Pollution Prevention/Waste Minimization Plan Template
Pollution Prevention/Waste Minimization Plan Template
Table of Contents
I.
II.
III.
OBJECTIVE AND SCOPE
DEFINITIONS
RESPONSIBILITIES
A.
Pollution Prevention/Waste Minimization Plan Manager
B.
Department Supervisor
C.
Employees
D.
Management
E.
Third Party Contractors
IV.
PROCEDURE
A.
Pollution Prevention/Waste Minimization (PPMW) Hierarchy
B.
Development of PPMW Plan
1. PPMW Policy Statement with Top Management Support
2. PPMW Team
3. Waste Audit
4. Waste Assessment
5. Cost Evaluation
6. PPWM Projects
7. PPMW Goals and Implementation Schedules
C.
Plan Evaluation and Reporting
V.
TRAINING
A.
Employee Training
B.
Training Records
VI.
REFERENCES
A.
Regulatory References
B.
NCH Global Environmental Health and Safety Policy
C.
Business Unit Policy References
D.
Site Policy References
VII. APPENDICES
A.
Form for Preparing Pollution Prevention/Waste Minimization Plan
B.
Common Pollution Prevention/Waste Minimization Options
VIII. DOCUMENT CONTROL
Pollution Prevention/Waste Minimization Plan Template
for
[Company Name/Location]
I.
OBJECTIVE AND SCOPE
The purpose of the [Company Name/Location] Pollution Prevention/Waste
Minimization (PPWM) Plan is to ensure that cost-effective pollution
prevention/waste minimization measures are an integral part of facility operations.
The facility recognizes the benefits of implementing PPWM practices, which
include conservation of resources, safer workplace, cleaner environment,
increased productivity, and reduced waste management costs, regulatory
requirements and environmental liability.
This Plan documents the facility’s goals, methods, and activities that will be
routinely employed to prevent or reduce waste generation for each year, and it
reports historical waste generation quantities and significant waste minimization
accomplishments. The Program also includes clear definition of roles and
responsibilities, employee training, record keeping, reporting, and monitoring
requirements.
The scope of PPWM plan covers a large spectrum of regulations at various levels.
This PPWM plan satisfies the requirement to have such a plan in place under
[hazardous waste, air emissions, wastewater, industrial storm water, and toxic
release reporting requirements].
Questions regarding this Plan should be directed to the Facility PPWM Plan
Manager.
The procedures described in this Plan are intended to facilitate compliance with
applicable governmental regulations. If there is a conflict between this Plan and a
governmental regulation, the governmental regulation will apply and this Plan
will be modified. However, all other requirements in this Plan will apply even if
they are more stringent than governmental regulations.
II.
DEFINITIONS
Waste Minimization. Means the reduction, to the extent feasible, of hazardous
waste that is generated prior to treatment, storage and disposal. Included is any
source reduction or recycling activity that results in either (1) reduction of the
total volume of hazardous waste, (2) reduction of the toxicity of the hazardous
waste, or (3) both. Practices that are considered waste minimization include
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
1
recycling, source separation, product substitution, manufacturing process changes,
and the use of less hazardous raw materials.
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 non-hazardous materials, energy, water, or
other resources as well as those that protect natural resources through
conservation or more efficient use. 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,
and reduced water consumption.
Source reduction. Means any effort to reduce, at the source, the quantity of waste
generated, toxic chemical use, or any release into the environment. Source
reduction measures include, but are not limited to, process modifications,
feedstock purity, good operating and management practices, increases in the
efficiency of machinery, and recycling within a waste generating or other
production process.
Recycle. Means to use, reuse or reclaim a material.
Reuse. Means reutilization of a material in an environmentally sound manner that
will not result in a hazard to human health or the environment. A material is
reused if it is either employed as an ingredient, including use as an intermediate in
an industrial process to make a product, or used in a particular function or
application as an effective substitute for a commercial product.
Reclaim. A material is "reclaimed" if it is processed to recover a usable product
or if it is regenerated.
Treatment. Means any method, technique or process designed to change the
physical, chemical or biological characteristics or composition of industrial waste
or other waste; to neutralize the waste; to recover energy or material resources
from the waste; to render the waste nonhazardous or less hazardous, safer to
transport, store, or dispose of, or amenable for recovery, storage, further
treatment, or disposal; or to reduce the volume of the waste.
