatic blanket cleaners.
Improve cleaning efficiency.
Collect and reuse solvent.
Recycle lube oils.
Finishing/ Reduce paper use.
Paper waste from damaged product Recycle waste paper.
90 Appendix B
-------
Table 4. Checklist for the Fabricated Metal Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Machining Wastes/
Metalworking Fluid
Machining Wastes/
Metal wastes, dust, and sludge
Parts Cleaning/
Solvents
Parts Cleaning/
Aqueous Cleaners
Parts Cleaning/
Abrasives
Parts Cleaning/
Rinsewater
Use of high-quality metalworking fluid.
Use demineralized water makeup.
Perform regularly scheduled sump and machine cleaning.
Perform regularly scheduled gasket, wiper, and seal
maintenance.
Filter, pasteurize, and treat metalworking fluid for reuse.
Assigning fluid control responsibility to one person.
Standardize oil types used on machining equipment.
Improve equipment scheduling/establish dedicated lines.
Reuse or recycle cutting, cooling, and lubricating oils.
Substitute insoluble borates for soluble borate lubricants.
Segregate and reuse scrap metal.
Install lids/silhouettes on tanks.
Increase freeboard space on tanks.
Install freeboard chillers on tanks.
Remove sludge from solvent tanks frequently.
Extend solvent life by precleaning parts by wiping, using
air blowers, or predipping in cold mineral spirits dip.
Reclaim/recover solvent on- or off-site.
Substitute less hazardous solvent degreasers (e.g.,
petroleum solvents instead of chlorinated solvents) or
alkali washes where possible.
Distribute parts on rack to allow good cleaning and
minimize solvent holup.
Slow speed of parts removal from vapor zone.
Rotate parts to allow condensed solvent drop-off.
Remove sludge frequently.
Use dry cleaning and stripping methods.
Use oil separation and filtration to recycle solution.
Use of greaseless or water-based binders.
Use an automatic liquid spray system for application of
abrasive onto wheel.
Ensure sufficient water use during cleaning by using
water level control.
Use synthetic abrasives.
Improve rack and barrel system design.
Use spray, fog, or chemical rinses.
Use deionized water makeup to increase solution life.
Industry-Specific Checklists
91
-------
Table 4. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Surface Treatment and Plating/
Process Solutions
Surface Treatment and Plating/
Rinsewater
Use material or process substitution e.g., trivalent
chromium.
Use low solvent paint for coating.
Use mechanical cladding and coating,
Use cleaning baths as pH adjusters.
Recover metals from process solutions.
Reduction in drag-out of process chemicals:
Reduce speed of withdrawal
Lower plating bath concentrations
Reuse rinsewater
Use surfactants to improve drainage
Increase solution temperature to reduce viscosity
Position workpiece to minimize solution holdup
System design considerations:
Rinsetank design
Multiple rinsing tanks
Conductivity measurement to control rinse water flow
Fog nozzles and sprays
Automatic flow controls
Rinse bath agitation
Counter current rinse.
92
Appendix B
-------
Table S. Checklist for the Metal Casting Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Baghouse Dust and Scrubber Waste/
Dust contaminated with lead, zinc,
and cadmium
Production of Ductile Iron/
Hazardous slag
Casting/
Spent casting sand
Identify the source of contaminants, e.g., coatings on
scrap, and work with suppliers to find raw materials that
reduce the contaminant input.
Install induction furnaces to reduce dust production.
Recycle dust to original process or to another process.
Recover contaminants with pyrometallurgical treatment,
rotary kiln, hydrogen reduction, or other processes.
Recycle to cement manufacturer.
Reduce the amount of sulfur in the feedstock.
Use calcium oxide or calcium fluoride to replace
calcium carbide as the desulfurization agent.
Improve process control.
Recycle calcium carbide slag.
Material substitution, e.g., olivine sand is more difficult
to detoxify than silica sand.
Separate sand and shot blast dust,
Improve metal recovery from sand.
Recover sand and mix old and new sand for mold
making.
Recover sand by washing, air scrubbing, or thermal
treatment.
Reuse sand for construction if possible.
Industry-Specific Checklists
93
-------
Table 6. Checklist for the Printed Circuit Board Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
PC Board Manufacture/
General
Cleaning and Surface Preparation/
Solvents
Pattern Printing and Masking/
Acid fumes/organic vapors; vinyl poly-
mers spent resist removal solution; spent
acid solution; waste rinse water
Electroplating and Electroless Plating/
Plating solutions and rinse wastes
Product substitution:
Surface mount technology
Injection molded substrate and additive plating
Materials substitution:
Use abrasives
Use nonchelated cleaners
Increase efficiency of process:
Extend bath life, improve rinse efficiency, countercur-
rent cleaning
Recycle/reuse:
Recycle/reuse cleaners and rinses
Reduce hazardous nature of process:
Aqueous processable resist
Screen printing versus photolithography
Dry photoresist removal
Recycle/reuse:
Recycle/reuse photoresist stripper
Eliminate process:
Mechanical board production
Materials substitution:
Noncyanide baths
Noncyanide stress relievers
Extend bath life; reduce drag-in:
Proper rack design/maintenance, better precleaning/
rinsing, use of demineralized water as makeup, proper
storage methods
Extend bath life; reduce drag-out:
Minimize bath chemical concentration, increase bath
temperature, use wetting agents, proper positioning on
rack, slow withdrawal and sample drainage, comput-
erized/automated systems, recover drag-out, use
airstreams or fog to rinse plating solution into the
tank, collect drips with drain boards,
Extend bath life; maintain bath solution quality:
Monitor solution activity
Control temperature
Mechanical agitation
Continuous filtration/carbon treatment
Impurity removal
Improve rinse efficiency:
Closed-circuit rinses
Spray rinses
Fog nozzles
94
Appendix B
-------
Table 6. (Continued)
Waste Origin/Type
Pollution Prevention and Recycling Methods
Electroplating and Electroless Plating/
(Continued)
Etching/
Etching solutions and rinse wastes
Improve rinse efficiency (continued):
Increased agitation
Countercurrent rinsing
Proper equipment design/operation
Deionized water use.
Turn off rinsewater when not in use.
Recovery/reuse:
Segregate streams
Recover metal values.
Eliminate process:
Differential plating
Use dry plasma etching.
Materials substitution:
Nonchelated etchants
Nonchrome etchants.
Increased efficiency:
Use thinner copper cladding
Pattern vs. panel plating
Additive vs. subtractive method.
Reuse/recycle:
Reuse/recycle etchants.
Industry-Specific Checklists
95
-------
Table 7. Checklist for the Coating Industry
Waste Origin/Type
Pollution Prevention and Recycling Methods
Coating Overspray/
Coating material that fails to
reach the object being coated
Stripping Wastes/
Coating removal from parts
before applying a new coat
Solvent Emissions/
Evaporative losses from process
equipment and coated parts
Equipment Cleanup Wastes/
Process equipment cleaning with
solvents
Source Reduction
Maintain 50% overlap between spray pattern.
Maintain 6- to 8-inch distance between spray gun and the
workpiece.
Maintain a gun speed of about 250 feet/minute.
Hold gun perpendicular to the surface.
Trigger gun at the beginning and end of each pass.
Properly train operators.
Use robots for spraying.
Avoid excessive air pressure for coating atomization.
Recycle overspray.
Use electrostatic spray systems.
Use turbine disk or bell or air-assisted airless spray guns in
place of air-spray guns.
Install on-site paint mixers to control material usage.
Inspect parts before coating.
Avoid adding excess stripper.
Use spent stripper as rough prestrip on next item.
Use abrasive media paint stripping.
Use plastic media bead-blasting paint stripping.
Use cryogenic paint stripping.
Use thermal paint stripping.
Use wheat starch media blasting paint stripping.
Use laser or flashlamp paint stripping.
Keep solvent soak tanks away from heat sources.
Use high-solids coating formulations.
Use powder coatings.
Use water-based coating formulations.
Use UV cured coaling formulations.
Use light-to-dark batch sequencing.
Produce large batches of similarly coated objects instead
of small batches of differently coated items.
Isolate solvent-based paint spray booths from water-based
paint spray booths.
Reuse cleaning solution/solvent.
Standardize solvent usage.
Clean coating equipment after each use.
Reexamine the need for coating, as well as available
alternatives.
Use longer lasting plastic coatings instead of paint.
96
Appendix B
-------
APPENDIX C
CUSTOMIZED POLLUTION
PREVENTION WORKSHEETS
The worksheets in this appendix were
taken from the manual Guides to Pollution
Prevention: The Pharmaceutical Industry (see
Appendix G). These worksheets illustrate how
personnel at a plant might customize the Pollu-
tion Prevention Worksheets in Appendix A to
fit a specific industry or facility. For a full de-
scription of waste minimization assessment
procedures, refer to the text of this manual.
Case Study -
Example Pollution Prevention
Opportunity Detailed Assessment
This study illustrates a pollution prevention
assessment done by a small pharmaceutical
company. This example is based on actual
experience but uses fictitious names, processes,
and data. The case study uses industry-specific
worksheets and covers detailed assessment
activities from forming an assessment team
through screening options.
The ABC Pharmaceutical Company, Inc.,
is a small production facility. Its main product
is a low-volume, high-value-added protein
solution product. ABC also manufactures a
high-volume, low-value-added saline solution
product. The growing cost of waste disposal
and the small margin of profit on the saline
solution product led management to institute a
pollution prevention program.
A pollution prevention task force was
assembled. It consisted of:
A process engineer
A product engineer
A process area supervisor
An environmental compliance
specialist
The process engineer was the team leader and
the corporate pollution prevention champion.
The team met and established the following
goals:
• Achieve a significant reduction in the
generation of hazardous wastes.
Identify data sources and deficiencies
and work toward developing reliable
means of measuring reductions.
Maintain product quality.
Maintain or improve profit margin of
saline solution in light of increasing
waste disposal costs.
The task force assembled as much data as
possible on those operations that use toxic
chemicals or generate hazardous waste. This
included preparing block diagrams of several
key processes. They found that, aside from
purchase and shipping records and regulatory
reports of releases, there were few records on
hazardous materials. They were unable to pre-
pare complete mass balances for any of the key
processes but were able to identify the major
waste streams. The mass balances also identi-
fied additional data that would increase under-
standing of the process operation without ex-
tensive new data collection.
The data gathering focused on waste sour-
ces, material-handling practices, input materi-
als, and products. The effort started with these
inputs because they were the areas most likely
to yield pollution prevention opportunities and
because they had the most available data. The
major data sources were purchasing records,
waste shipment manifests, material safety data
sheets, product specifications, Superfund A-
mendment and Reauthorization Act (SARA)
reports, and conversations with the production
area workers.
The team also prepared a description of the
key processes in the plant (aqueous cleaning,
disinfecting, venting, general housekeeping,
chemical synthesis, and research and develop-
97
-------
ment). They then described and prioritized the
waste streams.
After collecting and reviewing the plant
data, the team held a brainstorming session to
generate pollution prevention options. Several
pollution prevention options were identified
and selected for future feasibility study and
possible implementation.
Worksheet Titles
Worksheet 1. Waste Sources
Worksheet 2. Waste Minimization:
Material Handling
(2a, 2b, and 2c)
Worksheet 3. Input Materials Summary
Worksheet 4. Products Summary
Worksheet 5. Option Generation:
Material Handling
Worksheet 6. Process Description
(6a, 6b, 6c, 6d, and 6e)
Worksheet 7a. Waste Stream Summary
Worksheet 7b. Waste Description
Worksheet 8. Waste Minimization:
Reuse and Recovery
Worksheet 9. Option Generation:
Process Operation
Worksheet 10. Waste Minimization:
Good Operating Practices
Worksheet 11. Waste Minimization:
Good Operating Practices
93 Appendix C
-------
Arp s /"/--c>O> Pollution Prevention <~~xx- 1
e>< — C_-i-^-=-\ AMBfunufnt wOrif.sh««t« PreoaredBv —*--="_.
Site ^-^^ AtOGE: L3.S Checked Bv V^^P
Date V'.'.ŁM-<-Ł'K i l^S'- Proi. No, I Sheet i of ^ Pace ^ of ^
WORKSHEET WASTE SOURCES
c
Off-spec materials
Obsolete raw materials
Obsolete products
Spills and leaks (liquids)
Spills (powders)
Empty container cleaning
Container disposal (metal)
Container disposal (paper, plastic)
Pipeline/tank drainage
Laboratory wastes
Evaporative losses
Other
Waste Source: Process Operations
Tank cleaning
Container cleaning
Blender cleaning
Process equipment cleaning
Significance at Plant
Low
X
*
y
*
y
X
Medium
y.
/
/
*
High
X
XT
X
X
X
Customized Pollution Prevention Worksheets
99
-------
Firm -^=-
Site .
Date
; <•"*•
Pollution Prevention
Assessment Worksheets
Proi. No.
Prepared By
Checked By \ g :
Sheet 1 of L Page 2-_ of
WORKSHEET
2a
WASTE MINIMIZATION:
Material Handling
A. GENERAL HANDLING TECHNIQUES
Are all raw materials tested for quality before being accepted from suppliers?
Describe safeguards to prevent the use of materials that may generate off-spec product:
0Y
Yes Q No
Is obsolete raw material returned to the supplier?
Is inventory used in first-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
What information does the system track? T-^Z^X^^-'^T/ W\t\ !fc-?"'•«-•.L. I
4-
Is there a forma! personnel training program on raw material handling, spill prevention,
proper storage techniques, and waste handling procedures?
Does the program include information on the sate handling of the types of drums,
containers and packages received?
How often is training given and by whom?
Is dust generated in the storage area during the handling of raw materials?
If yes, is there a dedicated dust recovery system in place?
Are methods employed to suppress dust or capture and recycle dust?
Explain: j_
DYes QNo
HVes D No
D Yes 0^Jo
CfYes D No
DYes ffNo
D Yes D No
DYes
D Yes D No
D Yes D No
100
Appendix C
-------
Firm k 5=^ C-O G'^-'
Site *-ŁŁ• »— .'^^-jj-'JE-^
Date K'A2ŁJ- , H<^I
WORKSHEET
2b
Pollution Prevention T~V" I
&t*«f*m^nt Worksheets Prepared By *Łs3. ±r
Checked Bv *^E" \*^
Proi. No. ' Sheet 1 of ' Paae 2? of \^
WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the transfer and filling of
storage and blending tanks?
High level shutdown/alarms D Secondary containment &
Flow totalizers with cutoff D Other D
Describe the svstem: OkŁ)ET2.Ł* t>CU*J>> *'/ \ '/X*. f- f2iŁ ko^A."^ ~r-> l ^
f^ 4**^ i. "\ x*" f"~*'t f*~— •«') '-/""" _ . .^ *r**x* , A " _, , •r" _*»- r _ ^-i - . ( ~ ., •""'?""" * i i ,/•* ^ A r~"j> /" XiiC r^-1"' ~( * 'fc ~
^~ C~~s ps™J t=ir- \ w— fc^»- \ r~" n^ _^ I «—.j T™\ "**^JK^ ' f' **T7 W- »-"'*•• " I «••• ( ' «•— ~"~* F"""*i<*^ \~ ^~~* L. * \, vi >-* '" _/
^(YH iBe^rc'NX'S
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents D Absorber/Condenser D Adsorber D
Nitrogen Blanketing Q Other vapor loss control system D
Describe the svstem: rO C" *^\'~
FA<±.TO(2L[i°(^_ K^ET^.^ ,
What measures are emploved to prevent the spillage of liquids being dispensed? EHAOljdySc^
Tr2^M' «O ! rO <9r-
Are pipes cleaned regularly? Also discuss the way pipes are cleaned and how the resulting waste is handled:
When a spill of liquid occurs in the p
the way in which the resulting wasti
lant, what cleanup methods are employed (e.g., wet or dry)? Also discuss
js are handled: l^'GrT" s*-*5 E^TV ^"O IpofZ Lt\%3~ T -^p! LL'^5*
S>FV M FTffoT) JffcK. $S' / ». IL 6D/LLS -Tfi 1>JQ,^ TX *T^?.C|4-
Would different cleaning methods allow for direct reuse or recycling of the waste? (explain) ificUSfc K)* i
fVLI Ł> Uj gT> pE^Z_'^^^^p
^^tUfv't* -R?O 6f.'^LL--?0(2. fe^V^^^fO^U
*
Customized Pollution Prevention Worksheets
101
-------
f\'C2/' /^~f~~\r? f— ^ Pollution Prevention v— v
Firm -r-At-^4 — l—i H — . Assessment Worksheets Preoared By ^
Site L-O^p /XVOdsG'LE^' Checked Bv ^E
Date l\'k{^lil . IQ9 1 Proi. No. ^ Sheet 1 of i
WORKSHEET WASTE MINIMIZATION:
2C Material Handling
C. DRUMS, CONTAINERS. AND PACKAGES
Are drums, containers, and packages inspected for damage before being accepted?
Are employees trained in ways to safely handle the types of drums and packages received?
Are they properly trained in handling of spilled materials?
Are stored items protected from damage, contamination, or exposure to rain, snow,
sun and heat?
Describe handling procedures for damaaed items: WL&Łt ' 0 (-Ł\&Ł*c pL/^"
&ETT^n2.rO T^ T5 <Ł,Ttf-<.&OToi2-
Does the layout of the plant result in heavy traffic through the raw material storage area?
(Heavy traffic increases the potential for contaminating raw materials with dirt or dust and
for causing spilled materials to become dispersed throughout the facility.)
Can traffic through the storage area be reduced? A///^
To reduce the generation of empty bags and packages, dust from dry material handling
and liquid wastes due to cleaning empty drums, has the plant attempted to:
Purchase hazardous materials in preweighed containers to avoid the
need for weighing?
Use reusable/recyclable drums with liners instead of paper bags?
Use larger containers or bulk delivery systems that can be returned to
supplier for cleaning?
Dedicate systems in the loading area so as to segregate hazardous
from nonhazardous wastes?
Recycle the cleaning waste into a product?
Describe the results of these attempts: 1><2_uM''b> I/O ! TH, L 1 fO (=^<~> C
Are all empty bags, packages, and containers that contained hazardous materials segregated
contain nonhazardous wastes? Describe the method currently used to dispose of this waste
^-4A^ A(2^D*^<-*> yj^>C^\^=c» <^-feO^i^AT&^> ©Y' 'PLAN
<-!_
rp
Page ^
BTes
0Yes
CkYes
G'Yes
n^. Bv
DYes
DYes
DYes
B^s
DYes
QTes
DYes
:>.'<,
OfJ^
DNO
DNO
DNO
DNo
^=r)
/
Bl^o
DNo
Q'No
DNO
DNO
[jNo
from those that
^T.LAB
(
\A^\2Zt\(2-S>C2>OS> Uu-A^bsTtE?-, (DuT" ik) U-Af3> rŁ>Ł- -AfOI>
^fe^vVo^CETT^ 'f^-C^t^ 3— ŁvO L V^TI
102
Appendix C
-------
Firm /v^c. ^oret> J,
Sjte LC^ fVOSCT LE^
Dilution Prevention
essment Worksheets
i ' •' ' t x /• t ' \ /^ d l l
Date 1 ^T-VT-Cr- , Y-? ^ \ Proi. No. i
Preoared Bv T)^ L
Oz=O
Checked Bv i-^crj^
Sheet I of ! Paae ^ of \E>
WORKSHEET |NPUT MATERIALS SUMMARY
3. ,
Attribute
Material Name/ID
Source/Supplier
Hazardous Component
Annual Consumption Rate
Purchase Price, $ per
Overall Annual Cost
Material Flow Diagram available {Y/N)
Delivery Mode'
Shipping Container Size and Type2
Storage Mode3
Transfer Mode4
Control Mode5
Empty Container Disposal Management8
Shelf Life
Supplier Would
— accept expired material? (Y/N)
— accept shipping containers? (Y/N)
— revise expiration date? (Y/N)
Acceptable Substitute^!, if any
Alternate Supplier(s)
Description
Stream No. '
^0l'"J^(>tOiYjŁ,f
rrr o/^rfL
JO/A
^c,eec ^q
**l^a
^2^C,teo
\o
TE'u^l^
"ZŁ~L-B peofA
U3t-r?riACOs€
j4.MJE>*n2uŁ4i-
4>!60J euT"
Łev4P4L^'#-fa
•2.^(2-
y
/
V Ł&ic
IOŁloE'
-6eV5EA.u
Stream No. !
^nn'2-(w?i^
f.Vor tWils^^
IC/A
\ peeper U
•f4-/L-
•T3-^-, OŁC^ .^O'dD
V
pip&LtvoC"
'JO/A-
KJ A
P^C.' Ł"
^'Ot'L.TT) t,tU
- r^/A
0//V
\0 A
rC' A-
*J|A
^ocu^
Stream No.
Notes: 1. e.g., pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g., 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g., outdoor, warehouse, underground, aboveground, etc.
4. e.g., pump, forklift, pneumatic transport, conveyor, etc.
5. e.g., on-demand to alt, select people only, sign out.
6. e.g., crush and landfill, clean and recycle, return to supplier, etc.
Customized Pollution Prevention Worksheets
103
-------
A. GS/' s~s~\c?~ t> ^
Firm /^.t>c-- c-ov^.1— '_ AM
site u^ A,G^eu&-'S
Dilution Prevention
essment Worksheets
Date t'- '^-(^Ł1 fv i iGA-l Prol, No. 1
Prepared Bv ^J^3 ' — -
Checked Bv \^G\~">
Sheet 1 of I Paoe & of l"%
WORKSHEET PRODUCTS SUMMARY
4__ _____ ,„„,
Attribute
Name/ID
Hazardous Component
Annual Production Rate
Annual Revenues, $
Shipping Mode
Shipping Container Size and Type
On-site Storage Mode
Containers Returnable (Y/N)
Shelf Life
Re-work Possible (Y/N)
Customer would:
— Relax specification (Y/N)
— Accept larger containers {Y/N!
Description
Stream No. _j
4A.UK315 ^cuTiO;,
.
sOOOfOr:0 C_
•*Ł<ŁŁ• Mv>U-l to K->
-TTE'OC.kC-.
^fr?t^^cx
uJKeewcos^
O
\ ^e^e_
V
K)
K.
r™">
Stream No. ^i—
H^'f'eiO *;72 JJ"^
- —
Si;^(^
^-.sii-'o-* \-%^. ©.ONC
S'vr^'v i'
ioLb ^Tae^f
o
fc r\A'.^^
to
lO
^
Stream No,
104
Appendix C
-------
K*C2 /" /" /- F*-n> Pollution Preventic
Firm., t-^rzx— C — •(-> « — f . _^ AVI#* »m»"t Wo'k«h
Site UC---S \-^C&\JEŁ*>
Date A.V'-^-C^ s ;Q^! Proj.No, *
>n
aets Pr
a
st
eoared Bv 1^=" L —
lecked Bv wEr-'*
icet » of ' Pane "7 of W»
WORKSHEET OPTION GENERATION:
5 Material Handling
Meeting Format (e.g., brainstorming, nominal group technique)
Meetina Coordinator !P?U^>
\
Suggested Waste Minimization Options
A, General Handling Techniques
Quality Control Check
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Spilled Material Reuse
Cleanup Methods to Promote Recycling
C. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Preweighed Containers
Soluble Bags
Reusable Drums
Bulk Delivery
Waste Segregation
Reformulate Cleaning Waste
Currently
Dons Y/N?
y
y
/
N)
KJ
y
to
y
M
W
M
lO
V
•/
o
M
V
K)
KJ
NJ
Rationale/Remarks on Option
•C2ŁLdJ,<^_ Ax/OD CcyJ^Gp^-ljET
UoT ^c^Tgrprtjr-r.vC
To e^nv/CCS: U)^T/pfeloT:r
u^1^ i WTŁ> n-u •*>
5st^A\ue 6i>iL.uTVpes
ueet^~rgjA)euSB- -it V/EI^ r/
Voo
•T^D ^3^ Ł.eU$(Def C&
^JKSS^^S^b u:.lsTr
Customized Pollution Prevention Worksheets
105
-------
Date
Pollution Prevention
; Worksheets
Proi. No,
Prepared By Ł%=s '—-
Checked By _
P'ET
Sheet I of L Paae _2L of
WORKSHEET
6a
PROCESS DESCRIPTION
1. GENERAL
Aqueous Cleaning
Type of
Aqueous Cleaner
Alkaline Sufactant
Alkaline Cleaner
Acid Cleaner
Acid Sanitizer
Other
Cleaning Procedure
(CIP. mpnyaj wash)
Hazardous or
Active fnaredient
How are spent cleaning solutions managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
If ves. exolain:
DNO
Dhlo
DYes B^o
0 Yes BNo
List waste streams generated by aqueous cleaning:
So/vent Cleaning
Type of
Solvent ysed
Cleaning Procedure
Hazardous or
Active Ingredient
Hovv are spent solutions managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
If yes. explain:
D Yes D No
D Yes D No
D Yes D No
D Yes D No
List waste streams generated by solvent cleaning:
106
Appendix C
-------
K. d /** /^~ r*< C^ T^> Pollution 1
Firm f^-^>C— <—isK-{ Aff«»pn»nt
Date ^ \A4i_-I.*--* , (O^ 1 Proi. No. '
WORKSHEET PROCESS D
^ I _____
6b
'revention r^^- /
Workfhflfits Prepared By ±^.'•—3 *-~~
Checked Bv r trr""^
Sheet ' of ' Paae 9 of \&
ESCR1PTION
1. GENERAL (continued)
Disinfecting/Sterilizing
Type of Disinfecting Procedure Hazardous or
Disinf^ptant ysed (Sorav, Wipetfown, etc.) Active Inaredient
^Sst-Utr" t M-t P LOV p^^lDo CO /^
o GUKT k M ',' c •: • & ', cMP^> c
How are spent disinfectants managed:
Biodegradable; disposed of in sewer
Treated on-site; disposed of in sewer
Transported off-site
Other
H yes, explain: t*X<— C^--^- >>ŁX— uJTlOK-J
Is ethylene oxide ysed for sterilization?
What type of pollution control equipment is used?
What is the percent (%) ethvlene oxide captured?
What is the percent (%} chlorofluorocarbon captured?
List waste streams generated by disinfecting/sterilizing
Venting
What large-volume liquid chemicals are stored on-site?
Are storaae tanks with breathing vents used?
Do process vessels release vapors?
What chemicals are released through vessel vents?
What type of pollution control equipment is in place?
What percent (%) of vent gases generated are capture
List waste streams generated bv venting: t^TjjH-J
HYes Q No
D Yes D No
D Yes D No
D Yes D No
D^*4^"t> To*l>fSsV,P
D Yes ffNo
: (?&iŁ»$>4><4c>u_iTtoi^ T^Z<-fAX>k.'LV C"iU-
Mse^ tov^erxttto^.
i G't-1
y'ss
f^TH-^^^ « '
k23ior5
•d? $
r
Customized Pollution Prevention Worksheets
107
-------
Firm
Site __
Date J^.
Pollution Prevention
Assessment'
Proj. No.
"" !
=" t-
Prepared By _
Checked By _
Sheet \ of I Page \p of \ o
WORKSHEET
6c
PROCESS DESCRIPTION
1. GENERAL (continued)
Disposables
List the disposable items used in manufacturing:
(3TŁ-
Off-Spec Materials
List the production raw materials that have been disposed of due to being out-dated or
List the products you manufacture that have beervdestroyed and disposed of due to being out-dated or off-
soec: -^KLffsJCT -^dL- u Yl&N--1
How are these items managed?
kj <
2. FERMENTATION
Fermenter Information
Description of fermenter:
Identification number:
| A*
Type of growth media used:
Size of sump:
Frequency of sump cleanout:
Does sump fluid go to waste treatment tank?
How often is fermenter inspected for the following:
Heat transfer fluid leakage:
Agitator seal fluid leakage:
Integrity of process connectors:
Integrity of sterile barriers:
What is the length of the fermentation cycle?
Process Information
How is culture removed from fermenter?
108
Appendix C
-------
Firm
Site
Pollution Prevention
Proj. No.
Prepared By j-^%'—_
Checked By _
Sheet [ of I Page Jj_ of j!c
WORKSHEET
6d
PROCESS DESCRIPTION
2, FERMENTATION (continued)
Where does it go?
How are cells removed?
Is used media sterilized?
If so. how:
Are media, cell debris, or vent gas waste streams hazardous?
If yes, list hazardous components:
How are contaminated fermentation batches handled?
What is the fermentation vield oercentage?
List the waste streams that are generated by fermentation:
3. CHEMICAL SYNTHESIS, NATURAL PRODUCT EXTRACTION, FORMULATION
Solvent-Based Processes
Operation
Annual Usage
How are spent solvents managed:
List waste streams generated by solvent-based processes:
Customized Pollution Prevention Worksheets
109
-------
Av r2x" /" /*- <—; T^> Pollution P
Firm P\^> U-O'Ui.l--' AMassmnnt
Site ' & j> r4 JCrstr ' — t -—-"*
Date '\ iAf2Cf4 i IOO \ Proi. No. I
WORKSHEET PROCESS D
f* —
6e
i
revention ~^~~^Ł— 1
Workfheflts Prepared Bv , -i--^- — ^ ' — •
Checked Bv W&^t—
Sheet 1 of 1 Pace \2- of ID
ESCR1PTION
3. CHEMICAL SYNTHESIS, NATURAL PRODUCT EXTRACTION. FORMULATION (continued)
Aqueous-Rased Processes
What types of water are used in your plant? /
Water for injection 03^es D No
Distilled water ETYes D No
Softened water Q Yes D No
Municipal water Bres D No
Reverse osmosis/Deionized water QYes D No
What aqueous process solutions are generated or used?
Aqueous Solution Type of Water Operation Annual Usage
^ŁDUJfv\ ŁML&E.itŁ: S/O'Pn. 1i-Ł>E.fVi_"'!_ATl'""s''v~) \ , oo^OoiO ' —
1 VA"2C--^ 1 — WB> OpJ=»?-^-r^« DNO
BTes D No
D Yes D No
D Yes D No
DYes DNo
D Yes D No
'OL.V/dUrŁO OVCs-5l^E- (F OUT Op" 6P€2l^'
List waste streams generated by aqueous-based proce
4, RESEARCH AND DEVELOPMENT
List disoosable items used in R&D orocesses: (VM
List other R&D wastes:
Process Type
S^iLTIZAT'lON^ iTiUrt^EL h
sses: -<$per»>>5r'U*HB>oE^t^.y' t?e^(Łv T^sA.S+4 /l>/MOt^(t-J -
CkciLfc^ lO^l*- ^AjfeStC" P/^PE1^ ! pLASTI|2.[ L/
\ /
110
Appendix C
-------
f\ C2,/" /*"" '/^C>*C> Pollut
Firm +-* ^*<— (— <— '«-— f^i _ Af-»?«i
Date ^NA^ExCUr , K^^ Proj. No.
on Prevention
nent Worksheets
Prepared Bv _L^S" >— -
Checked Bv PHP
Sheet _V_ of [
WORKSHEET WASTE STREAM SUMMARY
™» _____
7a
Waste ID/Name:
Source/Origirt
Annual Generation Rate jurats/year)
Hazardous Component Name
Annual Rate of Components) of Concern
Annual Cost of Disposal
Unit Cost {S/ )
Method of Management1
Relative3
Priority Rating Criteria2 Wt. (W)
Regulatory Compliance ^
Treatment/Disposal Cost 4
Potential Liability 7
Waste Quantity Generated (_&
Waste Hazard '"Z
Safety Hazard 3
Minimization Potential ^
Potential to Remove Bottleneck "Z
Potential By-product Recovery O
Sum of Priority Rating Scores
Priority Rank
Paae 13 of > 0
Description
Stream No. \
ŁietuiuckJ&$?H
f>>KjŁl Ł-.fc-JL>
Ł?2>U(pMC* \'2-
^ "Z^"
Q ^4
-z A
1 *5
*? 4o
^ 4
( O
KRxW) \<^7-
Z
Stream No. 2-
&Td'A \)i#cK-
-ertDEivSr"
"Tt^jvi \j&i,rs
I poo. 6/- L 1 9 e.
—
^ (0 _=><=>
-^ i /sSM_
Mf2-fMi^4i6M
Rating
(R) R x W
-3 72.
•^ 12*
5* BŁ
4 2^-
<^0 VZ.
1 3
-7 ^^
_2" A
\ o
I(RxW) j^7
1
Stream No. __5>
PbiS. . ! OV\O"€
vO-^^Stt
R_I_:A^!V^C>-
^f-'tT-'r-f-LC.
z^r^Lg/ VKL
. —
-~
^\O{CoeD
^6.^ /'— B.
^jv^ev1
U^Oli^ ( L i—
Rating
2.
1 2^<
Ł* "^ty"
t=> 3&>
"Z. <4
| 5,
(Ł <4-O
« 4
I O
I(RxW) 1 *$ ZZ~
•^
Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, etc.
2. Rate each stream in in each category on a scale from 0 (none) to 10 (high).
3. A very important criteria for your plant would receive a weight of 10; a relatively unimportant
criteria might be given a weight of 2 or 3.
Customized Pollution Prevention Worksheets
111
-------
Firm .
Site I
Date
Pollution Pravention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet _ of . .1 Page jjr of I *?
WORKSHEET
7b
WASTE DESCRIPTION
i.
2.
3.
5.
6.
Waste Stream Name/ID:
Process Unit/Operation
Stream #
'characteristics (attach additional sheet with composition data, as necessary)
Bgas Qliquid 0solid Q mixed phase
Density, Ib/cu, ft. High Heating Value, Btu/lb
Viscosity/Consistency
PH
flash point
leavas process as:
'air emission D waste water
D other
D solid waste
% water
D hazardous waste
Waste generation is;
D-^ontinuous U UŁ>Ug1
D discrete
.
^ U M.*V.
— _
M C D tC
fA Pi'
discharge triggered by: D chemical analysis
[Hther (describe) _
Type: D periodic
length of period:
D sporadic (irregular occurrence)
D non-recurrent
Generation Rate
Annual
Maximum
Average
Frequency
Batch Size
. 000
Average
JJB€per year
Ibs per year
Ibs per year
batches per
Range
Wasta Origins/Sources
(Fill out this worksheet to identify the origin of the waste. If the waste is a mixture of waste streams,
fill out a sheet for each of the individual wastes).
Is waste mixed with other wastes? D yes
Is waste segregation possible? D yes
If yes, what can be segregated from it?
If no, why not?
Input material source of this waste Łz
112
Appendix C
-------
Pollution Prevention
Assessment Worksheets
Proj. No.
Prepared By
Checked By
Sheet I of
_ of Page J_ of
WORKSHEET
8
WASTE MINIMIZATION:
Reuse and Recovery
A. SEGREGATION
Segregation of wastes reduces the amount of unknown material in waste and
improves prospects for reuse and recovery.
Are different solvent wastes from equipment cleanup segregated?
Are aqueous wastes from equipment cleanup segregated from solvent wastes?
Are spent alkaline solutions segregated from the rinse water streams?
If no, explain:
D Yes D No
D Yes D No
D Yes D No
B. ON-SITE RECOVERY
On-site recovery of solvents by distillation is economically feasible for as little as 8 gallons
of solvent waste per day.
Has on-site distillation of the spent solvent ever been attempted? D^Yes D No
If yes, is distillation still being performed? Ores D No
If no, explain:
DJfJo
C. CONSOLIDATION/REUSE
Are many different solvents used for cleaning? rj Yes
If too many small-volume solvent waste steams are generated to justify on-site
distillation, can the solvent used for equipment cleaning be standardized? D Yes D No
Is spent cleaning solvent reused? D Yes D No
Are there any attempts at making the rinse solvent part of a batch formulation (rework)? Q Yes D No
Are any attempts made to blend various waste streams to produce marketable products? Q Yes D No
Are spills collected and reworked? D Yes Q^No
Describe which measures have been successful:
Is your solvent waste segregated from other wastes?
Has off-site reuse of wastes through waste exchange services been considered?
Or reuse through commercial brokerage firms?
If yes, results:
D No
DYes
DYes
Customized Pollution Prevention Worksheets
113
-------
K'tI2./* /"/^jfT* C5*1 Pollution Preventk
Firm r-A^>" — i_t_^i__r A«,««nM^nt W^^h
Site U.9t> ^ 4^ETL.ET6>
> , ^ , "'" " ~ j
Date 1 V -rvfciŁ-T-V , \^-p- Proi. No. '
>n
eets Pf
a
sr
eoared BY \_^X:3v—
lecked iy S,-— "ti'
leet ' of » Paae (O of \
WORKSHEET OPTION GENERATION:
9 Process Operation
Meeting Format (e.g., brainstorming, nominal group technique)
B4^^ 1 ^^TO e r\\ ! fOO-
Meeting Participants "NlPTl ^ V^^rV-^ O^— ^ ) lu-2:^
Suggested Option*
A. Substitution/Reformulation Options
Solvent Substitution
Product Reformulation
Other Raw Material Substitution
B. Cleaning
Vapor Recovery
Tank Wipers
Pressure Washers
Reuse Cleaning Solutions
Spray Nozzles on Hoses
Mop and Squeegees
Reuse Rinsewater
Reuse Cleaning Solvent
Dedicated Equipment
Clean with Part of Batch
Segregate Wastes for Reuse
Currently
Done Y/N?
to
(O
/o
••*
(0
M
\j
V
V
^
y
»o
y
rO
lO
Rationale/Remarks on Option
/
/* UoT~"p CT^J B LŁ~
1
•To 4l\JI>V TUj^ VbŁ-FTD&
-Ł&z~ C\P oMuY
<^^^Vu6feS'iti|ilfelFet
114
Appendix C
-------
A^IS,/"" /"/""d t-"' Pollution Prevention
Firm /-»i--x— — — — _ Assessment Worksheets
Date Is !^2(-I-H ^ '*-QQ Proi. No.
WORKSHEET WASTE MINIMIZATION:
1 0 Good Operating Practice
Prepared By L- i-=y L—
Checked Bv \ fe i
Sheet 1 of I Paae ' / of > w
S
A. PRODUCTION SCHEDULING TECHNIQUES
Is the production schedule varied to decrease waste generation? (For example, do you attempt to increase
size of production runs and minimize cleaning by accumulating orders or production for inventory?)
Describe: M&5 - ^OiMETH^e*^ tETSUtpr/eiJT i 6 SlU-fet? CKJLV ClOtT L^.SV'ST"^
C3tr~i UU^i-ErrO ^^(_2N! ^, "TH&T" 1AJI L.I &o ""to c^rOE" Ł3Ł^Tt.1-\
Does the production schedule include sequential formulat ons that do not require cleaning between batches?
