pollution prevention: establishing & implementing a...

TABLE OF CONTENTS

Foreword

Section I Background

Section I1 Establishing a Pollution Prevention

Section I11 Implementation

Section N Tracking and Measuring Progress-

Section V Where to Find Help

Section VI Information & Guidebooks

Program

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OREWORD -*..- Just as the

decade of the

period of internal business restruc- turing for C X , the 1990s will be character- iLed as one of internal cultural change as thc

1980s Was a

Company mows foiward wit.h Speed, Simplicity and Self-Confidence. Sirni- larly, as Work-Out represents a management vision for the businesses, the POWER (POlliition, Waste, and Ernis- sions Reduction) Program sets a vision for environniental leadership. This Best Practices document introduces you to (;E’s POWER Program and provides the i I I fo rm a t i o n necessary fo r yo 11 r 1) us i n e ss or plant to establish its own pollution preventioii program.

POWER, like Work-out, is a process to identify arid eliminate waste, though in a soniewhdt more literal context. The objective of the POWER Program is for each of us to think in terms of pollution prevention rather than pollution control, and actively integrate this concept into product design, production, and packaging. As we continue to eliminate the generation of wastes and reduce potentially toxic releases to the environment, we will reap enormous benefits, not oiily in terms of our public image, h i t also economically, by eliminating the polential long-term liability associated with waste generation.

Today we are witnessing what could he ~crmed an Environmental Revolu- tioii As the global community becomes increasingly concerned about the capacity of the environment to assimilate the pollutants and wastes which are gen- vi-atcd, a growiiig number of progressive <orripatlie\ are seiiing the opportunity

by installing competitive, pollution-free processes and marketing “green” products. While there is much that remains to be done, GE can be extremely proud of its recent accomplishments in pro- tecting the environment. For example, aggressive pollution prevention programs have already resulted in: 0

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A ’74% reduction in the generation of hazardous waste at GE Medical Systems’ E. Dale Trout Plant.

A 95% reduction in the production of hazardous wastewater treatment sludge at GE Xppliaiices’ Louisville Plant. A reduction in butadiene emissions at GE Plastics’ Ottawa Plant of mort‘ than 90%. Business-wide, a 72% reduction in CFC usage for all of GE Power Deliv- ery since 1986. Company-wide, an 1 1 “/c reduction in SARA 313 reported releases froni 1987 to 1988.

Though this document referenccs U.S. regulatory requirements, the best practices described should not be restricted to our domestic operations. Pollution is a global issue; therefore, pollution prevention must be an important component of GE’s global business strategy.

Now it is time to go fonvard and, in a systematic manner, evaluate additiotial opportunities to eliminate the generation of waste across the Company. Ulti- mately, the success of the POWER Program depends o n your leadership and individual efforts. Pollution prevcn- tion is a dynamic process that is integral I O all stages of‘ the manufacturing process. As a result, no oric is better prepared to identify opportunities for preventing pollulion than the employees actually involved in lhe design, opcra- tion and maintenance of the plant. Your active participation will make a differcncc.

ACKGROUND Historically, industry responded to

the regulations of the U.S. Environ- mental Protection Agency (EPA) by emphasizing treatment of waste streams just prior to their release to the environment. This “end-of-pipe” approach often succeeded only in transferring pollutants from one medium (i.e., air, water, or land) to another; e.g., pollutants removed from air emissions or wastewater discharges often w.ere concentrated in sludges which were then disposed of on the land.

ing and evolving public attitudes about the environment have resulted in a fundamental shift in focus from the external “envelope” around a manufacturing site to the core of the process itself. In fact, the entire “life cycle” of a product, from the design and manufacturing stage to its ultimate fate as a waste, is now very much an issue of concern. Key to this whole shift in focus is making pollution prevention an integral part of manufacturing operations.

Since the mid-l980s, however, chang-

GE’s POWER Program To emphasize the importance of pol-

lution prevention activities within GE, in 1989 the Company formalized and expanded its long-standing efforts to minimize waste generation and other releases to the environnicnt with the development of the POWER (an acro- nym for POllution, Waste arid Emissions

Reduction) Program. Indeed, this preventive program must be an important element of each business’ comprehensive environmental, health and safety strategy for the 1990s.

The POWER Program is really an umbrella for the pollution prevention efforts of all of the businesses over the coming years. It provides a name and focal point for communication purposes, and a sense of continuity across the Company.

This Best Practices document serves several fiinctions, including: 1. To introduce the POWER Program

and the benefits of developing and implementing a business and plant- specific program;

2. To establish a common understand- ing of the wastes and releases which should be reduced;

elements of a plant-level POWER Program; and

4. To identify resources, both internal and external to GE, that are available to assist.

3. To summarize the important

Program Benefits There are a number of reasons why

pollution prevention is good business. Among these is GE’s corporate responsibility to minimize the impact of its operations on the physical environment, and to provide a clean, healthy

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and safe working environment for its employees. There are other factors, which, though probably less obvious, are equally as compelling, and which affirm the importance of pollution prevention as an integral aspect of business operations. These factors are discussed below.

Economics: One of the most compelling reasons for embracing pollution prevention is economics, not only for the savings which are realized within the short-term (e.g., savings in production and disposal costs), but probably more importantly, for the avoided long- term liability costs resulting from off site management of the wastes.