III.
RESPONSIBILITY
A.
Pollution Prevention/Waste Minimization Plan Manager
[Responsible Person] shall manage PPWM plan for [Company Name/Location.]
The Plan manager is responsible for implementing all aspects of the Plan and
shall:
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
2
1. Maintain and update the PPWM plan, based on changes in facility
operations and regulations.
2. Assist in the implementation of the plan at the facility.
3. Train employees in involved in PPWM goals and schedules.
4. Keep records of all documents related to PPWM plan.
5. Submit PPWM progress reports to governmental agencies.
B.
Department Supervisor
Department Supervisors are responsible for ensuring that their departments
comply with PPWM plan requirements set forth in this Program. They will be
trained to do so by the PPWM Program Manager and shall assist PPWM Plan
Manager to implement the plan within the department.
C.
Employees
It is the responsibility of all employees in each department to follow procedures
outlined in the PPWM plan. They will be trained to do so by the Supervisors and
shall:
1. Become familiar with the PPWM plan.
2. Attend training provided by the Supervisors.
3. Practice Pollution Prevention/Waste Minimization program and seek out
potential opportunities for waste minimization in the department.
D.
Management
[Company Name/Location] will provide all necessary resources and training to
comply with PPWM plan requirements. Facility Manager will ensure proper
adherence to this plan through regular review.
E.
Third Party Contractors
Third Party Contractors are responsible for complying with this program, and
shall insure that their employees have the necessary training to comply with this
plan.
IV.
PROCEDURE
A.
Pollution Prevention/Waste Minimization Hierarchy
[Company Name/Location] will be guided by the following established
environmental protection hierarchy, given in order of preference in all its PPWM
activities.
1. Source reduction  pollution should be prevented or reduced at the
source whenever feasible;
2. Recycling  pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible;
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
3
3. Treatment  pollution that cannot be prevented or recycled should be
treated in an environmentally safe manner whenever feasible; and
4. Disposal  waste disposal or other release into the environment should be
employed only as a last resort and should be conducted in an
environmentally safe manner.
B.
Development of Pollution Prevention/Waste Minimization Plan
The Facility Manager shall prepare a Pollution Prevention/Waste Minimization
Plan using the form in Appendix A.
1. PPWM Policy Statement with Top Management Support
The Plan will contain a policy which meets NCH Global Environmental
Health and Safety Policy. That Policy states that one of its goals is to
strive for continuous improvement by applying risk management and
Pollution Prevention/Waste Minimization principles to facility activities,
products and services.
2. Pollution Prevention/Waste Minimization Team
The Facility Manager will create a PPWM team with members from all
areas and levels of the facility and designate a PPWM Plan Manager as the
coordinator for the team. This team sets goals, drafts a written PPWM plan
using the form attached in Appendix A, and helps communicate the plan
to all employees.
3. Waste Audit
PPWM Team will gather background information that will help to
characterize the processes within the facility. This information, ranging
from raw materials received to amounts of waste generated, can then be
used to put together a generalized process flow diagram which will:
a. List all waste being generated hazardous and nonhazardous;
b. Identify the composition of the waste and the source of each waste
stream;
c. List the processes and areas generating waste; and
d. Record the volumes of each waste stream.
4. Waste Assessment
The team will use the assessment results as the focal point for identifying
pollution prevention options that could best reduce or eliminate specific
wastes. The team must first prioritize waste streams or processes
considering factors such as:
a. cost of disposal,
b. amount of waste generated,
c. type and toxicity of waste,
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
4
d. regulatory concerns,
e. potential liability, and
f. threat to workers and the environment.
5. Cost Evaluation
The team will evaluate the full cost of waste management. The full cost of
waste will include:
a. purchase price of raw materials
b. storage and inventory
c. air/water emissions and solid waste collections
d. record keeping and reporting
e. inspection and permit fees
f. sampling and testing fees
g. safety equipment
h. secondary containment structures
i. storage and containers
j. employee training; and
k. costs associated with treatment and disposal
Knowing the full cost of a waste is important when determining whether a
particular pollution prevention option under consideration will be cost
effective.