If yes, indicate results: "iStkr -tV fcs<^>- j fc
Are there any other attempts at eliminating cleanup steps between subsequent batches? If yes, results:
B. AVOID OFF-SPEC PRODUCTS
Is the batch formulation attempted in the lab before large scale production? B' es D No
Are laboratory QA/QC procedures performed on a regular basis? Q'Tes D No
C. OTHER OPERATING PRACTICES
Are plant material balances routinely performed? D Yes EpJo
Are they performed for each material of concern {e.g., solvent) separately? Q Yes UNO
Are records kept of individual wastes with their sources of origin and eventual disposal? D Yes Q'NO
(This can aid in pinpointing large waste streams and focusing reuse efforts.)
Are the operators provided with detailed operating manuals or instruction sets? B^Yes D No
Are all operator job functions well defined? a Yes D No
Are regularly scheduled training programs offered to operators? BYCS Q No
Are there employee incentive programs related to pollution prevention? Q Yes Brto"
Does the plant have an established pollution prevention program in place? D Yes B No
If yes, is a specific person assigned to oversee the success of the program? D Yes D No
Discuss aoals of the program and results:
Has a pollution prevention assessment been performed at this plant in
the past? If yes, discuss:
Customized Pollution Prevention Worksheets
115
-------
Firm f*~^» \^^ — ^••C-^ r - \^
Site L^-Ł. MJc^-^7 E~S
Date r'^Z^1 , \^ I
i
WORKSHEET
11
Meeting Format (e.g., brainstorming,
Meetina Coordinator OcS I—
Meetina Particioants l\ J-J-^Tj p
1
Pollution Prevention
D
Proi. No. ' Sf
soared Bv \~L^ '—
iccked Bv \ er 1
i ( ( o (O-
ieet \ of > Paae v 0 of ' ^
OPTION GENERATION:
Good Operating Practices
nominal group technique)
B>f^A tO-ŁT<3ŁtfWWG-
>Ł=P HT^i-TBes.JDLS
I '
Suggested Options
A. Production Scheduling Techniques
Increase Size of Production Run
Sequential Formulating
Avoid Unnecessary Cleaning
Maximize Equipment Dedication
B. Avoid Off -Spec Products
Test Batch Formulation in Lab
Regular QA/QC
C. Good Operating Practices
Perform Material Balances
Keep Records of Waste Sources
& Disposition
Waste/Materials Documentation
Provide Operating Manuals/Instructions
Employee Training
Increased Supervision
Provide Employee Incentives
Increase Plant Sanitation
Establish Pollution Prevention Policy
Set Goals for Source Reduction
Set Goals for Recycling
Conduct Annual Assessments
Currently
Done Y/N?
V
vf
Y
/
r
y
|0
Kj
tO
Y
V
v'
fO
NJ
\/
Y
iO
Y
Rationale/Remarks on Option
^cuLt^ Łc> U\E^St~(2l-
iLŁ^fj|)J^. ORiA-u.V ^ŁŁŁ'&t;&
eO6»^' To "x^cs T^ ^>
S^EOli'^^-i TCJ T>C3 T^4\ <>
P(ZDT>W T6 ^CiTW-lS
To ^,^ 6 o k}^ CDG^-^ii
Ł^6{2/pfeJ1K"TD ^D'TV-r-^
f^^/^feoDivi ^0 l^oTUi.Ca.
T-"c>^fA VM/A'rnETvfA
116
Appendix C
-------
APPENDIX D
TECHNICAL/FINANCIAL
ASSISTANCE PROGRAMS
There are a number of organizations that can
assist you in developing and maintaining a pollu-
tion prevention program. This appendix lists
offices of the U.S. EPA, state agencies, and
assistance programs.
U.S. ENVIRONMENTAL PROTECTION
AGENCY
Pollution Prevention Information
Clearinghouse
The PP1C is dedicated to reducing industrial
pollutants through technology transfer, education,
and public awareness. It provides technical,
policy, programmatic, legislative, and financial
information upon request.
The PPIC provides businesses and government
agencies with information to assist them in a
range of pollution prevention activities, such as:
• Establishing pollution prevention programs
• Learning about new technical options
arising from U.S. and foreign R&D
• Locating and ordering documents
• Identifying upcoming events
• Discovering grant and project funding
opportunities
• Identifying pertinent legislation
• Saving money by reducing waste
The PPIC disseminates this information
through a number of services. These include:
• a telephone hotline
• a repository of publications, reports, and
industry-specific fact sheets
• an electronic information exchange network
• indexed bibliographies and abstracts of re-
ports, publications, and case studies
• a calendar of conferences and seminars
• a directory of waste exchanges
• information packets and workshops.
The electronic network maintained by PPIC is
designated as PIES. It provides access to infor-
mation databases and can be used to place orders
for documents. The subsystems of PIES in-
clude:
• a message center
a publication reference database
a directory of experts
• case studies
a calendar of events
• program studies
legislation summaries
topical mini-exchanges.
This interactive system can deliver information
to the user through screen display, downloading,
and FAX. It is available to off-site computers
via modem 24 hours a day. For information on
linking to PIES, contact:
PEES Technical Assistance
Science Applications International Corp.
8400 Westpart Drive
McLean, VA 22102
(703)821-4800
The PPIC operates a telephone hotline for
questions and requests for information. The hot-
line provides users who cannot access PIES elec-
tronically with access to its information and ser-
vices.
For information on any of PPlC's services,
write to:
U.S. EPA Pollution Prevention Office
401 M Street S.W. (PM-219)
Washington, D.C. 20460
or call:
Myles E. Morse
Office of Environmental Engineering and
Technology Demonstration
(202)475-7161
or:
Prise ilia Flattery
Pollution Prevention Office
(202) 245-3557
117
-------
Other U.S. EPA offices that can provide pol-
lution prevention information include:
U.S. EPA Solid Waste Office
Waste Management Division
401 M Street SW
Washington, D.C. 20460
(703) 308-8402
U.S. EPA Office of Pollution Prevention and
Toxics
401 M Street SW
Washington, D.C. 20460
(202) 260-3810
U.S. EPA Office of Air and Radiation
401 M Street SW
Washington, D.C. 20460
(202) 260-7400
U.S. EPA Office of Water
401 M Street SW
Washington, D.C. 20460
(202) 260-5700
U.S. EPA Office of Research & Development
Center for Environmental Research Information
26 Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7562
U.S. EPA Risk Reduction Engineering Laboratory
26 Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7931
U.S. EPA Office of Solid Waste and
Emergency Response
[For questions regarding RCRA and Superfund
(CERCLA), call (800) 424-9346 or
(703) 920-9810. To reach the Analytical
Hotline, call (703) 821-4789.)
U.S. EPA Regional Offices:
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3420
Region 2 (NY, NJ, PR, VI)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA, DC)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MM, MI, IL, IN, OH)
230 South Dearborn Street
Chicago, EL 60604
(312) 353-2000
Region 6 (MM, OK, AR, LA, TX)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO, 1A)
726 Minnesota Ave
Kansas City, KS 66101
(913) 551-7050
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region 9 (CA, NV. AZ, HI. GU)
75 Hawthorne Street
San Francisco. CA 94105
(415) 744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-4973
STATE LEVEL
The following lists agencies at the state or terri-
tory level as well as universities and other orga-
nizations that can provide assistance in the areas
of pollution prevention and treatment:
Alabama
Department of Environmental Management
1751 Congressman W.L. Dickenson Drive
Montgomery, AL 36130
(205) 271-7939
118
Appendix D
-------
Environmental Institute for Waste Management
Studies
University of Alabama
Box 870203
Tuscaloosa, AL 35487-0203
(205) 348-8403
Hazardous Material Management and Resource
Recovery Program (HAMMAR)
University of Alabama
Tuscaloosa, AL 35487-0203
(205) 348-8401
FAX 348-9659
Retired Engineers Waste Reduction Program
P.O. Box 1010
Muscle Shoals, AL 35660
(205) 386-2807
Alaska
Alaska Health Project
Waste Reduction Assistance Program
1818 West Northern Lights, Suite 103
Anchorage, AK 99517
(907) 276-2864
Alaska Department of Environmental
Conservation
Pollution Prevention Program
P.O. Box O
Juneau, AK 99811-1800
(907) 465-2671
Arizona
Arizona Department of Economic Planning and
Development
1645 West Jefferson St.
Phoenix, AZ 85007
(602) 255-5705
Arizona Department of Environmental Quality
Office of Waste and Water Quality Management
2005 N. Central Ave, Room 304
Phoenix, AZ 85004
(602) 257-2380
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501)682-1121
Arkansas Department of Pollution Control
and Ecology
Hazardous Waste Division — P.O. Box 8913
Little Rock, AR 72219-8913
(501) 570-2861
California
Bay Area Hazardous Waste Reduction Committee
(BAHWRC)
City of Berkeley Environmental Health
2180 Milvia, Room 309
Berkeley, CA 94708
(415)644-6510
Cal-EPA
Department of Toxic Substances Control
Alternative Technology Division
P.O. Box 806
Sacramento, CA 95812-0806
(916)324-1807
California Conference of Directors of
Environmental Health — Subcommittee for
the Development of Hazardous Waste Programs
Ventura County Environmental Health
800 S. Victoria
Ventura, CA 93009
(805) 654-5039
California Environmental Business Resources
Assistance Center
100 South Anaheim Boulevard
Suite 125
Anaheim, CA 92805
(714) 563-0135
(800) 352-5225
Central Valley Hazardous Waste Minimization
Committee
Environmental Management Division
8475 Jackson Road, Suite 230
Sacramento, CA 95826
(916) 386-6160
Local Government Commission
909 12th Street
#205
Sacramento, CA 95814
(916)448-1198
Pollution Prevention Program
San Diego County Department of Health Services
P.O. Box 85261
San Diego, CA 92186-5261
(619) 338-2205, -2215
Technical/Financial Assistance Programs
119
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Colorado
Pollution Prevention Waste Reduction Program
Colorado Department of Health
4210 E. lllh Ave.
Denver, CO 80220
(303) 320-8333
Connecticut
Bureau of Waste Management
Connecticut Department of Environmental
Protection
18-20 Trinity Street
Hartford, CT 06106
(203) 566-8476
Connecticut Technical Assistance Program
900 Asylum Avenue, Suite 360
Hartford, CT 06105
(203)241-0777
Delaware
Pollution Prevention Program in Depl. of Natural
Resources & Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-3822
District of Columbia
U.S. Department of Energy
Conservation and Renewable Energy
Office of Industrial Technologies
Office of Waste Reduction,
Waste Material Management Division
Bruce Cranford CE-222
Washington D.C. 20585
(202) 586-9496
Office of Recycling
D.C. Department of Public Works
2000 14th Street, NW, 8th Floor
Washington, D.C. 20009
(202)939-7116
Florida
Hazardous Waste Reduction Management
Waste Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Environmental Quality Corporation
259 Timberlane Road
Tallahassee, FL 32312-1542
(904) 386-7740
Waste Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Georgia
Hazardous Waste Technical Assistance
Program
Georgia Institute of Technology
GTRI/ESTL
151 6th Street
O'Keefe Building, Room 143
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
205 Butler Street S.E. Room 1154
Atlanta, GA 30334
(404) 656-2833
Guam
Solid and Hazardous Waste Management Program
Guam EPA
IT&E Harmon Plaza Complex, Unit D-107
130 Rojas Street
Harmon, GU 96911
(671) 646-8863-5
Hawaii
Department of Planning and Economic Development
Financial Management and Assistance Branch
P.O. Box 2359
Honolulu, HI 96813
(808) 548-4617
Hawaii Department of Health
Solid and Hazardous Waste Branch
Waste Minimization
5 Waterfront Plaza, Suite 250
500 Ala Moana Blvd
Honolulu, ffl 96813
(808) 586-4226
120
Appendix D
-------
Idaho
Division of Environmental Quality
Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83720-9000
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy & Natural
Resources
One E, Hazelwood Drive
Champaign, IL 61820
(217) 333-8940
Industrial Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Illinois Institute of Technology
3201 South Dearborn
Room 103 Alumni Memorial Hall
Chicago, IL 60616
(312) 567-3535
Illinois Environmental Protection Agency
Office of Pollution Prevention
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-8700
Indiana
Environmental Management & Education Program
School of Civil Engineering
Purdue University
2129 Civil Engineering Building
West Lafayette, IN 47907-1284
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172
Iowa
Iowa Department of Natural Resources
Wallace State Office Building
900 East Grand Avenue
Des Moines. IA 50319-0034
(515)281-5145
Iowa Waste Reduction Center
75 BRC
University of Northern Iowa
Cedar Falls, IA 50614-0185
(800) 422-3109
(319)273-2079
Iowa Waste Reduction Center
University of Norther Iowa
75 Biology Research Complex
Cedar Falls, IA 50614
(319)273-2079
Kansas
Division of Environment
Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620
(913)296-1535
Engineering Extension Program
Ward Hall 133
Kansas State University
Manhattan, KS 66506
(916) 532-6026
Kentucky
Waste Minimization Assessment Center
Department of Chemical Engineering
University of Louisville
Louisville, KY 40292
(502) 588-6357
Kentucky Partners
Room 312 Ernst Hall
University of Louisville
Louisville. KY 40292
(502) 588-7260
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 82178
Baton Rouge, LA 70884-2178
(504) 765-0355
Alternate Technologies Research and Development
Office of the Secretary
Louisiana Department of Environmental Quality
P.O. Box 44066
Baton Rouge, LA 70804
(504) 342-1254
Technical/Financial Assistance Programs
121
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Maine
Michigan
Office of Pollution Prevention
Department of Environmental Protection
State House Station 17
Augusta, ME 04333
(207)289-2811
Office of Waste Reduction and Recycling
Maine Waste Management Agency
State House Station 154
Augusta, ME 04333
(207) 289-5300
Maryland
Hazardous and Solid Waste Management
Administration
Maryland Department of the Environment
2500 Broening Highway — Building 40
Baltimore, MD 21224
(301)631-3315
Maryland Environment Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 454-1941
Technical Extension Service
Engineering Research Center
University of Maryland
College Park, MD 20742
(301)454-1941
Massachusetts
Executive Office of Environmental Affairs/
Office of Technical Assistance
100 Cambridge Street, Room 1904
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental
Protection
1 Winter Street, 7th Floor
Boston, MA 02108
(617) 292-5870
Massachusetts Department of Environmental
Protection
75 Grove Street
Worchester, MA 01606
(508) 792-7650
Resource Recovery Section
Department of Natural Resources
P.O. Box 30241
Lansing, MI 48909
(517) 373-0540
Office of Waste Reduction Services
Michigan Departments of Commerce and Natural
Resources
P.O. Box 30004
Lansing, MI 48909
(517)335-1178
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155-3898
(612) 296-6300
Minnesota Technical Assistance Program
1313 5th Street S.E., Suite 207
Minneapolis, MN 55414
(612) 627-4646
(800) 247-0015 (in Minnesota)
Minnesota Office of Waste Management
1350 Energy Lane
St. Paul, MN 55108
(612) 649-5741
Waste Reduction Institute for Training Application
Research, Inc. (WR1TAR)
1313 5th Street, S.E.
Minneapolis, MN 55414
(612) 379-5995
Mississippi
Waste Reduction & Minimization Program
Bureau of Pollution Control
Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
(601)961-5171
Mississippi Technical Assistance Program
(MISSTAP) and Mississippi Solid Waste
Reduction Assistance Program (MSWRAP)
P.O. Drawer CN
Mississippi State, MS 39762
(601) 325-8454
122
Appendix D
-------
Missouri
Missouri Environmental Improvement and Energy
Resources Authority
P.O. Box 744
325 Jefferson St.
Jefferson City, MO 65102
(314)751-4919
Waste Management Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(314)751-3176
Montana
Department of Health and Environmental Sciences
Room A-206
Cogswell Building
Helena, MT 59620
(406) 444-3454
Solid and Hazardous Waste Bureau
Department of Health and Environmental Sciences
Cogswell Building
Room B-201
Helena, MT 59620
(406) 444-2821
Nebraska
Hazardous Waste Section
Nebraska Department of Environmental
Control
P.O. Box 98922
Lincoln, NE 68509-8922
(402)471-2186
Nevada
Nevada Small Business Development Center —
Technical Assistance Program
Business Environmental Program
College of Business Administration, MS032
University of Nevada — Reno
Reno, NV 89557-0100
(702)784-1717
(800) 882-3233 (Nevada only)
State Energy Conservation Program
Office of Community Services
Nevada Energy Program
Capital Complex
400 W, King
Carson City, NV 89710
(702) 6874990
New Hampshire
New Hampshire Department of
Environmental Services
Waste Management Division —
Planning Bureau
6 Hazen Drive
Concord NH 03301-6509
(603)271-2901
(603) 271-2902
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
New Jersey Department of Environmental
Protection & Energy
401 East Stale Street
Trenton, NJ 08625
(609)777-0518
New Jersey Institute of Technology
Hazardous Substance Management Research
Center
Advanced Technology Center Building
323 Martin Luther King Jr. Boulevard
University Heights
Newark, NJ 07102
(201)596-5864
New Mexico
Economic Development Department
Bataan Memorial Building
State Capitol Complex
Santa Fe. NM 87503
(505) 827-0380
Technical/Financial Assistance Programs
123
-------
Hazardous and Radiation Waste Bureau
Environmental Improvement Division
1190 St. Francis Drive
Santa Fe, NM 87503
(505) 827-2926
New York
New York Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518)457-4222
Environmental Compliance Services
Erie County Office Building
95 Franklin Street
Buffalo, NY 14202
(716) 846-6716
North Carolina
Department of Environmental, Health, and Natural
Resources
Pollution Prevention Pays Program
Office of Waste Reduction
3825 Barrett Drive, 3rd Floor
Raleigh, NC 27609-7221
(919) 733-7015
(919) 571-4100
Waste Reduction Resource Center
3825 Barrett Drive, Suite 300
P.O. Box 27687
Raleigh, NC 27611-7687
(919)571-4100
(800) 476-8686
North Dakota
Environmental Health Section
State Department of Health
1200 Missouri Ave,
Bismarck, ND 58502
(701)258-2070
Division of Waste Management
Department of Health
1200 Missouri Ave., Room 302
Bismarck, ND 58502-5520
(701) 224-2366
Ohio
Division of Solid and Infectious Waste
Attn: Pollution Prevention Section
Ohio Environmental Protection Agency
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266-0149
(614)644-2917
Ohio Technology Transfer Organization
(OTTO)
Ohio Department of Development
77 South High Street, 26th Floor
Columbus, OH 43225-0330
(614) 644-4286
Ohio Department of Natural Resources
Fountain Square
Columbus, OH 43224-1387
(614)265-6333
Ohio Environmental Protection Agency
Division of Solid and Hazardous Waste
Management
Pollution Prevention Section
P.O. Box 1049
Columbus, OH 43266-0149
(614)644-2917
Oklahoma
Oklahoma Stale Department of Health
Hazardous Waste Management Service
1000 N.E. 10th St.
Oklahoma City, OK 73117
(405)271-5338
Hazardous Waste Management Service
Oklahoma State Department of Health
1000 Northeast 10th Street
Oklahoma City, OK 73152
(405)271-7047
Oregon
Oregon Hazardous Waste Reduction Assistance
Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204-1390
(503) 229-5913 (6570)
800)452-4011 (in Oregon)
124
Appendix D
-------
Pennsylvania
South Carolina
Pennsylvania Technical Assistance Program
248 Calder Way, Suite 306
University Park, PA 16801
(814) 865-0427
Center of Hazardous Material Research
Subsidiary of the University of Pittsburgh Trust
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
334-2467
Division of Waste Minimization and Planning
Department of Environmental Resources
P.O. Box 2064
Harrisburg, PA 17120
(717) 787-7382
Technical Specialist
PENNTAP
112 S. Burrowes Street
University Park, PA 16801
(814) 865-1914
NETAC
University of Pittsburgh Applied Research Center
615 William Pitt Way
Pittsburgh, PA 15238
(412)826-5511
Puerto Rico
Government of Puerto Rico
Economic Development Administration
Box 362350
San Juan, PR 00936
(809) 758-4747
Rhode Island
Office of Environmental Coordination
Rhode Island Department of Environmental
Management
83 Park Street
Providence, RI 02903
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Waste Minimization/Hazardous Waste
Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-5200
Hazardous Waste Management Research Fund
Institute of Public Affairs
4th Floor, Ganbreil Hall
University of South Carolina
Columbia, SC 29208
(803) 777-8157
Clemson University
Continuing Engineering Education Program
P.O. Drawer 1607
Clernson, SC 29633
(803) 656-4450
Sumter Technical College
South Carolina Environmental Training Center
506 N. Guignard Dr.
Surnter, SC 29150
South Dakota
Dept. of Environmental and Natural Resources
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3151
Division of Environmental Regulations
Department of Water and Natural Resources
Joe Foss Building, Room 416
523 E. Capital Ave.
Pierre. SD 57501
(605)773-3153
Tennessee
Tennessee Valley Authority
Mail Code Old City Hall Building 2f71b
Knoxville, TN 37901
(615)632-3160
Tennessee Valley Authority
Mail Code HV2S27OC
Chattanooga, TN 37402
(615) 751-3731
Technical/Financial Assistance Programs
125
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Tennessee Valley Authority
1195 Antioch Pike
Nashville, TN 37219
(615) 360-1680
Waste Reduction Assistance Program
Center for Industrial Services
University of Tennessee
226 Capitol Blvd. Building
Suite 401
Nashville, TN 37219
(615)242-2456
Texas
RENEW
Texas Water Commission
P.O. Box 13087 Capitol Station
Austin, TX 78711-7761
(512)463-7761
Texas Technical University
P.O. Box 4679
Lubbock, TX 79409-3121
(806)742-1413
Utah
Department of Chemical Engineering
3290 MEB
University of Utah
Salt Lake City. UT84112
(801) 581-5763
Department of Environmental Quality
288 North 1460 West
Salt Lake City, UT 84114-4810
(801) 538-6121
Planning and Program Development
Bureau of Solid and Hazardous Waste
Management
Utah Department of Health
P.O. Box 16690
288 North 1460 West Street
Salt Lake City, UT 84116-0690
(801) 538-6170
Utah State University
UMC 14
Logan, UT 84322
(801)750-3227
Vermont
Vermont Department of Environmental
Conservation
Pollution Prevention Division
103 South Main Street
Waterbury, VT 05671-0404
(802) 244-8702
Virginia
Air Pollution Control Board
P.O. Box 10089
Richmond, VA 23240
(804) 786-6035
Washington
Hazardous Waste Section
Mail StopPV-11
P.O. Box 47600
Washington Department of Ecology
Olympia. WA 98504-7600
(206) 459-6000
West Virginia
Generator Assistance Program
Waste Management Section
West Virginia Division of Natural Resources
1356 Hansford Street
Charleston, WV 25301
(304) 348-5989
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI 53707
(608) 267-3763
Wyoming
Wyoming Department of Environmental Quality
Solid Waste Management Program
Herschler Building, 4th Floor, West Wing
122 West 25lh Street
Cheyenne. WY 82002
(307) 777-7752
126
Appendix D
-------
APPENDIX E
OPTION RATING WEIGHTED
SUM METHOD
The Weighted Sum Method is a quantitative
method for screening and ranking pollution pre-
vention options. This method provides a means
of quantifying the important criteria that affect
waste management in a particular facility. This
method involves three steps.
1. Determine what the important criteria are in
terms of the program goals and constraints and
the overall corporate goals and constraints.
Example criteria are:
• Reduction in waste quantity
• Reduction in waste hazard (e.g., toxicity,
flammability, reactivity)
• Reduction in waste treatment/disposal costs
• Reduction in raw material costs
• Reduction in liability and insurance costs
• Previous successful use within the company
• Previous successful use in industry
• Not detrimental to product quality
• Low capital cost
• Low operating and maintenance costs
• Short implementation period with minimal
disruption of plant operations
The weights (on a scale of 0 to 10, for exam-
ple) are determined for each of the criteria in
relation to their importance. For example, if
reduction in waste treatment and disposal costs
are very important, while previous successful
use within the company is of minor impor-
tance, then the reduction in waste costs is
given a weight of 10 and the previous use
within the company is given a weight of either
1 or 2. Criteria that are not important are not
included or are given a weight of 0.
2. Each option is then rated on each criterion.
Again a scale of 0 to 10 can be used (0 for
low and 10 for high).
3. Finally, the rating of each option for a partic
ular criterion is multiplied by the weight of the
criterion. An option's overall rating is the sum
of the products of rating times the weight of
the criterion.
The options with the best overall ratings are
then selected for the technical and economic
feasibility analyses. Table E-l presents an ex-
ample using the Weighted Sum Method for
screening and ranking options.
Table E-l. Sample Calculation Using the
Weighted Sum Method
ABC Corporation has determined that reduction in
waste treatment costs is the most important criterion,
with a weight factor of 10. Other significant criteria
include reduction in safely hazard (weight of 8),
reduction in liability (weight of 7), and ease of im-
plementation (weight of 5). Options X, Y, and Z are
then each assigned effectiveness factors. For exam-
ple, option X is expected to reduce waste by nearly
80%, and is given a rating of 8. It is given a rating
of 6 for reducing safety hazards, 4 for reducing
liability, and because it is somewhat difficult to
implement, 2 for ease of implementation. The table
below shows how the options are rated overall, with
effectiveness factors estimated for options Y and Z.
Ratings for each option
Rating Criteria Weight
Reduce treatment costs 10
Reduce safety hazards 8
Reduce liability 7
Ease of implementation 5
Sum of weight times ratings
8
6
4
2
6
T
J
4
2
3
8
5
8
166 122 169
From this screening, option Z rates the highest with a
score of 169. Option X's score is 166 and option Y's
score is 122. In this case, both option Z and option
X should be selected for further evaluation because
their scores are high and close to each other.
127
-------
APPENDIX F
ECONOMIC EVALUATION
EXAMPLE
The following example presents a profitability
analysis for a relatively large hypothetical pollu-
tion prevention project. This project represents
the installation of a package unit that improves
plant production while reducing raw material
consumption and disposal costs. The analysis
was done on a personal computer using a stan-
dard spreadsheet program. The salient data used
in this evaluation are summarized below.
Capital Costs
• The delivered price of the equipment is quoted
by the vendor at $170,000. This includes
taxes and insurance.
• Materials costs (piping, wiring, and concrete)
are estimated at $35,000.
• Installation labor is estimated at $25,000.
• Internal engineering staff costs are estimated at
$7,000. Outside consultant and contractor
costs are estimated at $15,000.
• Miscellaneous environmental permitting costs
are estimated at $15,000.
• Working capital (including chemical inventoto-
ries, materials, and supplies) is estimated at
$5,000.
• Startup costs are estimated by the vendor at
$3,000.
• A contingency fund of $20,000 for unforeseen
costs and/or overruns is included.
• Planning, design, and installation are expected
to take 1 year.
Financing
• The project will be financed 60% by retained
earnings and 40% by a bank loan.
• The bank loan will be repaid over 5 years of
equal installments of principal plus interest at
an annual percentage rate of 13%. Interest
accrued during installation will be added into
the total capital costs.
• All capital costs, except working capital and
interest accrued during construction, will be
depreciated over 7 years using the double-de-
clining balance method, switching to the
straight-line method when the charges by this
method become greater.
The marginal income tax rate is 34%.
• Escalation of all costs is assumed to be 5%
per year for the life of the project.
• The firm's cost of capital is 15%.
Operating Costs and Revenues
• The pollution prevention project is estimated
to decrease raw materials consumption by
300 units per year at a cost of $50 per unit.
The project will not result in increased pro-
duction. However, it will produce a market-
able by-product to be recovered at a rate of
200 units per year and a price of $25 per
unit.
• The project will reduce the quantity of haz-
ardous waste disposed by 200 tons per year.
The following items make the total unit dis-
posal costs:
Costs per ton of waste
Offsite disposal fees $500
State generator taxes 10
Transportation costs 25
Other costs 25
TOTAL DISPOSAL COSTS $560
• Incremental operating labor costs are estimat-
ed on the basis that the project is expected to
require 1 hour of operator's time per 8-hour
shift. There are 3 shifts per day and the
plant operates 350 days per year. The wage
rate for operators is $12.50 per hour.
• Operating supplies expenses are estimated at
30% of operating labor costs.
128
Appendix F
-------
Maintenance labor costs are estimated at 2% of
the sum of the capital costs for equipment,
materials, and installation. Maintenance sup-
plies costs are estimated at 1% of these costs.
Incremental supervision costs are estimated at
30% of the combined costs of operating and
maintenance labor.
The following overhead costs are estimated as
a percentage of the sum of operating and main-
tenance labor and supervision costs.
Labor burden and benefit
Plant overhead
Headquarter overhead
28%
25%
20%
« Escalation of all costs is assumed to be 5% per
year for the life of the project.
* The project life is expected to be 8 years.
• The salvage value of the project is expected to
be zero after 8 years.
Results
The four-page printout in Figures F-l through
F-4 presents the pollution prevention project
profitability spreadsheet program. Figure F-l
represents the input section of the program.
Each of the numbers in the first three columns
represents an input variable in the program. The
righthand side of Figure F-l is a summary of the
capital requirement. This includes a calculation
of the interest accrued during construction and
the financing structure of the project.
Figure F-2 is a table of the revenues and oper-
ating cost items for each of the 8 years of the
project's operating life. These costs are escalat-
ed by 5% each year for the life of the project.
Figure F-3 presents the annual cash flows for
the project The calculation of depreciation
charges and the payment of interest and repay-
ment of loan principal are also shown here. The
calculation of the internal rate of return (IRR)
and the net present value (NPV) are based on
the annual cash flows. Because the project is
leveraged (financed partly by a bank loan), the
equity portion of the investment is used as the
initial cash flow. The NPV and the IRR are
calculated on this basis. The IRR calculated this
way is referred to as the "return on equity."
The program is structured to present the NPV
and FRR after each year of the project's operat-
ing life. In the example, after 6 years, the IRR
is 19.92% and the NPV is $27,227.
Figure F-4 is a cash flow table based entirely
on equity financing. Therefore, there are no
interest payments or debt principal repayments.
The NPV and the IRR in this case are based on
the entire capital investment in the project. The
IRR calculated this way is referred to as the "re-
turn on investment."
The results of the profitability analysis for this
project are summarized below:
Method of Financing
60% equity/40% debt
100% equity
IRR NPV
26.47% $84,844
23.09% $81,625
The IRR values are greater than the 15% cost of
capital, and the NPVs are positive. Therefore,
the project is attractive and should be implemen-
ted.
Economic Evaluation Example
129
-------
OJ
o
•a
•o
ft
a.
3"
•fl
Pollution Prevention
Profitability Program
Capital Cost Factors
Capital Cost
Equipment
Materials
Installation
Plant Engineering
Con tractor /Engineering
Permitting Costs
Contingency
Working Capital
Start-up Costs
% Equity
% Debt
Interest Rate on Debt, %
Debt Repayment, years
Depreciation period
Income Tax Rate, %
Escalation Rates, %
Cost of Capital (lor NPV)
$170,000
$35,000
$25,000
$7,000
$15,000
$15,000
$20,000
$5,000
$3,000
60%
40%
13.00%
5
7
34.00%
5.0%
15.00%
started 5/22/87
last changed 8/1/87
INPUT
Operating Coil/Revenue Faclort
Increased Production
Increased Rate, units/year
Price, $/unit
Marketable By-products
Rate, units/year
Price, $/unit
Decreased Raw Materials
Decreased Rate, units/year
Price, $/unit
Decreased Waste Disposal
Reduced Waste, tons/year
Offsite Fees, $/ton
State Taxes, $/ton
Transportation, $/ton
Other Disposal Costs, $/ton
Total Disposal Costs, $/ton
0
$100
200
$40
300
$50
200
$500
$10
$25
$25
$560
Operating Labor
Operator hours/shift
Shitts/day
Operating days/year
Wage rate, $/man-hour
Operating Supplies
(% ol Operating Labor)
Maintenance Costs
1% of Capital Costs)
Labor
Materials
Other Labor Costs
(% of O&M Labor)
Supervision
1
3
350
$13.50
30%
2.00%
1.00%
30.0%
(% of O&M Labor + Supervision)
Plant Overhead
Home Office Overhead
Labor Burden
25.0%
20.0%
28.0%
CAPITAL REQUIREMENT
Construction Year
Capital Expenditures
Equipment
Materials
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Start-up Costs
Depreciable Capital
Working Capital
Subtotal
Interest on Debt
Total Capital Requiremen
Equityjnvestment
Debt Principal
Interest on Debt
Total Financing
1
$170,000
$35jOOO
$25,000
$7,000
$15,000
$15,000
$20,000
$3,000
$290,000
$5,000
$295,000
$14,230
$309,230
$185,538
$109,462
$14,230
$309,230
Figure F-l. Input Information and Capital Investment
-------
m
o
i
o
3
m
73_
n'
REVENUE AND COST FACTORS
Operating Year Number
Escalation Factor
1.000
INCREASED REVENUES
Increased Production |
Marketable By-products
Annual Revenue
OPERATING COST/SAVINGS
Raw Materials
Disposal Costs
Maintenance Labor
Maintenance Supplies
Operating Labor
Operating Supplies
Supervision
Labor Burden
Plant Overhead
Home Office Overhead
Total Operating Costs
1
1.050
$0
$8,400
$8,400
$15,750
$117,600
($4,830)
($2,415)
($14.884)
($4,465)
($5,914)
($7,176)
($6,407)
[$5,126)
$82,134
2
1.103
$0
$8,820
$8,820
$16,537
$123,480
($5,071)
($2,536)
($15,628)
($4,688)
($6,210)
($7,535)
($6,727)
($5,382)
$86,240
3
1.158
$0
$9,261
$9,261
$17,364
$129,654
($5,325)
($2,663)
($16,409)
($4,923)
($6,520)
($7,911)
($7,064)
($5,651)
$90,552
4
1 216
$0
$9,724
$9,724
$18,233
$136,137
($5.591)
($2,796)
($17,230)
($5,169)
($6,846)
($8,307]_
($7,41_7|_
($5,933)
$95,080
5
1.276
$0
$10,210
$10,210
$19,144
$142,944
($5,871)
($2,935)
($18,091)
($5,427)
($7,189)
($8,722)
($7,788)
($6,230)
$99,834
6
1.340
$0
$10,721
$10,721
$20,101
$150.091
($6,164)
($3,082)
($18,996)
($5,699)
($7,548)
($9,158)
($8,177)
($6,542)
$104,826
7
1.407
$0
$11,257
$11,257
$21,107
$157,595
($6,473)
($3,236)
($19,946)
($5,984)
($7,925)
($9,616)
($8,586)
($6,869)
$110,067
8
1.477
$0
$11,820
$11,820
$22,162
$165,475
($6,796)
($3,398)
($20,943)
($6.283)
($8,322)
($10,097)
($9,015)
($7,212)
$115,570
Figure F-2. Revenues and Operating Costs
-------
RETURN ON EQUITY/RETURN ON ASSETS |
Construction Year
Operating Year
Book Value
Depreciation (by straight-
Depreciation (by double
Depreciation
Debt Balance
Interest Payment
Principal Repayment
CASH FLOWS
Construction Year
Operating Year
Revenues
+ Operating Savings
Net Revenues
• Depreciation
- Interest on Debt
Taxable Income
- Income Tax
Profit after Tax
+ Depreciation
- Debt Repayment
After-Tax Cash Flow
Cash Flow for ROE
Net Present Value
Return on Equity
26.46%
D
1
1
$290,000 $207,143
no) I $41,429
B) $82,857
$123.692
1
($185,538)
($185,538)
$82,857
$123,692
$16,080
$24,738
1
$8,400
$82,134
$90,534
$82,857
$16,080
($8,403)
($2,857)
($5,546)
$82,857
$24,738
$52,572
$52,572
($139,823)
-71,66%
i
"" 2[--- 3
$147,959 I $105,685
$41.429
$59,184
~~$59~,184~
$98,954
$12,864
$24,738
2
$8,820
$86,240
$95,060
$59,184
$12,864
$23,013
$7,824
$15,188
$59,184
$24,738
$49,634
$49,634
($102,293)
-32.21%
| $41,429
$42.274
$42,274
$74,215
$9,648
$24,738
3
$9,261
$90,552
$99,813
$42,274
$9,648
$47,891
$16,283
$31,608
$42.274
$24,738
$49,144
$49,144
($69,980)
•9.63%
4
$64.257
$41,429
$30,196
$41,429
$49,477
$6,432
$24,738
4
$9,724
$95,080
$104,804
$41,429
$6,432
$56,943
$19,361
$37,583
$41,429
$24,738
$54,273
$54,273
($38,949)
4.22%
5
$22,828
$41,429
$18,359
$41,429
$24,738
$3,216
$24,738
5
$10,210
$99,834
$110,044
$41,429
$3,216
$65,400
$22,236
$43,164
$41,429
$24,738
$59,854
$59,854
($9,191)
12.93%
6
$0
$41,429
$6,522
$22,828
$0
$0
$0
6
$10,721
$104,826
$115.546
$22,828
$0
$92,718
$31,524
$61,194
$22,828
$0
$84,022
$84,022
$27,134
19.91%
7
$0
$0
$0
$0
$0
$0
$0
7
$11,257
$110,067
$121,324
$0
$0
$121,324
$41 ,250
$80,074
$0
$0
$80,074
$80,074
$57,237
23.84%
8
$0
$0
$5J
$0 j
$0
$0
$0
8
$11,820
$115,570
$127,390
$0
$0
$127,390
$43,313
$84,077
$0
$0
$84,077
$84,077
$84,722
26.46%
"0
tt
a.