Pioneering companies like 3 M have demonstrated that pollution prevention can improve a company’s bottom line. Over the first 12 years of 3M’s Pollution Prevention Pays (3P) Program, 3 M has reportedly prei.ented or reduced pollutant generation to all media by 450,000 tons, representing a calculated savings (production costs including operations and maintenance, feedstock and raw material, and equipment) of $420 million, $350 million of which was in the U S . (ReJ 1, pcige21).

GE, too, has achieved substantial economic savings through pollution prevention initiati\res at a number of plants. These savings have been ach ieved th ro I ig h :

Reduced waste management costs

.,- Reduced production costs associated

(e.g., avoided disposal costs) ;

with the elimiiiation or reduced use of raw materials and natural resources;

0 Elimination of the need for expensive pollution control equipment; and Reduced adininistrativc and compliance costs associated with environmental permit requirements.

The most compelling economic reason for implementing an aggressive pollution prevention program, however, is to avoid the potential long-term liabilities resulting from waste disposal. According to federal law, GE, as a generator, could be held solely responsible for remediation costs for any disposal facility that GE utilized, even though GE may have only been a partial contributor to wastes at that site. As reported in the 1989 Annual Report, ‘-

GE spent approximately $75 million on remedial cleanups and related studies in 1989. This represents an increase of over an order of magnitude from the 1985 expenditure of about $6 million. These costs are expected to escalate over the coming years as more of the projects for which GE is wholly or partially responsible for cleanup, proceed through the remediation process. To the extent that GE can prevent the generation of wastes, likewise, the potential liability associated with the management of those wastes is eliminated.

Taken collectively, all of these economic factors should bc considered when evaluating the economic viability of a pollution prevention project. Often referred to as “full cost accounting,” a carefully executed analysis will often justify projects that were previously thought to be financially unattractive ( w u .%&on 3).

Safety and Health: AS the use of toxic materials for manufacturing and ancil- lary operations is reduced, the safety of the workplace and surrounding community are likewise improved. Siich toxic use reduction initiatives will become increasingly important as individual states legislate more stringent worker and community right-to-know require men ts.

One of the most compelling reasons for embracing pollution prevention is economics.

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The bottom line is that GE’s investment in pollution prevention now will pay off later.

Environmental Compliance : The following national waste reduction policy was incorporated within the Resource Consewation and Recovery Act, as amended by the U.S. Congress in November 1984:

“The Congress hereby declares it to be the national pol iq of the United States that, wheneuer feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is never- theless generated should be treated, stored or. disposed of so as to minimize the present and future threat to human health and the environment. ”

As will be discussed in more detail below, this policy has led EPA to develop a hierarchical strategy for the management of hazardous wastes, emphasizing source reduction and discouraging disposal and off site treatment. To encourage waste minimization activities, the EPA requires all generators of hazardous waste to certify on their waste manifests that the facility generating the waste has developed a program to reduce the volume or toxicity of waste generated. In June 1989, EPA issued non-binding guidance on what such a waste minimization program should include. This Best Practices document is in conformance with EPA’s guidance (ReJ 2, page 21).

Community Right-to-Know: The Super- fund Amendments and Reauthorization Act (SARA), Title 111, Section 313, requires U.S. industry to annually report the total volume of some 300 toxic chemicals which are released to air, water and land. It is important to note that, even if‘ your facility was not subject to reporting requirements for 1987 or 1988, this may change in the future as additional chemicals are listed and as reporting thresholds decrease. Public pressure on industry to reduce releases to the environment has increased substantially since these reporting requirements began.

Public Relations: There is an adage that says, “If you have a story to tell, tell it!” Remember, pollution prevention is good news. GE has some glowing examples of this “good news,” so we should start to take some well-deserved credit for these achievements. Over the last few years, several GE businesses (e.g., Motors, Medical Systems, Plastics and Nuclear) have been the recipient of state governor’s awards, for outstanding pollution prevention achievements and have, as a result, been recognized by their peers and the public.

Now the challenge is yours. In order to preserve public trust and foster good community relations, it is vital that GE proactively seek opportunities to share good news about pollution prevention achievements with its employees, cus- tomers, and the people in the commu- nities in which wework. Your efforts to prevent pollution Tn new and innovative ways will help foster that trust.

Competitive Advantage: Though not quite as obvious a benefit as the others already described, the potential for realizing a competitive advantage as a result of a pollution prevention initia- tive does exist. The global focus on “green” products is making both the public and industry aware of the potential benefits of manufacturing products which minimize potential adverse impacts on the environment over the entire life cycle of that product. Let’s broaden our thinking and start to ask ourselves the right questions - what can we gain by changing our process, product or its packaging?

In 1986, California voters adopted Proposition 65, an extremely stringent toxics control and consumer product labeling law. GE Plastics recognized that its polycarbonate water bottle business could evaporate overnight because the plastics used to mold the bottles con- tained traces of methylene chloride, a suspected carcinogen regulated under

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the new law. GE Plastics responded with process changes and reformulations that eliminated the targeted chemical, and, as a result, not only maintained the product line but captured the market in California.

Marketing: The environmcrital con- science OS the consumer is becoming increasingly important in purchasing decisions. The disposability of the product and its packaging, and its potential recyclability have become factors that could aid or potentially im- pede the success of a product in the marketplace. Consumer action groups both in the US. and abroad are draw- ing attention to these issues through campaigns, awards and product labeling programs.