6. PPWM Projects
Team discussions will be held with Supervisors and employees to
stimulate ideas and identify specific projects to change or modify
processes contributing to waste generation, including:
a. Identifying options to reduce the generation of these substances in the
production or manufacturing process.
b. Comparing technical and economic feasibility of the options
identified.
c. Focusing on wastes that are most hazardous and techniques that are
most easily implemented.
Some of the most common options for reducing or preventing pollution
are included in Appendix B.
7. Goals and Implementation Schedule
Once PPWM projects are prioritized, the Team will set achievable goals in
terms of percent of hazardous waste to be decreased or toxic chemicals to
be reduced or released or other criteria. An implementation schedule for
completing critical steps of the projects must also be established.
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
5
C.
Plan Evaluation and Reporting
Periodically [Once a year], the Team will re-evaluate the individual projects
implemented and the PPWM plan as a whole, redefining goals where necessary.
In addition to determining progress of the implemented project, the Team will
troubleshoot and determine why certain aspects have not worked.
The Plan Manager will submit PPMW progress reports to governmental agencies
if it is a requirement.
IV.
TRAINING
A.
Employee Training
The PPWM Plan Manager will insure that all employees are trained under this
Plan. The training will emphasize the new attitude about pollution control making
PPWM plan and its success everyone's responsibility. Training will include:
1. Clear communication of management’s commitment to the program;
2. Instruction on why employee participation is vital to a successful PPWM
plan;
3. Training employees in PPWM techniques;
4. Encouraging employee suggestions;
5. Providing incentives for employee participation;
6. Providing resources necessary to get the job done; and
7. Publicizing success stories within the facility and company.
B.
Training Records
[Responsible Person] shall document all training pertaining to this plan and shall
maintain records in accordance with facility Records Retention Plan.
V.
REFERENCES
A.
B.
C.
D.
VI.
Regulatory references
NCH Global Environmental Health and Safety policy
Business Unit Policy references
Site Policy references
APPENDICES
Appendix A – Form for Preparing Pollution Prevention/Waste Minimization Plan
Appendix B – Common Pollution Prevention/Waste Minimization Options
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
6
VII.
DOCUMENT CONTROL
This PPWM shall be reviewed annually, or as needed if changes to the facility
operations, processes, or personnel are made, by [Responsible Person]. Following
each change, [Responsible Person] shall document the change and inform all
affected by the changes.
Document History:
Procedure
version
Date Approved
Approved by
Date: April 15, 2009
Version: Final 1.0
Next Review: April 15, 2010
Reason for
Change
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
7
APPENDIX A
FORM FOR PREPARING
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
POLLUTION PREVENTION/WASTE MINIMIZATION POLICY
NCH Global Environmental Health and Safety policy states that one of its goals is to
strive for continuous improvement by applying risk management and pollution prevention
principles to our activities, products and services.
In keeping with this policy, our objective as a company is to reduce waste and achieve
minimal adverse impact on air, water and land through excellence in pollution control.
Our Pollution Prevention/Waste Minimization (PPWM) goals are stated as follows:
All employees are responsible for the elimination, reduction, and proper disposal
of waste. Source reduction and waste minimization are prime considerations in
product development and the design of manufacturing processes. They are also
essential elements for controlling pollution to prevent adverse impact to the air,
land, and water.
The facility manager is committed to reducing waste and will pass that
commitment on to the employees. Every employee will be trained and charged
with the responsibility to identify and carry our PPWM goals.
P
OL
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
CERTIFICATION OF COMPLETION
This document certifies that the Pollution Prevention/Waste Minimization plan has
been completed and meets the specific requirements of [regulatory citation] and that
the information provided herein is true, correct, and complete.
This document also certifies that the person/s whose signature appears below has the
authority to commit the corporate resources necessary to implement this plan.
Signed________________________ Title _______________________ Date____/____/______
Signed________________________ Title________________________ Date____/____/______
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
FACILITY DESCRIPTION
Facility Name and Address
NAME OF FACILITY
CONTACT PERSON