Figure F-3. Cash Flows for Return on Equity
-------
M
—
E
5'
i
3
•o
RETURN ON INVESTMENT
Construction Year
Operating Year
Book Value
1
$290,000
Depreciation (by straight-line)
Depreciation (by double DB)
Depreciation
CASH FLOWS
Construction Year
Operating Year
Revenues
* OpwrtrjJ Savings
Net Revenues
« Depreciation
Taxable Income
• Income Tax
Profit after Tax
+ Depreciation
After-Tax Cash Flow
Cash Flow for ROI
Net Present Value
Return on Investment
23.08%
1
($295,000)
($295,000)
1
$207,143
$41.429_|
$82,857
$82,857,
1
$8,400
$82,134
$90,534
$82,857
$7,677
$2,610
$5,066
$82,857
$87,924
$87,924
($218,545)
•70.20%
2
$147,959
$41,429
$59,184
$59,184
2
$8,820
$86,240
$95,060
$59,184
$35,877
$12,198
$23,679
$59,184
$82,862
$82,862
($155,889)
-30.04%
3
$105,685
$41,429
$42,274
$42,274
3
$9,261
$90,552
$99,813
$42,274
$57,539
$19,563
$37,976
$42,274
$80,250
$80,250
($103,123)
-7.77%
4
$64,257
$41,429^
$30,196
$41,429
4
$9,724
$95,080
$104,804
$41,429
$63.375
$21,548
$41,828
$41,429
$83,256
$83.256
($55,521)
5.25%
5
$22,828
$41,429
$18,359
$41,429
5
$10,210
$99,834
$110,044
$41,429
$68,616
$23,329
$45,286
$41,429
$86,715
$86,715
($12,408)
13.20%
6
$0
$41,429
$6,522
$22,828
6
$10,721
$104,826
$115,546
$22,828
$92,718
$31,524
$61,194
$22,828
$84,022
$84,022
$23,917
17.98%
7
$0
$0
$0
$0
7
$11,257
$110,067
$121,324
$0
$121,324
$41,250
$80,074
$0
$80,074
$80,074
$54,019
20.96%
8
$0
$0
$0
$0
8
$11,820
$115,570
$127,390
$0
$127,390
$43,313
$84,077
$0
$84,077
$84,077
$81,504
23.08%
Figure F-4. Cash Flows Based on Equity Financing
-------
APPENDIX G
POLLUTION PREVENTION
REFERENCE MATERIAL
This Appendix lists reference material that may
be helpful to you as you develop your pollution
prevention program. The list is divided into the
following sections:
• U.S. EPA reports
• state environmental agency reports
• reports by other U.S., regional, and local
agencies
• foreign and international agency documents
• industrial and professional societies; uni-
versities; corporations reports
• books
• journal articles
The mailing addresses and telephone numbers
for the U.S. EPA and the state environmental
agencies are listed in Appendix D.
U.S. ENVIRONMENTAL
AGENCY
PROTECTION
The Pollution Prevention Research Branch
maintains a listing of its current projects and
publications. Contact the U.S. EPA Risk Re-
duction Engineering Laboratory, Cincinnati,
Ohio.
Achievements in Source Reduction and Recy-
cling for Ten Industries in the United States,
EPA/600/2-91/051**
On this and subsequent pages,
* Available from National Technical Information
Service as part of a five-volume set, NTIS No.
PB-87-114-328. (703) 487-4650
** Available from U.S. EPA CER1 Publications
Unit, 26 West Martin Luther King Drive, Cin-
cinnati, OH 45268. (513) 569-7562.
Electronic Information Exchange System (EIES)
- User Guide, Version 1.1, U.S. EPA Pollution
Prevention Information Clearing House (PPIC),
EPA/600/9-89/086
The Environmental Challenges of the 1990' s,
Proceedings of the International Conference on
Pollution Prevention: Clean Technologies and
Clean Products, EPA/600/9-90/039.
Industrial Pollution Prevention Opportunities
for the 1990s, EPA/600/891/052**
Pollution Prevention Benefits Manual, Phase II,
October, 1989. Draft available from U.S. EPA
Pollution Prevention Information Clearing
House (PPIC).
Pollution Prevention 1991: Progress on Re-
ducing Industrial Pollutants, EPA-21P-3003.
Powder Coatings Technology Update, EPA-
450/3-89-33.
Total Cost Assessment: Accelerating Industrial
Pollution Prevention Through Innovative Pro-
ject Financial Analysis, with Applications to
the Pulp and Paper Industry, Report Prepared
by the Tellus Institute, December 1991.
A series of reports on waste minimization:
• Waste Minimization: Environmental Quali-
ty with Economic Benefits, 2nd. ed., April
1990, EPA/530/SW-90/044.
• Waste Minimization — Issues and Options,
Vols. I-III EPA/530/SW-86/041 through
/043 (Washington, D.C.: U.S. EPA, 1986)*
• Report to Congress: Waste Minimization,
Vols. I and II. EPA/530/SW-86/033 and
/034 (Washington, D.C.: U.S. EPA,
1986)**
134
Appendix G
-------
A series of manuals** describe waste mini-
mization options for specific industries. This
is a continuing series which currently includes
the following titles:
* Guide to Pollution Prevention: The Pesti-
cide Formulating Industry, EPA/625/7-
90/004.
* Guide to Pollution Prevention: The Paint
Manufacturing Industry, EPA/625/7-
90/005.
* Guide to Pollution Prevention: The Fabri-
cated Metal Products Industry,
EPA/625/7-90/006.
* Guide to Pollution Prevention: The Print-
ed Circuit Board Manufacturing Industry,
EPA/625/7-90/007.
• Guide to Pollution Prevention: The Com-
mercial Printing Industry, EPA/625/7-90/-
008.
• Guide to Pollution Prevention: Selected
Hospital Waste Streams, EPA/625/7-
90/009.
* Guide to Pollution Prevention: Research
and Educational Institutions, EPA/625/7-
90/010.
* Guide to Pollution Prevention: The
Photoprocessing Industry, EPA/625/7-90/-
012.
• Guide to Pollution Prevention: The Auto-
motive Repair Industry, EPA/625/7-
91/013.
« Guide to Pollution Prevention: The Fiber-
glass Reinforced and Composite Plastics
Industry, EPA/625/7-91/014.
* Guide to Pollution Prevention: The Ma-
rine Maintenance and Repair Industry,
EPA/625/7-91/015.
* Guide to Pollution Prevention: The Auto-
motive Refinishing Industry,
EPA/625/791/016.
« Guide to Pollution Prevention: The Phar-
maceutical Industry, EPA/625/7-91/017,
STATE ENVIRONMENTAL PROTECTION
AGENCIES
Alaska Health Project
Wigglesworth, D. Profiting from Waste Re-
duction in Your Small Business, 1988, 46 pp.
On-site Consultation Audit Reports for facilities
of the following types:
aviation facility
dairy foods processor
dry cleaner
fur dressing and tanning shop
high school
laboratory facility
oil field service company
photofinishing shop
plastic bottle making/chemical manufacturing
regional hospital
seafood processing plant
secondary seafood processor
Waste Reduction Tips for;
all businesses
dry cleaners
local governments
newspaper manufacturers
photofmishers
print shops
vehicle repair shops
California Environmental Protection Agency
Alternative Technologies for the Minimization
of Hazardous Waste, July 1990.
Alternative Technology for Recycling and Trea-
tment of Hazardous Waste: 3rd Biennial Re-
port, 1986.
Economic Implications of Waste Reduction,
Recycling. Treatment and Disposal of Hazard-
ous Wastes: Fourth Biennial Report, July 1988,
126 pp.
Guide to Solvent Waste Reduction Alternatives,
October 1986.
Waste Minimization for Hazardous Materials
Inspectors: Module I, Introductory Text with
Self-Testing Exercises, January 1991, 114 pp.
Waste Minimization Assessment Procedures:
Module II.
Unit 1: Waste Minimization Assessment
Procedures for the Inspectors with
Self-Testing Exercises.
Unit 2: Waste Minimization Assessment
Procedures for the Generator
Pollution Prevention Reference Material
135
-------
Waste Minimization for the Metal Finishing
Industry: Module III.
Waste Minimization: Small Quantity Genera-
tors at Los Angeles International Airport.
February, 1991.
Various industry-specific checklists; represen-
tative titles include:
Printed Circuit Board Manufacturers, Febru-
ary 1991.
Waste Reduction for the Pesticide Formulat-
ing Industry, March 1989.
Waste Reduction for the Aerospace Industry,
April 1990,
Waste Minimization for Metal Finishers,
February 1991.
Waste Minimization for Automotive Repair
Shops, February 1991.
Waste Reduction for the Commercial
Printing Industry, August 1989,
Waste Reduction Can Work for You!, April
1990.
Waste Reduction for Paint Formulators,
December 1989.
Connecticut Technical Assistance Program
Waste Minimization and Pollution Prevention:
Self-Audit Manual — Metal Finishing, prepared
by Integrated Technologies, Inc., September
1990.
Minnesota Technical Assistance Program
Final Report on the Internship served at Gage
Tool Company, 1985.
Minnesota Waste Reduction Institute for
Training and Applications Research, Inc.
(WRITAR)
Minnesota Guide to Pollution Prevention Plan-
ning, February 1991.
Survey of State Legislation. March, 1992.
Survey and Summaries of State Legislation
Relating to Pollution Prevention, January,
1991.
North Carolina Department of Environment,
Health, and Natural Resources
General and Program Information:
• Case Summaries of Waste Reduction by
Industries in the Southeast
• Developing and Implementing a Waste Re-
duction Program
• Pollution Prevention Challenge Grant
Information
• Waste Reduction Techniques: An Over-
view
* Handbook for Using a Waste Approach to
Meet Aquatic Toxicity Limits
• Hazardous Materials in North Carolina:
A Guide for Decisionmakers in Local
Government
• Directory of Industrial and Commercial
Recyclers Serving North Carolina Busi-
nesses and Communities
• Directory of State and Local Contacts for
Recycling Information and Assistance
• List of available audiovisual materials
Industry-Specific Information:
• Water Conservation for Electroplaters:
Rinse Tank Design
• Water Conservation for Electroplaters:
Rinse Water Reuse
• Water Conservation for Electroplaters:
Counter-Current Rinse
• Drag-out Management for Electroplaters
• Atmospheric Evaporative Recovery Applied
to a Nickel Plating Operation
• A Workbook for Pollution Prevention by
Source Reduction in Textile
• Wet Processing
• Identification and Reduction of Pollution
Sources in Textile Wet Processing
• Identification and Reduction of Toxic Pol-
lutants in Textile Mill Effluents
• Water Conservation for Textile Mills
* Dye Bath and Bleach Bath Reconstitution
for Textile Mills
• Ultraviolet Light Disinfection of Water in
a Textile Air Washer
• Water and Chemical Reduction for Cool-
ing Towers
• Small Solvent Recovery Systems
• Solvent Loss Control - Things You Can Do
Now
• Managing and Recycling Solvents
136
Appendix G
-------
• Managing and Recycling Solvents in the
Furniture Industry
• Waste Reduction Options for Radiator
Service Firms
• Waste Reduction Options for Automobile
Salvage Yards
• Garage Owners: Handling of Hazardous
and Solid Waste
• Pollution Prevention Techniques for the
Wood Preserving Industry
• Silver Recovery Systems and Waste Reduc-
tion in Photoprocessing
• Recovery of Volatile Organic Compounds
from Small Industrial Sources
• Companion Document for the Conference
on Waste Reduction for Industrial Air
Toxic Emissions
• Pollution Reduction Strategies in the Fi-
berglass Boatbuilding and Open-Mold
Plastics Industries
• Marine Maintenance and Repair: Waste
Reduction and Safety Manual
• List of available pollution prevention pub-
lications for the food processing industry
• Ten Fact Sheets on Pesticides and Water
Quality
• Pesticide Rinsatc Recycling Facilities
Design Guide
• Reduction in Pollution from Irrigated
Farming
• Waste Management Strategies for Hos-
pitals and Clinical Laboratories
• Reduction Techniques for Laboratory
Chemical Wastes
• Reduction of Hazardous Waste from High
School Chemistry Labs
• Pollution Prevention Pays Instruction
Manual for Technical Colleges
Ohio EPA
Facility Pollution Prevention Planning: A
Matrix of the Provisions of Twelve State Laws,
October 1990, 25pp.
Oregon Department of Environmental Quality
Benefitting for Toxic Substance and Hazardous
Waste Reduction, October 1990.
Tennessee Waste Reduction Assistance
Program
Waste Reduction Assessment and Technology
Transfer (WRATT) Training Manual, 2nd ed.,
1989, 200+ pp.
Writing a Waste Reduction Plan: Charting
Your Company's Course Towards Better Waste
Management, A How-To Book for Tennessee
Generators
OTHER U.S., REGIONAL, AND LOCAL
AGENCIES
City of San Jose, CA
Brown, S., R. Kessler, and G. Lynch. Hazard-
ous Waste Management and Reduction: A
Guide for Small- and Medium-Sized Businesses,
1989.
Great Lakes Rural Network
Maher, J., P. Rafferty, and 0. Burch. The
Small Business Guide to Hazardous Materials
Management, 1988, 195 pp.
Local Government Commission
Low Cost Ways to Promote Hazardous Waste
Minimization: A Resource Guide for Local
Governments, October 1988, 54 pp.
Minimizing Hazardous Wastes: Regulatory
Options for Local Governments, December
1988, 31 pp.
Reducing Industrial and Commercial Toxic Air
Emissions by Minimizing Waste: The Role of
Air Districts, November 1990, 33 pp.
Reducing Industrial Toxic Waste and Dis-
charges: The Role ofPOTW's, December 1988,
33pp.
Ohio Department of Natural Resources
Recycling Basics: A Positive Waste Manage-
ment Alternative for Ohio, 1989, 43 pp.
Pollution Prevention Reference Material
137
-------
Southern States Energy Board
Waste Minimization: Workshop Guidance and
Sourcebook, July 1990,
U.S. Congress, Office of Technology
Assessment
Serious Reduction of Hazardous Waste, 1986,
U.S. Department of Defense
Proceedings of the 1991 DODIIndustry Ad-
vanced Coatings Removal Conference, San
Diego.
Proceedings of the 1990 DODI Industry Ad-
vanced Coatings Removal Conference, Atlanta,
U.S. Department of Energy
Architect's and Engineer's Guide to Energy
Conservation in Existing Buildings, DOE/RL/-
01830P-H4.
Volume 1: Energy Use Assessment and Sim-
ulation Methods.
Volume 2: Energy Conservation Opportuni-
ties.
First Annual International Workshop on Sol-
vent Substitution, Phoenix, December, 1990.
(With U.S. Air Force)
Model Waste Minimization and Pollution Pre-
vention Awareness Plan, February 1991, 32 pp.
FOREIGN AND INTERNATIONAL
AGENCIES
Dutch Ministry of Economic Affairs.
DDU/DOP, Rooseveltstraat 52-56, 2321 BM
Leiden, The Netherlands, tcl. +3171352500
Manual for the Prevention of Waste and Emis-
sions, Pan I, June 1991.
World Bank
The Safe Disposal of Hazardous Wastes, Tech-
nical Paper Number 93.
INDUSTRIAL AND PROFESSIONAL
ASSOCIATIONS; UNIVERSITIES;
CORPORATIONS
Air Pollution Control Association
Cole, G. E. VOC emission reduction and other
benefits achieved by major powder coating
operations. Paper No. 84-38,1, June 25, 1984.
American Society for Testing and Materials
Handbook of Vapor Decreasing. Special
Technical Publication 310-A. April, 1976.
Center for Hazardous Materials Research.
University of Pittsburgh Applied Research Cen-
ter, 320 William Pitt Way, Pittsburgh, PA 15238
Hazardous Waste Minimization Manual for
Small Quantity Generators in Pennsylvania.
April 1987.
Chemical Manufacturers Association. 2501 M
Street, N.W., Washington, DC 20037, (202) 887-
1100
Improving Performance in the Chemical In-
dustry, Ten Steps for Pollution Prevention,
September 1990,
Waste Minimization Resource Manual, 1989.
CH2M Hill. Washington, D.C.
Higgins, T, E. Industrial Process Modifications
to Reduce Generation of Hazardous Waste at
DOD Facilities: Phase I Report, 1985.
Dow Chemical. Midland, MI 48674,
Environmental Protection Guidelines for Oper-
ations. 18 pp.
Environment Reporter.
Blueprint for National Pollution Prevention
Strategy, 56 FR 7849, February 26, 1991.
138
Appendix G
-------
Hazardous Materials Control Research Insti-
tute. Atlanta, GA.
Fromm, C. H. and M. S. Callahan. "Waste
Reduction Audit Procedure." Conference of the
Hazardous Materials Control Research Insti-
tute, pp. 427-435, 1986.
HAZTECH International
Fromm, C., S. Budaraju, and S. A. Cordery.
"Minimization of Process Equipment Cleaning
Waste." Conference Proceedings of HAZTECH
International, pp. 291-307, Denver, August 13-
15, 1986.
3M Corporation. St. Paul, MN.
Ideas — A Compendium of 3M Success Stories
Rutgers University
D. Sarokin. "Reducing Ha/ardous Wastes at
ihe Source: Case Studies of Organic Chemical
Plants in New Jersey." paper presented al
Source Reduction of Hazardous Waste Con-
ference, August 22, 1985.
Pollution Probe Foundation, Toronto, Ontario.
Campbell, M. E., and W. M. Glenn. Profit
from Pollution Prevention, 1982.
Pacific Basin Consortium for Hazardous
Waste Research, East/West Cenier, Honolulu,
HI.
Waste Minimization: Training Course. Novem-
ber 1990.
BOOKS
Durney, L. J., edilor. Electroplating Engineer-
ing Handbook. 4In ed., New York: Van Nos-
trand Reinhold. 1984.
Freeman, H. Hazardous Waste Minimization.
New York: McGraw-Hill, 1990, 343 pp. ISBN
0-07-022043-3.
Glasstone, S. Energy Deskbook. New York: Van
Nostrand Reinhold, 1983, 453 pp.
Hu, S. D. Handbook of Industrial Energy Con-
servation. New York: Van Nostrand, 1983, 520
pp.
Industrial Waste Audit and Reduction Manual.
2nd ed. Ontario: Ontario Waste Management
Corporation, July 1989, 91 pp. ISBN-7729-
5851-3.
Van Weenan, J. C. Waste Prevention: Theory
and Practice. The Hague: CIP-Gegevans Konin-
klije Bibliotheek, 1990.
JOURNAL ARTICLES
Baunier, A. R. "Making Environmental Audits,"
Chemical Engineering 89(22) 1982, p. 101.
"Cryogenic Paint Stripping." Product Finishing,
December 1982, pp. 54-57.
Danneman, J. "UV Process Provides Rapid Cure
for Compliant Wood Finishes." Modern Paint
and Coatings 78(2) 1988, pp. 28-29.
Dumey, J. "How to Improve Your Paint Strip-
ping." Product Finishing, December 1982,
pp.52-53.
Fischback, B. C. "Waste Reduction Methodology
and Case Histories al Dow Chemical's Pittsburg,
California Plant Site." Environmental Progress
10(1) 1991, pp. F12-F13.
Geltenan, E. "Keeping Chemical Records on
Track." Chemical Business 6(11) 1984, p. 47.
Hickman, W. E. and W. D. Moore. "Managing
the Maintenance Dollar," Chemical Engineering
93(7) 1986, p. 68.
Ingleston, R. "Powder Coatings: Current Trends,
Future Developments." Product Finishing, Au-
gust 1991, pp. 6-7.
Kletz, T. A. "Minimize Your Producl Spillage."
Hydrocarbon Processing 61(3) 1982, p. 207.
Pollution Prevention Reference Material
139
-------
Krishnaswamy, R. and N. H. Parker. "Corrective
Maintenance and Performance Optimization,"
Chemical Engineering 91(7) 1984, p. 93.
Lenckus, D. "Increasing Productivity." Wood
and Wood Products 87(4) 1982, pp. 44-66, May
1982.
Manik, R. and L. A. Dillard. "Toxics Use Re-
duction in Massachusetts: The Blackstone Pro-
ject." Journal of the Air Waste Management
Association 40(10) 1990, pp. 1368-1371.
"Measuring Pollution Prevention Progress."
Pollution Prevention Review, Spring 1991, pp.
119-130.
Nelson, K. E. "Use These Ideas to Cut Waste."
Hydrocarbon Processing, March 1990, pp. 93-
98.
Pilcher, P. "Chemical Coatings in the Eighties:
Trials, Tribulations, and Triumphs." Modern
Paint and Coatings 78(6) 1988, pp. 34-36.
Pojasek, R. "Contrasting Approaches to Pollution
Prevention Auditing." Pollution Prevention Re-
view, Summer 1991, pp. 225-235.
Rimberg, D. "Minimizing Maintenance Makes
Money." Pollution Engineering 12(3) 1983, p.
46.
Singh, J. B. and R. M. Allen. "Establishing a
Preventative Maintenance Program," Plant Engi-
neering, February 27, 1986, p. 46.
Smith, C. "Troubleshooting Vapor Degreasers."
Product Finishing, November 1981, pp. 90-99.
"Waste Minimization for Chlorinated Solvent
Users." ChemAware, June 1988.
140 Appendix G
-------
APPENDIX H
GLOSSARY OF POLLUTION
PREVENTION TERMS
This appendix describes terms specifically relat-
ed to pollution prevention as they are used in
this guide.
Assessment Phase — See Pollution Prevention
Assessment Program.
Assessment Team — See Pollution Prevention
Assessment Team,
CERCLA — Comprehensive Environmental Re-
sponse Compensation and Liability Act,
Cross-Media Transfer — Refers to the transfer
of hazardous materials and wastes from one
environmental medium to another.
Environmental Management Hierarchy — The
Pollution Prevention Act of 1990 established a
hierarchy as national policy. The hierarchy fol-
lows 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. (4) Dispose of, or otherwise release
into the environment, pollution only as a last
resort.
Feasibility Analysis Phase — The point in a pol-
lution prevention program at which screened
waste reduction options are evaluated techni-
cally, economically, and environmentally. The
results are used to select options to be recom-
mended for implementation.
Implementation Phase — The step in a pollution
prevention assessment where procedures, train-
ing, and equipment changes are put into action
to reduce waste.
Mass Balance — A method of accounting for the
quantities of materials produced, consumed,
used, or accumulated at; released from; or trans-
ported to or from a process or facility as a
waste, commercial product or byproduct, or
component of a commercial product or byprod-
uct.
Multimedia — Refers to all environmental media
(air, land, and water) to which a hazardous sub
stance, pollutant, or contaminant may be dis-
charged, released, or displaced.
Pollution/Pollutants — In this report, the terms
"pollution" and "pollutants" refer to all nonpro-
ducl outputs, irrespective of any recycling or
treatment that may prevent or mitigate releases
to the environment.
Pollution Prevention — The use of materials,
processes, or practices that reduce or eliminate
the creation of pollutants or wastes at the source.
It includes practices that reduce the use of haz-
ardous materials, energy, water or other resourc-
es, and practices that protect natural resources
through conservation or more efficient use.
Pollution Prevention Assessments — System-
atic, periodic internal reviews of specific pro-
cesses and operations designed to identify and
provide information about opportunities to re-
duce the use, production, and generation of toxic
and hazardous materials and waste.
Pollution Prevention Assessment Team — A
group assembled within a facility to conduct
waste reduction assessments. They are selected
on the basis of their expertise and knowledge of
the process operations.
141
-------
Pollution Prevention Champion — One or more
people designated to facilitate the pollution pre-
vention program by resolving conflicts.
Pollution Prevention Task Force — Overall
group responsible for instituting a pollution pre-
vention program, for performing a preliminary
assessment, and for guiding the program through
the development stages.
Preliminary Assessment/Pre-assessment — A
facility survey performed early in the develop-
ment of a pollution prevention program for the
purpose of determining which areas present
opportunities for pollution prevention. The
information gathered during the pre-assessment
is used to prioritize sites for detailed assessment
later.
RCRA — Resource Conservation and Recovery
Act.
Recycling — Using, reusing, or reclaiming mate-
rials/waste, including processes that regenerate a
material or recover a usable product from it.
SARA — Superfund Amendments and Reauthori-
zation 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 contami-
nant entering any waste stream or otherwise re-
leased into the environment (including fugitive
emissions) prior to recycling, treatment, and dis-
posal; and 2) reduces the hazards to public
health and the environment associated with the
release of such substances, pollutants, or con-
taminants. The term includes equipment or tech-
nology modifications, process or procedure mod-
ifications, reformulation or redesign of products,
substitution of raw materials, and improvements
in housekeeping, maintenance, training, or inven-
tory 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 sub-
stance, pollutant, or contaminant through a pro-
cess or activity which itself is not integral to and
necessary for the production of a product or the
providing of a service."
Task Force — See Pollution Prevention Task
Force.
Toxic Chemical Use Substitution — This term
describes replacing toxic chemicals with less
harmful chemicals, although relative toxicities
may not be fully known. Examples would in-
clude substituting a toxic solvent in an industrial
process with a chemical with lower toxicity and
reformulating a product so as to decrease the use
of toxic raw materials of the generation of toxic
byproducts.
In this report, this term also includes attempts
to reduce or eliminate the use in commerce of
chemicals associated with health or environmen-
tal risks. Examples include the phaseout of lead
in gasoline, the attempt to phase out the use of
asbestos, and efforts to eliminate emissions of
chlorofluorocarbons and halons. Some of these
attempts have involved substitution of less haz-
ardous chemicals for comparable uses, but others
involve the elimination of a particular process or
product from the market without direct substitu-
tion.
Toxics 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 of work-
ers, 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 separa-
tion/concentration processes into harmless or less
toxic substances.
Waste — In theory, the term "waste" applies to
nonproduct outputs of processes and discarded
products, irrespective of the environmental medi-
um affected. In practice, since the passage of
RCRA, most uses of the term "waste" refer ex-
clusively to the hazardous and solid wastes regu-
lated under RCRA, and do not include air emis-
sions or water discharges regulated by the Clean
Air Act or the Clean Water Act. The Toxics
142
Appendix H
-------
Release Inventory, TRI, refers to wastes that are
hazardous as well as nonhazardous.
Waste Exchange — A central office in which
generators who want to recycle valuable compo-
nents of their waste can register the waste for
off-site transfer to others.
Waste Minimization — Source reduction and the
following types of recycling: (1) beneficial
use/reuse, and (2) reclamation. Waste minimi-
zation does not include recycling activities
whose uses constitute disposal and burning for
energy recovery.
Waste Reduction — This term has been used by
the Congressional Office of Technology Assess-
ment and INFORM to mean source reduction.
On the other hand, many different groups have
used the term to refer to waste minimization.
Therefore, care must be employed in determin-
ing which of these different concepts is implied
when the term "waste reduction" is encountered.
• U.S. GOVERNMENT PRINTING OITICt: L995-650-006/2203L
143
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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati, OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
Official Business
Penalty for Private Use, $300
Please make all necessary changes on the above label,
detach or copy, and return to the address in the upper
lett-hand comer.
If you do not wish to recede these reports CHECK HERE (] ;
detach, or copy this cover, and return to the address in the
upper lett-hand comer.
EPA/600/R-92/088
-------
f^ArC^i-l-VxjM C_
EPA/62S/7-86/003
July 1988
Waste Minimization
Opportunity Assessment Manual
Hazardous Waste Engineering Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
REPRODUCED BY
U.S. DEPARTMENT OF COMMERCE
NATIONAL TECHNICAL
INFORMATION SERVICE
SPRINGFIELD, VA 22161
-------
Motfce
This report has been reviewed by the Hazardous Waste Engineering Research
Laboratory, U.S. Environmental Protection Agency, and approved for publication.
Approval does not signify that the contents necessarily reflect the views and policies of
the U.S. Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
Users are encouraged to duplicate those portions of the manual as needed to implement
a waste minimization program. Organizations interested in publishing and distributing the
entire manual should contact the Alternative Technologies Division, Hazardous Waste
Engineering Research Laboratory, U.S. Environmental Protection Agency, Cincinnati,
Ohio 45268, to obtain a reproducible master.
-------
4. TITLE *ND SUBTrTLE
Waste Minimization Opportunity Assessment Manual
TECHNICAL REPORT DATA
(Please read instructions on the reverse before cot
REPORT NO.
EPA/625/7-88/003
PB92-216985
5. REPORT DATE
1988
6, PERFORMING ORGANIZATION CODE
. AUTHOH(S)
B. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Jacobs Engineering Group
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
HWERL
Cincinnati, OH
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Project Officer: Harry M. Freeman (HWERL)
16. ABSTRACT
, This manual describes a recommended procedure for identifying
waste minimization applications, ft will be of benefit to those
responsible for reducing waste streams, and to those
interested in teaming about waste minimization in general.
17.
KEY WORD AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI HefcVGroup
18. DISTRIBUTION STATEMENT
IB, SECURITY CLASS {This Report)
Unclassified
21. NO. OF PAGES
IOB
20. SECURITY CLASS (This Pag*}
Unclassified
22. PRICE
I/-4
-------
Foreword
The term, "waste minimization" is heard increasingly at meetings and conferences of
individuals working in the field of hazardous waste management. Waste minimization is an
umbrella term that includes the first two categories of the EPA's preferred hazardous
waste management strategy which is shown below:
1. Source Reduction: Reduce the amount of waste at the source, through changes in
industrial processes,
2. Recycling: Reuse and recycle wastes for the original or some other purpose, such
as materials recovery or energy production,
3. Incineration/Treatment: Destroy, detoxify, and neutralize wastes into less harmful
substances.
4. Secure Land Disposal: Deposit wastes on land using volume reduction,
encapsulation, leachate containment, monitoring, and controlled air and
surface/subsurface waste releases.
in carrying out its program to encourage the adoption of waste minimization, the
Hazardous Waste Engineering Research Laboratory has supported the development of a
recommended procedure for identifying waste minimization applications. This manual
describes that procedure and will be of interest to those responsible for reducing waste
streams, and to those interested in learning about waste minimization in general.
Hi
-------
Contents
Page
Foreword iii
Acknowledgments vfl
1. Introduction 1
2. Planning and Organization 6
3. Assessment Phase 10
4. Feasibility Analysis 19
5. Implementing Waste Minimization Options 24
Appendices
A. Waste Minimization Assessment Worksheets A-1
B. Simplified Waste Minimization Assessment Worksheets B-1
C. Example Waste Minimization Assessment C-1
D. Causes and Sources of Waste D-1
E. Waste Minimization Techniques E-1
F. Government Technical/Financial Assistance Programs F-1
Q. Option Rating: Weighted Sum Method Q-1
H. Economic Evaluation Example H-1
Preceding page blank
-------
Ust of Worksheets
Page
Appendix A
1. Assessment Overview A-3
2. Program Organization A-4
3. Assessment Team Make-up A-5
4. Site Description A*6
5, Personnel A-7
6. Process Information A-8
7. Input Materials Summary A-9
8. Products Summary A-10
9. Individual Waste Stream Characterization A-11
10. Waste Stream Summary A-15
11. Option Generation A-16
12. Option Description A-17
13. Options Evaluation by Weighted Sum Method A-18
14. Technical Feasibility A-19
15. Cost Information A-25
16. Profitability Worksheet #1: Payback Period A-31
17. Profitability Worksheet #2: Cash Flow for NPV and IRR A-32
18. Project Summary A-33
19. Option Performance A-34
Appendix B
S1. Assessment Overview B-2
S2. Site Description B-3
S3. Process Information B-4
S4. Input Materials Summary B-5
S5. Products Summary B-i
S6. Waste Stream Summary B-7
S7. Option Generation B-8
S8. Option Description B-9
S9. Profitability B-10
VI
-------
Acknowledgments
The following people are members of the advisory committee that contributed valuable
comments and insights to the preparation of this manual:
Denny J. Beroiz
General Dynamics Pomona Division
Elaine Eby
Office of Solid Waste
US Environmental Protection Agency
John Frick, PhD
Directorate of Supply Operations
Defense Logistics Agency
Kevin Gashlin
Hazardous Waste Assistance Program
New Jersey Department of Environmental Protection
Gregory J. Hollod, PhD
Petrochemicals Department
E.I. DuPont de Nemours & Co.
Gary Hunt
Pollution Prevention Pays Program
North Carolina Department of Environmental
Management
John S. Hunter, III, PhD
3M Corporation
Michael Overcash, PhD
Department of Chemical Engineering
North Carolina State University
Robert Pojasek, PhD
ChemCyde Corporation
Dennis Redington
Monsanto Co
Michael E. Resch
Waste Disposal Engineering Division
US Army Environmental Hygiene Agency
Jack Towers
Waste Reduction Services
Chemical Waste Management
David Wigglesworth
Waste Reduction Assistance Program
Alaska Health Project
Kathleen Wolf, PhD
Source Reduction Research Partn
rship
Harry M. Freeman of the U.S. Environmental Protection Agency, Office of Research and
Development, Hazardous Waste Engineering Research Laboratory, was the project
officer responsible for the preparation of this manual. Special acknowledgment is given to
Myles Morse of the U.S. Environmental Protection Agency, Office of Solid Waste, for his
assistance and comments. James Lounsbury and Roger Schecter of the EPA Office of
Solid Waste are also acknowledged for their assistance in the preparation of this manual.
This manual was developed by the Hazardous and Toxic Materials Division of Jacobs
Engineering Group as a subcontractor to Versar. inc. Marvin Drabkin was the project
manager for Versar. Participating in the preparation of this manual for Jacobs were
Gregory A. Lorton, Carl H. Fromm, Michael P. Meltzer, Deborah A. Hanlon, Sally
Lawrence, Michael S. Callahan, and Srinivas Budaraju.
vii
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Section 1
Introduction
Waste minimization (WM) has been successful for
many organizations. By following the procedures
outlined in this manual, a waste generator can:
• Save money by reducing waste treatment and
disposal costs, raw material purchases, and other
operating costs.
• Meet state and national waste minimization policy
goals.
• Reduce potential environmental liabilities.
• Protect public health and worker health and safety.
• Protect the environment.
Waste minimization to a policy specifically mandated by
the U. S. Congress in the 1984 Hazardous and Solid
Wastes Amendments to the Resource Conservation
and Recovery Act (RCRA). This mandate, coupled
with other RCRA provisions that have led to
unprecedented increases in the costs of waste
management, have heightened general interest in
waste minimization. A strong contributing factor has
been a desire on the part of generators to reduce their
environmental impairment liabilities under the
provisions of the Comprehensive Environmental
Response, Compensation, and Liabilities Act
(CERCLA, or "Superfund"). Because of these
increasing costs and liability exposure, waste
minimization has become more and more attractive
economically.
The following terms, used throughout this manual, are
defined betow:
Waste Minimisation /WML in the working definition
currently used by EPA. waste minimization consists of
source reduction and recycling. Thto concept of waste
minimization to presented In Figure 1-1. Of the two
approaches, source reduction to usually preferable to
recycling from an environmental perspective. Source
reduction and recycling each are comprised of a
number of practices and approaches which are
Illustrated In Figure 1-2.
The present focus of WM activities to on hazardous
wastes, as defined In RCRA. However, K to important
that an pollutant emissions into air, water and land be
considered as part of a waste minimization program.
The transfer of pollutants from one medium to another
to not waste minimization. For example, the removal of
organics from wastewater using activated carbon, in
and of Itself, to not waste minimization, since the
pollutants are merely transferred from one medium
(wastewater) to another (carbon, as solid waste).
Waste minimization program fWMP). The RCRA
regulations require that generators of hazardous waste
"have a program In place to reduce the volume and
toxicity of waste generated to the extent that to
economicany practical.' A waste minimization program
to an organized, comprehensive, and continual effort
to systematicaRy reduce waste generation. Generally.
a program to established for the organization as a
whole. Its components may include specific waste
minimization projects and may use waste minimization
assessments as a tool for determining where and how
waste can be reduced. A waste minimization program
should reflect the goals and policies for waste
minimization set by the organization's management.
Also, the program should be an ongoing effort and
should strive to make waste minimization part of the
company's operating philosophy. White the main goal
of a waste minimization program Is to reduce or
eliminate waste, It may also bring about an
improvement in a company's production efficiency.
EPA will pubfeh separate guidance on the elements
of effective waste minimization programs. This
guidance win discuss the following elements likely to
be found in an effective WM program:
Top management support
Explicit program scope and objectives
Accurate waste accounting
Accurate cost accounting
Pervasive waste minimization philosophy
Technology transfer
mmnf
A waste
minimization assessment to a systematic planned
procedure with the objective of identifying ways to
reduce or eliminate waste. The steps involved in
conducting a waste minimization assessment are
outlined In Figure 1-3. The assessment consists of a
careful review of a plant's operations and waste
streams, and the selection of specific areas toassess.
After a specific waste stream or area to established as
the WMA focus, a number of options with the potential
to minimize waste are developed and screened. Third,
the technical and economic feastolllty of the selected
options are evaluated. Finally, the most promising
options are selected for implementation.
-------
WASTE MINIMIZATION
SOURCE REDUCTION
I
RECYCLING
FUST
MQH
ORDER OF EXPLORATION
RELATIVE ENVRONMENTAL DESRABUIY
UkST
LOW
WASTE MNIMZATION
The reduction, to the extent feaeHe, of hazardous waste that h generated or eubee*iently treated, stated or
disposed of. I includes any source (eduction or reeydng activity undertaken by •p^MrrtorttMifwute In
•Miar(1)tlwraAMllono1tolalvoluiMwojuai^o1hazaid^ ttw
hazardous watto, or both, to long M aueh reduction is ooncialwit wth the goal of mlnlmizkig prM«nt and
tutur«thrMto to human hMlhandtha«nvhi>iWMiil(B>A%RaportloCkinv«aa,10«,E^
SOURCE REDUCTION
Any actlwty that raduoaa or aUminata* ttw ganaratlon of hazardout wart* at th« aouroa, uaualy wthta a
prooMi (op. dL).
RECYCLING
A miiwial b Iraeydad* 11 b IM^ i«UM4 or iveWmad (^
11 MI attar (1) amptoyad M an (nguadiant (Jnchxino to uaa at an intarm«dlata)tomakaaproduct;howav«ra
fHMftAB^kl laiM MJ^ AAft^tu flik^B ^^KBK^JIdjh^ H jJI^^^MM^ .^t^ujuut^^^^ ^^ AL^ ^^^^^^^1^^ ^i^^ • ^.^ — m -- Mg^A^ ^h^k^
nwHinw WM im Muny ma oonowon • vaanBi uufiipoiwm 01 vw IIIUMM an IWJMWWWJ •• aapvan vno
producto (at wnan matah art raomwrad from matal oortaMng aaoondaty matoriahi) or (2) «rnployad In a
pariipuivfinclionasManao**at*atti^ (e) d)). A iMtorW to
•radalmad" 11 la ptooaaatd to raoovw • utaM produot or I k la rao*n*ratad ExamplMbwtudattwraomwy
of laad valuat fmm apant battwiaa and tha raganantfen of apart io»v«f«i(40CFR2ei.l (c)(4)).