In October 1989, the Washington Citizens Sor Recycling, a non-profit organization based in Seattle, Washing- ton, issued its first “Packaging Awards and Booby Prizes from an Environ- mental Point of View.” Praising the packaging and its ease of recyclability, the group selected the GE light bulb for its “ S o Ordinary You May Have Misscd Its Minimal Elegance” Award.

vehicle to convey information about products and influence purchase decisions, both by the manufacturer

Labels are also becoming a common

Figure I . Canada’s EcoLogo

(e.g., “no cholesterol” labels) and regulatory and consumer groups. For example, both West Germany and Canada have established environmental product labeling programs to assist consumers with identifying environmentally preferable products. Products which satisfy the established government requirements are issued a special logo which can be placed on these “green” products for marketing purposes. The EcoLogo for Canada’s Environmental Choice Program is shown on Figure 1 . Several organizations, including the EPA, are already developing product labeling programs for the U.S.

prevention a winning proposition for GE and its employees. Aggressively pur- suing a pollution prevention program can allow us to reduce costs, increase our productivity, reduce our risk of long-term liability, potcntially capture increased market share, and niaximi/e profitability in the long run. The bottom line is that GE’s investment in pollution prevention now will pay off later.

These benefits make pollution

Program Definitions There is no statutory definition of‘

“pollution prevention”; as a result, the scope of activities encompassed by the term varies by the group or organization using the term. To some, “pollution prevention” is synonymous with solid or hazardous waste minimization, whereas others have more broadly defined it to include releases to the air arid water as well.

Program, GE is defining “pollution prevention” as follows:

Pollution preuention means preventing or minimizing the generation or release of wastes and pollutants, to the extent technically and economically feasible, throughout the l i f . cycle of the product, including its des@, production, packaging and ultimate fate in the environment.

For purposes of the POWER

Environmental product labeling programs assist consumers with identifying environmentally preferable products.

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. . .it is usually cheaper and environmentally preferable to avoid the generation of a potential waste than to have to treat it once it has been generated.

There are two important elements to GE’s definition - the scope of pollutants covered, and the methodology which can be used to achieve the reductions.

Scope. It is intended that GE’s pollution prevention program encompass all waste streams - solid, liquid and gaseous. Therefore, business and plant- specific POWER Programs should include projects which will minimize:

Generation of hazardous wastes, as defined by RCRA or state law; Toxic releases, as defined by SARA, Title 111, or more stringent state law; The use of toxic chemicals for process operations; Generation of industrial non-hazardous wastes; and Geiieration of other solid waste, such as paper, cardboard, and packing materials. To address product life cycle issues

(i.e., the disposition of the product at the end of its operational life; and the disposition of materials used in the packaging of finished goods), your POWER Program should also evaluate projects which will minimize:

The use of toxic or non-recyclable materials in the packaging and production of finished goods, to the extent that these materials could ad- versely impact the environment upon disposal of the finished product or packaging material.

Methodology. As mentioned previously, EPA developed a waste management hierarchy which places primary emphasis on source reduction and recycling as preferred methods for managing wastes, with waste treatment and disposal at the bottom of the hierarchy. A graphical representation of this hierarchy is shown on Figure 2.

Source reduction refers to any practice that reduces, or eliminates the generation of a waste, or the toxicity of the waste at the source, usually within a process. In simplistic terms, source reduction is waste avoidance. Source reduction can be achieved through: Procedural changes, such as

Good operating practices - Material handling and storage

improve men ts - Scheduling improvements - Inventory control - Spill and leak prevention - Preventive maintenance Waste stream segregation Training and awareness

Process modifications Operational adjustments Equipment modifications Automation improvements Water and energy conservation

Technology modifications, such as

Raw material substitutions Product alterations/reformulations

Recycling is any process that uses or reuses potential emissions or waste as an effective substitute for a commercial product, or as an ingredient or feedstock in an industrial process. The term “recycling” is a catchall term that em- braces use, reuse, recovery and reclama- tion. Examples would include the recovery of potential organic vapors for burning or the removal of contaminants from a waste to allow it to be used; e.g., solvent distillation unit.

It is preferable to recycle wastes on site if economically feasible, in order to avoid the potential liability associated with the transportation and off site management of the waste prior to its recycling. Nonetheless, off site recycling is an acceptable means of achieving pollution prevention goals under the POWER Program.

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Waste Management Hierarchy

High Source Reduction

Recycling

Waste Separation 8c Concentration

Pollution Prevention

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Energy/Material Recovery t 4 I Waste Incineration/Treatment I

Pollution 'I Ultimate Disposal Control

low

Relative Environmental

Desirability

Figure 2. U. S. €PA Waste Management Hierarchy

Pollution control: Since it will riot always be possible to completely prevent the generation of a waste or completely recycle a waste stream, GE considers treatment to be an important component of its comprehensive environmental protection strategy. Treatment, however, should be considered the last, and least preferable alternative for reducing the volume or toxicity of a waste, and should only be considered after all source reduction and recycling options have been exhausted. As a practical matter, i t is usually cheaper and environmentally preferable to /LlJOid

the generation of a potential waste than

to have to treat it once it has been gcn- erated. POWEK Program reduction goals can be credited for additional on site treatment technologies that reduce the volume or toxicity of a waste that cannot otherwise be feasibly eliminated or recycled. Off site treatment cannot, however, be counted. Additional information on goals and tracking and measuring progress can be found in Section I1 & IV.