MAILING ADDRESS:
CITY, STATE, ZIP:
CONTACT PHONE:
CONTACT FAX:
CONTACT EMAIL:
Facility Location
The site is located at
The site is an [ -acre parcel of land and located in an area of].
[Description of neighboring properties and activities]
The geographical coordinates of the facility are:
Latitude:
Longitude:
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
PPWM PLAN TEAM
The facility will form a PPWM team consisting of members from all areas and levels of the
facility. The PPWM plan manager will serve as the coordinator of the team. This team
will set PPWM goals, draft the written plan, evaluate progress, and help to implement the
plan in all areas and among the employees.
Name
Senior Management
Team Coordinator
EHS Manager
Department Supervisors
Employees
Purchasing staff
Department
Responsibilities
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
FACILITY ENVIRONMENTAL PERMITS
WASTE GENERATOR ID:
WASTEWATER PRETREATMENT
PERMIT NO.
AIR PERMIT NO.
STORM WATER PERMIT
TOXIC RELEASE INVENTORY ID:
SIC CODE:
NAICS CODE:
OTHER PERMIT:
OTHER PERMIT:
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
FACILITY OPERATIONS
Waste generation activities
Water discharges
Air releases
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
WASTE STREAM IDENTIFICATION AND ASSESSMENT
YEAR - - - Waste stream
name/description
Point of
generation
Estimated
quantity
(lbs/year)
Method of
disposal
Cost of
disposal
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
TOXIC RELEASE INVENTORY (TRI) ASSESSMENT
YEAR - - - TRI CHEMICAL
CAS NO.
Estimated
Method of
Cost of
quantity
disposal
disposal
(lbs/year)
TOXIC RELEASE INVENTORY (TRI) SUMMARY OF RELEASES
YEAR - - - TRI Chemical
Releases to (pounds)
Total
Releases
Stack air
Fugitive air Water
Land
Totals
TOXIC RELEASE INVENTORY (TRI) SUMMARY OF OFFSITE TRANSFERS
YEAR - - - TRI Chemical
Offsite Transfers (pounds)
Total
Releases
Disposed
Recycled
Treated
Totals
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
PRIORITIZED LIST OF WASTE STREAMS
Prioritization Criteria
[Company Name/Location] has prioritized its waste streams using the following criteria:
1.
2.
3.
4.
5.
6.
7.
Current disposal practices and cost
Current and potential future environmental regulations
Raw material costs
Threat to workers, public, and environment
Handling, storage and disposal problems
Amount of waste generated
Length of time waste displays hazardous characteristics
Waste stream name
Rank/Priority
Reasons for prioritization
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
GOALS AND WASTE REDUCTION ESTIMATES
[Company Name/Location] commitment to the protection of the environment and waste
reduction practices is stated in its corporate Environmental, Health and Safety Policy. As
part of the commitment, the facility has set the following goals to reduce waste over the
next five years.
[Objective: Reduce Waste from use of Hazardous Material. Target: Reduce Hazardous
Materials turned in as hazardous waste by an average of at least 10 percent from the
previous year.
Objective: Reduce air Pollutants, CO, PM-10, NO2, O3, Pb, and SO2. Target: Implement
cost effective opportunities within 12 months of funding. Reduce emissions of each
pollutant by 20% by the end of the third year and 50% by the end of the fifth year.
Objective: Reduce wastewater production. Target: By the end of the next fiscal year,
reduce wastewater discharge to 25 percent based on baseline year.]
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
PPWM TARGETS AND IMPLEMENTATION SCHEDULE
This section provides an implementation schedule that [Company Name/Location] will
follow in order to meet the goals as stated above. The table covers the five year period of
------------------through------------------. The first year in the table will be the period of -------------- through------------------------------, and all subsequent years will follow the same
plan.
Waste stream
name
PPWM
target
Implementation
options
Implementation
time
See Appendix B for common PPWM options and projects.
Cost
savings
Volume/weight
reduction target
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
PPWM PLAN PROGRESS EVALUATION
The PPWM team will meet [annually] to evaluate progress and measure results of plan
implementation. Any adjustments to plan implementation will also be made at this time
and senior management will be notified of the progress.
The PPWM Plan Manager will submit annual PPWM progress reports to governmental
agencies if required.
POLLUTION PREVENTION/WASTE MINIMIZATION PLAN
FOR
[Company Name/Location]
EMPLOYEE AWARENESS TRAINING
[Company Name/Location] conducts PPWM plan training to employees annually. Topics
discussed at the training include PPWM goals and projects currently being pursued and
goals under consideration. During training, potential Pollution Prevention/Waste
Minimization ideas are solicited from employees and discussed.
APPENDIX B
POLLUTION PREVENTION/WASTE MINIMIZATION OPTIONS
POLLUTION PREVENTION/WASTE MINIMIZATION OPTIONS
Good
Housekeeping