Flgura 1-1. Wvate Mlnlmteailon D«flnttlon«
-------
WASTE MINIMIZATION TECHNIQUES
RECYCLING
(ONSITE AND OFFSITE)
SOURCE REDUCTION
USE AND REUSE
RECLAMATION
SOURCE CONTROL
Processed for
resource recovery
Product substitution
Product oonservinW)
Change in product
* Return to original process
-Raw material subetitutt
for another process
INPUT MATERIAL
CHANGES
TECHNOLOGY
CHANGES
GOOD OPERATING
PRACTICES
Equipment, piping, or
layout changes
Additional automation
Changes in operational
settings
Procedural measures
Lost prevention
Management practi
Waste stream segregation
Material handing
improvements
Production schedulng
Figure 1-2. Waste Minimization Techniques
-------
Figure 1-3. The Waste Minimization Aaaeaament Procedure
The recognized need to minimize wart*
PLANNING AND ORGANIZATION
* Get management eommfcment
• Set over*! aMeMmerrt program goal* .
• Organize a**e**ment program ta*k rorce
Aaeeaement organization
wwJ coffHiUuiMfit to i
ASSESSMENT PHASE
1 Coleet proceee and fedtty data
• PrtorMie and aateet ataeaament target*
• Review data and taped ate
> Generate option*
'Screen and select option* tor farther etudy
nt report of
FEAWBIUTY ANALYSIS PHASE
* Technical evaluation
* Economic evaluation
Final report. Including
recommended option* i
IMPLEMENTATION
• Jua% project* and obtain funding
• hwtalation (equipment)
* Implementanon (procedure)
* Evaluate performance
Suooaaafufly Implemented
waate minimization projeda
liianment target*
and reeveluale
prevlom option*
Repeat the i
-------
Incentives for Waste Minimization
There are a number of compelling incentives for
minimizing waste. Table 1-1 summarizes some of
these incentives.
Tab)* 1-1. Waste Minimization InoantlVM
Economics
• Landfill disposal cost Increases.
• Costly alternative treatment technologies.
• Savings in raw material and manufacturing costs.
Reputation*
• Certification of a WM program on the hazardous waste
manifest.
• Biennial WM program reporting.
• Land disposal restrictions and bans.
• Increasing permitting requirements for waste handling
and treatment
U&Bty
• Potential reduction in generator liability for environmental
problems at both onsfte and offsfte treatment, storage,
• Potential reduction in BabiHty for worker safety.
Pubic Image and Envtorwnentiv Concern
• Improved image In the community and from employees.
• Concern for improving the environment
EPA intends to publish a manual entitled "Waste
Minimization Benefits Handbook" which wRI discuss in
detail the cost/benefit analyses of WM options.
About this manual
This manual has been prepared for those responsbte
for planning, managing, and implementing waste
minimization activities at the plant and corporate levels.
The manual concentrates on procedures that motivate
people to search, screen, and put Into practice
measures involving administrative, material, or
technology changes that result In decreased waste
generation. It Is also a source of concepts and Ideas
for developing and implementing a waste minimization
program.
The manual to organized as foBows:
• Section 2 outRnes the planning ard organizational
aspect
waste i
aspects that provide a necessary foundation for a
i minimization i
Section 3 describes the assessment phase,
including collecting information, selecting
assessment targets, selecting assessment teams,
and identifying potential WM options.
Section 4 discusses the methods for evaluating
options for technical and economic f easbitty.
• Section 5 describes the implementation of attractive
options: obtaining funding, installation and
Implementation, and measuring the effectiveness
of implemented options.
A set of worksheets useful in carrying out assessments
Is included in Appendix A. Because individual
.generators' circumstances and needs vary widely,
users of this manual are encouraged to modify the
procedures and worksheets to fit their unique
requirements. The manual is intended to serve as a
point of departure, rather than as a set of rigid
requirements. Accordingly, Appendix B presents a
simplified set of worksheets that are designed to assist
generators who are interested in performing only
preliminary assessments. These worksheets also
provide a useful framework for conducting
assessments for smal businesses and small quantity
generators.
A sample assessment Is presented In Appendix C.
Appendix D describes waste streams from common
industrial operations. Appendix E te a catalog and brief
description of waste minimization techniques
applicable in a number of common waste-intensive
operations. Appendix F is a list of addresses and
telephone numbers of state programs for technical
assistance in waste minimization. Appendix G
presents describes a method for screening and rating
potential waste minimization options for further study.
Finally, an example of an economic feasibility analysis
of a large waste minimization project Is presented In
Appendix H.
-------
Section 2
Planning and Organization
The recognized need to minimize watt*
i
PLANNING AND ORGANIZATION
Get management oommttmant
Sat overaJ aaaaaament program goals
Organize aaaaaamant program task force
Assessment
Phase
FeasbilKy
Analysis Phase
Success! uty implemented
waste minimization projects
This section discusses factors thai are Important to the
success of a waste minimization program. Because a
comprehensive WM program affects many functional
groups within a company, the program needs to bring
these different groups together to reduce wastes.
The formality of the program depends upon the size
and complexity of the organization and its waste
problems. The program structure must be flextole
enough to accommodate unforeseen changes. The
developmental activities of a WM program include:
• getting management commitment
• setting WM goals
• staffing the program task force
Getting Managtmtnt Commltmtnt
The management of a company wfll support a waste
minimization program If K is convinced that the benefits
of such a program will outweigh the costs. The
potential benefits include economic advantages,
compliance with regulations, reduction In liabilities
associated with the generation of wastes, improved
public image, and reduced environmental Impact
The objectives of a WM program are best conveyed to
a company's employees through a formal pofcy
statement or management directive. A company's
upper management is responsible for establishing a
formal commitment throughout all divisions of the
organization. The person in charge of the company's
environmental affairs is responsible to advise
management of the importance of waste minimization
arid trie need for this formal commitment. An example
of a formal policy statement follows:
CORPORATE ENVIRONMENTAL POLICY
[A major chemical company].. .*to committed to continue
excellence, leadership, and stewardship In protecting the
environment. Environmental protection is a primary
management responsMMy, aa wad as the responsibility of
every employee.
In keeping wth this poftcy, our objective aa a company Is to
reduce wast* and achieve minimal adverse Impact on the air.
water, and land through axoatsno* In environmental control
The Environmental QuktaNM* include the following points:
• Environmental protection is a On* reeponsMNty and an
important measure of employee performance. In addi-
tion, every employ** is reeponsfcle for environmental
protection In the same manner he or she is for safety.
• Minimizing or eliminating the generation of wast* has
been and continues to be a prime consideration hi
research, process design, and plant operations; and is
viewed by management lice safety, yield, and loss
Reuse and recycftng of materials has been and wll
continue to be given first consideration prior to
dassfteatton and disposal of waste.*
/nvorV* Employe**
Alhough management commitment and direction art
fundamental to the success of a waste minimization
program, commitment throughout an organization Is
necessary in order to resolve conflicts and to remove
barriers to the WM program. Employees often cause
the generation of waste, and they can contribute to the
overall success of the program. Bonuses, awards.
plaques, and other forms of recognition are often used
to provide motivation, and to boost employee
cooperation and participation. In some companies.
meeting the waste minimization goals to used as a
measure for evaluating the Job performance of
managers and employees.
6
-------
Cans* Chimplon*
Any WM program needs one or more people to
champion the cause. These "cause champions' help
overcome the inertia present when changes to an
existing operation art proposed. They also toad the
WM program, either formally or Informally. An
environmental engineer, production manager, or plant
process engineer may be a good candidate for this
role. Regardless of who takes the toad, this cause
champion must be given enough authority to
effectively cany out the program.
Organizing a WM Program:
The Program Task Force
The WM program wB affect a number of groups w&Nn a
company. Fir this reason, a program task force should
be assembled. This group should include members of
any group or department in the company that has a
significant interest In the outcome of the program.
Tabte 2-4 at the end of this section and Worksheet 3 In
Appendix A lists departments or groups of a typical
manufacturing company that should be involved in the
program.
The formality or informality of the WM program will
depend on the nature of the company. The program in
a large highly structured company will probably
develop to be quite formal, hi contrast to a small
company, or a company in a dynamic Industry, where
the organizational structure changes frequently.
Table 2-1 lists the typical responsibilities of a WM
program task force. It will draw on expertise within the
company as required. The scope of the program wBI
determine whether fuH-tlme participation is required by
any of the team members.
Table 1-1. Reepon*lbilHle« of the WM Program
Task Force
Get commitment and • statement of policy from
management
Establish overall WM program goals.
Establish a wasts tracking system.
Prioritize the waste streams or facility areas for
assessment.
Select assessment teams.
Conduct (or supervise) assessments.
Conduct (or monitor) technical/economic feasibility
analyses of favorable options.
Select and Justify feast* options for implementation.
Obtain funding and establish schedule for
^MMl^MK^fl«tMftb*M
iiipieiiieiiiaiiun.
MonAor (and/or direct) implementation progress.
Monitor performance of the option, one* It is operating.
In a small company, several people at most wW be al
that anj retired to implement a WM program. Include
the people with responsblky for production, facilities,
maintenance, quality control, and waste treatment and
disposal on the team, it may be that a single person,
such as the plant manager, has all of these
responsibilities at a smaJ facility. However, even at a
srnaB faclBty, at toast two people should be Involved to
get a variety of viewpoints and perspectives.
Some larger companies have developed a system in
which assessment teams periodically visit different
facilities within the company. The benefits result
through sharing the Ideas and experiences with other
divisions. Similar results can be achieved wfth periodic
in-house seminars, workshops, or meetings. A large
chemical manufacturer held a corporate-wide
symposium hi 1986 deaRng specifically with waste
minimization. Trie company has also developed other
programs to Increase company-wide awareness of
waste minimization, including an internally published
newsletter and videotape.
Salting Goala
The first priority of the WM program task force Is to
establish goals that are consistent with the policy
adopted by management. Waste minimization goals
can be qualitative, for example, "a significant reduction
of toxic substance emissions Into the environment.'
However, it to better to establish measurable,
quantifiable goals, since qualitative goals can be
interpreted ambiguously. Quantifiable goals establish
a dear guide as to the degree of sucess expected of
the program, A major chemical company has adopted a
corporate-wide goal of 5% waste reduction per year. In
addition, each faclity within the company has set its
own watte minimization goals.
As part of Is general polcy on hazardous waste, a targe
defense contractor has established an ambitious
corporate-wide goal of zero discharge of hazardous
wastes from its facilities by the end of 1988. Each
division within the corporation to given the
responsWUry and freedom to develop Is own program
(wWi intermediate goals) to meet thto overal goal. This
has resulted in an extensive investigation of
procedures and technologies to accomplish source
reduction, recycling and resource recovery, and onaMe
treatment.
Tabto 2-2 ists the qualities that goals sriouW poeeesa.
it is Important that the company's overall waste
mWmizatJon goals be incorporated Into the appropriate
individual departmental goals.
The goals of the program should be reviewed
penodlcaly. As the focus oftheWM program becomes
more defined, the goals should be changed to reflect
any changes. Watte mWrntzatton assessments are not
Intended to be a one-time prelect. Periodic
revaluation of goals to recommended due to
changes, tor example, hi avalabte technology,
-------
Table 2-2. AttrlbutM of Effective Goals
ACCEPTABLE to those who wi work to achieve them.
FLEXIBLE and adaptable to changing requirements.
MEASURABLE over time.
MOTIVATIONAL
SUITABLE to th« overall corporate goat* and mission.
UNDERSTANDABLE
ACHIEVABLE wth a practical lava! of aftort
Source: Pearca and Robinson, Strategic Management
(1985)
material supplies, environmental regulations, and
economic dniate.
Overcoming Barriers
As tt sets goals for waste minimization and then defines
specific objectives that can be achieved, the program
task force should recognize potential barriers.
Although waste minimization projects can reduce
operating costs and Improve environmental
compliance, they can lead to conflicts between
different groups wkhin the company. Table 2-3 Usts
examples of juriadterjonal conflicts that can arise during
the implementation of a waste minimization project
in addition to jurisdiction*! conflicts related to these
objective barriers, there are attitude-related barriers
that can disrupt a WM program. A commonly held
attitude is "V I ain't broke, donl fix IP This attitude
stems from the desire to maintain the status quo and
avoid the unknown. It is also based on the fear that a
new WM option may not work as advertised. Without
the commitment to carefuly conceive and implement
the option, this attftuda can become a self-fulfilling
prophecy. Management must declare that "It is broker
Another attitude-related barrier is the feeling that It
just wont workf This response is often given when a
person does not fully understand the nature of the
proposed option and its Impact on operations. The
danger here is that promising options may be dropped
before they can be evaluated. One way to avoid this is
to use idea-generating sessions (e.g., brainstormjng).
This encourages participants to propose a large
number of options, .which are indhridualy evaluated on
their merits.
An often-encountered barrier is the fear that the WM
option will diminish product quality. This is particularly
common In situations where unused feed materials are
recovered from the waste and then recycled back to
the process. The deterioration of product quality can
be a vaHd concern I unacceptable concentrations of
waste materials buld up in the system. The best way to
allay this concern is to set up a small-scale
demonstration in the facility, or to observe the
particular option in operation at another facility.
Table 2-3. Ex amp Us of Barrlare to Waata
Minimization
Pt
• A new operating procedure wM reduce waste but may also
that decreases the overall production
be a boManac
rate.
• Production will be afoppad while the naw process
• A new piett of equipment has rot been o^tnenstrsted In a
It nuy not WOIK ntwo«
Adequate space is not available for the installation of naw
equipment
• Adequate utilities are not available for the naw
equipment.
• Engineering or construction manpower will not be
ayalable In tin* to meat the project schedule.
• Extensive maintenance may be required.
Quiify Control
• More intensive QC may be needed.
• Mora rework may be required
• Changes in product characteristics may affect customer
acceptance.
• A program to reduce inventory (to avoid material
deterioration and reprocessing) may lead to stockouts
during high product demand.
nnanoa
• There is not enough money to fund the project.
• Existing stocks (or binding contracts) wRI daisy the
replacement of a hazardous materiel with a non-
hazardous substitute.
Accepting another plant's waata aa a
require a lengthy resolution of regulatory Issues.
Use of a new nonhazardoua raw material wH adversely
Impact the existing wsstewatsr treatment f acffty.
Planning and Organization Summary
Table 2-4 provides a summary of the steps Involved in
planning and organizing a waste irinbifeatton program.
Assessment Worksheets
Appendix A Includes a set of worksheets for use hi
planning and carrying out a waste minimization
assessment, and implementing the selected options.
Worksheet 1 summarizes the entire assessment
procedure. Worksheets 2 and 3 are used to record the
organization of the WM program task force and the
8
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individual assessment teams, respectively. Worksheet
3 includes a list of (unctions and departments that
should be considered when organizing the
assessment teams.
Table 2*4. Planning and Organization Actlvltlea
Summary
SETTING UP THE PROGRAM
Get management commitment to:
• Establish waste minimization aa a company goal.
* Establish a waste minimization program to meet this
goal.
» Give authority to the program task force to
implement this program.
Sat overall goals for the program. These goals should be:
* ACCEPTABLE to trose who wtil work to achieve
them,
FLEXIBLE to adapt to changing requirements.
MEASURABLE over time.
MOTIVATIONAL
SUITABLE to the overall corporate goals.
UNDERSTANDABLE
ACHIEVABLE with a practical level of effort.
STAFFING THE PROGRAM TASK FORCE
Find a 'causa champion", with the following attributes:
• Familiar with the facility, its production processes,
and its waste management operations.
• Familiar with the people.
* Familiar with quality control requirements,
* Good rapport with management.
* Familiar with new production and waste
management technology.
* Familiar with WM principles and tachniquaa, and
environmental regulations.
* Aggressive managerial style.
Gat people who know the facility, processes, and
procedures.
Gat people from the affected departments or groups.
Production.
Facilities/Maintenance.
Process Engineering.
Quality Control.
Environmental
Research and Development.
Safety/Health.
Marketing/Client Relations.
Purchasing.
Material Control/Inventory.
Legal.
Finance/Accounting.
Information Systems.
GETTING COMPANY-WIDE COMMITMENT
Incorporate the company's WM goats Into departmental
goals.
Solid! employe* cooperation and participation.
Develop incentives and/or awards for managers and
employees.
9
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Section 3
Assessment Phase
The recognized need to minimize wwlt
Planning end
Organization
ASSESSMENT PHASE
* Collect procaaa and facility date
* Prioritize and aalael aaaeaament targets
• Salad people for aaaaaamant taama
• Review data and inapect aft*
• Generate opttona
• Screen and aelect opttona for further study
FeaalbUity
AnaVeie Phaae
SuoceaafuRy implemented
waate minimizatton projects
The purpose of trie assessment phase is to develop a
comprehensive set of waste minimization options, and
to identify the attractive options that deserve
additional, more detailed analysis. In order to develop
these WM options, a detailed understanding of the
plant's wastes and operations is required. The
assessment should begin by examining information
about the processes, operations, and waste
management practices at the faculty.
Collecting and Compiling Data
The questions that thte information gathering effort wiB
attempt to answer include the following:
* What are the waste streams generated from the
plant? And how much?
• Which processes or operations do these waste
streams come from?
• Which wastes are classified as hazardous and which
are not? What rnakes them hazardous?
• What are the input materials used that generate the
waste streams of a particular process or plant area?
• How much of a particular input material enters each
waste stream?
• How much of a raw material can be accounted for
through fugitive losses?
• How efficient to the process?
* Are unnecessary wastes generated by mixing
otherwise recyclable hazardous wastes with other
process wastes?
• What types of housekeeping practices are used to
limit the quantity of wastes generated?
* What types of process controls are used to improve
process efficiency?
Table 3-1 lists Information that can be useful In
conducting the assessment. Reviewing this
information will provide important background for
understanding the plant's production and
maintenance processes and wll allow priorities to be
determined. Worksheets 4 through 10 in Appendix A
can be used to record the information about site
characteristics, personnel, processes, input materials,
products, and waste streams. Worksheets 82 through
S6 in Appendix B are designed to record the same
information, but in a more simplified approach.
Mfeefe Stream Records
One of the first tasks of a waste minimizatton
assessment Is to identify and characterize the facltty
waste streams, information about waste streams can
come from a variety of sources. Some Information on
waste quantities is readtty available from the completed
hazardous waste manifests, which include the
description and quantity of hazardous waste shipped
to a TSDF. The total amount of hazardous waste
shipped during a one-year period, for example, is a
convenient means of measuring waste generation and
waste reduction efforts. However, manifests often tack
such information as chemical analysis of the waste,
specific source of the waste, and the time period
during which the waste was generated. Also,
manifests do not cover wastewater effluents, air
emissions, or nonhazardous sold wastes.
Other sources of information on waste str earns include
biennial reports and NPDES (National PoMant
10
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Table 3-1. Facility Information for WM
Assessment*
Design Information
* Process flow diagrams
* Material and heat balances (both design balances and
actual balances) for
production processes
pollution control processes
Operating manuals and process descriptions
Equipment lists
Equipment specifications and data sheets
Piping and instrument diagrams
Plot and elevation plans
Equipment layouts and work flow diagrams
Environmental Information
Hazardous waste manifests
Emission inventories
Biennial hazardous waste reports
Waste analyses
Environmental audit reports
Permits and/or permit applications
Raw Material/Production Information
Product composition and batch sheets
Material application diagrams
Material safety data sheets
Product and raw material inventory records
Operator data togs
Operating procedures
Production schedules
Economic Information
• Waste treatment and disposal costs
* Product, utility, and raw material costs
• Operating and maintenance costs
* Departmental cost accounting reports
Other Information
* Company environmental policy statements
• Standard procedures
* Organization charts
Discharge Elimination System) monitoring reports.
These NPDES monitoring reports will include the
volume and constituents of wastewaters that are
discharged. Additionally, toxic substance release
inventories prepared under the "right to know'
provisions of SARA TKIe 111, Section 313 (Superfund
Amendment and Reauthorization Act) may
providevaluable information on emissions into all
environmental media (land, water, and air).
Analytical test data available from previous waste
evaluations and routine sampling programs can be
helpful if the focus of the assessment is a particular
chemical within a waste stream.
Flow Diagrams and Material Balances
Flow diagrams provide the basic means for identifying
and organizing information that is useful for the
assessment. Flow diagrams should be prepared to
identify important process steps and to identify
sources where wastes are generated. Flow diagrams
are also the foundation upon which material balances
are built.
Material balances are important for many WM projects,
since they allow for quantifying losses or emissions
that were previously unaccounted for Also, material
balances assist in developing the following
information:
* baseline for tracking progress of the WM efforts
• data to estimate the size and cost of additional
equipment and other modifications
* data to evaluate economic performance
In Its simplest form, the material balance Is represented
by the mass conservation principle:
Mass in » Mass out + Mass accumulated
The material balance should be made individually for all
components that enter and leave the process. When
chemical reactions take place in a system, there is an
advantage to doing "elemental balances* for specific
chemical elements In a system.
Material balances can assist in determining
concentrations of waste constituents where analytical
test data is limited. They are particularry useful where
there are points in the production process where ft Is
difficult (due to inaccessibility) or uneconomical to
collect analytical data. A material balance can help
determine if fugitive losses are occurring. For
example, the evaporation of solvent from a parts
cleaning tank can be estimated as the difference
between solvent put Into the tank and solvent
removed from the tank.
To characterize waste streams by material balance can
require considerable effort. However, by doing so, a
more complete picture of the waste situation results.
This helps to establish the focus of the WM activities
and provides a baseline for measuring performance.
Appendix D lists potential sources of waste from
specific processes and operations.
Sources of Material Balance Information
By definition, the material balance includes both
materials entering and leaving a process. Table 3-2
lists potential sources of material balance information.
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Table 3-2. Source* of Material Balance
Information
Sample*, analyses, and flow measurements of feed
stocks, products, and waste streams
Raw material purchase records
Material inventories
Emission inventories
Equipment cleaning and validation procedures
Batch make-up records
Product specifications
Design material balances
Production records
Operating logs
Standard operating procedures and operating manuals
Waste manifests
Material balances are easier, more meaningful, and
more accurate when they are done for individual units,
operations, or processes. For this reason, it is
important to define the material balance envelope
properly. The envelope should be drawn around the
specHc area of concern, rather than a larger group of
areas or the entire fadtty. An overal material balance
for a facility can be constructed from individual untt
material balances. This effort will highlight
Interrelationships between units and wll help to point
out areas for waste minimization by way of cooperation
between different operating units or departments.
Pitfalls In Preparing Material Balances
There are several factors that must be considered
when preparing material balances in order to avoid
errors that could significantly overstate or understate
waste streams. The precision of analytical data and
flow measurements may not allow an accurate measure
of the stream. In particular, in processes with very large
Inlet and outlet streams, the absolute error in
measurement of these quantities may be greater in
magnitude than the actual waste stream tee*. In this
case, a reliable estimate of the waste stream cannot be
obtained by subtracting the quantity of hazardous
material in the product from that in the feed.
The time span is Important when constructing a
material balance. Material balances constructed over a
shorter time span require more accurate and more
frequent stream monitoring in order to close the
balance. Material balances performed over the
duration of a complete production run are typically the
easiest to construct and are reasonably accurate. Time
duration also affects the use of raw material purchasing
records and onsite inventories for calculating input
material quantities. The quantities of materials
purchased during a specific time period may not
necessarily equal the quantity of materials used in
production during the same time period, since
purchased materials can accumulate In warehouses or
stockyards.
Developing material balances around complex
processes can be a complicated undertaking,
especially if recycle streams are present. Such tasks
are usually performed by chemical engineers, often
with the assistance of computerized process
simulators.
Material balances will often be needed to comply with
Section 313 of SARA (Superfund Amendment and
Reauthorization Act of 1986) In establishing emission
inventories for specific toxic chemicals. EPA's Office
of Toxic Substances (OTS) has prepared a guidance
manual entitled Estimating Releases and Waste
Treatment Efficiencies for the Toxic Chemicals
Inventory Form fEPA S6Q/A^fl-Q21. The OTS manual
contains additional information for developing material
balances for the listed toxic chemicals. The information
presented in this manual applies to a WM assessment
when the material balances are for Individual
operations being assessed rather than an overall
facility, when the variations in flow over time is
accounted for, and when the data is used from
separate streams rather than from aggregate streams.
Tracking Wastes
Measuring waste mass flows and compositions Is
something that should be done periodically. By
tracking wastes, seasonal variations in waste flows or
single large waste streams can be distinguished from
continual, constant flows. Indeed, changes in waste
generation cannot be meaningfully measured unless
the information Is collected both before and after a
waste minimization option is implemented.
Fortunately, ft is easier to do material balances the
second time, and gets even easier as more are done
because of the "learning curve" effect In some larger
companies, computerized database systems have
been used to track wastes. Worksheets 9 and 10 in
Appendix A (and Worksheet S6 in Appendix B)
provide a means of recording pertinent waste stream
characteristics.
Prioritizing Waste Streams and/or
Operations to Assess
Ideally, an waste streams and plant operations should
be assessed. However, prioritizing the waste streams
and/or operations to assess Is necessary when
available funds and/or personnel are limited. TheWM
assessments should concentrate on the most
important waste problems first, and then move on to
the tower priority problems as the time, personnel, and
budget permit.
Setting the priorities of waste streams or facility areas to
assess requires a great deal of care and attention,
since this step focuses the remainder of the
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assessment activity. Table 3*3 lists important criteria to
consider when setting these priorities.
Table 3-3. Typical Consideration*
Prioritizing Watt* Streams to Aeaeca
for
Compliance with currant and future regulations.
Costs of wast* management (treatment and disposal).
Potential environmental and safety liability.
Quantity of wast*.
Hazardous properties of th* wast* (including toxictty,
flammability, corrosivtty, and reactivity).
Other safety hazards to employees.
Potential for (or ease of) minimization.
Potential for removing bottlenecks in production or wast*
treatment.
Potential recovery of valuable by-products.
Available budget for the wast* minimization assessment
program and projects.
Worksheet 10 in Appendix A (Worksheet S6 in
Appendix B) provides a means for evaluating waste
stream priorities for the remainder of the assessment.
Small businesses, or large businesses with only a few
waste generating operations should assess their entire
fadlfty. It is also beneficial to took at an entire facility
when there are a large number of simitar operations.
Similarly, the implementation of good operating
practices that involve procedural or organizational
measures, such as soliciting employee suggestions,
awareness-building programs, better inventory and
maintenance procedures, and internal cost accounting
changes, should be implemented on a facility-wide
basis. Since many of these options do not require
large capital expenditures, they should be
implemented as soon as practical.
Selecting the Assessment Teams
The WM program task force is concerned with the
whole plant. However, the focus of each of the
assessment teams is more specific, concentrating on a
particular waste stream or a particular area of the plant.
Each team should include people with direct
responsibility and knowledge of the particular waste
stream or area of the plant. Table 3-4 presents four
examples of teams for plants of various sizes in
different industries.
In addition to the internal staff, consider using outside
people, especially in the assessment and
implementation phases. They may be trade
association representatives, consultants, or experts
from a different facility of the same company. In large
multi-division companies, a centralized staff of experts
at the corporate headquarters may be available. One
or more "outsiders* can bring in new ideas and provide
an objective viewpoint. An outsider also is more likely
to counteract bias brought about by "inbreeding*, or
Table 3-4. Example* of WM Assessment Team*
1. Metal finishing department in a large defense contractor.
• Metal finishing department manager
• Process engineer responsible for metal finishing
processes
• Facilities engineer responsible for metal finishing
department*
* Wastewater treatment department supervisor
* Staff environmental engineer
2. Small pesticide formulator.
* Production manager*
* Environmental manager
* Maintenance supervisor
* Pesticide industry consultant
3. Cyanide plating operation at a military facility.
* Internal assessment team
Environmental coordinator*
Environmental engineer
Electroplating facility engineering supervisor
Metallurgist
Materials science group chemiet
Outside assessment team
Chemical engineer* (2)
Environmental engineering consultant
Plating chemistry consultant
Large off set printing facility.
* Internal assessment team
Plant vice president
FUm processing supervisor
Pressroom supervisor
Outside assessment team
Chemical engineers (2)*
Environmental scientist
Printing Industry technical consultant
• Team leader
the "sacred cow* syndrome, such as when an old
process area, rich in history, undergoes an
assessment.
Outside consultants can bring a wide variety of
experience and expertise to a waste minimization
assessment. Consultants may be especially useful to
smaller companies who may not have in-house
expertise in the relevant waste minimization
techniques and technologies.
Production operators and line employees must not be
overlooked as a source of WM suggestions, since they
possess firsthand knowledge and experience with the
process. Their assistance is especially useful in
assessing operational or procedural changes, or in
equipment modifications that affect the way they do
their work.
•Quality circles* have been Instituted by many
companies, particularly in manufacturing Industries, to
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improve product quality and production efficiency.
These quality circles consist of meetings of workers
and supervisors, where improvements are proposed
and evaluated. Quality circles are beneficial in that they
involve the production people who are closely
associated with the operations, and foster participation
and commitment to improvement. Several large
companies that have quality circles have used them as
a means of soliciting successful suggestions for waste
minimization.
Site Inspection
With a specific area or waste stream selected, and with
the assessment team in place, the assessment
continues with a visit to the site. In the case where the
entire assessment team is employed at the plant being
assessed, the team should have become very familiar
with the specific area in the process of collecting the
operating and design data. The members of the
assessment team should familiarize themselves with
the site as much as possible. Although the collected
information is critical to gaining an understanding of the
processes involved, seeing the site is important in
order to witness the actual operation. For example, in
many instances, a process unit is operated differently
from the method originally described in the operating
manual. Modifications may have been made to the
equipment that were not recorded in the flow diagrams
or equipment lists.
When people from outside of the plant participate in
the assessment, it is recommended that a formal site
inspection take place. Even when the team is made up
entirely of plant employees, a site inspection by all
team members is helpful after the she information has
been collected and reviewed. The inspection helps to
resolve questions or conflicting data uncovered during
the review. The site inspection also provides
additional information to supplement that obtained
earlier.
When the assessment team includes members
employed outside of the plant, the team should
prepare a list of needed information and an inspection
agenda. The list can be presented In the form of a
checklist detailing objectives, questions and issues to
be resolved, and/or further information requirements.
The agenda and information list are given to the
appropriate plant personnel in the area* to be
assessed early enough before the visit to allow them to
assemble the Information in advance. Of course, It may
be that the assessment team members themselves are
in the best position to collect and compile much of the
data. By carefully thinking out the agenda and needs
list, important points are less likely to be overlooked
during the inspection. Table 3-S presents useful
guidelines for the site Inspection.
Table 3-5. Guidelines for the Sit* Inspection
• Prepare an agenda in advance that covers all point* that
still require clarification. Provide staff contacts in the
area being assessed with the agenda several days
before the inspection.
• Schedule the inspection to coincide with the particular
• operation that is of interest (e.g., make-up chemical
addition, bath sampling, bath dumping, start-up.
shutdown, etc.).
• Monitor the operation at different times during the shift.
and if needed, during all three shifts, especially when
waste generation is highly dependent on human
involvement (e.g., in painting or parts cleaning
operations).
• Interview the operators, shift supervisors, and foremen in
the assessed area. Do not hesitate to question more
than one person if an answer is not forthcoming. Assess
the operators' and their supervisors' awareness of the
waste generation aspects of the operation. Note their
familiarity (or lack thereof) with the impacts their
operation may have on other operations.
• Photograph the area of interest, if warranted.
Photographs are valuable in the absence of plant layout
drawings. Many details can be captured in photographs
that otherwise could be forgotten or inaccurately recalled
at a later date.
• Observe the "housekeeping" aspects of the operation.
Check for signs of spills or leaks. Visit the maintenance
shop and ask about any problems In keeping the
equipment leak-free. Assess the overall cleanliness of
the site. Pay attention to odors and fume*.
• Assess the organizational structure and level of
coordination of environmental activities between variow
department*.
• Assess administrative controls, such as cost accounting
procedure*, material purchasing procedure*, and waste
collection procedures.
In performing the she inspection the assessment team
should follow the process from the point where raw
materials enter the area to the point where the
products and the wastes leave the area. The team
should identify the suspected sources of waste. This
may include the production process; maintenance
operations; storage areas for raw materials, finished
product, and work-in-process. Recognize that the
plant's waste treatment area itself may also offer
opportunities to minimize waste. This inspection often
results in forming preliminary conclusions about the
causes of waste generation. Fun confirmation of these
conclusions may require additional data collection,
analysis, and/or site visits.
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Generating WM Options
Once the origins and causes of waste generation are
understood, the assessment process enters the
creative phase. The objective of this step is to
generate a comprehensive set of WM options for
further consideration. Following the coHectton of data
and site inspections, the members of the team will
have begun to identify possible ways to minimize
waste in the assessed area. Identifying potential
options relies both on the expertise and creativity of
the team members. Much of the requisite knowledge
may come from their education and on-the-job
experience, however, the use of technical literature,
contacts, and other sources is always helpful. Some
sources of background information for waste
minimization techniques are listed in Table 3-6.
Table 3*6. Source* of Background Information
on WM Option*
Trade attodationa
A* part of their overall function to aaaiat companies
within their industry, trad* association* generally
provide assistance and information about environmental
regulations and various available techniques for
complying with these regulations. The information
provided is especially valuable since it is industry-
specific.
Plant engineer* and opinion
The employees that are intimately familiar with a faculty's
operations are often the best source of suggestions for
potential WM options.
Published literature
Technical magazines, trade journals, government
reports, and research briefs often contain information
that can be used as waste minimization options.
Stale and local environmental agendea
A number of states and local agencies have, or are
developing, programs that include technical assistance,
information on industry-specific waste minimization
techniques, and compiled bibliographies. Appendix E
provides a list of addresses for state and federal
programs for WM assistance.
Equipment vendor*
Meetings with equipment vendors, as wen as vendor
literature, are particularly useful in identifying potential
equipment-oriented options. Vendors are eager to assist
companies in implementing projects. Remember, though,
that the vendor's job is to sell equipment
Consultant*
Consultants can provide information about WM
techniques. Section 2 discusses the use of consultants
In WM programs. A consultant wfch wast* minimization
experience in your particular industry is most desirable.
Waato Minimization Options
The process for identifying options should follow a
hierarchy in which source reduction options are
explored first, followed by recycling options. This
hierarchy of effort stems from the environmental
desirability of source reduction as the preferred means
of minimizing waste. Treatment options should be
considered only after acceptable waste minimization
techniques have been identified.
Recycling techniques allow hazardous materials to be
put to a beneficial use. Source reduction techniques
avoid the generation of hazardous wastes, thereby
eliminating the problems associated with handling
these wastes. Recycling techniques may be
performed onsite or at an offsfte facility designed to
recycle the waste.
Source reduction techniques are characterized as
good operating practices, technology changes,
material changes, or product changes. Recycling
techniques are characterized as use/reuse techniques
and resource recovery techniques. • These techniques
are described below:
Source Reduction: Good Operating
Practice*
Good operating practices are procedural,
administrative, or institutional measures that a company
can use to minimize waste. Good operating practices
apply to the human aspect of manufacturing
operations. Many of these measures are used in
industry largely as efficiency improvements and good
management practices. Good operating practices can
often be implemented with little cost and, therefore,
have a high return on investment These practices can
be Implemented in all areas of a plant, including
production, maintenance operations, and in raw
material and product storage. Good operating
practices include the following:
Waste minimization programs
Management and personnel practices
Material handling and inventory practices
Loss prevention
Waste segregation
Production scheduling
Management and personnel practices include
employee training, incentives and bonuses, and other
programs that encourage employees to
conscientiously strive to reduce waste. Material
handling and inventory practices include programs to
reduce loss of input materials due to mishandling,
.expired shelf life of time-sensitive materials, and
proper storage conditions. Loss prevention minimizes
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wastes by avoiding leaks from equipment and spills.
Waste segregation practices reduce the volume of
hazardous wastes by preventing the mixing of
hazardous and nonhazardous wastes. Cost
accounting practices include programs to allocate
waste treatment and disposal costs directly to the
departments or groups that generate waste, rather
than charging these costs to general company
overhead accounts. In doing so, the departments or
groups that generate the waste become more aware of
the effects of their treatment and disposal practices,
and have a financial incentive to minimize their waste.
By judicious scheduling of batch production runs, the
frequency of equipment cleaning and the resulting
waste can be reduced.
Goad Operating Practices
A large consumer product company in California
adopted a corporate policy to minimize the
generation of hazardous waste. In order to
implement the policy, the company mobilized
quality circles made up of employees representing
areas within the plant that generated hazardous
wastes. The company experienced a 75%
reduction in the amount of wastes generated by
instituting proper maintenance procedures
suggested by the quality circle teams. Since the
team members were also line supervisors and
operators, they made sure the procedures were
followed.
Source Reduction: Technology Changes
Technology changes are oriented toward process and
equipment modifications to reduce waste, primarily In a
production setting. Technology changes can range
from minor changes that can be implemented in a
matter of days at low cost, to the replacement of
processes involving large capital costs. These
changes include the following:
• Changes in the production process
• Equipment, layout, or piping changes
• Use of automation
• Changes in process operating conditions, such as
- Flow rates
• Temperatures
- Pressures
- Residence times
Srampte: Technology Changes
A manufacturer of fabricated metal products
cleaned nickel and titanium wire in an alkaline
chemical bath prior to using the wire in their product.
In 1986, the company began to experiment with a
mechanical abrasive system. The wire was passed
through the system which uses silk and carbide
pads and pressure to brighten the metal. The
system worked, but required passing the wire
through the unit twice for complete cleaning. In
1987. The company bought a second abrasive unt
and installed It in series with the first unit. This
system allowed the company to completely
eliminate the need for the chemical cleaning bath.
Source Reduction: Input Material Changes
Input material changes accomplish waste minimization
by reducing or eHminatlng the hazardous materials that
enter the production process. Also, changes in input
materials can be made to avoid the generation of
hazardous wastes within the production processes.
Input material changes include:
• Material purification
• Material substitution
Example: Inout Material Chanpos
An electronic manufacturing facility of a large
diversified corporation originally cleaned printed
tiruk boards wih solvents. The company found that
by switching from a solvent-based cleaning system
to an aqueous-based system that the same
operating conditions and workloads could be
maintained. The aqueous-baaed system was found
to dean ate times more effectively. This resulted In a
lower product reject rate, and eliminated a
hazardous waste.
Source Reduction: Product Changes
Product changes are performed by the manufacturer
of a product with the Intent of reducing waste resulting
from a product's use. Product changes Include:
• Product substitution
• Product conservation
• Changes in product composition
Pioduct chanes
In the paint manufacturing Industry, water-based
coatings are finding increasing applications where
solvent-based paints were used before. These
products do not contain toxic or flammable solvents
that make solvent-based paints hazardous when
they are disposed of. Also, cleaning the applicators
with solvent is not necessary. The use of water-
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based paints instead of solvent-based paints also
greatly reduces volatile organic compound
emissions to the atmosphere.