STABLISHING A POLLUTION PREVENTION PROGRAM

Commitment and Support: The Cornerstone of Success

A successful pollution prevention program requires the commitment and support of management and employee alike. At the corporate level, in mid- 1989 the Corporate Executive Council challenged each business to build on its long-standing waste minimization efforts and formally develop a business- wide pollution prevention program. Since that time the importance of preventive programs, such as the POWER Program, has been repeatedly reinforced by the company's General Counsel as well as its Chief Executive Officer in communications with Com- pany officers.

For a successful program at the plant level, this commitment must manifest itself in a very real manner - a commitment to provide the necessary resources (human as well as financial) to get the job accomplished, and a commitment to continually support the Program over time. Just like the physics formula which states that

Power = Wo'rk /Time !ikewise, the success of the POWER Program is also dependent on the amount of work devoted to the effort over an extended period of time.

As each business goes forward with the development of its own POWER Program, it may bc helpful to review the individuals and groups whose support nnd assistance will be instrumental.

Business level Pollution prevention programs

typically focus on the elimination of existing waste streams, and the avoidance of waste streams associated with a new process operation. The businesses can support these initiatives by requir- ing the plants to develop their individual reduction plans, measuring their progress toward achieving agreed upon reduction goals, and providing incen- tives to sustain employee involvement.

Equally as important though, there are potential competitive opportunities in the environmental area which should be explored at the business level. For example, individuals from the business, R&D, marketing, sourcing, customer service and community relations depart- ments can often contribute ideas for enhancing product design, production, packaging and marketing, from an environmental perspective, by providing input on product life cycle issues including:

Consumer attitudes; Real or perceived environmental issues associated with the use and/or disposal of the product, as well as the chemicals used in product manufacturing; The recyclability of the product or product components; Regulatory bans or restrictions effect- ing chemicals used in manufacturing;

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The energy consumption or generation characteristics of the product relative to that of competitors, and

strategies of competitors The challenge at the business level

The advertising and marketing

then, is not only to ensure that the plants are aggressively reducing and avoiding waste generation, but also to proactively design, manufacture and market products which minimize the impact of the product on the environment over its entire life cycle.

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Plant level The Plant Manager has the most

important role since he not only has the responsibility for establishing the plant-level Program, including the development of reduction goals, but, ultimately, has the responsibility for achieving the goals as well. The perceived importance of the Program in the plant, and ultimately the degree of reductions achieved, depend heavily o n the vision aiid leadership provided by the Plant Manager. To assist in getting a Program initiated, or to keep the momentum of an existing program going, the Plant Manager should:

Advocate the benefits of minimizing waste generation and reducing emissions by formally initiating the development of a plant-level POWER Program; Establish a plant-wide POWER Task Force (described more fully below) and assign a key individual to head that task force; and Establish some form of ongoing plant- level communication or awards program to obtain a broad-based level of interest aiid participation in the Program, and sustain its momentum.

Plant POWER Task Force Organization and Responsibility

The broad scope of a pollution prevention program makes teamwork essential to success. One person simply cannot do it alone. Team members should represent the key manufacturing and support areas. Persons involved do not need an environmental back-

usually beneficial to have a diversity of backgrounds represented. Task Force Teamwork

ground to participate; in fact, it is

members could include, for insvdnce, process (design and operations) engi-

- is essential to success.

neers, environmental engineers, operations and maintenance personnel, and marketing and purchasing personnel. Though the size of the plant Task Force is not important, for ease of scheduling meetings and reaching consensus, the size should probably be limited to a core group of about 4 6 individuals. Specialists can be brought in or con- sulted with as necessary.

- The person selected as Task Force

leader must be given the authority LO

carry out the designated responsibili- ties. Since this individual will be the prime motivator for siiccess of the Program, the leader should communicate effectively, work well with people, be technically proficient, and be a real supporter of pollution prevention. Finally, the leader must be a good manager, capable of motivating others. Due to the multi-disciplinary nature of the program, the Task Force leader does not have to be an environmental professional.

With changing regulatory priorities, technology improvernen~s, arid raw material developments, the priorities of the Program and potential reductions that can be achieved will likely change over the coming years. Therefbrc it should be recognifed that the job of' 1hc POWER Task Forcc will not concludc with achievement o f its first established reduction goals.

Goals The first task the Task Force should

undertake is the establishment (or re- evaluation) of plant-level reduction goals. The development of goals should be coordinated with the business EHS Manager who can inform you of any business-specific goals or objectives

that can be implemented over a relatively short time period and yield significant reductions. This type of project, often referred to as “low hanging fruit,” can be pursued while the longer-term, more resource intensive projects are being evaluated. Examples of these lower cost projects are listed on Table 1.

which may need to be considered. This bottom-up approach to the development of reduction goals (that is, the development of goals at the plant and/ or business level rather than at the corporate level) is being used by GE not only to account for the diversity of its

Finally, goals should be realistic, yet challenging, and established relative to a “base year,” that will provide a bench- mark against which progress will be measured. 1n.recognition that many individual plants and businesses have already achieved significant reductions

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operations, but also to encourage “ownership” of the goals that are developed. Goals are important to: 0 Facilitate tracking and reporting; 0 Establish a target against which

0 Demonstrate commitment and results For 31:3 chemicals the year could be 1987, which was the first year that reporting of such releases to the environment was required.