Material
Substitution



Equipment
Modifications







Process
Modifications








Inspect and repair equipment to reduce waste caused by equipment
breakdown, leaks and spills
Contain leaks and spills by installing drip trays and splash guards
Keep containers closed except when material is added or withdrawn
Segregate different kinds of waste to increase opportunities for recycling
and reduce the volume of waste that must be considered hazardous
Track wastes to insure proper handling
Use water soluble cleaning agents in place of organic solvents and
degreasers
Replace hydrocarbon-based paints and inks with water based ones; then use
water rather than hydrocarbon solvents for cleanup
Buy recycled and recyclable products
Automate process monitoring to reduce errors that may produce offspecification batches
Choose equipment that is easy to clean
Use spray equipment that reduces overspray
Modify equipment to reduce materials lost to the waste stream (e.g. reduce
water use; install tank overflow controls, revise rinsing methods)
Modify equipment to reduce emissions (e.g. increase freeboard on tanks or
install chillers in the freeboard zone to reduce volatile gas emissions)
Use high pressure nozzles for cleaning
Maximize equipment dedication
Use spill cleanup methods that allow for recycling of spilled materials. If
spilled materials cannot be reworked into product, use dry cleanup methods
for spills
Purge pipelines before disconnecting when filling storage tanks.
Avoid unnecessary equipment cleaning. Explore the feasibility of
eliminating cleaning steps between batches
Prevent products from drying in the tanks
Store containers and packages properly to prevent damage or
contamination. Protect items stored outdoors from temperature extremes,
rain, snow, and wind
Substitute water-based for solvent-based formulations whenever possible.
Replace caustic equipment cleaning solutions with alkaline cleaning
solutions
Modify equipment and materials cleaning practices to reduce the frequency
of cleaning, to minimize quantity of cleaning material used, or to enhance
recycling of raw materials removed during cleaning
Reuse




Consider onsite distillation of solvents
Reuse cleanup solvents
Rework wastes into useful products
A material that one firm cannot reuse may be perfect for another. Waste
Exchanges attempt to match waste generators with potential users.
Recycling and
Reconditioning

Arrange to have a commercial reclaimer recycle certain wastes.
Repurchasing the recycled material may cost much less than purchasing
virgin material.
Segregate solvent wastes
Use only one type of solvent if possible
Recycle as many waste materials as possible. Computer and office paper,
aluminum, ferrous metals, and plastic and glass containers are some
commonly recycled items
Recycle scrap metal, glass, and pallets, and corrugated cardboard
Recycle lube oils
Recycle fluorescent bulbs, batteries, thermostats, mercury containing
products as Universal wastes
Arrange to have metal and poly drums reconditioned








Inventory control






Other waste
Minimization
Options






Use a first in, first out policy for raw materials to prevent them from
becoming too old to be used. A computerized inventory control system is
sometimes the best way to implement this policy
Designate raw material and hazardous waste storage areas. Provide
weather protection and spill containment. Keep areas clean and organized.
Return obsolete raw materials to the supplier if possible
Segregate waste streams for easier recycling and to keep non-hazardous
material from becoming contaminated
Test raw materials before accepting them from the supplier. This can help
eliminate the production of off-spec products
Control inventories by purchasing only what is needed, and date and label
all storage containers so products will not exceed their shelf life
To minimize spills during tank filling, install high level shut off and flow
totalizers with cutoff
Standardize cleaning product. Use a solvent that is an ingredient of the
final product so that it can be reworked
Reduce traffic through raw materials storage area (reduces contamination,
dispersal of materials)
Implement a cost incentive program to encourage customers who purchase
large volumes of drummed products to convert to bulk purchase. This
reduces the quantity of drums returned for cleaning, and also reduces
residuals
Reduce amount of packaging
Conserve water and energy