Recycling: Use and Reuse
Recycling via use and/or reuse involves the return of a
waste material either to the originating process as a
substitute for an input material, or to another process
as an input material.
Sramote; Reuse
A printer of newpaper advertising in California
purchased an ink recycling unit to produce black
newspaper ink from its various waste inks. The unit
blends the different colors of waste ink together
with fresh black ink and black toner to create the
black ink. This ink Is then filtered to remove flakes of
dried ink. This ink is used in place of fresh black ink,
and eliminates the need for the company to ship
waste Ink off site for disposal. The price of the
recycling unit was paid off in 18 months based only
on Me savings in fresh Mack ink purchases. The
payback improved to 9 months when the costs for
disposing of ink as a hazardous waste are Included.
Recycling: Reclamation
Reclamation is the recovery of a valuable material from
a hazardous waste. Reclamation techniques differ
from use and reuse techniques In that the recovered
material is not used in the facility, rather it is sold to
another company.
Example:
A photoprocessing company uses an electrolytic
deposition cell to recover silver out of the rinsewater
from film processing equipment. The silver is then
sold to a small recyder. By removing the silver from
this wastewater, the wastewater can be discharged
to the sewer without additional pretreatment by the
company. This unit pays for itself in less than two
years with the value of silver recovered.
The company also collects used film and sells It to
the same recyder. The recyder bums the f Km and
collects the silver from the the residual ash. By
removing the silver from the ash, the ash becomes
nonhazardous.
Appendix E lists many WM techniques and concepts
applicable to common waste-generating operations
(coating, equipment cleaning, parts cleaning, and
materials handling). Additionally, a list of good
operating practices is provided.
Methods ef Generating Options
The process by which waste minimization options are
identified should occur in an environment that
encourages creativity and independent thinking by the
members of the assessment team. While the individual
team members will suggest many potential options on
their own, the process can be enhanced by using
some of the common group decision techniques.
These techniques allow the assessment team to
Identify options that the individual members might not
have come up with on their own, Brainstorming
sessions with the team members are an effective way
of developing WM options. Most management or
organizational behavior textbooks describe group
decision techniques, such as brainstorming or the
nominal group technique.
Worksheet 11 In Appendix A is a form for listing
options that are proposed during an option generation
session. Worksheet 12 in Appendix A is used to
briefly describe and document the options that are
proposed. Worksheets 8? and S8 in Appendix B
perform the same function In the simplified set of
worksheets.
Screening and Selecting Options for Further
Study
Many waste minimization options wlil be identified in a
successful assessment. At this point, H is necessary to
identify those options that offer real potential to
minimize waste and reduce costs. Since detailed
evaluation of technical and economic feasibility is
usually costly, the proposed options should be
screened to identify those that deserve further
evaluation. The screening procedure serves to
eliminate suggested options that appear marginal,
impractical, or inferior without a detailed and more
costly feasibility study.
The screening procedures can range from an informal
review and a decision made by the program manager or
a vote of the team members, to quantitative decision-
making tools. The informal evaluation Is an
unstructured procedure by which the assessment
team or WM program task force selects the options that
appear to be the best. This method is especially useful
in small facilities, with small management groups, or In
situations where only a few options have been
generated. This method consists of a discussion and
examination of each option.
The weighted sum method is a means of quantifying
the important factors that affect waste management at a
17
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particular facility, and now each option win perform with
respect to these factors. This method is
recommended when there are a large number of
options to consider. Appendix Q presents the
weighted sum method In greater detail, along with an
example. Worksheet 13 in Appendix A is designed to
screen and rank options using this method.
The assessment procedure is flexble enough to alow
common group decision-making techniques to be
used here. For example, many large corporations
currently use decision-making systems that can be
used to screen and rank WM options.
No matter what method is used, the screening
procedure should consider the following questions.
• What is the main benefit gained by Implementing
this option? (e.g., economics, compliance, labiHty,
workplace safety, etc.)
• Does the necessary technology exist to develop
the option?
• How much does ft cost? Is K cost effective?
• Can the option be Implemented within a reasonable
amount of time without disrupting production?
• Does the option have a good "track record"? Knot,
is there convincing evidence that the option will
work as required?
• Does the option have a good chance of success?
(A successfully initiated WM program will gain wider
acceptance as the program progresses.)
• What other benefits wfll occur?
The results of the screening activity are used to
promote the successful options for technical and
economic feasbUtty analyses. The number of options
chosen for the feasibility analyses depends on the
time, budget, and resources available for such a study.
Some options (such as procedural changes) may
involve no capital costs and can be implemented
quickly with little or no further evaluation. The
screening procedure should account for ease of
implementation of an option. If such an option is dearly
desirable and Indicates a potential cost savings. It
should be promoted for further study or outright
implementation.
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Section 4
Feasibility Analysis
The recognized need to minimize wad*
Planning and
Organization
Assessment
Phase
FEASIBILITY ANALYSIS PHASE
* Technical evaluation
* Economic evaluation
* Select options for implementation
Implementation
Successfully implemented
waste minimization projects
The final product of the assessment phase is a list of
WM options for the assessed area. The assessment
will have screened out the impractical or unattractive
options. The next step is to determine if the remaining
options are technically and economically feasible.
Technical Evaluation
The technical evaluation determines whether a
proposed WM option will work in a specific application.
The assessment team should use a last-track"
approach in evaluating procedural changes that do not
involve a significant capital expenditure. Process
testing of materials can be done relatively qulckry, K the
options do not Involve major equipment Installation or
modifications.
For equipment-related options or process changes,
visits to see existing installations can be arranged
through equipment vendors and industry contacts.
The operator's comments are especially Important and
should be compared with the vendor's claims. Bench-
scale or pilot-scale demonstration is often necessary.
Often It is possible to obtain scale-up data using a
rental test unit for bench-scale or pilot-scale
experiments. Some vendors will install equipment on a
trial basis, with acceptance and payment after a
prescribed time, H the user is satisfied.
The technical evaluation of an option also must
consider facility constraints and product requirements,
such as those described in Table 4-1. Although an
inability to meet these constraints may not present
insurmountable problems, correcting them will likely
add to the capital and/or operating costs.
Table 4-1. Typical Technical Evaluation Criteria
• to the system safe tor workers?
• * Will product quality be maintained?
* to space available?
* Is the new equipment, materials, or procedures
compatble with production operating procedures, work
flow, and production rate*?
• to additional labor required?
• Are utllHitiM available? Or must they be installed,
thereby raising capital costs?
• How tong will production be stopped In order to install the
system?
• to special expertise required IB operate or maintain the
new system?
* Does ins vendor provide acceptable service?
* Does the system create other environmental problems?
Ad affected groups in the facility should contribute to
and review the results of the technical evaluation. Prior
consultation and review with the affected groups (e.g.,
production, maintenance, purchasing) is needed to
ensure the viability and acceptance of an option. If the
option calls for a change in production methods or
input materials, the project's effects on the quality of
the final product must be determined. H after the
technical evaluation, the project appears Infeasibte or
impractical, It should be dropped. Worksheet 14 in
Appendix A is a checklist of important Kerns to consider
when evaluating the technical feasibility of a WM
option.
Economic Evaluation
The economic evaluation is carried out using standard
measures of profitability, such as payback period,
return on investment, and net present value. Each
organization has its own economic criteria for selecting
projects for implementation. In performing the
economic evaluation, various costs and savings must
be considered. As in any projects, the cost elements
of a WM project can be broken down into capital costs
and operating costs. The economic analysis descrtoed
hi this section and in the associated worksheets
represents a preliminary, rather than detafled, analysis.
For smaller facilities with only a few processes, the
entire WM assessment procedure will tend to be much
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Table 4-2. Capital Investment for a Typical
Urge WM Project
Direct Capital Costs
Site Development
Demotion and alteration wort?
She clearing and grading
Wakwaya, roads, and fencing
Proceee Equipment
AH equipment Beted on flow sheets
Spare part*
Taxes, freight, Insurance, and dutiee
Materials
Piping and ducting
Insulation and painting
Electrical
instrumentation and controls
Building* and ctructuree
ejection* to Existing UtflWee and Service* (water,
HVAC, power, steam, refrigeration, fuels, plant air
and inert gee. lighting, and fire control)
New UtIBty and Service FadlWea (same items as above)
Other Non-Process Equipment
Construct ion/lnstsllation
Construction/Installation labor salariee and burden
Supervision, accounting, timekeeping, purchasing.
safety, and expediting
Temporary fadHttee
Construction loots and equipment
Taxes and insurance
Building permits, field tests, licenses
Indirect Capital Costs
In-house engineering, procurement, and other home
office coats
Outside engineering, design, and consulting Services
Permitting costs
Contractors'tees
Start-up costs
Training costs
Contingency
Interest accrued during construction
TOTAL FIXED CAPITAL COSTS
Working Capital
Raw materials inventory
Finished product inventory
Materials and supplies
TOTAL WORKING CAPITAL
TOTAL CAPITAL NVESTMENT
Source: Adapted from Perry, Ch«mle«l Engineer's
Handbook nMSV. and Peteta and TimnwhaiM. Plant Dolan
and georomlo tor Chemtesl J-najne
A proper perspective must be maintained between the
magnitude of savings that a potential option may offer,
and the amount of manpower required to do the
technical and economic f easfoility analyses.
Capftal Cott*
Table 4*2 is a comprehensive (tot of capital cost Kerns
associated with a large plant upgrading prelect. These
costs include not only the fixed capital costs for
designing, purchasing, and Installing equipment, but
also costs for wortdng capital, permitting, training, start-
up, and financing charges.
With the increasing level of environmental regulations,
Initial permitting costs are becoming a significant
portion of capital costs for many recycling options (as
well as treatment, storage, and disposal options).
Many source reduction techniques have the
advantage of not requiring environmental permitting in
order to be Implemented.
Optnting Cowl* and Saving*
The basic economic goal of any waste minimization
project Is to reduce (or eliminate) waste disposal costs
and to reduce input material costs. However, a variety
of other operating costs (and savings) should also be
considered, in making the economic evaluation, it is
convenient to use Incremental operating costs in
comparing the existing system with the new system
that incorporates the waste minimization option.
('incremental operating costs" represent the
difference between the estimated operating costs
associated with the WM option, and the actual
operating costs of the existing system, without the
option.) Table 4-3 descrtbes incremental operating
costs and savings and incremental revenues typtealy
associated with waste minimization protects.
Reducing or avoiding present and future operating
costs associated with waste treatment, storage, and
disposal are major elements of the WM prelect
economic evaluation. Companies have tended to
ignore these costs hi the past because land <"
less formal. In thto situation, several obvious WM
options, such as InstaBation of flow controls and good
operating practices may be implemented wtth Nttle or
no economic evaluation. In these instances, no
complicated analyses are necessary to demonstrate
the advantages of adopting the selected WM options.
was relatively inexpensive. However, recent regui
requirements Imposed on generators and waste
management facilities have caused the costs of waste
management to Increase to the point where H is
becoming a signlfcant factor in a company's overall
cost structure. Table 4-4 presents typical external
costs for offstte waste treatment and disposal. In
addition to these external costs, there are significant
internal costs, Including the labor to store and ship out
wastes, tiabiMy Insurance coats, and onsite treatment
costs.
20
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Table 4-3. Operating Cost! and Savings
Associated with WM Projects
Reduced waste management coats.
This includes reductions in costs for.
Offsfte treatment, storage, and disposal IMS
Stats fsss and taxes on hazardous wast* generators
Transportation costs
Onsfte treatment, storage, and handling costs
Permitting, reporting, and recordkeeping costs
Input material oott savings.
An option that reduces waste usually decreases the
demand for input materials.
Insurance and liability savings.
A WM option may be significant enough to reduce a
company's Insurance payment*, h may also lower a
company's potential liability associated with remedial
dean-up of TSDFs and workplace safety. (The
magnitude of liability savings is difficult to determine).
Changes n COM aseodated with quality.
A WM optkjn may have a pos ftive or negative effect on
product quality. this couid result in higher (or tower)
costs for rework, scrap, or ojualtty control functions.
Changes in utilities costs.
Utilities costs may increase or decrease. This Includes
steam, electricity, process and cooling water, plant air,
refrigeration, or inert gas.
Changes in operating and maintenance tabor, burden, and
An option may sfther increase or decrease labor
requirements. This may be reflected hi changes hi
overtime hours or In changes in the number of
employees. When direct labor costs change, then the
burden and benefit costs will also change. In large
projects, supervision costs will also change.
Changes In operati ng and maintenance auppftea.
An option may result increase or decrease the use of
O&M supplies.
Changes in overhead costs.
Large WM projects may aff set a facility's overhead
costs.
Changes in revenue* from Increased (or decreased;
production.
An option may result hi an increase In the productivity of
a unit This will result in a change in revenues. (Note that
operating costs may also change accordingly.)
Increased revenues from by-products.
A WM option may produce a by-f»oduct that can be sold
to a recyder or sold to another company as a raw
material. This will increase the company's revenues.
Table 4-4. Typical Coata of OfteHe Induatrlal
Waate Management*
Disposal
Drummed hazardous waste**
Solids $75 to $110 per drum
Liquids $65 to $120 per drum
Bufc waste
Solids $120 per cubic yard
Liquids $0.60 to $2.30 per galon
Lab packs $110 per drum
Analysis (at disposal she)
Transportation
$200 to $300
$65 to $85 per hour 0 45 mles
per hour (round trip)
Does not include internal coats, such as taxes and fees,
and labor for manlest preparation, storage, handing, and
recordkeeping.
Based on 55 gallon drums. These prices are for larger
quantities of drummed wastes. Disposal of a smal
number of drums can be up to tour times higher par
drum.
For the purpose of evaluating a project to reduce
waste quantities, some types of costs are larger and
more eas8y quantified. These include:
disposal fees
transportation costs
predispose! treatment costs
raw materials costs
operating and maintenance costs.
it is suggested that savings in these costs be taken
into consideration first, because they have a greater
effect on project economics and involve less effort to
estimate reliably. The remaining elements are usually
secondary In their direct impact and should be
included on an as-needed basis In fine-tuning the
analysis.
Profitability Antlyflm
A project's profitability is measured using the estimated
net cash flow* (cash incomes minus cash outlays) for
each year of the project's Me. A profitability analysis
example in Appendix H includes two cash flow tables
(Figure H-3 and H-4).
If the project has no significant capital costs, the
project's profitability can be judged by whether an
operating cost savings occurs or not. H such a project
reduces overall operating costs, ft should be
implemented as soon as practical.
21
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For projects with significant capital costs, a more
detailed profitability analysis is necessary. The three
standard profitability measures are:
* Payback period
• Internal rate of return (IRR)
* Net present value
The payback period for a project is the amount of time I
takes to recover the initial cash outlay on the project.
The formula for calculating the payback period on a
pretax basis is the foBowing:
Payback period -
flnytw)
Capital lnv>«tm«nt
Annual operating COM saving*
For example, suppose a waste generator Installs a
piece of equipment at a total cost of $120.000. Nthe
piece of equipment is expected to save $43,000 per
year, then the payback period Is 25 years.
Payback periods are typically measured in years.
However, a particularly attractive project may have a
; period measured in months. Payback periods
payback)
in the n
in the range of three to four years are usually
considered acceptable tor low-risk Investments. This
method Is recommended for quick assessments of
profltabWy. Mlarge capital expenditures are involved, I
is usuafly followed by more detailed analysis.
The internal rate of return (IRR) and the net present
value (NPV) are both Discounted cash flow techniques
for determining profitability. Many companies use
these methods for ranking capital projects that are
competing for funds. Capital funolng for a project may
weH hinge on the ability of the project to generate
positive cash flows beyond the payback period to
realize acceptable return on investment. Both the
NPV and IRR recognize the time value of money by
Discounting the projected future net cash flows to the
present. For investments with a low level of risk, an
aftertax IRR of 12 to 15 percent Is typtealy acceptable.
Most of the popular spreadsheet programs for
personal computers wi automaticaly calculate IRR and
NPV for a series of cash flows. Refer to any financial
management, cost accounting, or engineering
economics text for more Information on determining
the IRR or NPV. Appendix H presents a profitability
analysis example tor a WM project using IRR and NPV.
Adjustment* for fit** *nd Liability
As mentioned earter, watte minimization projects may
reduce the magnitude of environmental and safety
risks for a company- Although these risks can be
identified, I Is difficult to predict if problems occur, the
nature of the problems, and their resulting magnitude.
One way of accounting for the reduction of these risks
is to ease the financial performance requirements of
the project. For example, the acceptable payback may
be lengthened from four to five years, or the required
internal rate of return may be lowered from 15 percent
to 12 percent. Such adjustments reflect recognition of
elements that affect the risk exposure of the company,
but cannot be included directly in the analyses. These
adjustments are Judgmental and necessarily reflect the
individual viewpoints of the people evaluating the
project tor capital funding. Therefore, It is Important
that the financial analysts and the decision makers In
the company be aware of the risk reduction and other
benefits of the WM options. As a policy to encourage
waste minimization, some companies have set lower
hurdle rates for WM projects.
White the profttabnty is important to deciding whether
or not to implement an option, environmental
regulations may be even more important. A company
operating in violation of environmental regulations can
face fines, lawsuits, and criminal penalties for the
company's managers. Ultimately, the factty may even
be forced to shut down. In this case the total cash flow
of a company can hinge upon implementing the
environmental project
Wortcahaita tor Economic Evaluation
Worksheets 15 through 1? in Appendix A are used to
determine the economic evaluation of a WM option.
Worksheet 15 is a checklist of capital and operating
cost items. Worksheet 16 is used to find a simple
payback period for an option that requires capital
investment. Worksheet 1? is used to find the net
present value and internal rate of return for an option
that requires capital investment. Worksheet S9 in
Appendix B is used to record estimated capital and
operating costs, and to determine the payback period
In the simplified assessment procedure.
Final Rtport
The product of a waste minimization assessment is a
report that presents the results of the assessment and
the technical and economic feasfeWty analyses. The
report also contalnes recommendations to Implement
the f eastote options.
A good final report can be an important tool for getting
a project implemented. H Is particularly valuable hi
obtaining funding for the project In presenting the
feasWRty analyses, It is often useful to evaluate the
project under different scenarios. For example,
comparing a projects's profttabity under optimistic and
pessimistic assumptions (such as increasing waste
disposal costal) can be beneficial. Sensitivity analyse*
that Indicate the effect of key variables on profltabWy
are also useful.
22
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The report should include not only how much the
project wffl cost and Is expected performance, but also
how It will be done, ft is Important to discuss:
* whether the technology is established, with
mention of succesful applications;
* the required resources and how they wlH be
obtained;
• estimated construction period;
* estimated production downtime;
* how the performance of the project can be
evaluated after I is Implemented.
Before the report is finaRzed, K is Important to review
the results with the affected department* and to sofctt
their support. By having department representatives
assist In preparing and reviewing the report, the
chances are Increased that the projects wM be
implemented. In summarizing the resuts, a quaJMative
evaluation of intangible costs and benefits to the
company should be included. Reduced Habitties and
improved image in the eyes of the employees and the
community should be discussed.
23
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Section 5
Implementing Waste Minimization Options
Th* recognized need to minMz* waste
Planning and
Organization
Assessment
Phase
Feastoihy
Analysis Ph
IMPLEMENTATION
Justify projects and obUin funding
Installation (equipment)
Implementation (procedure)
EvakMt* performance
Successfully implemented
wast* minimization projects
The WM assessment report provides the basis for
obtaining company funding of WM projects. Because
projects are not always sold on their technical merits
atone, a clear description of both tangible and
intangible benefits can help edge a proposed project
past competing projects for funding.
The champions of the WM assessment program
should be flextole enough to develop alternatives or
modifications. They should also be committed to the
point of doing background and support work, and
should anticipated potential problems In implementing
the options. Above all, they should keep in mind that
an idea will not sel H the sponsors are not sold on M
themselves.
Obtaining Funding
Waste reduction projects generally involve
improvements in process efficiency and/or reductions
In operating costs of waste management. However, an
organization's capital resources may be prioritized
toward enhancing future revenues (for example,
moving Mo new lines of business, expanding plant
capacity, or acquiring other companies), rattier than
toward cutting current costs. If this Is the case, then a
sound waste reduction project could be postponed
until the next capital budgeting period. It is then up to
the project sponsor to ensure that the project is
reconsidered at that time.
Knowing the level within the organization that has
approval authority for capital projects will help in
enlisting the appropriate support. In large
corporations, smaller projects are typically approved at
the plant manager level, medium-size projects at the
divisional vice president level, and laiger projects at the
executive committee level.
An evaluation team made up of financial and technical
personnel can ensure that a sponsor's enthusiasm is
balanced with objectivity, ft can also serve to queB
opposing "cant be done" or "H K aJnl broke, dont ftc r
attitudes that might be encountered within the
organization. The team should review the project in
the context of:
* past experience In thte area of operation
• what the market and the competition are doing
* how the Implementation program fits into the
company's overall business strategy
* advantages of the proposal in relation to competing
requests for capital funding
Even when a project promises a high interal rate of
return, some companies will have difficulty raising
funds intemalfy for capital investment. In this caw, the
company should look to outside financing. The
company generally has two major sources to consider:
private sector financing and government-assisted
funding.
Private sector financing includes bank loans and other
conventional sources of financing. Government
financing is available in some cases. It may be
worthwhile to contact your state's Department of
Commerce or the federal Small Business
Administration for Information regarding loans for
pollution control or hazardous waste disposal projects.
Some states can provide technical and financial
assistance. Appendix F includes a list of states
providing this assistance and addresses to get
information.
24
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Installation
Waste minimization options that Involve operational,
procedural, or materials changes (without additions or
modifications to equipment) should be implemented
as soon as the potential cost savings have been
determined. For projects involving equipment
modifications or new equipment, the installation of a
waste minimization project is essentially no different
from any other capital improvement project. The
phases of the project include planning, design,
procurement, and construction.
Worksheet 18 is a form for documenting the progress
of a WM project through the implementation phase.
Demonstration and Follow-up
After the waste minimization option has been
implemented, it remains to be seen how effective the
option actually turns out to be. Options that don't
measure up to their original performance expectations
may requre rework or modifications. It is important to
get warranties from vendors prior to installation of the
equipment.
The documentation provided through a follow-up
evaluation represents an important source of
information for future uses of the option in other
facilities. Worksheet 19 fe a form for evaluating the
performance of an implemented WM option. The
experience gained in implementing an option at one
facility can be used to reduce the problems and costs
of implementing options at subsequent facilities.
Measuring Waste Reduction
One measure of effectiveness for a WM project is the
project's effect on the organization's cash flow. The
project should pay for itself through reduced waste
management costs and reduced raw materials costs.
However, it is also Important to measure the actual
reduction of waste accomplished by the WM project.
The easiest way to measure waste reduction is by
recording the quantities of waste generated before
and after a WM project has been implemented. The
difference, dividied by the original waste generation
rate, represents the percentage reduction In waste
quantity. However, this simple measurement ignores
other factors that also affect the quantity of waste
generated.
In general, waste generation is directly dependent on
the production rate. Therefore, the ratio of waste
generation rate to production rate is a convenient way
of measuring waste reduction.
Expressing waste reduction in terms of the ratio of
waste to production rates is not free of problems,
however. One of these problems is the danger of
using the ratio of infrequent large quantities to the
production rate. This problem is illustrated by a
situation where a plant undergoes a major overhaul
involving equipment cleaning, paint stripping, and
repainting. Such overhauls are fairly infrequent and
are typically performed every three to five years. The
decision to include this intermittent stream in the
calculation of the waste reduction index, based on the
ratio of waste rate to product rate, would lead to an
increase in this index. This decision cannot be
justified, however, since the infrequent generation of
painting wastes is not a function of production rate. In
a situation like this, the waste reduction progress
should be measured In terms of the ratio of waste
quantity or materials use to the square footage of the
area painted. In general, a distinction should be made
between production* related wastes and maintenance-
related wastes and dean-up wastes.
Also, a few waste streams may be inversely
proportional to production rate. For example, a waste
resulting from outdated input materials is likely to
increase H the production rate decreases. This is
because the age-dated materials in inventory are more
likely to expire when their use in production
decreases.
For these reasons, care must be taken when
expressing the extent of waste reduction. This
requires that the means by which wastes are
generated be well understood.
In measuring waste reduction, the total quantity of an
individual waste stream should be measured, as wen as
the individual waste components or characteristics.
Many companies have reported substantial reduction
in the quanHHes of waste disposed. Often, much of
the reduction can be traced to good housekeeping
and steps taken to concentrate a dilute aqueous
waste. Although concentration, as such, does not fall
within the definition of waste minimization, there are
practical benefits that result from concentrating
wastewater streams, including decreased disposal
costs. Concentration may render a waste stream easier
to recycle, and is also desirable if a facility's current
wastewater treatment system is overloaded.
Obtaining good quality data for waste stream quanhies,
flows, and composition can be costly and time
consuming. For this reason, it may be practical, in
some instances, to express waste reduction indirectly
In terms of the ratio of input materials consumption to
production rate. These data are easier to obtain,
although the measure is not direct.
25
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Measuring waste minimization by using • ratio of waste
quantity to material throughput or product output is
generally more meaningful for specific units or
operations, rather than for an entire facility. Therefore,
it is important to preserve the focus of the WM project
when measuring and reporting progress. For those
operations not involving chemical reactions, It may be
helpful to measure WM progress by using the ratio of
input material quantity to material throughput or
production rate.
Wast* Minimization Aaaaaamanta for
Naw Production Procaaaaa
This manual concentrates on waste minimization
assessments conducted in existing facilities.
However, .It is important that waste minimization
principles be applied to new projects. In general, it is
easier to avoid waste generation during the research
and development or design phase than to go back and
modify the process after it has already been Installed.
The planning and design team for a new product,
production process, or operation should address
waste generation aspects early oa The assessment
procedure In this manual can be modtled to provide a
WM review of a product or process In the planning or
design phase. The earlier the assessment is
performed, the less likely tt is that the project will
require expensive changes. All new projects should
be reviewed by the waste minimization program task
force.
A better approach than a pre-project assessment is to
include one or more members of the WM program task
force on any new project thai:wW generate watte. In
influence to
m generate*
nef> from the
)Ns or her M
this way, the new project wil be;
presence of a WM champion and
design the process to minimize waste At a CaMomia
facilty of a major defense contractor, al new projects
and modfficattons to existing faclUes and equipment
are reviewed by the WM program team. All projects
that have no environmental impact are quickly
screened and approved. Those projects that do have
an environmental impact are assigned to a team
member who participates hi the project kick-off and
review meetings from inception to implementation.
Ongoing Waata Minimization Program
The WM program is a continuing, rather than a one-
time effort. Once the highest priority waste streams
and facility areas have been assessed and those
projects have been Implemented, the assessment
program should look to areas and waste streams wtti
tower priorities. The ultimate goal of the WM program
should be to reduce the generation of waste to the
maximum extent achievable. Companies that have
eliminated the generation of hazardous waste should
continue to took at reducing industrial wastewater
dtocharges, air emissions, and solid wastes.
The frequency wlh which assessments are done wll
depend on the program's budget, the company's
I cyde (annual cycle In most companies), and
uuogvung uywv \W«M«I uywo »i nwot V*/IIV«MWW»/, *•**
special circumstances. These special circumstances
might bs:
• a change In raw material or product requirements
• higher waste management costs
• new regulations
• new technology
• annajoreverftwttiundesirabtoerivironrnental
consequences (such as a major spfl)
Aside from the special circumstances, a new series of
assessments should be conducted each fiscal year.
To be truly effective, a philosophy of waste
minimization must be developed In the organization.
This means that waste minimization must be an Integral
part of the company's operations. The moat
successful waste minimization programs to date have
al developed this philosophy within their companies.
26
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Appendix A
Waste Minimization Assessment Worksheets
The worksheets that follow are designed to facilitate the WM assessment procedure. Table A-1 lists the worksheets,
according to the particular phase of the program, and a brief description of the purpose of the worksheets.
Appendix B presents a series of simplified worksheets for small businesses or for preliminary assessments.
Table A-1. List of Wssls Minimization Assessment Worksheets
Phase Number and Title
Purpoee/Remarke
1. Assessment Overview
Planning and Organization
(Section 2)
2. Program Organization
3. Assessment Team Make-up
Aaeeaament Phase
(Section 3)
4. SMe Description
5. Personnel
6. Process Information
7. Input Materials Summary
8. Products Summary
8. Individual Waste Stream
Characterization
10. Waste Stream Summary
Summarizes the overaJ assessment procedure.
Records key members in the WMA program task force and the WM
assessment teams. Also record* the relevant organization.
Usts names of assessment team members as wel as duties. Includes
a list of potential departments to consider when selecting the teams.
UsU background Information about the facility, Including location,
products, and operations.
Records information about the personnel who work in the
assessed.
to be
This to a checklist of useful process Information to look for before
starting the assessment.
Records input material information for a specific production or process
area. This include* name, supplier, hazardous component or
properties, cost, delivery and sheH~Me inform*!ion, and possible
substitutes.
Identifies hazardous components, production rate, revenues, and
other information about products.
Records source, hazard, generation rate, disposal cost, and method
of treatment or disposal for each waste stream.
Summarizes all of the information collected for each waste stream.
This sheet to also used to prioritize waste stream* to i
(continued)
A-1
-------
Table A-1. Uat of Watte Minimization AaaaaanMnt Workeheeta (eontlnuad)
Phaae Number and Tttto
Purpoae/Ramarka
Aaaaaamant Phaaa (eontlnuad)
(Section 3)
11. Option Generation
12. Option Description
13. Optiont Evaluation by
Weighted Sum Method
Paaalblltty Analyala Phaaa
(Section 4)
14. Technical FeaaiUMy
15. Coat Information
16. ProfltabttyWorkeheettl
Payback Period
17. ProRtabttyWofkeheett?
Cajh Flow for NPV and BR
Implementation
(Sections)
18. Project Summary
19. Option Performance
Record* option* proposed during braJnetorming or nominal group
t
iqu
kidudee the rationale tor proposing each option.
DMcrbat and aummarizea information about a prepoaed option. Abo
note* approval of promWng optiona.
Ueed for ecreening options using the weighted aum method.
Delated cheddat for performing a technical evaluation of a VWoptjon,
The) worKahoot to divided into aectione for ccjuipmonweiewd opuonat
•ted optiont, and mejeriale^elated optiona.
economic evaluation of an option.
i for uee In the
Baaed on the<
i developed from
Worksheet 15, thb woikaheet la wed to calculate the payback period.
Thtewoftaheetteueed to develop cMhflo»» for cateutatinq NPV or BR.
Summarizaa Important taaka to be performed during the
iiBM»lAMA«»ft«rfbMk mA ^«k «M«^Lb«k ^l
ini|iiviiivnunDn 01 m vyy»»vn< i I
A-2
-------
Him.
Site.
Date.
Waste Minimization Assessment
Worksheets
Proj. No.
Prepared By
Checked By
Sheet 1 ol 1 Page of.
WORKSHEET
1
ASSESSMENT OVERVIEW
&EPA
Begin the Waste Minimization
Assessment Program
I
Worksheets used
PLANNING AND ORGANIZATION
* Get management commitment
• Set overall aaseMinent program goals
• Organize assessment program task force
I
Assessment organization
and commitment to proceed
Select new
assessment targets
and reevaluate
previous options
ASSESSMENT PHASE
* Compile process and fadNy data
• Prioritize and select assessment targets
* Select people for assessment teams
• Review data and inspect site
* Generate options
* Screen and select options for further study
I
Assessment report of
selected options
FEASIBILITY ANALYSIS PHASE
* Technical evaluation
• Economic evaluation
• Select options for implementation
I
Final report, including
recommenced options
Repeat the process
IMPLEMENTATION
• Justify projects and obtain funding
• Installation (equipment)
* Implementation (procedure}
* Evaluate performance
Successfully operating
waste minimization prelects
4,6,7.8,9,10
10
3
11,12
13
14
1S.1S.17
18
18
19
A-3
-------
Firm,
Site .
Date
Waata Minimization AsMsamant
Proj. No.
Prepared By
Checked By
Shett J_ of J_ Paga
of
WORKSHEET
2
S*:*:4;:S»5;: 'i ->--™' ;.: :ft»t-:m::5-:K; VĄ
PROGRAM ORGANIZATION
'X^ii^^^^^i^X^S^l^W^^^i^^^^^^^^^
SEPA
FUNCTION
NAME
LOCATION
TELEPHONE f
Proflfam Managar
3Ra Coordinator
Aaaaaamant Taam Laadar
Organization Chart
(akateh)
A-4
-------
Firm
Site
Waste Mnlmlzatton Assessment
Pml.Ho.
Prepared By
Checked iy
Sheet _L_ of J_ Page
of
WORKSHEET
3
IWSSESSMEfflii
&EPA
Function/Department
Asstsmmtt TMm
Lttctor
Silt Coordinator
Operations
Engln««rlng
Malntananct
Schadutlnfl
Mat*rtal« Corrtrot
PfOOUIWIMMM
Shlpplng/Racatvlng
FadlKlat
Quality Control
Environmarttal
Accounting
^^^UMMIkflfe VMkl
PHvonnw
RI.D
Ugal
Managarnant
^ . . _« UK. „
Contractor/consultant
Safety
Nama
Location/
Talaphonaff
Manhoura
Raqulrad
Duties
Lead
Support
Review
A-5
-------
Firm
Site
Dale
WMM Mntmiattoii AstMmiMtt
Pro), No.
Prepared By
ClwckidBy •
Shift J_ of J_ Ptflt o(
WORKSHEET
4
&EPA
Firm:
Plant:
)«partm>nt;
Stm«t
Otv:
State^lP Cod«:
cj )
Mator Products
EPA Qtrwttor Numbtr :
MalorUnnor
Product or.
Op»r»tlon«;
FaclinkM/EqutortMrtt AM:
A-6
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Firm
Site
Data
Waste Minimization Assessment
Pmj No
Prepared By
Chocked By
Sheet J_ of J_ Page of
WORKSHEET
5
PERSONNEL
&EPA
Attribute
Overall
Department/Area
Total Staff
Direct Supv. Staff
Management
Average Age, yrt.
Annual Turnover Rate %
Seniority, yrt.
Yrs. of Formal Education
Training,
Additional Remarks
A-7
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Firm
SH«
Date
Waste Minimization Assessment
Proj No
Prepared By
Checked Bv
Sheet J_ of _1_ Page of
WORKSHEET
6
4»EPA
Process Unit/Operation:
Operation Type: D Continuous
D Discrete
D Batch or Semi-Batch D Other _
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/ Assavs
mwij wwmir^mmttfm
Stream
Operating Manuals
Equipment List
Equipment Specifications
Piping & Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Used In this
Report (Y/N)
Document
Number
Location
A-B
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Firm
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Date
Wast* Minimization AaMsamant
Pro). No.
Prepared By
Checked By
SheetJ_ of J_ Pace of
WORKSHEET
7
&EPA
Attribute
Name/ID
Source/Supplier
Component/Attribute of Concern
Annual Consumption Rate
Overall
Components) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode*
Shipping Container Size & Type*
Storage Mode4
Transfer Mode*
Empty Container Disposal/Management*
Shelf Life
Supplier Would
- accept expired material (Y/N)
• accept shipping containers (Y/N)
• revise expiration date (Y/N)
Acceptable Substitutes), H any
Alternate Suppliers)
Description1
Stream No.___
Stream No.
•
Stream No.
1 stream numbers, If applicable, should correspond to those used on process flow diagrams.
e.g., pipeline, tank car, 100 bbl. tank truck, truck, etc,
e.g., 55 gal. drum, 100 Ib. paper bag, tank, etc.
e.g., outdoor, warehouse, underground, aboveground, etc.
e.g., pump, fforklift, pneumatic transport, conveyor, etc.
e.g., crush and landfill, clean and recycle, return to supplier, etc.
A-9
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Firm.
Site
Date
Waste Minimization Assessment
Pro|.No.
Prepared By
Checked By
Sheet _1_ of J_ Page of
WORKSHEET
8
PRODUCTS SUMMARY
&EPA
Attribute
Name/ID
Component/Attribute of Concern
Annual Production Rate
Overall
Component(s) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Size ft Type
Onstte Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
• relax specification (Y/N)
-accept larger containers (Y/N)
Description1
Stream No.
Stream No.
Stream No.
1 stream numbers, H applicable, should correspond to those used on process flow diagrams.
A-10
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Finn
SHA
Data
WMI* Mlnhnlmtlnn A >**••"****
Pro] No
Prepared Bv
Cheeked By
Sheet .? of 4 Page of
WORKSHEET
9a
&EPA
1. Watte Stream Name/ID:.
Process Unit/Operation
Stream Number.
Waste Characteristics (attach additional sheets with composition data, as necessary.)
D
gas
D
liquid
DsoBd D
mixed phase
4.
Density, b/cuft
Viscosity/Consistency
pH ,Ftash Point.
High Heating Value, Btu/to.
.;% Water
Waste Leaves Process as:
LJ air emission LJ waste water LJ solid waste LJ hazardous waste
Occurrence
I—I continuous.
discrete '.
discharge triggered by LJ chemical analysis
LJ other (describe)
Type: ED period* length of period:
I—I sporadic (irregular occurrence)
LJ non-recurrent
Generation Rate
Annual
Maximum .
Average -
Frequency.
Batch Size.
average
t» per year
be per
fosper
batches per
range
A-11
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Rrm.
Site .
Date
Want Minimization Assessment
Proc. Untt/Oper..
Pro], No
Prepared By
Checked By
Sheet J_ of J_ Page of
WORKSHEET
9b
&EPA
6. Wast* Origins/Sources
Fill out this workaheet to Identify tha origin of the waste. If the waste la a mixture of waste
streams, fill out a sheet for each of the Individual waste streams.
l« the waste mixed wrth other wastes?
Q
Yes
No
Describe how tha waste la generated.
Example: Formation and removal of an undesirable compound, removal of an uncon-
verted Input material, depletion of a key component (e.g., drag-out), equip-
ment cleaning waste, obsolete Input material, spoiled batch and production
run, spin or leak cleanup, evaporative loss, breathing or venting bases, ate.
A-12
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Firm.
Site .
Date
Wast* Minimization Assessment
Proe. UnWOper.