0 For RCRA hazardous wastes the base year could be 1985, the first full calendar year after the enactment of the 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA which established waste reduction as a n at io 11 a1 pol icy. As an example, GE Plnstics recently

allriounced its goal to l e d ~ c e toxic air emissions by 75% within the 1988-1993 time frame. Other companies have gone public with similar

over the last several years, and because it would not be appropriate to pena1ir.e these plants for their achievements, GE is not establishing a common base year across the Company. Rather, establishment of a base year will be up to the individual businesses, though the following suggestions are offered: progress can be measured;

to management, employees and the local community; and

motivate employees and maintain their interest. Since GE’s ultirnate goal is to elimi-

0 Provide the target necessary to

nate wastes and releases to the maxi- mum extent feasible, the plant goals should reflect a strong commitmenl toward aggressive reductions.

Plant-level goals should be established in consistent quantifiable terms (i.e., percentages, pounds, etc.) and include a time frame for implementation. To provide consistency across the company, each plant should establish objectives. both short-term and long-term reduction goals as follows: 0 Short-term goal achievabl

by 1/1/93. 0 Long-term goal ac hiev-

able by 1 / 1 /98. There are a number of

relatively low cost pollu- tioil prevention projects

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TABLE 1 Examples of relatively low cost pollution prevention projects

Training and Preventive Maintenance Opportunities 1. Increase awareness among plant employees that

“pollution prevention” is an important issue. A heightened awareness is a vital prerequisite to changing old waste generating practices.

2. Improve housekeeping practices, as well as operator and maintenance personnel training. Such actions often translate into reduced waste production, fewer leaks and therefore reduced fugitive emissions from equipment, and improved performance in waste and emission generating systems (e.g., incinerators, stacks, wastewater treatment systems). Such efforts can often improve product quality as well as reduce costs.

3. Segregate waste streams - that is, do not mix a relatively low volume hazardous waste stream with a non-hazardous waste stream, in order to avoid managing the larger combined waste stream as hazardous.

4. Minimize the inventory of raw materials (chemicals) that is kept on site in order to rnitiimiLe the disposal of old or out-of-specification materials, as well as the potential for damages resulting from leaks or spills from the inventoried materials.

5. When large volumes of raw materials are required, try to order in large containers that are returnable to the product supplier, in order to minimiLe the generation of empty drums.

D eg re as i n g/C lea n i ng Ope rat ion 0 p po rtunit ies 6. Evaluate opportunities to switch from a solvent-

based cleaning/degreasing system to either a steam cleaning or alkaline-based system in order to reduce hazardous waste generation, eliminate toxic air emissions, and reduce system exposure to the chemicals.

7. Evaluate the use of water-based lubricants so that a non-solvent based cleaning system can be employed.

8. Where solvent-based degreasing systerns cannot be eliminated:

Install an in-house solvcnt recyclitig s)’stcni t o reclaim solvents for subsequcnt reuse, iti id t o reduce hazardous wastc gene rat iot 1.

Replace a toxic degreasing solvent (e.g., methylene chloride) with a less toxic material (e.g., Stoddard solvent).

Change the degreasing system from a spray system to vapor degreasing with controls for reducing solvent emissions.

Evaluate the feasibility of upgrading an old degreasing system with a new automatic system which should significantly decrease solvent usage.

Install programmed hoists in the degreasing operation in order to eliminate solvent dragout and thus minimize emissions of volatile organic compounds (VOCs).

Pa inti n g/Str i p p i n g 0 p po rtu n i t i es 9. Change from methylene chloride paint stripping

10. Convert where possible to the use of water-based

to abrasive blasting.

or powder-based paints to reduce VOC emissions.

Machining 11. Switch to the use ofwater soluble oil for machin-

ing needs, which in turn allows the use o f an aqueous-based cleaner rather than a solvent degreasing system.

12. Where petroleuni-based o i l is necessaty, use, a s feasible, one that does not leave a residue which would require degreasing.

13. Install a hydraulic and/or niachinc o i l purifica- tion system, perhaps coinl)ining irnproved filtra- tion and clarification capabili tics with incrcxsed maintenance on these systems. ‘I’his wou ld allow the reuse of these oils for various machining purposes.

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MPLEMENTATION Once the plant POWER Task Force

has been orgar:ized and reduction goals have been established, program implementation can begin. The implementation activities described in this section are based largely on guidance materials and publications written by EPA as well as a number of experts in the field of waste minimization. Though the steps may seem laborious, they are tried and true. Reference sources for additional information on the material below can be found in Section VI.

Performing the Opportunity Assessment

The Opportunity Assessment, or waste audit as it is also often called, is an essential first step in implementing a pollution prevention program. Though the steps below focus 011 the reduction of existing waste streams, with modifica- tion, the process can and should be used to evaluate options for reducing toxic substances used in products 01

packaging that will remain a concern upon their disposal. Likewise, similarly modified-analyses can also be per- formed during the process design stage. The objectives of this assessment are to systematically identify wastes that can be reduced and evaluate the technical and economic viability of decreasing their volume or toxicity.

The Opportunity Assessment consists of the following steps:

Compiling an inventory of waste

Formulating a range of potential streams and flow or generation rates;

solutions to eliminate their gene ration ; Priorit ihg the projects for implementation; Screening the feasibility of the various akernatives based on economic and technical criteria; and Making recommendations to management.