ProJ.No
Prepared By
Checked By
Sheet J__ of 4 Page of
WORKSHEET
9c
Wast* Stream
(oonHmMd)
&EPA
7. Management Method
Leaves site In
D
bull
roll off bins
55 gal drums
D other (describe)
Disposal Frequency
Applicable Regulations1
Regulatory Classification2
Managed
Recycling
onsRe
commercial TSDF
D own TSDF
D other (describe)
I—I direct use/re-use
Q energy recovery
D radMMed
O other (describe)
offsite
reclaimed material returned to site?
D Yes D No D usedbyothers
residue yield
residue disposal/repository
Note1 list lederal, state & tocal regulations, (e.g., RCRA, TSCA, etc.) .
Note2 1st pertinent regulatory classification (e.g., RCRA - Usted K011 waste, etc.)
A-13
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Firm
Site
Date
Watt* Minimization Assessment
Proc. Unit/Oper..
Proj. No
Prepared By
Checked By
Sheet ±_ of _Ł_ Page of
WORKSHEET
9d
7.
-: :-•-:- -_.;-.:-.:. \:.-;>:.-,^.!.-^-.!^.-.. .-.-.-.,.:.,>.,.%.%-,-. .v.-,-^^: .%•.•.-.•.•.-.-, •,.%•.•...•.-.-.•.•. ^'-•.-.•.•- .-.-.:•. ,:-• .-.•.-,•.•.- • -.v.-.-.v.---^ .•.....-.-.-.-.-.•:•.
&EPA
Waste Stream
Management Method (continued)
Treatment
D biological
LJ oxidation/reduction
LJ incineration
LJ pH adjustment —
EH precipitation
I I solidification _
D other (describe) —
residue disposal/repository
Final Disposition
Costs as of
D landffl
D pond
LJ lagoon
EH deep well
ocean
I_J other (describe).
(quarter and year)
Cost Element:
Onstte Storage & Handlina
Pretreatmertt
Container
Transportation Fee
Disposal Fee
Local Taxes
State Tax
Federal Tax
Total Disposal Cost
UnR Price
joec
Reference/Source:
A-14
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Rim
Site
Data
Waste Minimization Assessment
Ptoe Unit/Oper
Pro). No.
Pre
Ch
Sh(
WORKSHEET
10
WASTE STREAM SUMMARY
pared By
acked By
jet 1 of 1 Page of
4»EPA
Attribute
Wast* ID/Name:
Source/Origin
Component/or Property of Concern
Annual Generation Rate (units )
Overall
Components) of Concern
Cost of Disposal
UnK Cost (i per: )
Overall (per year)
Method of Management*
Priority Rating Criteria9
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
R*lttiV*
Wt.(W)
Sum of Priority Rating Scores
Priority Rank
Description1
Stream No.
Rating (R)
E(RxW)
RxW
Stream No.
Rating (H)
X(RxW)
RxW
Stream No.
Rating (R)
ICHxW)
RxW
Notes: 1 . Stream numbers, If applicable, should correspond to those used on process flow diagrams.
2. For example, sanitary landfill, hazardous waste landfill, onslte recycle, Incineration, combustion
with heat recovery, distillation, dewaterlng, etc.
3. Rate each stream In each category on a scale from 0 (none) to 10 (high).
A-15
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Firm
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Date
Watt* Minimization Assessment
Proc. UnJt/Oper.
Proj. No
Prepared By
Checked By
Sheet J_ of J_ Page of
WORKSHEET
11
OPTION GENERATION 4> E PA
Matting format (e.g., bramttormlng, nominal group technique)
Matting Coordinator
Meeting Participant*
List Suggested Option*
Rationale/Remark* on Option
A-16
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Firm
Site
Data
WORKSHEET
12
Ootlon Name:
til
Waste Minimization Assessment
Proc. Untt/Oper
Proj. No.
••:•:'•.•: :•:-• •*• •' :'-'- - ••-•- - '••'•:• '- '••'• '•'•'•' '-'• '• '•:'•' •• ' ' •'•'•' '•• -:-'--->'-:•'••'• '••',-'•'• •••••:•:•:•;':•; :•:.•.•.•!•.•!•.•;•.•.•:••:•:•:
;.-:; v : v*':v:v::.:::::::::::;:::':::.:*!:J;vv>';-'-::Ą:-:':: •: ':.:::'::-:' ' ';' ;;'r-: ••:;:':'; :'::::: :•:' ':'"':',' •,'.• : '• ' *".-.v.'. !.•>,';•;';";•;•:":
Prepared By
Checked By
Sheet 1 of 1 Page of
i &EPA
Briefly describe the option
Waste Stream(s) Affected:
Input Materfal(t) Affected:
Product(s) Affected:
Indicate Type:
LJ Source Reduction
,LL:JI Equipment-Related Change
Personnel/Procedure-Related Change
Materials-Related Change
LJ Recycling/Reuse
Onstte _
Oftslte _
Material reused for original purpose
Material used for a lower-quality purpose
Material sold
Material burned for neat recovery
Originally proposed by:
Reviewed by:
Approved for study?—
yes
Reason for Acceptance or Rejection
Date:
Date:
no, by:
A-17
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Firm
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Date
Wttte Minimization Assessment
UnWOper.
Pro). No
Prepared By
Checked By
Sheet J_ of .1 Page 1 of t
WORKSHEET
13
s»EPA
>
«A
OB
Crfiwfa
Reduction hi
Reduction of
Reduction of
Reduction of
waste's hazard
treatment/disposal costs
safety hazards
Input material costs
Extent of current use In Industry
Effect on product quality (no effect = 10)
Low capital cost
LowOftMcost
Short Implementation period
Ease of Implementation
Final
Evaluation
Weight
(WJ
Sum of Weighted Ratings Ł (WxR)
Option Ranking
FeaafcHlty Analysis Sctwoulstf for (Dale)
Options Rating (R)
tl Option
R
RiW
i2 Option
R
RxW
f3 Option
R
RxW
94 Option
R
RxW
•5 Option
R
RxW
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Firm
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Data
WM
WORKSHEET
14a
Wast* Minimization Assessment
Pme llnft/Opflr
Proj. No.
Prepared By
Checked By
Sheet 1 of Ł Page of
iiiiiiiiiiiiiBiiiS A F P A
%^ fci F^
Option Description
1. Nature of WM Option Q Equipment-Related
LJ Personnel/Procedure-Related
EH Materials-Related
2. If the option appears technically feasible, state your rationale for this.
Is further analysis required? D YesD No.
worksheet If not, skip to worksheet 15.
3. Equipment - Related Option
Equipment available commercially?
Demonstrated commercially?
In similar application?
Successfully?
Describe closest industrial analog
If yes, continue with this
IBS
D
D
D
D
D
D
D
D
Describe status of development
Prospective Vendor
Working Installation(s)
Contact Person(s)
Data Contacted 1.
1. Also attach filled out phone conversation notes, installation visit report, etc.
A-19
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Firm,
Site .
Date
Waste Minimization Assessment
Proc,
Pro). No.
Prepared By
Checked By
Sheet _2_ of J__ Page of
WORKSHEET
14b
TECHNICAL FEASIBILITY
WM Option Description
&EPA
3. Equipment-Related Option (continued)
Performance Information required (describe parameters):
Scateup Information required (describe):
Testing Required*. ED yes EH no
Scale: CD bench d pilot CD
Test unit available? Q yes D no
Test Parameters (list)
Number of test runs:
Amount of matertal(s) required.*
Testing to be conducted:
ED m-ptont
ED
Facility/Product Constraints:
Space Requirements
Possible locations within facility
A-20
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Firm.
Site
Date
Wast* Minimization Assessment
Free. UnH/Oper.
Proj.No
Prepared By
Checked By
Sheet J_ of _§_ Page of
WORKSHEET
14C
WM Option Description
2. Equipment-Related Option (continued)
Utility Requirements:
Electric Power Volts (AC or DC) kW
Process Water Flow Pressure
Cooling Water
Quality (tap, demln, sic.)
Flow Pressure.
Temp. In
Coolant/Heat Transfer Fluid —
Tamp. Out
Steam
Temp. In
Duty —
Pressure
Duty
Tamp. Out
Tamp.
- Flow
&EPA
Fuel
Plant Air.
Mart Gas.
Type
Flow.
Duty.
Flow
Flow
Estimated delivery time (after award of contract)-
Estlmated Installation time
Installation dates
Estimated production downtime.
will production be otherwise affected? Explain the effect and Impact on production.
Will product quality be affected? Explain the effect on quality.
A-21
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Site
Date
Wssts Minimization Assessment
Pnoc. Unft/Oper..
ProJ.No
Prepared By
Checked By
Sheet 4 of 6_ Page of
WORKSHEET
14d
&EPA
WM Option Description
3. Equipment-Related Option (continued)
Will nxxllflcatlons to woik fkm or prooXrctton procedures be required? Explain. -
Operator ami maintenance training requirements
Number of peopl* to be trained
D Onslte
O OHtlte
Duration of training
Describe catalyst, chemicals, replacement parts, or other supplies required.
Item
Rats or Frequency
of Replacement
Supplier, Address
Doss tits option meet government and company safety and health requirements?
to Explain
How is service handled (maintenance and technical assistsncs)? Explain
What warranties are offered?
A-22
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Proj.No.
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Sheet i_ of _fe_ Page of
WORKSHEET
146
TECHNICAL FEASIBILITY
(eenttmMd)
oEPA
WM Option Description
3. Equipment-Related Option (continued)
Describe any additional storage or material handling requirements.
Describe any additional laboratory or analytical requirements.
4. Personnel/Procedure-Related Changes
Affected Departments/Areas
Training Requirements
Operating Instruction Changes. Describe responsible departments.
Materials-Related Changes (Note: H substantial changes In equipment are required, then handle the
option as an equipment-related one.) &• M°-
Has the new material been demonstrated commercially? LJ LJ
In a similar application? ED LJ
Successfully? G D
Describe closest application
A-23
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CheckedBy
Sheet JL_ of _fi_ Page of
WORKSHEET
14f
WM Option Description
Mat«rtal«-fl«tat«d CtangM (continued)
Affected Oepartmenta/Areae
Will production be affected? Explain the effect and Impact on production.
Will product quality be affected? Explain the effect and the Impact on product quality.
Will additional etorafle, handling or other ancillary equipment be required? Explain.
Deecrtbe any training or procedure changes that an required.
Decr1b« any matertaJ teatlng program that win be required.
A-24
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Sile
Date
Wast* Minimization Assessment
Proj.No,
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Checked By
Sheet J_ of _6_ Page of
WORKSHEET
15a
&EPA
WM Option Description.
CAPITAL COSTS»Include all costs as appropriate.
LJ Purchased Process Equipment
Price (fob factory)
Taxes, freight, Insurance
Delivered equipment cost
Price for Initial Spare Parts Inventory
D Estimated Materials Cost
Piping —
Electrical —
Instruments —
Structural —
Insulation/Piping —
TOTALS
O Estimated Costs for utility Connections and New Utility Systems
Electricity
Steam
Cooling Water
Process Water
Refrigeration
Fuel (Gas or OH)
Plant Air
Inert Gas
O Estimated Costs for Additional Equipment
Storage & Material Handling
Laboratory/Analytical
Other
LJ Site Preparation
(Demolition, site clearing, etc.)
[~| Estimated Installation Costs
Vendor .
Contractor
In-house Staff
A-25
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Wast* Minimization Assessment
Proj. No.
Prepared By
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Sheet JL of J_ Page of
WORKSHEET
15b
(combuiM)
vvEPA
CAPITAL COSTS (Cont)
Engineering and Procurement Costs (In-house & outside}
Planning _
Engineering _
Procurement _
Consultants _
TOTALS
EH Start-up Costs
Vendor
Contractor
In-house
ED Training Costs
EH Permitting Costs
Fees
in-house Staff Costs
EH Initial Charge of Catalysts and Chemicals
Item*!.
Item 42
EH Working Capital [Raw Materials, Product, Inventory, Materials and Supplies (not elsewhere specified)].
rtemfl-
ftemf2.
ttemfS.
Item §4.
D Estimated Salvage Value (If any)
A-26
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Firm
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Data
Wast* Minimization Assessment
Pnv. Untt/Gpar
Pmj Nn
Pre
Chi
SlK
WORKSHEET
• 35* —
ipared By'
acted By
set 3 of 6 Paew of
&EPA
CAPITAL COST SUMMARY
Cost Item
Purchased Process Equipment
Materials
Utility Connections
Additional Equipment
Site Preparation
Installation
Engineering and Procurement
Start-up Cost
Training Costs
Permitting Costs
Initial Charge of Catalysts and Chemicals
Fixed Capital Investment
Working Capital
Total Capital Investment
Salvage Value
Cost
A-27
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Date
Waste Minimization Assessment
Proc. UnB/Opar
PTOJ.NO
Prepared By _
Checked By
Sheet _4_ of J_ Page of
WORKSHEET
15d
&EPA
D Estimated Dscrease (or mcreass) In Utilities
UtHtty
Electricity
Sttam
Cooling Proeww
Prooeea Water
Refrigeration
FiMl(QMorOII)
Plant Air
inert Air
Unit Cost
Spwuntt
DACTMM (or IncrMM) In Quinttty
UnMpcrtimt
Total Owrmw (or IncrMM)
$p«rtlnMi
INCREMENTAL OPERATING COSTS - Include all relevant operating savings. Estimate these costs on an incre-
mental baste (i.e., as decreases or Increases over existing costs).
BASIS FOR COSTS Annual.
Quarterly
Monthly
Dally
Other-
D
D
Estimated Disposal Cost Saving
Decrease In TSDF Feet
Decrease in State Fees and Taxes
Decrease In Transportation Costs
Decrease In Onslte Treatment and Handling
Decrease In Permitting, Reporting and Recordkeeplng
Total Decrease In Disposal Costs
Estimated Decrease In Raw Materials Consumption
Materials
t
Unit Cost
(per unit
Reduction In Quantity
Units per time
Decrease In Cost
f per time
A-28
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Proc. UnJt/Oper
Proj. No
Prepared By
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Sheet JL of _6_ Page of
WORKSHEET
15e
COST INFORMATION
&EPA
D
Estimated Decrease (or Increase) In Ancillary Catalysts and Chemicals
CftUlyct/Owmteal
UnltCoct
Iperuntt
DMTMM (or IncrMM) hi Quantity
Unit per thm
Total DtcrMM (or IncrMM)
$ per tlrrw
LJ Estimated Decrease (or Increase) In Operating Costs and Maintenance Labor Costs
(Include cost of supervision, benefits and burden).
I I Estimated Decrease (or Increase) In Operating and Maintenance Supplies and Costs.
D
Estimated Decrease (or Increase) In Insurance and Liability Costs (explain).
ED Estimated Decrease (or Increase) In Other Operating Costs (explain).
INCREMENTAL REVENUES
Q Estimated Incremental Revenues from an Increase (or Decrease) In Production or Marketable
By-products (explain).
A-29
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Date
Waste Minimization Assessment
PflQC Unit/Op** r
Pm] No
Pre
Ch
Shi
WORKSHEET
15f
COST INFORMATION
(pared By
eckedBy
set 6 of 6 Paps of
&EPA
INCREMENTAL OPERATING COST AND REVENUE SUMMARY (ANNUAL BASIS)
Decreases in Operating Cost or Increases In Revenue are Positive.
Increases In Operating Cost or Decrease In Revenue are Negative.
Operating Cost/Revenue Item
Decrease In Disposal Cost
Decrease In Raw Materials Cost
Decrease (or Increase) In Utilities Cost
Decrease (or Increase) In Catalysts and Chemicals
Decrease (or Increase) In 0 & M Labor Costs
Decrease (or Increase) In o & M Supplies Costs
Decrease (or Increase) In Insurance/Liabilities Costs
Decrease (or Increase) In Other Operating Costs
Incremental Revenues from increased (Decreased) Production
Incremental Revenues from Marketable By-products
Net Operating Cost Savings
1 per year
A-30
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Sheet J_ of J_ Page of
WORKSHEET
16
PROFITABILITY WORKSHEET # 1
PAYBACK PERIOD
&EPA
Total Capital Investment ($) (from Worksheet 15c)
Annual Net Operating Cost Savings ($ per year) (from Worksheet I5f).
Payback Period (In years) i
Total Capital Investment
Annual Net Operating Cost Savings
A-31
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Sheet J_ of J_ Page of
WORKSHEET
17
&EPA
Cash Incomes (such as net operating cost savings and salvage value) art shown as positive.
Cash outlays (such as capital investments and increased operating costs) are shown as negative.
Urn
A Fixed Capital Investment
B + Working Capital
C Total Capital Investment
D Selvage VehM*
E Net Operating Costs Savings
F * Interest en Loans
Q -Depredation
H Taxable Income
I
• Income Tax*
J Aftertax ProW
K + Depredation
L • Repayment of Loan Principal
M -Capital Investment (line C)
N * Selvage Value (line P)
O Cash Flew
P Present Value of Cash Flow*
Q Net Present Value (NPV)»
Present Worth* (5% discount)
1.0000
0.8524
0.9070
0.8838
OJ227
0.7835
0.7482
0.7107
04768
(10% discount)
1.0000
0.9091
0.8264
0.7513
OJ830
0.8209
OJ64S
OJ132
0.4685
(15% discount)
1.0000
0.8696
0.7561
0.6575
OJ718
0.4972
0.4323
0.3759
0.3269
(20% discount)
1.0000
03333
0.6944
QJ787
0.4823
0.4019
OJ34f
0^791
0.2326
(25%dlaoourrt)
1.0000 OJOOO 0*400 OJ120 0.4096 0.3277 0.2821 0^097 0.1678
1
2
Adjust table ee necessary If the anticipated project life ie less than or mors than • years.
Salvage value Ineludee acrap value of ecfulpment Blue sate of working capital minus demo-
lition costs.
3. The worksheet Ie used for calculating an aftertax cash flow. For pretax cash flow, use sn income tsx wte of 0%.
4 The pressnt value of the cash flow Is equal to the cash flow multiplied by the present worth factor.
5 The net present value la the sum of the present value of the cash flow for that year and all of the proceeding years.
6 The formula for the pressnt worth factor Is 1 where n Is yssrs and r Is the discount rate.
7 The Internal rats of ratum (IRR) Is the discount rate (r) that result! In a net present value of zero over the life of the
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Sheet J_ of J__ Page of
WORKSHEET
18
&EPA
Goals/Objective*
Task
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
Deliverable
Task Leader
TOTALS
Aoorova! Bv Date
Manhours
Budget
•
Duratto
Wk»
Stvt
n
Finish
Reference
Authorization By
Project Started (Date)
A-33
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Finn
Date
WMte Minimization Assessment
Pro). No.
Prepared By
Checked By
Sheet J_ of J_ P*S« of
WORKSHEET
19
OPTION PERFORMANCE <>EPA
WM Option Description
CU Baseline
(without option)
(a) Period Duration
D Projected
From
(b) Production per Period
Units (.
(c) Input Materials Consumption per Period
D
Actual
.To
Malarial
Pounds
Pounds/Unit Product
(d) Waste Generation per Pertod
Waste Stream
Pound*
Pounda/UnH Product
(•) 8uDStance(s) of Concern • Generation Hate per Period
Waste Stream
Substance
Pounds
Pounds/Unit Product
A-34
-------
Appendix B
Simplified Waste Minimization Assessment Worksheets
The worksheets thai follow are designed to facilitate a simplified WM assessment procedure. Table B-1 Usts the
worksheets, accxirding to the particular phase of the program, and a brisf description of the purpose of the
worksheets. The worksheets here am presented as supporting only a preliminary effort at minimizing waste,
or In a situation where a more formal rigorous assessment is not warranted.
Table B-1. List of Simplified WM Assessment Worksheets
Phase Number and Title
Purpose/Remarks
S1. Assessment Overview
Assessment Phase
(Section 3)
82. Site Description
S3. Process Information
84. Input Materials Summary
S5. Products Summary
S6. Waste Stream Summary
57. Option Generation
SS. Option Description
Feasibility Analyala Phase
(Section 4)
99. Profitability
Summarizes the overall assessment procedure.
Lists background Information about the facility, including location,
products, and operations.
This Is a checklst of useful process Information to look for before
starting the assessment.
Records Input material information for a specific production or process
area. This Includes name, supplier, hazardous component or
properties, cost, delivery and shelf-life information, and possible
substitutes.
Identifies hazardous components, production rate, revenues, and
other information about products.
Summarizes all of the information collected for each waste stream.
This sheet Is also used to prioritize wests streams to assess.
Records options proposed during brainstorm ing or nomine) group
technique sessions. Includes the rationale for proposing each option.
Describes and summarizes information about a proposed option. Also
notes approval of promising options.
ting costs and to
This worksheet is used to identify capital and opt
calculate the payback period.
B-1
-------
Rm
Sit*
Data
Waste Minimization Assessment
Simplified Worksheets
Proi. No.
Prepared By
Checked Bv
Sheet 1 of 1 Paqe of
WORKSHEET
S1
ASSESSMENT OVERVIEW
&EPA
Begin the Waste Minimization
Assessment Program
1
Worksheets used
PLANNING AND ORGANIZATION
• Gat management commitment
• Set overall assessment program goals
• Organize assessment program task force
1
Assessment organization
and commitment to proceed
»> ASSESSMENT PHASE
assessment Uraets ' Compile process and facility data
andreevaliwrte " Prtorltize and *el*ct *»«»«*fn«nt targets
nr*uinn« nntinn* * Select people for assessment teams
previous options ^ Review data and inspect site
• Generate options
• Screen and select options for further study
S5
S2.S3.S4
S6
S7.S8
S8
S8
I
Assessment report of
selected options
FEASIBILITY ANALYSIS PHASE
• Technical evaluation
• Economic evaluation
• Select options for implementation
S9
I
Final report. Including
recommended options
IMPLEMENTATION
Repeat the process
• Justify projects and obtain funding
• Installation (equipment)
• Implementation (procedure)
• Evaluate performance
Successfully operating
waste minimization projeeta
B-2
-------
Firm
Site
nate
Wast« Minimization Assessment
Simplified Workeheets
Pro] No
Prepared By
Checked By
Sheet 1 of 1 Page of
I WORKSHEET
I S2 I
SITE DESCRIPTION
&EPA
Firm:
Plant:
Department:
Area;
Street Address;
Cltv;
State/ZIP Code:
Telephone: (
Mator Products;
SIC Codes:
EPA Generator Number
Major Unit or:
Product or:
Operations:
Facilities/Equipment Age;
B-3
-------
Firm
SHs
nats
UffAAftA Ma>iiiemt'»ail»^ A AAAAAMtAMft
Simplified Worksheets
Pmj No
.
Prepared By
Checked Bv
Sheet _1_ of J_ Page of
WORKSHEET
PROCESS INFORMATION
&EPA
Process Unit/Operation:
Operation Type: C
LJ Continuous D Discrete
D Batch or Semi-Batch D Other—
Document
Process Flow Diagram
Material/Energy Balance
Design
Operating
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Process Description
Operating Manuals
Equipment List
Equipment Specifications
Piping & Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reports
Permit/Permit Applications
Batch Sheet(s)
Materials Application Diagrams
Product Composition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules
Status
Complete?
(Y/N)
Current?
(Y/N)
Last
Revision
Used In this
Report (Y/N)
Document
Number
Location
B-4
-------
Firm
Sits
Data
WORKSHEET
S4
Waste Mintmtzatlon Assessment
Simplified Worksheets
Pro] No
Pra
cr*
Shi
jjf
;::v!::::;s;::^;ft<:^^
•A- • :• :':
pared By '
sckedBy
set 1 of 1 Page of
4* EPA
Attribute
Name/ID
Source/Supplier
Component/ Attribute of Concern
Annual Consumption Rate
Overall
Component(s) of Concern
Purchase Price, $ per
Overall Annual Cost
Delivery Mode1
Shipping Container Size & Type*
Storage Mode*
Transfer Mode4
Empty Container Disposal/Management*
Shelf Life
Supplier Would
• accept expired material (Y/N)
- accept shipping containers (Y/N)
• revise expiration date (Y/N)
Acceptable Substitute^), If any
Alternate Suppliers)
Description
Stream No.
Stream No.
Stream No.
1 ••g., pipeline, tank car, 100 bbl. tank truck, truck, etc.
1 e.gn 55 gal. drum, too IB. paper bag, tank, etc.
* e.g., outdoor, warehouse, underground, aboveground, etc.
4 e.g., pump, forkllft, pneumatic transport, conveyor, etc.
* e.g., crush and landfill, clean and recycle, return to supplier, etc.
B-5
-------
Finn
Site
Dale
Wast* Minimization Assessment
Slmpl!fl«d Worksheets
Pmj No
Pw
Chi
SI*
WORKSHIET
S5
PRODUCTS SUMMARY
oared By
BckedBy
Mt 1 of 1 Page , of
x>EPA
Attribute
Name/ID
component/ AiiriDine 01 concern
Annual Production Rate
Overall
Components) of Concern
Annual Revenues, $
Shipping Mode
Shipping Container Sire ft Type
Onalte Storage Mode
Containers Returnable (Y/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
- relax specification (Y/N)
• accept larger containers (Y/N)
.
Stream No.
Description
Stream No.
Stream No^_
B-6
-------
Firm
Site
Data
WOflK&igET
^6
Wast* Mlnknlzatlon As**ssm*nt
Simplified Worksheet*
Pmr llnlTf^Mr
Pmj No
P«
Ch
SI*
WASTE STREAM SUMMARY
ipared BY
eckedBv
wt 1 of 1 Page of
&EPA
Attribute
Waste ID/Nam*:
Source/Origin
Component/or Property of Concern
Annual Gantratlon Rat* (units )
Overall
Components) of Conoarn
Cost of Disposal
Unit Co« (S p«r: )
Overall (per yaar)
Method of Management1
ReHrtive
Priority Rating Criteria1 wt. nm
Regulatory Compliance
TreatmenVDIspoaal Cost
Potential Uablllty
Wast* Quantity Generated
Wast* Hazard
Safety Hazard
Minimization Potential
Potential to Remov* Bottleneck
-Potential By-product Recovery
Sum of Priority Rating Score*
Priority Rank
Description
Stream No.
Rating (ft)
SRxW)
RxW
Stream No.
Rating (R)
XCRxW)
RxW
Stream No.
Rating (R)
XCRxW)
RxW
Notes: 1 . , For example, sanitary landfill, hazardous watte landfill, onslt* recycle, Incineration, combustion
with heat recovery, distillation, dewatertng, *te.
2. Rate each stream In each category on a seal* from 0 (non*) to 10 (high).
B-7
-------
Pirm
Wast* Mntail
Simplified Worksheets
ent
Proj. No.
Prepared By
Checked By
Sheet J_ of 1 Page of
WOWCSHEIT
S7
&EPA
MMtlng format («.0t bralnttormlng, iKMnlnal group t*crtnlqu«)
MMIIng Coordinator
iMotlng Participants
List Suggested Options
Rationale/Remarks on Option
B-8
-------
Firm
Site
Data
WORKSHEET
S8
Waste Minimization Assessment
S Impllfled Worksheets
Pmj No
Pfi
Ch<
Shi
OPTION DESCRIPTION
oared By
ackedBy
jet 1 of 1 Paoe of
oEPA
Option Name:
Briefly describe the option
Waste Stream(s) Affected:
Input Matarial(s) Affected:
Produces) Affected:
indicate Type:
LJ Source Reduction
__ Equipment-Related Change
Personnel/Procedure-Related Change
Matertalafleiatsd Change
LJ Recycima/Reuse
Onslts __
OffUte _
Material reused for original purpose
Material used for a tower-quality purpose
Material sold
Material burned for heat recovery
Originally proposed by:
Reviewed by:
Approved for study?—
Data:
Data:
yes
no, by:
Reason for Acceptance or Rejection
B-9
-------
Flmn
sim
Data
Wast* Minimization Assessment
Simplified Worksheets
Pme I In»/Op«r
Proj No
Prepared By
Checked By
Sheet 1 of 1 Page of ,„
WORKSHEET
S9
PROFITABILITY
oEPA
Capital Costs
Purchased Equipment
Material*
Installation
Utility Connectlons-
ErtQlneenng
Start-up and Training.
Other Capital Costs -
Total Capital Costs
incremental Annual Operating Costs
Change In Disposal Costs —
Change in Raw Material Costs •
Change In Other Costs
Annual Net Operating Cost Savings
Payback Period (inyeara)
Total Capital Costs
cost savings
B-10
-------
Appendix C
Waste Minimization Assessment Example
Amalgamated Metal Re finishing Corporation
The following case study Is an example of a waste
minimization assessment of a metal plating operation.
This example Is reconstructed from an actual
assessment, but uses fictitious names. The example
presents the background process and facility data, and
then describes the waste minimization options that are
identified and recommended for this facility.
Amalgamated Metal Refinishing Corporation is in the
business of refinishing decorative items. The
corporation owns and operates a small facility in
Beverly Hills, California. The principal metals plated at
this facility are nickel, brass, silver, and gold.
Preparing for the Assessment
Since the facility is a small one with a rather small
number of employees, an assessment team was
assembled that included both company personnel and
outside consultants. The team was made up of the
following people:
• Plant manager (assessment team leader)
• First shift plating supervisor
• Corporate process engineer
• Plating chemistry consultant
• Environmental engineering consultant
The assessment team chose to look at all of the plating
operations, rather than focusing on one or two specific
plating processes.
The assessment began by collecting recent
production records, input material information,
equipment layout drawings and flow diagrams, waste
records, and plant operator instructions. After each of
the team members had reviewed the information, a
comprehensive inspection of the Dialing room was
carried out. The following process, layout, and waste
descriptions summarize the Information that was
collected for the assessment.
Process Description
items brought in for refinishing are cleaned,
electroplated and polished The basic operations
include paint stripping, cleaning, electroplating, drying,
and polishing.
In silver plating, the original plated metal is stripped off
the item by dipping tt into a sodium cyanide solution
with the system run in reverse current. This is followed
by an acid wash in a 50% muriatic acid solution. The
item is then polished to a bright finish. The polished
Item is then cleaned with caustic solution to remove
dirt, rinsed with a 5% suHuric acid solution to neutralize
any remaining caustic solution on the item, and rinsed
with water. The item is now ready for electroplating.
After the Item is immersed in the plating tank for the
required amount of time, It is rinsed in a still rinse tank,
followed by a continuous water rinse. Tap water is
used for both the still and continuous rinsing steps.
Solution from the still rinse tank is used as make-up for
the plating baths, in places where two still rinse tanks
are used, water from the second tank is used to-
replenish the first still rinse tank. Overflow from the
continuous rinse tank is discharged as wastewater.
The item is polished following the plating step.
Gold plating generally does not require stripping. After
the initial cleaning operation, the Mem is electroplated.
Nickel and brass plating are also done in a similar
manner. Vapor degreaslng using 1,1,1-
trichloroethane is often perfomed on brass- and nickel-
plated items to remove oil and grease. In some cases,
Hems are first nickel-plated and then plated with gold,
silver, or brass.
For electroplating operations, the constituents of the
cyanide solutions must be kept at an optimum
concentration. The solutions are analyzed twice a
month by an outside laboratory. A representative
sample from a tank is obtained by dipping a tube to the
bottom of the plating tank. The sample is analyzed and
recommendations tor make-up are made based on the
test results. Table C-1 shows a typical analysis for
brass and nickel electroplating solutions, respectively.
This table also shows the optimum concentrations for
each constituent in the baths, as well as the
recommended make-up and/or dilution requirements.
All plating operations at the facility are performed
manually. The facility operates one shift per day and
employs eight operators.
Equipment Layout Description
All plating, cleaning, and rinse tanks are located In one
room at the plating shop, while an adjacent room
houses aN equipment used tor buffing and polishing.
C-1
-------
Tab)* C-1. Electroplating Solution Analyse*
Concentrations
Table C-2. W«»t*watar characteristic*
Brass Plating
Copper metal
Zinc metal
Sodium cyanide
Sodium hydroxide
Copper cyanide
Zinc cyanide
Roehell* salts
0.3oz/gal
6.0
8.0
10.0
0.5
2.0
Actual
7.S2oz(gaJ
OJO
3S4
7JBQ
10.60
1.45
359
Nickol Plating
Nickel metal
Nickel chloride
Boric add
Nickel suttate
A-5
SA-1
PH
-
8.0oz/gal
6.0
40.0
25%
12%
4.0
16.65oz/gal
15.86
6.92
5726
2.86%
1.38%
45
Figure C-1 tea plan of the facility. The area north of the
buffing room bused for drying and storage purposes.
Finished goods, as wel as raw materials, are stored hi
the front of the buikfing.
Thirty tanks are used in cleaning and electroplating
operations. Figure C-1 includes the names and normal
working volumes of these tanks. The configuration of
a typical plating unit includes a plating bath, followed by
one ore two still tanks and a continuous rinse tank.
Except for nickel plating, all plating and stripping
solutions used at the facility are cyanide-based.
Wssts Stream Description
Cyanide waste is generated from silver stripping; from
silver, gold, brass, and copper electroplating; and from
the associated rinsing operations. The principal waste
streams are wastewater from the continuous rinse
tanks and from floor washings, and plating tank filter
waste.
Aqueous streams generated from paint stripping, from
metal stripping and electroplating, and from floor
washings are routed to a common sump. This sump
discharges to the santtary sewer. Table C-2 presents
the results of a typical analysis on the wastewater.
Metal sludges accumulate in the plating tanks. This
sludge is filtered out of the plating solution once a
month using a portable dual cartridge filter. Two filler
cartridges are used for each plating tank. Cartridges
are typically replaced every two to three months.
The sump Is pumped out and disposed of as
hazardous waste once every six months. When
pumped out the sump usually contains 300 to 400
Sampling date
Sampling location
Type of sample
Reporting period
Total flow in
Total flow out
Peak flow
Augusts, 1987
ClariHer Sample Box
Time Composite
July *B7 to August I?
322galons
290galons
1.5 gallons per minute
Suspended solid*
PH
Total cyanide
Total chromium
Cnrmsf
"***W"WI
Nickel
Silver
OH and grease
Temperature
1.0 moA
7J
1,Omg/L
0.42 moA
1,30 mg/L
0.93 mg/L
<0.05mg/L
02 mg/L
TOT
gallons of sludge comprised of dirt, stripped paint, and
a solution containing cyanide and heavy metals.
Proposed Waste Minimization Options
After the site Inspection was completed and additional
information was reviewed, the team held a
brainstorming session to identify potential waste
minimization options for the facility. The following
options were proposed during the meeting:
• Reduce solution drag-out from the plating tanks by:
. Proper positioning of workpiece on the plating
rack.
- Increasing plating solution temperatures.
- Lowering the concentration of plating solution
constituents.
* Increase the recovery of drag-out with drain
boards.
• Extend plating solution bath Nfe by:
- Reducing drag-In by better rinsing.
• Using tetonbed make-up water.
- Using purer anodes.
• Returning spent sohrttons to the suppliers.
* Reduce the use of rinse water by:
• Using multiple countercurrent rinse tanks.
- Using still rinsing.
- Using spray or fog rinsing.
• Prevent dust from the adjacent buffing and
polishing room from entering the plating room and
contaminating the plating baths.
Segregate cyanide wastes from the rinse tanks from
other wastewater streams, such as floor washings
and paint stripping wastes.
C-2
-------
Figure C-1. PLANT LAYOUT
Amalgamated Metal Reflnlshlng Corporation
Worldwide Headquarters and Production Facilities
Beverly Hills, California
C-3
-------
The team members each independently reviewed the
options and then met to decide which options to study
further. The team chose the following options for the
feasibility analysis:
• Reduce drag-out by using drain boards.
* Extend bath life using deionized water for make-up.
* Use spray rinsing to reduce rinsewater usage.
* Segregate hazardous waste from nonhazardous
waste.
Feasibility Analysis
The assessment team conducted technical and
economic feasibility analyses on each of the four
options.
Segregate Hazardous Wastes
The assessment team recognized that segregating
hazardous wastes from nonhazardous wastes could be
implemented at virtually no cost and would save money
immediately. There were no identified technical
problems.
Use Drain Boards to Reduce Drag-out
Drain boards are used to collect plating solution that
drips off the rack and the workpiece after they are
pulled out of the plating tank. The plating solution
drains back into the plating tank. This option reduces
the amount of dilute rinse water waste, but impurities
build up faster in the plating solution. Since drag-out is
reduced, make-up chemical consumption is reduced.
The purchase price of drain boards is estimated at
$115, with installation costs of $200, for a total capital
cost of $315. This option is expected to reduce rinse
water disposal costs by $500 per year, and reduce
make-up chemicals costs by $400 per year. The
resulting payback period is 0.35 years, or about 4
months.
Use Deionized Water for Make-up Solutions
and Rinse Water
Using Dl water will reduce the build-up of impurities in
the plating solutions. In particular, the build-
uphardness minerals from tap water will be avoided.
This, in turn, will avoid the precipitation of carbonates in
the plating tanks.
The assessment team decided to combine the
evaluation of this option with the previous option of
using drain boards. The initial purchase and installation
of the detonizer was $267. When adding the cost of
the drain boards, the total capital cost of this option to
$582. The detonizer Is rented and serviced by an
outside water treating service company for $450 per
year. The savings in disposal costs and make-up
chemical costs is $900 per year. Therefore, the annual
net operating cost savings is $450 per year. The
payback period is 1.3 years.
Install Spray Rinses
Installing spray rinses will reduce the amount of rinse
water required to clean the Hems. With spray rinse
nozzles and controls, rinsing can be done on demand.
Rinse water usage was estimated to be reduced by
50%. The resulting rinse wastewater is more
concentrated and some can be returned to the plating
tanks as a water make-up.
The assessment team determined that four spray rinse
units would cost $2,120, plus an additional $705 for
piping, valves, and installation labor. The total capital
cost was $2825. The reduction in disposal costs were
estimated at $350 per year, based on a 50% reduction
in rinse wastewater. This resulted in a payback of over
8 years.
Implementation
The procedures for segregating hazardous wastes
from nonhazardous wastes was implemented before
the feasibility analysis was completed for the other
three options. The installation of drain boards and the
purchase of a water detonizer were made shortly after
the feasibility analysis was completed. The Dl water
system was online two months later. The assessment
team decided not to implement the spray rinse option
because of the long payback period.
Future WM Assessments
During the next cycle of waste minimization
assessments, the assessment team will review
previously suggested options in the plating area and
will took at ways to reduce the generation of metallic
dust in the buffing and polishing area. In the
meantime, the assessment team will continue to look
for additional opportunities to reduce waste
throughout the facility.