Compiling an Inventory The Opportunity Assessment begins

by determining the sources and characteristics of all plant waste streams and releases, and how they are managed on or off site. Resources available to assist with this data gathering effort include: 0 Hafardous waste manifests and

annual waste generator reports; SARA Tide 111, Section 313 Toxic Chemical Release Reports; Permits (e.g., RCRA, NPDES, etc.) and their supporting documentation; Lab reports and characterization data (e.g., waste stream profiles);

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Material Safety Data Sheets; Chemical purchasing records; Process flow diagrams and facility layout; .

Production records; Internal waste tracking reports; Discussions with plant workers involved in waste/release generating activities. In addition, a facility tour can also be

a useful tool to supplement and veri9 information gained from this data gathering effort. In fact, some guidance materials on performing a waste audit suggest that after development of the initial inventory from company record5, an inspection checklist should be prepared for focusing the plant tour to achieve those verification needs.

The completed inventory should trace each waste stream from its source of generation (including information on the chemicals and processes which generate the waste), through its mode of final disposition. A process flow diagram such as that developed by GE Superabrasives in Worthington, Ohio (see Figure 3 ) can provide a convenient format for summarizing individual waste and emission sources, or, the data can be tabularized and computerized.

For mu I at i ng 0 pt i o ns After development of the inventory,

potential options for eliminating or reducing the volume or toxicity of the waste streams should be prepared. The plant POWER Task Force could hold a brainstorming session at which time potential options are tentatively identi- fied. It is not necessary at this stage to consider the technical or economic feasibility of the options in detail. What i s important is to consider the broadest

range of pollution prevention opportunities that could apply such as:

Improved housekeeping; Material substitutions; Process modifications; and Recycling and reuse.

Prioritization Recognizing that due to time, re-

source, and technical considerations, potential pollution prevention projects must be scheduled over a number of years, the next step of Program implementation involves prioritizing the waste streams for further action. A variety of criteria can be used to priori- tiLe the streams, including:

Volume, toxicity, and/or mobility

Regulatory compliance

Off site management costs Potential environmenval liability Safety/health risks Ease of implementation Estimated cost Technical feasibility In its “Manual for Waste MinimiLa-

tion Opportunity Assessments,” (Ref: 3, page 21), EPA outlined a methodolo<gy for prioritking waste minimiLation options called the Weighted Sum Method. Though it is not necessary to use it, some plants may find that this method, or some facsimile thereof, could be helpful in prioritizing pollution prevention projects.

considerations

(e.g., land ban considerations)

The Opportunity Assessment . . . is an essential first step in implementing a pollution prevention program.

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Graphite Ceramic Feedstock Catalyst Metal Parts Boron Nitrate Alkali Metal Salts Sodium Silicate Carbide

Process Chemicals

Acetone Halogenated Solvents Lubricants Hydraulic Oil Maintenance Chemicals

Process Chemicals

Ethylene Glycol Halogenated Solvents Grinder Coolants

Process Chemicals

Bromine HF, HCI, HN03, H2S04 NaOH Ni & Cu Solutions IPA Deionized Water

Off-Spec Materials Spent Halogenated Solvents (H) Spent Flammable Solvents (HI Raw Materials and Tooling

Reactive Metal Salts(H) Waste Ink (Methanol) (H) Ceramic Dust

Saleable Used Hyd. Oil Waste Oily Water Ceramic Dust/Pa rts

Waste Solvents (H) Saleable Ethylene Glycol Waste Coolant Iron Contaminated Product

Classification

Waste Treatment

Waste Graphite Sewer Effluent WWTU Filter Cake S-90 Sulfuric Acid (H) Waste Coating Solution

(H) = Hazardous Waste

Miscellaneous Support Operation Wastes

Spent Lead Acid Batteries Waste or Off Spec Laboratory Chemicals Contaminated Residue

F/gure 3 Environmental Process Flow Diagram GE Superabrasives, Wnrtliingtnn, Ohio

14

Identifying Options Once the waste streams have been

prioritized, options for reducing these streams can be explored in more detail. Emphasis should first be placed on any potential “high priority” stream. It is likely that some waste streams could be minimized or eliminated in one of several ways. To determine which option to pursue, the various options could be screened using various technical and economic criteria.

The technical criteria are used to assess whether a particular option will work in a specific application, given plant-specific or product-specific con- straints. The economic criteria that could be used, and the financial calcula- tions made, are those normally used within GE to justify any investment or expense decision and may vary with the estimated cost of the project. Examples of the technical and economic criteria that could be considered include:

Tech n i c a I Criteria Economic Criteria

Effects on product quality Effects on production Worker health and safety

Space requirements Utility requirements Reliability Commercial availability Permitting requirements

considerations

Capital investment Operating expenses Net present value/Return on

Avoided/reduced costs: * investment

-waste disposal - waste end taxes - long-term liability - permitting/compliance - raw material purchases - production/operations costs

* I n 1987, GE dezjelopd a workbook entitlrd, ‘Financial Analysis of Wnsle Management Altrmalives, ” ruhicli could be usrful in estirntrti,ng the moided costs associated with a pollution prevention project (I?$ 4, page 21).

Recommendations to Management

When a final set of technically and economically achievable pollution prevention options has been developed, recommendations to management on specific projects can be made. These recommendations can be transmitted for approval in whatever format is normally used at the plant, given the

cost of the particular project. The contribution of these projects toward the short-term and long-term reduction goals should be demonstrated and the tola1 cost and potential savings of individual projects should be provided.