C-4
-------
Appendix D
Typical Causes and Sources of Waste
In order to develop a comprehensive list of waste minimization options for a facility, N Is necessary to
understand the sources, causes, and controlling factors that influence waste generation. The tables
in this Appendix list this information for common industrial operations.
TabteD-1. Typical Wastes from Plant Operations
Table D-2. Causes and Controlling Factors of Waste Generation
Table D-1. Typical Wastes from Plant Operations
Plant Function Location/Operation
Potential Wast* Material
Material Receiving Loading docks, incoming
pipelines, receiving areas
Raw Material and
Product Storage
Production
Tanks, warehouses, drum
storage yards, bbis,
storerooms
Melting, curing, baking,
distilling, washing, coating,
formulating, reaction
Support Services Laboratories
Maintenance shops
Garages
Powerhouses/boilers
Cooling towers
Packaging materials, off-spec materials, damaged containers,
inadvertent spills, transfer nose emptying
Tank bottoms; off-spec and exoass materials; spill residues;
leaking pumps, valves, tanks, and pipes; damaged containers,
empty containers
Washwater; rinse water; solvents; still bottoms; off-spec
products; catalysts;«mpty containers; sweepings; ductwork
dean-out; additives; oil; filters; spill residue; excess materials;
process solution dumps; leaking pipes, valves, hoses, tanks,
and process equipment
Reagents, off-spec chemicals, samples, empty sample and
chemical containers
Solvents, cleaning agents, degreaslng sludges, sand-blasting
waste, caustic, scrap metal, oHs. greases
Oils, filters, solvents, adds, caustics, deaning bath sludges,
Fly ash, slag, tube dean-out material, chemical additives, oil
empty containers, boiler btowdown, water-treating chemical
wastes
Chemical additives, empty containers, cooling tower bottom
sediment, coding tower btowdown, fan kibe oils
Source: adapted from Gary Hunt and Roger Schecter, "Minimization of Hazardous Waste Generation",
Standard Handbook of Hazardous Waste Management. Harry Freeman, editor, McGraw-Hill, New York (currently in press).
D-1
-------
Table D-2. CauMS and Controlling Factor* In West* Generation
Waste/Origin Typical Causes Operational Factor*
Design Factor*
Chemical Reaction
Contact between
aqueous and
organic phases
Process equipment
cleaning
Heat exchanger
cleaning
Metal parts
cleaning
Metal surface
treating
Disposal of
unusable raw
material* or
off-spec product*
dean-up of spill*
and leak*
• Incomplete conversion
• By-product formation
• Catalyst deactivate
(by poisoning or eintering)
• Condensate from ateam
jet ejector*
• Presence of water aa a
reaction byproduct
•Use of water for product
rinea
* Equipment cleaning
• SpiR dean-up
• Presence of ding
• Deposit formation
•Uaa of flier aide
• Use of chemical cleaner*
• Presence of ding (preceea
sida) or seals (cooing
water aide)
• Depoat formation
• Use of chemical deanera
• Disposal of apent solvents,
•pent cleaning solution, or
cleaning sludge
• Dragout
• Disposal of spent treating
solution
• Obsolete raw materials
• Off-spec products caused
by contamination, improper
reactant controls, inadequate
pre-deaning of equipment or
workpiece, temperature or
pressure excursions
• Manual material transfer and
handling operations
•Leaking pump aeeJs
• Leaking flange gaskets
* Inadequate temperature control
* Inadequate mixing
* Poor feed flow control
• Poor feed purity control
* Indiscriminate use of water for
cleaning or washing
* Drainage prior to cleaning
* Production scheduling to
reduce cleaning frequency
• Inadequate cooling water
treatment
• Exoassive cooing water
temperature
Indiscriminate use of solvent
or water
1 Poor rack maintenance
> Excessive rinsing with water
• Fast removal of workpiece
•ator training or
Inadequate quality control
1 Inadequate production planning
and inventory control of
feedstocks
* Inadequate maintenance
• Poor operator training
• Lack of attention by operator
• Excessive use of water In
cleaning
* Proper reactor design
• Proper catalyst selection
* Choice of process
* Choice of reaction condftfona
* Vacuum pumps Instead of
steam jet ejectors
* Choice of process
»Use of reboHere inataad of
steam stripping
• Design reactors or tanks
wiper blades
• Reduce ding
• Equipment dedication
• Design for lower film temparature
end high turbulence
• Controls to prevent cooling
water from overheating
• Choice between cold dip tank or
vapor degreastng
* Choice between solvent or
aqueous cleaning solution
* Countercurrent rinalng
• Fog rinsing
* Dragout coBectton tanks or trays
• Use of automat ton
• Maximize dedication of
equipment to a single function
• Choice of gasketing materlala
•Choice of eeaJs
• Use of welded or seal-welded
construction
Source: Jacobs Engineering Group
D-2
-------
Appendix E
Waste Minimization Techniques
The tables in this appendix lists techniques and practices for waste reduction in operations that are
applied In a wide range of industries. Most of the techniques listed here are source reduction techniques.
Table E-1. Waste Minimization Options for Coating Operations
TabteE-2. Waste Minimization Options for Equipment Cleaning Operations
Table E-3. Waste Minimization through Good Operating Practices
Table E-4. Waste Minimization Options in Materials Handing, Storage, and Transfer
Table E-5. Waste Minimization Options for Parts Cleaning Operations
Source: Jacobs Engineering Group
E-1
-------
Table E-1. Waste Minimization Options for Coating Operations
Waste
Source/Origin
Waste Reduction Measures
Remarks
References
Coating overspray
Coating material that fate
to reach the object being
coated
* Maintain 50% overlap between spray pattern
* Maintain 6" - 8" distance between spray gun
and the workpieca
• Maintain a gun speed of about 250 feet/minute
• Hold gun perpendicular to the surface
* Trigger gun at the beginning and end of each
pass
* Proper training of operators
* Use robots for spraying
* Avoid excessive air pressure for coating
atomization
* Recycle overspray
• Use electrostatic spray systems
• Use air-assisted airless spray guns in place of
air-spray guns
The coated object does not look
streaked, and wastage of coating
material is avoided. V the spray
gun is arched 45*. the overspray
can be as high as 65%.
By air pressure adjustment,
overspray can be reduced to 40%.
Overspray can be reduced by 40%.
Increases transfer efficiency.
1,2
2
2
2
3
4
4
Stripping wastes
m
ro
Coating removal from parts
before applying a new coat
Solvent emissions
Evaporative losses from
process equipment and
coated parts
Equipment cleanup Process equipment cleaning
wastes with solvents
Overall
« Avoid adding excess thinner
• Use abrasive media stripping
• Use bead-blasting for paint stripping
• Use cryogenic stripping
• Use caustic stripping solutions
* dean coating equipment after each use
• Keep solvent soak tanks away from heat sources
• Use high-solids formuiatform
* Use powder coatings
• Use water-based formulations
* Light-to-dark batch sequencing
* Produce large batches of similarly coated
objects instead of smal batches of differently
coated kerns
• Isolate solvent-based paint spray booms from
water-based paint spray booths
• Reuse cleaning soMbn/sofvent
* Standardize solvent usage
• Reexamine the need tor coating, as we! as
available alternatives
Reduces stripping wastes due to rework.
Solvent usage is eliminated.
Solvent usage la eliminated.
Solvent usage is eliminated.
Solvent mage Is eliminated.
Lower usage of solvents.
Avoids solvent usage.
Avoids solvent usage.
6
7
8
1
9
10,11
4,12
13
20
-------
Table E-2. Waste Minimization Options for Equipment Cleaning Operations
Waste
Source/Origin
Waste Reduction Measures
Remarks
References
Spent advent- or
inorganic-based
cleaning solutions
Tank cleaning operations
ttl
Maximize dedication of process equipment
Use squeegees to recover ding of product
prior to rinsing
Avoid unnecessary cleaning
Closed storage and transfer systems
Provide sufficient drain time for liquids
Lining the equipment to prevent ding
"Pigging" process lines
Use high-pressure spray nozzles
Use countercurrent rinsing
Use dean-in-piace systems
dean equipment immediately after use
Reuse cleanup advent
Rework deanup solvent into useful products
Segregate wastes by solvent type
Standardize advent usage
Reclaim solvent by distillation
Schedule production to lower deaning
frequency
Scaling and drying up can be prevented.
Minimizes leftover material.
Reduces ding.
Minimizes advent consumption.
Prevents hardening of scale that requires
more severe deaning.
18
19
Wastewater
sludges, spent
acidic solutions
Heat exchanger cleaning
* Use bypass control or pumped recycle to
maintain turbulence during turndown
* Use smooth heat exchange surfaces
* Use on-stream deaning techniques
« Use hydroWasting over chemical deaning
where possible
Onstte or offsKe recydkig.
Electroplated or Teflon* tubes.
"Superscrubber", (or example.
20
21
-------
Table E-3. Waste Minimization through Good Operating Practices
Good Operating Practice
Program Ingredients
Remarks
References
Waste minimization assessments
IT!
Environmental audits/reviews
Loss prevention programs
Waste Segregation
Preventive maintenance programs
Form a team of qualified individuals
Estabish practical short-term and long-term goals
Allocate resources and budget for the program
Establish assessment targets
Identify and select options to minimize waste
Periodically monitor the program's effectiveness
* Assemble pertinent documents
• Conduct environmental process reviews
* Cany out a site inspection
* Report on and fotow up on the findings
* Estabish SpU Prevention, Control, and
Countermeasures (SPCC) plans
* Conduct hazard assessment in the design and
operating phases
* Prevent mixing of hazardous wastes wfth
non-hazardous wastes
* Isolate hazardous wastes by contaminant
* Isolate liquid wastes from soBd wastes
* Use equipment data cards on equipment location,
characteristics, and maintenance
* Maintain a master preventive maintenance (PM)
schedule
* Deferred PM reports on equipment
* Maintain equipment history cards
* Maintain equipment breakdown reports
* Keep vendor maintenance manuals handy
• Mairtain a manual or oxnputerized repair history file
These programs are conducted to reduce
waste in a facflHy.
22
These audits are conducted to monitor
compliance with regulations.
SPCC plans are required by law for 08
storage facilities.
These measures can result in lower waste
haulage volumes and easier disposal of
the hazardous wastes.
These programs are conducted to cut
production costs and decrease
equipment downtime, in addition
to preventing waste releases due
to equipment faBure.
23,24
3,25,26
27,28.29
-------
Tattle E-3. Waste Minimization through Good Operating Practices (continued)
Good Operating Practice
Program Ingredients
Remarks
References
TraMng/Awareness-buBding
programs
m
61
Effective supervision
Emptoyee participation
Production echeduing/plannlng
Cost accounting/allocation
> Provide training tor
- Safe operation ol *e equipment
- Proper materials handling
- Economic and environmental ramifications of
hazardous waste generation and disposal
- Detecting releases of hazardous materials
* Emergency procedures
-Uaa of safety gear
Closer supervision may improve production efficiency
and reduce inadvertent waste generation
Management by objectives (M8O), wth goals for
waste reduction
•QuaRty circles" (tree forums between employees
and supervisors) can identify ways to reduce waste
SoUcK employee suggestions for waste reduction Ideas
Maximize batch sire
Dedicate equipment to a single product
Alter batch sequencing to minimize cleaning frequency
(Bght-to-dark batch sequence, for example)
Schedule production to minimizing cleaning frequency
Cost accounting done fer all waste streams leaving
the facilities
Aftocata waste treatment and disposal costs to the
operations mat generate the waste
These programs are conducted to reduce
occupational health and safety
hazards, in addition to reducing
waste generation due to operator
or procedural errors.
increased opportunity for early detection
of mistakes.
Better coordination among the various
parts of an overall operation.
Employees who intimately understand the
operations can identify ways to reduce
waste.
Altering production schedule can have a
major impact on waste minimization.
Allocating costs to the waste-producing
operations will give them an incentive
to cut their wastes.
-------
Table E-4. Waste Minimization Options In Materials Handling, Storage, and Transfer
Waste/Source
Wast* Reduction Manures
Remarks
References
Material/waste tracking and
Inventory control
O)
* Avoid over-purchasing
* Accept raw material only after inspection
• Ensure that inventory quantity does not go to
wast*
« Ensure that no containers stay in inventory
longer than a spedRed period
* Review material procurement specifications
* Return expired material to suppler
• Validate shel-llfe expiration dates
* Test outdated material for effectiveness
• Eliminate shel-We requirements for stable
compounds
* Conduct frequent inventory checks
* Use computer-assisted plant inventory system
* Conduct periodic materiah tracWng
• Proper tabelng of al containers
* Set up manned stations tor dtepensing
chemicals and collecting wastes
These procedures are employed to find
areas where the waste minimization
efforts are to be concentrated.
30,31
Loss prevention programs
Use property designed tanks and vessels only for
their intended purposes
Instal overflow alarms for all tanks and vessels
Maintain physical integrity of al tanks and vessels
Set up written procedures for aJ loading/unloading
and transfer operations
Install secondary containment areas
Forbid operators to bypass interlocks, alarms, or
slgnMteantfy alter setpoints without authorization
Isolate equipment or process tnes that leak or are
not in service
Use seal less pumps
Us* bellows-seal valves
Document al spWage
Perform overal material balances and estimate
th* quantity and dollar value of aR losses
Use floating-roof tanks for VOC control
Us* conservation vents ton fixed roof tanks
Use vapor recovery systems
-------
Table E-4. Waste Minimization Opttons In Materials Handling. Storage, and Transfer (continued)
Waste/Source Waste Reduction Measures Remarks References
Spills and leaks * Stora containers in such a way as to afaw for
visual inspection tor corrosion and leaks
• Stack containers in a way to minimize the chance
of tipping, puncturing, or breaking
* Prevent concrete "sweating" by raising the
drum off storage areas
* Maintain MSDSs to correctly handle spill
situations
• Provide adequate lighting In the storage area
* Maintain a dean, even surface in transportation
areas
• Keep aisles dear of obstruction
* Maintain distance between incompatible chemicals
* Maintain distance between different types of
_ chemicals to prevent cross-contamination
• * Avoid stacking containers against process
equipment
* Follow manufacturers' suggestions on the storage
and handing of af raw materials
• Insulation and inspection of electric circuitry for
corrosion and potential sparking
Cling * Use large containers instead of small containers
whenever possible
* Use containers with height-to-diameter ratio equal
to one to minimize wetted area
* Empty drums and containers thoroughly before
cleaning or disposal
-------
Table E-5. Waste Minimization Options for Parts Cleaning Operations
Waste
Source/Origin
Wast* Reduction Measures
Remarks
References
Spent solvent
Contaminated solvent from
parts cleaning operations
Use water-soluble cutting fluids instead
of on-based fluids
Use peel coatings in place of protective oils
Use aqueous cleaners
Use aqueous paint stripping solutions
Use cryogenic stripping
Use bead Wasting for paint stripping
Use mull-stage countarcurrent cleaning
Prevent cross-contamination
Prevent drag-in from other processes
Prompt removal of sludge from the tank
Reduce the number of different solvents
used
This could eliminate the need for solvent
cleaning.
A single, larger waste that is more
amenable to recydng.
8
7
6
Air emissions
Solvent toss from
degreasers and cold tanks
m
oo
Use roHype covers, not hinged covers
Increase freeboard height
tnstal freeboard chRters
Use silhouette entry covers
Proper equipment layout
Avoid rapid insertion and removal of lams
Avoid Inserting oversized objects into
the tank
Allow for proper drainage before removing
* Avoid water contamination o( solvent
in degreasers
24 to 50% reduction in emissions.
39% reduction in solvent emissions.
The speed that items are put into the
tank should be less than 11 feet/min.
Doss-sectional area of the kern should
be less that 50% of tank area to reduce
piston effect.
15
15
15
16
17
Rinse water
Water rinse to remove
solvent carried out with
the parts leaving the
cleaning tank
Reduce solvent dragout by proper design and
operation of rack system
Install air jets to btow parts dry
Us* fog nozzles on rinse tanks
Proper design and operation of barrel system
Use countercurrent rinse tanks
Use water sprays on rinse tanks
The dragout can be 0.4 gal/1000 sqft.
versus 24 gaY1000 soft tor poorly
drained parts.
More efficient rinsing is achieved.
15
15
15
15
-------
Appendix E
References
1. Kohl, J., J. Pearson, and P. Wright. Managing and Recycling Solvents In the FumKuffl
North Carolina State University, Raleigh, 1986.
2. Lenckus, D. "Increasing productivity'. Finishing Wood and Wood Pmducte Magazine Vol. 87, No.
4, May 1982, pp 44-66.
3. Campbell, M. E., and W. M. Glenn. Profit from Pollution Prevention. The Pollution Probe
Foundation. Toronto, Canada, 1982.
4. Kohl, J., P. Moses, and B. Triplett. Managing and Recycling Solvents: North Carolina PrartinAa
Facilities and Regulations North Carolina State University, Raleigh, 1984.
5. Dumey.J. J. "How to improve your paint stripping". Product Finishing. December 1982, pp 52-53.
6. Higgins, T. E. Industrial Process Modifications to Reduce Qeneratton of Hazardous Waste at POD
Facilities: Phase I Report CH2M Hill, Washington, D.C., 1985.
7. "Cryogenic paint stripping". Product Finish December 1982.
8. Mallamee, W. M. "Paint and varnish removers". Klfk-Qthmer Encyclopedia of Chemical Technology.
3rd edition, Volume 16, pp 762-767,1981.
9. Sandberg, J. Final Report on the Internship served at Gape Tool Company. Minnesota Technical
Assistance Program, Minnesota Waste Management Board, Minnesota, 1985.
10. Powder Coatings Institute. Information brochure. Washington, D. C., 1983.
11. Cole, G. E. "VOC emission reduction and other benefits achieved by major powder coating
operations". Paper No. 84-38.1 presented at the Air Pollution Control Association. June 25,1984.
12. California State Department Of Health Services. Alternative Technology for Recycling and Treatment
of Hazardous Waste 3rd Biennial Report. Sacramento, 1986.
13. California State Department of Health Services. Guide to Solvent Waste Reduction Alternatives.
October 1986, pp 4-25 to 4-49.
14. Kenson. R. E. "Recovery and reuse of solvents from VOC air emissions". Environmental Progress.
August 1985, pp 161-165.
15. Dumey, L J., editor. Electroplating Engineering Handbook. 4th edition. Van Nostrand ReinhoW.
New York, 1984.
16. American Society of Testing Materials. Handbook of Vapor Deoreasino. Special Technical
Publication 310-A.. ASTM, Philadelphia, April 1976.
17. Smith, C. Troubleshooting vapor degreasers". Product Finish. November 1981.
18. Loucks, C. M. "Boosting capacities with chemicals". Chemical Engineering Deskhook Issue. Vol.
80, No. 5, pp 79-84,1973.
19. 3M Corporation. Ideas - A Compendium of 3M Success Stories. St. Paul, MN.
E-9
-------
20. Fromm, C. H., S. Budaraju, and S, A. Cordery. "Minimization of process equipment cleaning waste".
Conference proceedings of HAZTECH International, Denver, August 13-15,1986, pp 291-307.
21. Versar, Inc. and Jacobs Engineering Group. Waste Minimization: Issues and Options. Vol. II. U. S.
Environmental Protection Agency, Washington, D. C., October 1986.
22. Fromm, C. H. and M. S. CaBahan. "Waste reduction audH procedure". Conference proceedings of
the Hazardous Materials Control Research Institute. Atlanta, 1986, pp 427-435.
23. North Carolina Pollution Prevention Pays Program. Environmental Auditing. North Carolina
Department of Environmental Health. 1985.
24. Baumer, R. A. Making environmental audits". Chamleal Engineering. Vol. 89, No. 22. November 1,
1982, p 101.
25. Kletz.T.A, "Minimize your product SpiRage". Hydrocarbon Pmcasslno. Vol.61, No. 3,1982, p 207.
26. Sarokin, D. "Reducing hazardous wastes at the source: Case studies of organic chemical plants In
New Jersey. Paper presented at Source Reduction of Hazardous Waste Conference, Rutgers
University, August 22,1985.
27. Singh, J. B. and R. M. Allen. "Establishing a preventive maintenance program". Plant Engineering.
February 27,1986, p 46.
28. Rlmberg, D. "Minimizing maintenance makes money*. Pollution Engineering. Vol. 12, No. 3,
December 1983, p 46.
29. Parker, N. H. "Corrective maintenance and performance optimization*. Chemical Engineering. Vol.
91, No. 7, April 16,1984, p 93.
30. Geftenan. E. "Keeping chemical records on track". Chamfeal Business Vol. 6, No. 11,1984, p 47.
31. Hickman, w. E. and W. D. Moore. "Managing the maintenance dollar". Chemical Engineering Voi
93, No. 7, April 24,1986, p 68.
E-10
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Appendix F
Government Technical/Financial Assistance Programs
The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-In service to answer
questions regarding RCRA and Superfund (CERCLA):
(800) 424-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)
The following states have programs that offer technical and/or financial assistance in the areas of waste
minimization and treatment.
Alabama
Hazardous Malarial Management and Resource
Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa. AL 35487-6373
(205) 348-8401
Alaika
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907)276-2864
Arkanaaa
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501)371-1370
California
Alternative Technology Section
Toxic Substances Control Division
California State Department of Hearth Services
714/744 P Street
Sacramento, CA 94234-7320
(916)324-1807
Connecticut
Connecticut Hazardous Waste Management Sen/ice
Suite 360
BOO Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Connecticut Department of Economic Development
210 Washington Street
Hartford CT 06106
(203)566-7196
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404)894-3806
Georgia (continued)
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta, CA 30334
(404) 656-2833
////no/*
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1808 Woodfieid Drive
Savoy, IL 61874
(217) 333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(312)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172
Iowa
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515)281-8690
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515) 294-3420
F-1
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Bureau of Wasta Managam«nt
Dapartmant of Haalth and Environmant
Forbes Field, Building 730
Topaka, KS 66620
(913)296-1607
Kentucky
Division of Wasta Management
Natural Raaourcas and Environmental Protection Cabinet
18RefllyRoad
Frankfort, KY 40601
(502)564-6716
iou/a/ana
Departmant of Environmantal Quality
Offloa of Solid and Hazardous Waata
P.O. Box 44307
Baton Rouga, LA 70804
(504)342-1354
MeryfMMf
Maryland Hazardous Waata Facilities Siting Board
60 West Street. Suite 200A
AnnapoBs, MO 21401
(301)974-3432
Maryland Environmental Service
2020 Industrial Drive
AnnapoBs, MD 21401
(301)269-3291
(800) 492-9168 (in Maryland)
Afaaaacni/sefta
Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(617)727-3260
Source Reduction Program
Massachusetts Department of Environmental Quality
Engineering
1 Winter Street
Boston, MA 02108
(617)292-5982
Mlchlgtn
Resource Recovery Section
Department of Natural Resources
P.O. Box 30026
Laming, Ml 48909
(517)373-0540
M/nneaofa
Minnesota Pollution Control Agency
Solid and Hazardous Watte Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-6300
Af/nnaaota (continued)
Minnesota Technical Assistance Program
W-140 Boynton Health Service
University of Minnesota
Minneapolis. MN 55455
(612)625-9677
(800) 247-0015 (in Minnesota)
Mihnesots Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612)536-0816
M/aaour/
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314)751-4919
Me* Jersey
New Jersey Hazardous Waste FacaWes Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08606
(609)292-1459
(609)292*1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
New York Stale Environmental Facilities Corf
50 Wolf Road
AJbany, NY 12205
(518)457-3273
North Caroffna
PoRution Prevention Pays Program
Department of Natural Resources and Community
Development
P.O. Box 27687
512 North Salisbury Street
RaWgh. NC 27811
(919)733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raieigh.NC 27611
(919) 733-9020
F-2
-------
North Carolina (eontlnuod)
Technical Assistance Unit
Solid and Hazardous W»«t« Manag*m*nt Brand)
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919)733-2178
Ohto
Division of Solid and Hazardous Wast* Management
Ohio Environmental Protection Agency
P.O. Sox 1049
1800 WatarMark Drive
Columbus. OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City. OK 73152
(405)271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quafity
81 1 Southwest Sixth Avenue
Portland, OR 97204
(503)229-5913
Pannaylvanla
Pennsylvania Technical Assistance Program
501 F. Orvto Keller Building
University Park, PA 16802
(114)865*0427
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisbuig, PA 17120
(717)787-6239
Center of Hazardous Material Research
Pittsburgh, PA 15238
(412)826-5320
MMfio
Ocean State Cleanup and Recycling Program
Rhode (aland Department of Environmental Management
9 Hayes Street
Providence, Rl 02908-5003
(401)277-3434
(800) 253-2674 (in Rhode Wand)
Rhode
Center of Environmental Studies
Blown University
P.O. Box 1943
136 Angell Street
Providence, Rl 02912
(401)863-3449
Ftmt*****
Center for Industrial Services
102 Alumni Hal
University of Tennessee
Knoxvlle.TN 37996
(815)97441456
Virginia
Office of Poficy and Planning
Virginia Department of Waste Management
11ft Floor, Monroe Buidtng
101 North 14th Street
Richmond, VA 23219
(804)2254*667
Washington
Hazardous Waste Section
Mat Stop PV-11
Washington Department of Ecology
Otympia, WA 98504-8711
(206)459-6322
MVMMMffl
Bureau of Sold Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, Wl 53707
(608)266-2699
fasts Management Program
Wyoming Department of Environmental Quaity
Herachier Buldlng, 4th Ftoor, West Wing
122 Wen 25th Street
Cheyenne, WY 82002
007)777-7712
F-3
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Appendix G
Option Rating
Weighted Sum Method
The Weighted Sum Method is a quantitative method
for screening and ranking waste minimization options.
This method provides a means ot quantifying the
important criteria that affect waste management in a
particular facility. This method involves three steps.
1. Determine what the important criteria are in terms
of the WM assessment program goals a
constraints, and the overall corporate goals an
constraints. Examples of criteria are the following:
• Reduction in waste quantity
• Reduction in waste hazard (e.g., toxicity,
flammability, reactivity, corrosivity, etc.)
• Reduction in waste treatment/disposal costs
• Reduction in raw material costs
« Reduction in liability and insurance costs
* Previous successful use within the company
* Previous successful use in industry
• Not detrimental to product quality
• Low capital cost
* Low operating and maintenance costs
• Short implementation period (and minimal
disruption of plant operations)
• Ease of implementation
The weights (on a scale of 0 to 10, for example) are
determined for each of the criteria in relation to
their importance.For example, if reduction in waste
treatment and disposal costs are very Important,
while previous successful use within the company
is of minor importance, then the reduction in waste
costs is given a weight of 10 and the previous use
within the company is given a weight of 1 or 2.
Criteria that are not important are not included (or
given a weight of 0).
2. Each option is then rated on each of the criteria.
Again, a scale of 0 to 10 can be used (0 for low and
10 for high).
3. Finally, the rating of each option from particular
criteria is multiplied by the weight of the criteria. An
option's overall rating is the sum of the products of
rating times the weight of the criteria.
The options with the best overall ratings are then
selected for the technical and economic feasibility
analyses. Worksheet 13 in Appendix A is used to rate
options using the Weighted Sum method. Table G-1
presents an example using the Weighted Sum Method
for screening and ranking options.
Table G-1. Sample
Weighted Sum Method
Calculation using tit*
ABC Corporation has determined that reduction in waste
treatment costs Is the most important criterion, with a weight
factor of 10. Other significant criteria include reduction in
safety hazard (weight of 8), reduction in liability (weight of 7),
and ease of implementation (weight of 5). Options X, Y, and
Z are then each assigned effectiveness factors. For
example, option X is expected to reduce waste by nearly
80%, and is given an rating of 8. R is given a rating of 6 tor
reducing safety hazards, 4 for reducing liability, and
because it is somewhat difficult to implement, 2 for ease of
implementation. The table below shows how the options are
rated overall, with effectiveness factors estimated for
options Y and Z.
Ratings for each. optiBD
Rating Criteria Weight X Y Z
Reduce treatment costs 10 863
Reduce safety hazards 8 638
Reduce liability 7 445
Ease of implementation S 2 2 8
Sum of weight times ratings 166 122 169
From this screening, option Z rates the highest with a score
of 169. Option X's score is 166 and option Y*s score is 122.
In this case, option Z and option X should both be selected
for further evaluation because both of their scores are high
and relatively close to each other.
G-1
-------
Appendix H
Economic Evaluation Example
The following example presents a profitability analysis
for a relatively large hypothetical waste minimization
project. This project represents the installation of a
package unit that improves plant production while
reducing raw material consumption and disposal costs.
The analysis was done on a personal computer using a
standard spreadsheet program. The salient data used
in this evaluation are summarized below.
Capital Costs
• The delivered price of the equipment is quoted by
the vendor at $170,000. This includes taxes and
Insurance.
• Materials costs (piping, wiring, and concrete) are
estimated at $35,000.
• Installation labor is estimated at $25,000.
• Internal engineering staff costs are estimated at
$7,000. Outside consultant and contractor costs
are estimated at $15,000.
• Miscellaneous environmental permitting costs are
estimated at $15,000.
• Working capital (including chemical inventories, and
materials and supplies) is estimated at $5,000.
• Start-up costs are estimated by the vendor at
$3,000.
• A contingency of $20,000 for unforeseen costs
and/or overruns is included.
• Planning, design, and installation are expected to
take one year.
Financing
• The project will be financed 60% by retained
earnings and 40% by a bank loan.
• The bank loan will be repaid over 5 years of equal
installments of principal, plus interest at an annual
percentage rate of 13%. Interest accrued during
installation will be added into the total capital costs.
• All capital costs, except working capital and interest
accrued during construction, will be depreciated
over 7 years using the double-declining balance
method, switching to the straight-line method when
the charges by this method become greater.
• The marginal income tax rate Is 34%.
• Escalation of all costs is assumed to be 5% per year
for the life of the project.
• The firm's cost of capital is 15%.
Operating Costs and Revenues
• The WM project is estimated to decrease raw
materials consumption by 300 units per year at a
cost of $50 per unit. The project will not result in an
increased production. However, ft will produce a
marketable by-product to be recovered at a rate of
200 units per year and a price of $25 per unit.
• The project will reduce the quantity of hazardous
waste disposed by 200 tons per year. The following
items make the total unit disposal costs:
Offstte disposal fees
State generator taxes
Transportation costs
Other costs
TOTAL DISPOSAL COSTS
Costs per ton of waste
$500
10
25
$560
Incremental operating labor costs are estimated on
the basis that the project is expected to require one
hour of operator's time per eight-hour shift. There
are three shifts per day and the plant operates 350
days per year. The wage rate for operators is
$12.50 per hour.
Operating supplies expenses are estimated at 30%
of operating labor costs.
Maintenance labor costs are estimated at 2% of the
sum of the capital costs for equipment, materials,
and installation. Maintenance supplies costs are
estimated at 1% of these costs.
Incremental supervision costs are estimated at 30%
of the combined costs of operating and
maintenance labor.
The following overhead costs are estimated as a
percentage of the sum of operating and
maintenance labor and supervision costs.
Labor burden and benefit 28%
Plant overhead 25%
Headquarter overhead 20%
H-1
-------
* Escalation of all exists is assumed to be 5% per year
for the life of the project.
* The project life is expected to be 8 years.
• The salvage value of the project Is expected to be
zero after eight years.
Results
The four-page printout in Figures H-1 through H-4
presents the WM project profitability spreadsheet
program. Figure H-1 represents the input section of
the program. Each of the numbers in the first three
columns represents an input variable in the program.
The rigrrthand side of Figure H-1 is a summary of the
capital requirement. This includes a calculation of the
interest accrued during construction and the financing
structure of the project.
Figure H-2 is a table of the revenues and operating
cost Kerns for each of the eight years of the project's
operating life. These costs are escalated by 5% each
year for the fife of the project.
Figure H-3 presents the annual cash flows for the
project. The calculation of depreciation charges and
the payment of interest and repayment of loan principal
is also shown here. The calculation of the internal rate
of return (IRR) and the net present value (NPV) are
based on the annual cash flows. Since the project is
leveraged (financed partly by a bank loan), the equity
portion of the investment is used as the initial cash
flow. The NPV and the IRR are calculated on thte basis.
The IRR calculated this way is referred to as the "return
on equity". The program is structured to present the
NPV and IRR after each year of the project's operating
life. In the example, after six years, the IRR Is 19.92%
and the NPV is $27,227.
Figure H-4 is a cash flow table based entirely on equity
financing. Therefore, there are no interest payments
or deb principal repayments. The NPV and the IRR in
thte case are based on the entire capital investment hi
the project. The IRR calculated this way Is referred to
as the "return on investment".
The results of the profitability analysis for this project
are summarized below:
Method of Financing Ffi NPV
60% equity/40% debt 26.47% $84,844
100% equity 23.09% $81,625
The IRR values are greater than the 15% cost of
capital, and the NPVs are positive. Therefore, the
project is attractive, and should be implemented.
H-2
-------
Waste Minimization
Profitability Program
Capital Co«t Factors
Capital Cost
Equipment
Materials
Installation
Plant Englneerfno,
Contractor/Engineering
Permitting Costs
Contingency
Working Capital
Start-up Costs
% Equity
%Debt
Interest Rate on Debt, %
Debt Repayment, years
Depredation period
Income Tax Rate. %
Escalation Rates, %
Cost of Capital (for NPV)
$170,000
$35.000
$25.000
$7.000
$15.000
$15.000
_$20,000
$5.000
$3.000
60%
40%
13,00%
5
7
34.00%
5.0%
15.00%
started 5/22/87
last changed 8/1/87
MPUT
Operating Cost/Revenue Factors
Increased Production
Increased Rate, units/year
Price, $/unrt
Marketable By-products
Rate, units/year
Price. $/un«
Decreased Raw Materials
Decreased Rate, units/year
Price. $/un»
Decreased Waste Disposal
Reduced Waste, tons/year
Orfstte Fees. $/ton
State Taxes, $/ton
Transportation! $/ton
Other Disposal Costs, $/ton
Total Disposal Costs, $/ton
0
$100
200
$40
300
$50
200
$500
$10
$25
$25
$560
Operating Labor
Operator hours/shift
Shifts/day
Operating days/Year
Wage rate, $/man-hour
Operating Supplies
(% of Operating Labor]
Maintenance Costs
{% of Capital Costs)
Labor
Materials
Other Labor Costa
r% of O&M Labor)
Supervision
(% of O&M Labor + Sui
Plant Overhead
Home Office Overhead
Labor Burden
;
350
$13.50
30%
2.00%
1.00%
30.0%
rvtsbn
25.0%
20.0%
28.0%
CAPITAL REQUIREMENT
Construction Yea
Capital Expenditures
Equipment
Materials j
Installation
Plant Engineering
Contractor/Engineering
Permitting Costs
Contingency
Start-up Costs
Depreciable Capital
Working Capital
Subtotal
Interest on Debt
Total Capital Requirement
Equity Investment
5ebt Principal
nterest on Debt
Total Financing
1
$170.000
$35.000
_i2l5,000
$7.000
_|15,000
_J15,000
$20.000
$3,000
$290,000
$5,000
_$J?5,000
_$J4,230
$309,230
$185,538
M 09,462
$14,230
$309,230
Figure H-1. Input Information and Capital Investment
-------
REVENUE AND COST FA(
Operating Year Number
Escalation Factor 1
MCflEASED REVENUES
Increased Production
Marketable By-products
Annual Revenue
OPERATING COST/SAVI
Raw Materials
Disposal Costs
Maintenance Labor
Maintenance Supplies
Operating Labor
Operating Supplies
Supervision
Labor Burden
Plant Overhead
Home Office Overhead
TotsJ Operating Costs
TORS
1.000
IGS
1
1.050
10
$8,400
$8.400
$15.750
_$1 17,600
($4.830)
($2.415)
($14.884)
($4.466)
($5.914)
($7.176)
($6.407)
($5.126)
$82.133
2
1.103
$0
$8,824
$8.824
$16545
$123,536
($5.074)
($2.5371
($15.635)
($4.691)
($6,213)
($7.538)
($6.731)
($5.384)
$86278
3
1.158
$0
$9.264
$9.264
$17.370
$129.696
($5.327)
($2.663)
($16.415)
($4.925)
($6.523)
($7.914)
($7.066)
($5.653)
$90.580
4
1.216
$0
$9.728
$9.728
$18.240
$136.192
($5.594)
($2.797)
($17.237)
($5.171)
($6.849)
($8.310)
($7.420)
($5.936)
$95.118
5
1.277
$0
$10.216
$10.216
$19.155
J143JE4
($5.874)
($2.937)
($18.101)
($5.430)
($7.193)
($8.727)
($7.792)
($6.234)
$99.891
6
1.341
$0
$10,728
$10.728
$20.115
$150.192
($6,169)
($3.084)
($19.009)
($5.703)
($7.553)
($9,165)
($8,183)
($6.546)
$104.895
7
1.408
$0
$11,264
$11.264
$21.120
$157.696
($6.477)
($3,238)
($19.958)
($5.987)
(1(7.931)
(! 9.622)
($8.592)
($6.873)
$110.138
8
1.478
$0
$11.824
$11.824
$22J70
$165.536
($6.799)
($3399)
($20,951)
($6285)
($8.325)
($10.101)
($9.019)
($7215)
$115.612
Figure H-2. Revenues and Operating Costs
-------
I
t
01
RETURN ON EQUITY/RE!