15

RACKINGAND MEASURING PROGRESS

Tracking and documenting plant- level pollution prevention activities is important to: 1. Meet current and anticipated

2. Measure progress toward established

3. Facilitate the sharing of information between similar process areas or plants; and

4. Communicate results to management, cmployees, the community and government agencies.

regulatory requirements;

goals;

Regulatory Reporting Requirements

From a regulatory standpoint, there are three main reasons why the Program efforts and achievements should be tracked and recorded:

EPA requires generators to report on the progress of their waste minimi- mtion program in biennial generator reports. EPA can make pollution prevention reporting a condition of a RCRA permil and having a documented program in place can often facilitate obtaining other permits for wastewater discharges and air emissions. SARA Title 111, Section 313 reporting, which currently requests voluntary su I> ni i ss io n of po 11 11 t i0 n prevention in for matioii, may man dare this in for- inatiori in the future.

It is also important to track and measure progress in order to be prepared to meet a variety of proposed federal and state pollution prevention initiatives that are likely to be promulgated.

Measuring Progress Another important reason to track

program results is to measure progress toward established business and/or plant-level goals. This important information should be regdarly shared with plant management and employees, and is a useful too1 in maintaining Program momentum. This data will also be necessary to respond to the questions on pollution prevention that will be incorporated into the PULSE audits as a component of 20.3 compliance reviews.

Sharing Information Between Plants/Operations

Plants which utiliLe similar processes or operations can share valuable information on pollution prevention suc- cesses and failures, including information on the avoided or actual costs. associated with implementation. This information can be shared both within the business (e.g., if it involves manufacturing processes) or across the Company (e.g., if it involves more commonly used processes such as parts degreasing).

16

Communications Communications, both internal and

external to GE, is an important and necessary component of the POWER program. Feedback with plant employees, showing ongoing progress toward established goals, is vitally important to maintain Program momentum. Like- wise, management needs information not only on how work is progressing, but also on the costs and savings involved. External communications are becoming increasingly important as well. With community right-to-know issues becoming an increasingly important aspect of plant public relations, the tracking of pollution prevention achievements is very important.

Data Tracking There are a number of factors that

will dictate the method used to track Program results, such as facility type, complexity, size, internal resources (such as personnel and computer systems), and the kind of goals established.

There are generally two approaches to tracking data - on an absolute basis, or a normalized basis. Tracking data on an absolute basis is usually the easiest approach, however, it can also be misleading; e.g., gross increases or de- creases in waste generation are recorded without qualifying the data with factors, such as production level, that might help explain the result. The reporting of toxic chemical releases to the EPA under SARA 313 is required on an absolute basis.

On the other hand, it is sometimes advantageous (especially for communication purposes) to also track data on a normalized basis. For example, it is expected that as production levels increase or decrease, the volume of

waste generated will likewise fluctuate. Therefore, in order to calculate the “true” reduction achieved as the result of a waste reduction project, the data could be “normalized” (i.e., a ratio of waste generated to production rate) against a theoretical base year production level. This concept of normalization, however, can be a frustrating and often difficult one to accomplish if there are a number of products manufactured (and no direct correlation between a specific generated waste and a specific product manufactured), or the product slate changes from year to year. Indeed, some wastes, such as those resulting from remedial activities, cannot be normalized. Potential data normalization options include:

Production levels * Labor man-hours worked

Sales and/or revenues Raw material purchases It is suggested that you find the

option that works best in your plant- specific application. If assistance is needed, contact the business EHS Manager, or call Corporate Environ- mental Programs.

To develop an effective data tracking system, the plant POWER Task Force may find it useful to look at the kinds of related systems that already exist at the plant. For example, if the plant has been subject to S A M reporting for the 1987 or 1988 calendar years, it may already be using, or have established, an effective tracking process. This tracking system could, perhaps, be modified and used to track other waste streams cho- sen for reduction and ultimately to measure progress toward plant reduction goals.

17

HERE TO FIND HELP In implementing your plant’s pollu-

tion prevention program, obstacles will undoubtedly be encountered. The good news is that help is readily available from many sources.

GE Internal Resources There are a number of individuals

and organizations within GE that are available to provide information and assistance on pollution prevention. Among these are the business Environ- mental, Health and Safety (EHS) Man- agers, Corporate Research & Develop- ment, and Corporate Environmental Programs.

The EHS Managers, and especially those members who are participating in GE’s Company-wide Pollution Preven- tion Task Force, are important contacts at the business level. These individuals can either personally assist or provide the name of an individual who can assist with aiding the transfer of pollution prevention “best practices” from one plant to another within the business. Likewise, these individuals can also provide information about any generic business-wide POWER reduction goals that may have been developed. They will likely also be involved, to some extent, in monitoring achievement of the goals which are established at the plant level.

The Corporate Research 81 Develop- ment (CR&D) Center has an exper- ienced staff of highly trained technical experts who are available to assist on pollution prevention issues. Contact should be made through your designated CR8cD business repre- sentative, whose name can probably be provided by either your own business R&D engineer or your EHS manager.

Corporate Environmental Programs (CEP), working with the assistance of the Pollution Prevention Task Force, will be developing programmatic and technology transfer materials for use by the businesses and plants. Furthermore, CEP will continue to work with the Corporate Executive Office to keep management informed of the progress being achieved under the POWER Program. Finally, CEP will provide, on an ongoing basis, materials to keep the Program visible and alive over the coming years. For example, CEP will be publishing a monthly newsletter called “Progress Toward POWER,” which will highlight GE pollution prevention . success stories.