Construction Year
Operating Y«ar
Book Value
Depreciation (by straight-
Depreciation (by doubfeD
Depreciation
Debt Balance
Interest Payment
Principal Repayment
CASHFLOWS
Construction Year
Operating Year
Revenues
+ Operating Savings
Net Revenues
- Depredation
- Interest on Debt
Taxable Income
-Income Tax
Profit after Tax
+ Depreciation
- Debt Repayment -
Aflw-Tax Cash Row
Cash Fbw for ROE
Met Present Value
Return on Equity
26.47%
JRN ON ASSETS
1
$290.000
ne)
)
$123.692
1
($185^38)
($185,538)
1
$207.143
$41,429
$82.857
$82,857
$123.692
$16,080
$24,738
1
$8.400
$82.133
$90.533
$82.857
$16,080
($8,404)
($2,857)
($5.547)
$82,857
$24.738
$52372
$52372
($139.823)
ffNUMI
2
$147.959
$41,429
$59,184
$59,184
$98.954
$12.864
$24,738
2
_$8»824
$86.278
$95.102
$59.184
$12.864
$23,054
$7,838
$15.216
$59.184
$24.738
$49.662
$49,662
($102.272)
-32.19%
3
$105.685
$41.429
$42,274
$42.274
$74,216
$9.648
$24.738
3
$9,264
$90,580
$99.844
$42.274
$9.648
! 47,922
i 16,293
$31.629
$42.274
$24.738
$49.165
$49.165
($69.945)
-9.62%
4
$64.256
$41,429
$30,196
$41.429
$49,478
$6.432
$24,738
4
$9,728
$95,118
$104.846
$41,429
$6,432
$56,985
$19.375
$37.610
$41.429
$24.738
$54.301
$54.301
($38.898)
4.24%
5
$22.827
$41.429
$18.359
$41,429
$24.740
$3.216
$24,738
5
$10,216
$99.891
$110.107
$41.429
$3.216
$65.462
$22.257
$43.205
$41,429
$24.738
$59.896
__$J9,896
($9.119)
1295%
6
$0
$41.429
$6.522
$22,827
$2
$0
$2
6
$10,728
I$_104,895
$115,623
$22,827
$0
$92.796
$31.551
$61,245
$22.827
$2
$84.070
$84,070
$27.227
19.92%
7
$0
$0
$0
$0
$0
$0
$0
7
$11,264
$110,138
$121,402
$0
$0
$121,402
$41,277
$80,125
$0
$0
$80,125
$80.125
$57.349
23.85%
8
$0
$0
$0
$0
$0
$0
$0
8
$11,824
$115.612
$127.436
$0
$0
$J27,436
$43,328
$84,108
$0
$0
$84,108
$84.108
$84.844
26.47%
Figure H-3. Cash Flows for Return on Equity
-------
f&UfUto»*tesnjEH
Construction Year
Operating Year
Book Value
Depreciation {by straight-
Depreciation (by double D
Depreciation
CASHFLOWS
Construction Year
Operating Year
Revenues
+ Operating Savings
Net Revenues
• Depreciation
Taxable Income
-Income Tax
'rofrt after Tax
+ Depreciation
After-Tax Cash How
Cash Flow for ROI
•Jet Present Value
teturn on Investment
23.05%
1
$290.000
ne)
W
1
($295.000)
($295.000)
1
$207,143
$41.429
$82,857
$82.857
1
$8.400
$82,133
$90.533
$82,857
$7.676
$2.610
$5.066
$82.857
$87.923
$87.923
($218.545)
fNUM!
2
$147.959
$41,429
$59.184
$59.184
2
$8.824
$86,278
$95.102
$59,184
$35,918
$12.212
$23.706
$59.184
$82,890
$82,890
($155.868)
-30.04%
3
$105.685
$41.429
$42.274
$42.274
3
$9.264
$90,580
$99.844
$42.274
$57.570
$19,574
$37.996
$42.274
$80.270
$80,270
($103.090)
-7.76%
4
$64,256
$41.429
$30,196
$41,429
4
$9.728
$95.118
$104,846
$41.429
$63.417
$21.562
$41.855
$41.429
$83.284
$83,284
($55.472)
5.26%
5
$22.827
$41,425
$18.359
$41.429
5
$10.216
$99,891
$110.107
$41,429
$68,678
$23.351
$45.327
$41.429
$86,756
$86,756
($12,339)
13.21%
6
$C
$41.42S
$6.522
$22.827
6
$10,728
$104.895
$115.623
$22,827
$92,796
$31.551
$61,245
$22.827
$84,072
$84.072
$24.008
17,99%
7
$0
$c
$0
$0
7
$11,264
$110,138
$121.402
$0
$121,402
$41.277
$80,125
$0
$80.125
$80.125
$54.130
20.97%
8
$0
$0
$0
$0
8
$11.824
$115.612
$127.436
$0
$127.436
$43,328
$84,108
$0
$84,108
$84,108
$81.625
23.09%
Figure H-4. Cash Ftows for Return on Investment
-------
-------
vvEPA
United States
Environmental Protection
Agency
Office of Pollution Prevention
and Toxics
Washington, DC 20460
May 1995
EPA/742-F-95-005
EPA Standards Network Fact Sheet
Role of Voluntary
Standards
What are Voluntary
Standards and Who
Develops Them?
Federal government activities involve the use of products or services that must meet reliable
design and/or performance standards. Many of these standards are developed by the private
sector through standards developing organizations referred to as "voluntary" standards bodies.
The Federal government's participation in these standards bodies can provide incentives and
opportunities to develop standards that serve national needs in environmental, health, safety and
other areas. Government adoption of voluntary standards can help reduce costs to Agencies and
Departments and also further enhances effective public-private partnerships.
Originally, the term "voluntary" distinguished the standards development process from govern-
mental or regulatory processes. Private sector standards that come under international trade
rules, or are referenced in specifications and contracts, are not voluntary in application.
Voluntary standards are also made mandatory at times by being incorporated into law by
governmental bodies.
A generally accepted definition of standards states that they are sets of rules, conditions or
requirements concerned with the definition of terms, classification of components; delineation
of procedures; specification of dimensions, materials, performance, design or operations;
measurement of quality and quantity in describing materials, products, systems, services or
practices; or descriptions of fit and measurement size. Voluntary standards can be used by any
person or organization, whether private or governmental.
International agreements, including the General Agreement on Trade and Tariffs (GATT) and
the North American Free Trade Agreement (NAFTA), define standards and international
standards-developing bodies somewhat differently for the purposes of trade-related issues.
Voluntary standards are developed by industry, nonprofit organizations, trade associations, and
others. Examples of voluntary standards developers in the United States include the American
Society for Testing and Materials (ASTM), The Society for Automotive Engineers (SAE) and
The National Sanitation Foundation International, Inc. (NSF). Examples of international
standards organizations include the International Organization for Standardization (ISO) and the
International Electrotechnical Commission (IEC). Within these bodies, standards-developing
groups, such as committees, boards and working groups, write, review and revise standards in
accordance with the procedures established by the standards body. ISO's Technical Committee
207 for Environmental Management Standards, for example, is a standards group.
Printed on Recycled Paper
-------
What Is ANSI?
Why Does the U.S.
Government Use
Voluntary
Standards?
How Is EPA
Using Voluntary
Standards?
The American National Standards Institute (ANSI) maintains policies and procedures for the
development, review, and coordination of voluntary standards that are designated as American
National Standard; however, ANSI is not a standards developer. ANSI, headquartered in New
York, is the official U.S. member body to ISO and IEC, and its membership derives from
organizations, companies, and government agencies.
OMB Circular No. A-l 19 provides guidance to Federal agencies in working with, and using the
products of private sector standards organizations. The circular sets a policy whereby the
Federal government, in its procurement and regulatory activities, is directed to:
a. Rely on voluntary standards, both domestic and international, whenever
feasible and consistent with law and regulations pursuant to law;
b. Participate in voluntary standards bodies when such participation is in the public
interest and is compatible with agencies' missions, authorities, priorities, and budget
resources; and
c. Coordinate agency participation in voluntary standards bodies so that (1) the most
effective use is made of agency resources and representatives; and (2) the views
expressed by such representatives are in the public interest and, as a minimum, do
not conflict with the interests and established views of the agencies.
EPA uses voluntary standards to support rulemaking compliance activities and partnership
programs with industry, such as the Environmental Leadership Program, Green Lights, 33/50
and the Common Sense Initiative. Two examples of using voluntary standards to support rule
making include:
In a final rule on degradable plastic ring carriers, EPA requires that ring carriers be made
of degradable material. Rather than specifying a particular type of degradable plastic,
EPA chose a degradability performance standard for ring carriers. To test the degradability
of carrier rings, the EPA adopted two ASTM tests, specifically D-3826-91, Standard
Practice for Determining Degradation End Point in Degradable Polyolefins Using a
Tensile Test, and D-5208-91 Standard Practice for Operating Fluorescent Ultraviolet (UV)
and Condensation Apparatus for Exposure of Photodegradable Plastics.
In a proposed rule under the Clean Air Act Section 112(r), scheduled to be finalized by
Spring of 1996, EPA proposed to require facilities who store extremely hazardous
substances on site to develop risk management plans which demonstrate compliance with
performance-based standards.
Where Can I Get
More Information?
For additional information, contact:
Mary McKiel
EPA Standards Network Coordinator
U.S. Environmental Protection Agency
401 M Street, SW (OPPT-7409)
Washington, D.C. 20460
Telephone: (202) 260-3584
Fax: (202)260-0178
mckiel.mary@epamail.epa.gov
Marilyn Hernandez
ANSI
11 West 42nd Street
New York, New York 10036
Telephone: (212)642-4915
Fax: (212)398-0023
mhernand@ansi.org
-------
f/EPA
United States
Environmental Protection
Agency
Office of
Prevention, Pesticides,
and Toxic Substances
MC 7409
EPA742-F-96-001
September 1996
Environmental Accounting Project
Quick Reference Fact Sheet
Goal: To encourage and motivate businesses to
understand the full spectrum of their environmental
costs, and integrate these costs into strategic decision
making.
Background: Environmental and economic benefits
of practicing pollution prevention can be difficult to
measure using traditional methods of accounting. As
a consequence, industrial managers often may not
adopt pollution prevention even when it might be in
the best interest of a facility or company to do so,
Description: EPA initiated the Environmental
Accounting Project in 1992 to encourage businesses
to incorporate environmental costs into managerial
accounting and capital budgeting practices.
Implementing environmental accounting will make
environmental costs more visible to company
managers, thus making these costs more manageable
and easier to reduce. Environmental accounting
should help companies significantly reduce or
eliminate environmental costs, improve
environmental performance, and gain competitive
advantage.
The Project's Action Agenda incorporates
recommendations from the business community,
accounting and professional societies, the academic
and research community, small businesses, and
government on what needs to be done by various
stakeholder groups to increase the use of
environmental accounting. Major issues addressed
by the Action Agenda include:
* Terms, concepts, and roles,
• Management incentives,
• Education, guidance, and outreach, and
• Tools, methods, and systems.
The Environmental Accounting Project maintains a
Network Directory of some 680 members who are
actively participating or are interested in the issue.
Examples of Accomplishments to Date:
• Developed an environmental accounting primer
that covers the basic terms and concepts and
discusses application options
• Completed a status report the on the extent to
which the nation's manufacturing firms consider
environmental costs in investment decisions
• Published case studies on environmental
accounting initiatives at AT&T and at Ontario
Hydro (a Canadian utility)
• Trained state technical assistance providers and
permitters on the environmental accounting
concept in several regions
• Hosted workshops for industry and government
creating dialogue on environmental accounting
• Developed a software tool to help companies
incorporate environmental costs into their capital
budgeting decisions
• Published resource guide on tools and software
that account for environmental costs
Projects Underway Include:
* Best Practices report of chemical companies'
environmental accounting efforts
» Analysis of how environmental accounting
applies to the metal finishing industry
» Documentation of available techniques for
estimating potential environmental liabilities
« Continued outreach and exploration of ways to
simplify implementation of environmental
accounting
For further information: See the Project's Website
@ http://es.inel.gov/partners/acctg, or Contact
EPA's Pollution Prevention Information
Clearinghouse: 202/260-1023, fax 202/260-
0178,or Internet: ppic@epamail,epa,gov
-------
United States
Environmental Protection
Agency
EPA530-K-95-004
September 1995
&EPA
Solid Waste and Emergency Response (5305W)
Recycling Means
Business
-------
The Benefits of Recycling Market Development
This booklet introduces Recycling
Means Business, the U.S.
Environmental Protection Agency's
(EPA's) strategy for supporting the
national effort to expand markets
for recycled materials. In addition
to its environmental benefits,
in scope. For example, strong
recycling markets will:
* Increase the revenues paid to
communities for their recyclable
materials.
• Create jobs in communities
-te
become a major sector of the
national economy, fueling
greater economic growth, ^
-------
EPA's
"Greenprint"
for Market
Development
ver the past decade, ambitious
collection programs instituted by
communities and organizations across
America have diverted millions of tons of
recyclable materials from the solid waste stream. The
number of community curbside collection programs alone
has increased by 5OO percent over the past five years, with
more than 6,6OO curbside collection programs in place.
Many government agencies, businesses, and organizations
also instituted in-house recycling collection programs,
successfully diverting everything from office paper to scrap
tires. The nation is collecting over 2O percent of its solid
waste for recycling—the highest rate since World War II.
-------
Recycling what would
otherwise be thrown away
has obvious environmental
benefits. Using recovered materials as
a substitute for virgin feedstocks
conserves natural resources, reduces
the energy used for manufacturing,
and lessens the environmental impacts
associated with the
extraction and harvesting
of raw materials. In
addition, recycling makes
sense as a waste
management technique,
diverting valuable
materials from the
waste stream and
reducing the burden
on landfills and
incinerators.
Recycling also has inherent economic
benefits. Every step in the recycling
process, from collection to
remanufacturing to purchasing
recycled products, adds value to
recovered materials. In fact, "value
added" (defined as the difference
between the cost of materials and the
selling price of the products made
from these materials) is a measure
frequently used to gauge the
economic contribution of
recycling. The process of
turning collected materials into
new products creates a chain of
economic activity that can result
in business expansion, jobs, and other
economic growth in communities
across the country—all from a resource
that used to be thrown away.
Everyone benefits from this increase in
economic activity. Recycling
businesses are able to earn profits that
in turn can be reinvested in new plants
and processes. In addition, these
businesses require supplies and
services from other industries, such as
construction, equipment supply,
transportation, and research and
development, expanding their
economic impact and creating more
jobs for area residents. And the jobs
created by recycling businesses tend
to draw from the full spectrum of the
labor market. The material collection
and sorting industries primarily
contribute low- and semi-skilled jobs.
-------
while the companies in the
manufacturing sector, which
typically create the lion's share of
new employment opportunities,
offer more highly skilled jobs.
Communities and businesses looking
for new routes to economic growth
are recognizing that the waste they
generate every day is a valuable
economic resource. Instead of
paying to have recyclable materials
disposed of, or sending them to be
recycled elsewhere, communities can
keep the added value by providing
the materials, labor, and markets that
fuel local growth.
The Balancing Act
For recycling to realize its full
environmental and economic
potential, however, the three
components of recycling-
collecting, remanufacturing, and
purchasing recycled products—must
be in balance. This balance is
illustrated by the universal symbol of
recycling, the "chasing arrows."
The first arrow
represents the
( \ \ ^ collection of
\~ I/ f materials for
^— recycling, which
has grown dramatically since the
early 1980s. The other two sides
of the recycling equation,
however—the remanufacturing of
new products and the purchasing
^-V'
Recycling Versus Waste
DisposaL
remain
(ONI
the waste landfilled. ILSR found
i
: that for a city of one million
V"
residents, a single mill
processing 100,000 tons of ONP
up to
',. &, r*. .
$57 million in
I cost t|ie
city |4 million In disposal costs
annually (assuming an average
tipping fee of $40 per ton).
of these products by consumers—
are only beginning to match the
strength of the collection side of
recycling. Since sustainable
recycling hinges on turning
collected materials into new
products, and on selling these
products to consumers, expanding
the processing and remanufacturing
capacity of recycling businesses is
critical. This process is known as
market development.
-------
Making Market
Development Work
To further the development
of recycling markets, EPA
created a strategy called
Recycling Means Bus/ness. EPA
interviewed over 150 individuals
from governments, businesses, and
nonprofit organizations to identify
real and potential market
development issues that affect
sustainable recycling. Using this
information. Recycling Means
Business aims to:
The Importance of Market
Development
Market development is the key to
unleashing the economic potential of
the recycling industry. Market
development includes:
* Starting new recycling-based
businesses.
* Expanding existing businesses
and increasing revenues.
• Creating new jobs and adding
wages,
• Expanding the local tax base.
* Making additional capital
available to firms for growth.
Market Development's
Key Players
Recycling Means Business
fosters the development of
recycling-based businesses.
It provides a national forum to
build markets by facilitating the
efforts of:
• State, tribal, and local
governments
• Private sector entities
• Other federal agencies
• Nonprofit groups
• Educational institutions
• Individuals
• Support and sustain the link
between increased market
capacity and sustainable
economic growth.
• Leverage federal resources and
build federal partnerships for
market development.
• Develop infrastructures that
support markets for recyclables
and recycled products.
Together, these goals form a
"greenprmt" to help ensure markets
for environmentally sound and
economically sustainable recycling.
-------
Linking and
Economic Growth
Recycling Means Business fosters
interaction and coordination
among economic development
professionals, financial institutions,
and recycling businesses. It is
critical that these groups work in
partnership to ensure that recycling
fulfills its potential for job creation
and economic revitalization.
Recycling Means Business
addresses the need to provide
marketing, technical, and financial
assistance to recycling businesses,
and to promote the use of
recovered materials.
State and local economic
development programs can be
instrumental in championing and
coordinating recycling projects
within their jurisdictions. These
programs serve as catalysts for
recycling businesses by encouraging
banks, investment groups, small
business lenders, and others within
the financial community to identify
and help fund recycling ventures.
They also help new recycling
businesses seek out and acquire the
capital and other resources they
need to be successful.
Through Recycling Means Business,
EPA is building the capacity of
those groups that provide capital
and information to budding
recycling businesses.
Bringing Together
and Recycling G
EPA's Jobs Through Recycling
initiative is one part of the
Recycling Means Business
strategy. Jobs Through Recycling
was launched to:
* Expand local and regional
markets tar recycled materials.
iic
* Create jobs In recycling-related
Recognizing that recycling can be
an important part of their '
economic development strategy, .
communities across the country
-------
For example, EPA established four
Recycling and Reuse Business
Assistance Centers (RBACs) and nine
Recycling Economic Development
Advocate (REDA) positions to help
recycling businesses gain access to
information and markets. These
RBACs and REDAs inform manu-
facturers about the economic
benefits of using recycled feedstocks,
finding these materials, and
switching from virgin-based raw
materials. These programs also help
individual companies learn how to
assess the equipment and process
modifications necessary to convert
from virgin to recycled feedstocks.
They also are helping companies
locate sources of high-quality
recovered materials and perform
cost analyses to help determine
when they might begin saving
money from switching to these
materials.
Industry also is taking action. Start-
up recycling businesses, with hard
work and assistance from the
growing number of economic
development programs, are making
the collection and remanufacture of
recovered materials a reality. Other
companies are reaching out within
the business community for
information and assistance on
collecting their recyclable materials
and finding ways to use recycled
products in their service and
manufacturing processes.
Leveraging Federal Resources
Recycling Means Business recognizes
and uses the federal government's
ability to stimulate recycling market
development. With its significant
purchasing power, federal procure-
ment alone represents about 8
percent of the nation's Gross
Domestic Product. Aggressive buy-
recycled policies by federal agencies
help to generate critical markets for
recycled products.
Procurement, however, is just one
part of market development. Many
federal agencies—from the
Department of Commerce to the
Small Business Administration—have
experience in job creation, business
assistance, community economic
development, and technology
development. EPA and other
agencies together can facilitate the
dissemination of this knowledge
throughout industry, thereby building
and strengthening recycling markets.
Building a Recycling
Infrastructure
Just as building a house requires a
strong infrastructure—a solid
foundation, a framework for
supporting the walls and roof, and
connections such as electricity and
clean water—sustainable recycling
-------
feds la
on
Order
tablish recycling
i '
Whenever
as developed the ',
jcurement of Products
(and the
J$ Advisory Notice
}. The CP6 lists currently available items made
from recovered materials. Other federal agencies can :
refer to these resources for recycled products.
The federal contribution also includes entering into
partnerships with other organizations to help build
recycling markets. For example, to help companies
acquire specific information about using recovered
feedstocks, the National Institute of Standards and
Technology (NIST, a division of the U.S. Department of
Commerce), Washington State's Clean Washington
Center, and the National Recycling Coalition (NRC)
created the Recycling Technology Assistance Project
(ReTAP). ReTAP has two distinct missions: (1) to provide
direct technical assistance to companies interested in
switching to recycled materials in plant operations, and
(2) to disseminate recycling technology information
across the country. With funding support from EPA,
ReTAP offers such services as identifying and resolving
recycled product manufacturing difficulties and
{identifying potential end uses for recycled products.
-------
Structures for Sustainable Recycling
EPA's Recycling Means Business strategy was designed
to build on efforts already under way to develop the
foundation of recycling. One such project is the
establishment of an exchange for buying and selling
recovered materials in the mecca of commodity
markets—the Chicago Board of Trade (CBOT). The
Chicago Board of Trade Recycling Partnership was
created by the New York State Office of Recycling
Market Development, the National Recycling Coalition
(NRC), Clean Washington Center, EPA, and CBOT itself
to provide a formal recovered materials market
exchange. This new recycling market is helping to
remove uncertainties over recovered materials' price
and availability. The exchange also is helping minimize
concerns over the quality of recycled feedstocks
through standardized inspection procedures and a
neutral process for settling trade disputes.
To encourage businesses to adopt or expand buy-
recycled programs, EPA also created its WasteWi$e
program. In addition to implementing recycling
collections and adopting waste prevention activities,
corporations that join the program agree to increase
their purchase and/or manufacture of recycled products.
By increasing the demand for recovered materials, the
hundreds of corporations that have joined WasteWiSe
are poised to make a major contribution to the
development of a recycling infrastructure.
-------
also depends on developing a basic
infrastructure. This infrastructure
includes elements such as:
» Networks of information
supporting markets for recyclable
materials and recycled products.
• Links between buyers and sellers.
» Established consumer demand for
recycled products.
This nationwide base is critical for
sustainable recycling. Recycling
Means Bus/ness helps to support and
expand this foundation. Recycling
Means Business is helping improve
existing market development
programs, provide opportunities for
information exchange, and promote
recycled products procurement in
both the public and private sectors.
Recovered Materials Market Capacity Growth
in Minnesota 1087 to 1193
Market
Development:
2000 and Beyond
R
c
o
Q.
03
O
11987
H993
Total 1987 capacity: 5.3 million tons
Total 1993 capacity: 15 million tons
ONP
ecyc/ing Means Business
provides focus and guidance
for EPA's growing market
development activities. At the same
time, it serves as a "greenprint" to
help organize the market develop^
ment efforts of governments,
businesses, and nonprofit
organizations. As these efforts take
root and our economy moves toward
a greater use of recovered raw
materials, EPA will monitor Recycling
Means Business trends closely to
ensure its continuing effectiveness.
In particular, EPA will
continue to study the
market development
r^_ needs of the recycling
fjt business community.
f« Soliciting feedback
V,'iJS:
«| will remain an
important part of the
process. In this way,
EPA can maintain the
collaborative spirit
under which this
strategy was drafted,
identify emerging
market development
issues, and design
new projects to meet
these challenges.
11
1
I
ft
-------
More Studies Link He cycling and Jobs
A series of studies examining the emerging recycling
industry has found that recycling is having a major impact
on job creation in local and state economies. For example,
in a recent report entitled California Recycling Means
California Jobs: A Library of Facts, the Californians Against
Waste Foundation reported that recycling businesses in the
state employ about 18,000 residents. Small business
manufacturers, who have entered the recycling market in
response to the state laws encouraging recycling and the
steady growth in recycling collections, are accounting for
much of this growth. The report also predicts a continu-
ation of this trend. About 45,000 recycling jobs are
expected by the year 2000, over 20,000 of which should
come from the manufacturing sector.
In Philadelphia, city planners decided to conduct a multi-
year study to gauge recycling's impact on the economy of
the metropolitan Philadelphia area. The city gathered
baseline data in 1991, finding that the potential existed for
665 jobs from recycling (based on the city's count of 35
companies that had started up, were intending to start up,
or had expanded since 1986). By 1992, the city found that
Recycling Employment in Washington State ny Commodity:
Jobs Created Since 1989
Paper•
1,300
tiass^i j Other (-Plastic r Compos! .-- Metal
10 I | 90 I 100 140 / 410
1°89:
2,050
-------
25 of the 35 original companies were operating, providing
a total of 599 jobs—over 90 percent of the potential
maximum. Moreover, in 1992, businesses that had not
been in operation or were missed in 1991 generated 134
additional jobs for Philadelphia-area residents. AH together,
the city found that 733 jobs had been created in
Philadelphia's recycling industry since 1986.
Number of Recycling Jobs in the Northeast, by State
40,893
40,000
30,000
20.000
10.000
0
Total number of recycling ji bs
in the region: 103,413
21,792
12,549
9,824
8,112
4,261
1,282
2,583
378
1,739
CT DE ME MA NH NJ NY PA Rl VT
Source. Roy F. Westoi, 1994, for the Northeast Recycling Council
The North Carolina Office of Waste Reduction also found
that recycling is a major source of employment, according
to its report The Impact of Recycling on Jobs in North
Carolina. Recycling industries have created over 8,700 jobs
in North Carolina. And the study offers more important
evidence. Using its Recycling Jobs Model, the report found
that these kinds of job gains can far outnumber those jobs
lost in other industries. For every 100 recycling jobs
created, according to the report, just 10 jobs were lost in
the solid waste industry, and three jobs were lost in the
timber harvesting industry.
-------
Value Mded by Recycling in Massachusetts*
Value Added
by Processors
Value Added
by Manufacturers
Material
Paper
Plastic
Glass
Metals
Compost
Subtotal
(in dollars)
42,909,000
2,891,000
2,429,000
44,022,000
0
92,251,000
(in dollars)
475,307,000
58,000
20,010,000
3,000
400,000
495,778,000
TOTAL VALUE ADDED
BY MANUFACTURING SECTORS:
$588,029,000
'•Estimates do not include semiprecious or precious metals, auto scrap, mill
scrap portion of tonnage from nonrecycled materials, or value added after
manufacture (e.g., intellectual property, paperboard made into games, etc.).
No avoided disposal costs have been figured into this analysis.
-------
EPA Resource Centers
The following clearinghouses, dockets,
and hotlines stock up-to-date recycling
information.
Public Information Center (PIC)
U.S. Environmental Protection Agency
Public Information Center (3404)
401 M Street, SW.
Washington, DC 20460
phone: 202 260-7751
fax: 202 260-6257
Serves as the primary point of contact between
EPA and the public. Refers calls and letters to
the appropriate sources for technical information,
and distributes a variety of general-interest items.
RCRA Information Center (RIC)
RCRA Information Center (RIC)
U.S. Environmental Protection Agency
Office of Solid Waste (5305W)
401 M Street, SW.
Washington, DC 20460
phone: 202 260-9327
fax: 202 260-4937
Holds and provides public access to all
regulatory materials on solid waste and
distributes technical and nontechnical
information on solid waste.
RCRA/Superfund/OUST Hotline
RCRA/SF/OUST Hotline
1725 Jefferson Davis Highway
Arlington, VA 22202
phone: 800 424-9346 (outside
Washington, DC metropolitan area)
within Washington, DC: 703 412-9810
fax: 703 486-3333
Answers questions on matters related to solid
waste, hazardous waste, or underground
storage tanks. Also can be used to find and
order EPA publications.
Pollution Prevention Information
Clearinghouse (PPIC)
PPIC (3404)
401 M Street, SW.
Washington, DC 20460
phone: 202 260-1023
fax: 202 260-0178
Provides a library and an electronic bulletin
board (accessible by any PC equipped with a
modem) dedicated to information on pollution
prevention.
Environmental Financing
Information Network (EFIN)
U.S. Environmental Protection Agency
EFIN (3304)
401 M Street, SW.
Washington, DC 20460
phone: 202 260-0420
fax: 202 260-0710
Provides an on-line computer database
containing abstracts of publications and a
network of public financing and environmental
program experts. Help using the database is
available.
Small Business Ombudsman
Clearinghouse/Hotline
U.S. Environmental Protection Agency
Small Business Ombudsman (1230C)
401 M Street, SW.
Washington, DC 20460
phone: 800 368-5888
fax: 703 305-6462
Helps private citizens, small businesses, and
smaller communities with questions on all
program aspects within EPA.
-------
Solid Waste Assistance Program
(SWAP)
SWANA
Solid Waste Assistance Program
Post Office Box 7219
Silver Spring, MD 20907
800 677-9424
Collects and distributes current municipal solid
waste information.
EPA Main Library
U.S. Environmental Protection Agency
Headquarters Library (3404)
401 M Street, SW. Room 2904
Washington, DC 20460
202 260-5921 or 5922
Maintains environmental reference materials for
EPA staff and the general public, including
books, journals, abstracts, newsletters,
newspapers, and audiovisual materials
generated by government agencies and the
private sector. Also provides access to on-line
computer services, bulletin boards, and CD-
ROM systems.
EPA Regional Offices
EPA's ten regional offices can offer
further information on recycling.
Region 1
Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island, Vermont
JFK Building
One Congress Street
Boston, MA 02203
Library: 617 565-3298
Waste Management Division
Mail Code: HAA-CAN2
617 573-5700
Region 2
New Jersey, New York, Puerto Rico,
Virgin islands
Javitz Building
290 Broadway
New York, NY 10007
Library: 212 637-3010
Hazardous Waste and Solid Waste
Programs Branch
Mail Code: 2AWMD
212 637-4100
Region 3
Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia
841 Chestnut Street
Philadelphia, PA 19107
Library: 215 597-6633
Hazardous Waste Management
Division
Mail Code: 3HW53
215 597-8181
Region 4
Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South Carolina,
Tennessee
345 Courtland Street, NE
Atlanta, GA 30365
Library: 404 347-4216
Waste Management Division
Mail Code: 4WD-RCRA
404 347-3454
-------
Region 5
Illinois. Indiana, Michigan, Minnesota, Ohio,
Wisconsin
11 West Jackson Blvd.
Chicago, IL 60604-3507
Library: 312 886-9906
Waste Management Division
Mail Code: HS-6J
312 886-7579
Region 6
Arkansas, Louisiana, New Mexico, Oklahoma,
Texas
First Interstate Bank Tower
1445 Ross Avenue, Suite 1200
Dallas, IX 75202-2733
Library: 214 665-6424
Hazardous Waste Management
Division
Mail Code: 6HHW
214 665-6701
Region 7
Iowa, Kansas, Missouri, Nebraska
726 Minnesota Avenue
Kansas City, KS 66101
Library: 913 551-7358
Waste Management Division
Mail Code: SUPR
913 551-7050
Region 8
Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming
999 18th Street, Suite 500
Denver, CO 80202-2405
Hazardous Waste Management
Division
Mail Code: HWM-HW
303 293-1720
Region 9
Arizona, Caiifornia, Hawaii, Nevada,
American Samoa, Guam
75 Hawthorne Street
San Francisco, CA 94105
Library: 415 744-1510
Hazardous Waste Management
Division
Mail Code: H-1
415 744-1730
Region 10
Alaska, Idaho, Oregon, Washington
1200 Sixth Avenue
Seattle, WA 98101
Library: 206 553-1289
Hazardous Waste Division
Mail Code: HW111
206 553-1296
Accessing This Document on the Internet
This document can be accessed on line
using one of several Internet pathways:
Through the World Wide Web: Access the home page
at http//www.epa.gov. Select EPA Offices and
Regions. Recycling Means Business is under the
Office of Solid Waste directory.
Through Gopher: Access the EPA Public Access
Gopher at gopher.epa.gov. Select EPA Offices and
Regions. Recycling Means Business is under the
Office of Solid Waste directory.
Through FTP: Go to the ftp.epa.gov server. Login as
"anonymous" using your Internet address as the
password. Recycling Means Business is located in
/pub. All OSW files are in directories beginning with
"OSW."
This document is available at these sites as an Adobe
Acrobat file (an electronic version containing both
text and graphics).
-------
United States
Environmental Protection
Solid Waste and EPA530-F-94-001
Emergency Response June 1994
(5305)
v>EPA
Recycling Means Business:
EPA's Market Development Strategy
The three chasing arrows of the recycling logo portray a seemingly simple
system. Materials are collected out of the waste stream for recycling. Next, they are
processed and used to make new products. Finally,, the purchase of recycled products
closes the loop. Recycling, however, is much more complex than the symbol indicates.
At its core, recycling is about shifting to an environmentally-responsible manufacturing
economy that conserves natural resources, energy, and disposal capcity. For this shift
to take place, numerous barriers must be addressed. For example:
»• Recycling businesses often lack ready access to technology, marketing information, and business
development assistance. In addition, recycling businesses are often perceived as risky ventures by
financiers unfamiliar with the recycling industry.
> Many state and lo«al government market development programs need mechanisms to coordinate
their activities, share information, and learn from each other's experiences.
»• Government agencies and private sector entities often lack partnerships that would enable them to
work cooperatively to build markets.
» Manufacturers and distributors of recycled products often find it difficult to gain access to
markets provided by large purchasers such as government agencies and large corporations.
» Recycled products have not achieved widespread public acceptance due to a lack of performance
history and general public awareness.
Market Development, which is defined as the process of strengthening or expanding both
intermediate and end-uses of materials collected for reuse or recycling, can mitigate these barriers
while advancing other national goals of the U.S. Environmental Protection Agency, such as:
Harmonizing environmental protection with economic growth
Preventing pollution and conserving natural resources and energy
Enhancing the capacity of State, Tribal, and local government programs
Promoting public-private partnerships and building government alliances
Fostering technology development and transfer.
In this Strategy, EPA is adopting three equally important Market Development goals that will
guide the Agency's market development activities and leverage other resources outside EPA.
-------
EPA's Market Development Goals
1) SUPPORT AND STRENGTHEN THE LINK BETWEEN INCREASED MARKET CAPACITY AND
SUSTAINABLE ECONOMIC GROWTH.
Objectives: Stimulate interaction and coordination among the economic development,
financial, and recycling communities.
promote the use of recycled feedstock by assisting recycling businesses.
Through leadership and advocacy, EPA can demonstrate that environmental protection and economic
prosperity are complementary pursuits. By implementing this goal, EPA trfW build bridges between the public
and private sectors, create and expand networks to provide processors and manufacturers with needed
assistance, and encourage them to use recycled feedstock.
2) LEVERAGE FEDERAL RESOURCES AND BUILD FEDERAL PARTNERSHIPS FOR MARKET
DEVELOPMENT.
Objectives: Maximize Federal purchases of recycled products.
Facilitate access to Federal information, research, and programs.
Mobilize Federal participation in market development.
Acting as a catalyst, EPA can demonstrate haw Federal agencies can further their primary missions while
Incorporating environmental protection goals. Achieving this goal will demonstrate how Federal agencies can
not only procure recycled products, but also participate in the strengthening of recycling infrastructure by
promoting resource efficient approaches and partnerships.
3) DEVELOP INFRASTRUCTURES THAT SUPPORT MARKETS TOR RECYCLABLES AND
RECYCLED PRODUCTS.
Objectives: Strengthen State, Tribal, and local government capabilities.
faster the establishment and exchange of market development information.
Maximize public and private sector purchases of recycled products.
By helping to create, expand, and disseminate information about existing organizational infrastructures, EPA
can establish foundations for the activities of other groups. Through this goal, EPA will help improve
existing market development programs, provide opportunities Jar the exchange of information and lessons
learned, and promote Increased procurement of recycled products by the public and private sectors.
These goals are the basis for EPA's internal market development Strategy which will direct EPA
activities in fiscal years 1995-1996 and beyond. I look forward to working'with the public and private
sectors to implement this Strategy which will promote the development of mature recycling markets to
permanently "close the recycling loop.*
Carol M. Browner
EPA Administrator
-------
vvEPA
United States
Environmental Protection Agency
(5305W)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
-------
Just keep examining every low
bid quoted for zinc etchings.
-------
Blinds & Shutters
Section 1200
1200-S-3 Machining and Joinery
In the absence of specifications, the following standards will apply. Where more than one method or material is listed for a Grade,
woodworkers will supply their choice from the alternatives.
Machining
Premium
Custom
Economy
Plant Machining Considerations
Shutter and Blind Sizing
Unless otherwise specified, units will be shipped full-width and full-height for field fitting.
Prefitting and premachining available from most AWI manufacturers.
Panel Retention Note: Regardless of method of retention, panels must have freedom and room to expand and contract in
reaction to ambient humidity changes.
Joinery and Assembly Considerations
Stiles, rails, & mullions
Solid lumber panels
Raised panel rims
Panel product centers
Applied mouldings
Joined with mortise and tenon, dowel or spline joinery, glued under pressure.
Moulded profiles (sticking) shall be at the option of the woodworker, unless full size details
are shown in bid documents. Involve your AWI woodworking professional in the design.
Not permitted
Mitered; splined or doweled
to panel body and glued under
pressure
Panel edge must be covered
by veneer or concealed by
moulding
Plant fastened; spot glued,
fine finish nailed, set, filled,
and sanded
Edge glued and planed/sanded
to thickness (up to 14")
Mitered; and glued to panel
body under pressure
Panel edge must be covered
by veneer or concealed by
moulding
Plant fastened; spot glued,
fine finish nailed
Edge glued and planed/sanded
to thickness (up to 28")
Mitered; and glued to panel
body under pressure
No edge treatment required
Plant fastened; spot glued,
fine finish nailed
Fixed Slat Detail Considerations
Rounded edge slats
Flat edge slats
Set in routed slot
Set in through dado slot,
moulding applied to rail faces
to cover dado
Set in routed slot
Set in through dado slot,
moulding applied to rail faces
to cover dado
Set in through dado slot
Set in through dado slot
Movable Slat Considerations (interior only)
Round or Flat edge slats
Pivot pins either metal or
wood dowels*. Vertical
control bar for interior slat
blinds connected to slats with
curved staples to allow
movement.
Pivot pins either metal or
wood dowels*. Vertical
control bar for interior slat
blinds connected to slats with
curved staples to allow
movement.
Pivot pins either metal or
wood dowels.* Vertical
control bar for interior slat
blinds connected to slats with
curved staples to allow
movement.
Edge Treatments of Stiles and Rails
Outside Square Edge:
solid lumber (top and
bottom not considered
exposed edges)
Inside Moulded Edge
All exposed
edges same
Mill option
species as
face
All exposed
edges same A ,.„
5 . Mill option
species as
face
Mill option Mill option
Permitted only in solid lumber. Profile must be capable of being coped without a feather edge.
NOTE: Site-applied mouldings are governed by Section 300 and Section 1700. The following applies to mouldings
contained wholly within an individual panel or used as rim or panel retention members.
Integral Applied Moulding: Acceptable with solid or veneered stiles and rails. Mouldings must be mitered. Mouldings must
be fastened to stile or rail (not to panel to permit movement), utilizing not more than two positioning nails.
Hardware Considerations
* Pivot pins for use in damp coastal areas shall be nylon, stainless steel or brass.
Operating hardware must be specified, as it dictates the details of the construction.
Unless specified, woodworking professional does not supply, machine for, or install operating hardware.
© 1999 Architectural Woodwork Institute - 7th Edition Quality Standards
------- |