18

State-Level Resources Due to a number of factors, including

enforcement responsibility, public awareness and pressure, and a perceived lack of movement at the federal level, individual states have aggressively begun to take the lead on pollution prevention initiatives. Some states, including California, Georgia, Massachusetts, Minnesota, New York, North Carolina, and Pennsylvania have established waste minimization programs. Many more, including Connecticut, Maryland, Michigan, New Jersey, and Ohio are planning or developing programs. Due to the diversity of the initiatives by the states, it is impossible to summarize each of their programs. It is advisable therefore to monitor program developments within your state and avail your- selves of any pollution prevention assistance programs that may have been developed.

Federal-Level Resources The U.S. Environmental Protection

Agency through its newly established Pollution Prevention Office and the Office of Solid Waste are developing a number of useful guidance documents as well as an informative monthly newsletter called “Pollution Prevention News” (see General Injorwzation, page 20).

Other Resources Information about pollution preven-

tion is also available from a variety of private sector sources, including:

Trade associations (e.g., CMA) Consulting/engineering firms Equipment manufacturers and suppliers Chemical suppliers, both those supplying the more conventional chemicals (e.g., DOW, Ashland, DuPont), and those supplying alternative products, like those listed below:

Functional Quality Products Pittsburgh, PA

Source of natural soh~ent cleanm and deLgwasers

Sunshine Makers, Inc. Sunset Beach, CA 213/592-2844 or 800/228-0709 Source of “SimfAe G e m , ’’ a non-toxic industm’al cleaner and dqq~asm

4 1 2/469-224 1

Companies with similar challenges

Conferences and seminars. H and waste streams

19

NFORMIATTION 8 GUIDEBOOKS

General Information Center for Hazardous Material Research, “Hazardous Waste Minimization Manual for Small Quantity Generators,” Revised Edition, October 1989. Available from CHMR, University of Pitts- burgh Applied Research Center, 320 William Pitt Way, Pittsburgh, PA 15238 4 12/826-5320

Chemical Manufacturers Association, “CMA Waste Minimization Resource Manual,” 1989. AvnilablpJrom CMA, 2501 M Street, Nw, Washington, D. C. 20037

National Association of Manufacturers, ‘Waste Minimization: Manufacturers’ Strategies for Success,” Washington, D.C., 1989. Copies avazlaOle from GI.: CEP, DialCoinm 8 *22 9-30 78

NYSDEC, “New York State Wask Reduc- tion Guidance Manual,” New York State Department of Environmental Conserva- tion, March 1989. Available from NYSDEC, Division of Hazard- oiis . J ’ i i / ) ~ t ~ n ( ~ s J + p lotion, 50 Wocf Roodz L 4 1 / m i ~ , iVm~ Yorlt 12233-7253

C

USEPA, “Pollution Prevention Now,” issued monthly. Pollution Prevention Office, Office of Policy, Planning and Evaluation, USEPA, 401 M Street SW, (PM-219), Washington, D.C. 20460.

USEPA, ‘Waste Minimization Benefits Manual, Phase 1 ,” USEPA, Office of Policy, Planning and Evaluation, December 1988.

USEPA, ‘Waste Minimization Opportunity A5sessment Manual,” EPA/625/7-88/003,July 1988. Iimited copies available from GE CEP, or contact thP National Technical Information SmJicPs (WIX) in Washington, D. C

USEPA, “Waste Minimization,” EPA/ 530-SW-87-026. October 1987.

cI

1

20

l e c h no I o g y Tr a n sf e r : References: NYSDEC, Ibid. Includes information

011 numerous industrial waste minin1ir.a- tion options for electroplating, degreasing and paint stripping operations.

USE PA, “Waste Mini mimtio n i I I

Metal Parts Cleaning,”

AuailicOIR from N 7 X . EPA/530-SbJ-89-049, 1989.

1. Bringer, R.P., “Pollution Prevention Plus,” Pollution Engineering Mag;i- zine, October 1988.

2. Federal Register, Vol. 54, No. 1 1 1 , June 12, 1989, pg. 25056-25057.

3. USEPA, “Manual for Waste Minirni- Lation Opportunity Assessments,” 600/2-88/025, April 1988. Availahlc from NTIS.

4. General Electric Company, “Finan- cial Aiialyses of Waste Management

22

Acknowledgments Special thanks are given to the following

individuals whose participation on GE’s Pollution Prevention Task Force and review of this document proved invaluable:.

David Bradley GE Corporate Research L3 Development

Jack Campbell GE Capital Corljorat ion

Tom Corneil GE Motor5

Sherman Friedman Gt; Major Appliances

Coleen Fuerst GE Power Deliver L3 Control

Dennis Hussey GE Medical Systems

Art Kaplan Gt; Lighting

Rick Monty GE Plastics

Clem Schimikowski GE KAPL

Wayne Simpson GE Aircraft Enpnes

Daniel Uyesato Corljorate Environ- mental Programs

Charles Vaughan GE Nuclear

Acknowledgment is also provided to the staSf of Corporate Environmental ProLgrams and to ENSR Corporation, Pittsburgh, PA, both of which prouided valuable input to the drafting of this document. Finally, many thanks to GE Graphic Communications, Fai$eld, which not only completed the design layout but also developed the POWER logo.

Questions about the POWER Program can be

Karen Rnsmussen Corporate Environmental Programs 8 Yi229-30 74 2031’3 73-30 74

directed to:

pollution prevention: establishing & implementing a...

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