Pollution Prevention/Waste Minimization Plan Template

Pollution Prevention/Waste Minimization Plan Template

Table of Contents

I.OBJECTIVE AND SCOPE

II. DEFINITIONS

III. RESPONSIBILITIES

  1. Pollution Prevention/Waste Minimization Plan Manager
  2. Department Supervisor
  3. Employees
  4. Management
  5. Third Party Contractors

IV. PROCEDURE

  1. Pollution Prevention/Waste Minimization (PPMW) Hierarchy
  2. Development of PPMW Plan
  3. PPMW Policy Statement with Top Management Support
  4. PPMW Team
  5. Waste Audit
  6. Waste Assessment
  7. Cost Evaluation
  8. PPWM Projects
  9. PPMW Goals and Implementation Schedules
  10. Plan Evaluation and Reporting

V.TRAINING

A.Employee Training

B.Training Records

VI. REFERENCES

  1. Regulatory References
  2. NCH Global Environmental Health and Safety Policy
  3. Business Unit Policy References
  4. Site Policy References
  1. 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 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
  1. 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:

  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.
  1. 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.

  1. 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.
  1. 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.

  1. 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;
  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 PolicyStatement 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.

  1. PollutionPrevention/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.

  1. 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.

  1. 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,

d.regulatory concerns,

e.potential liability, and

f.threat to workers and the environment.

  1. 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.

  1. 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.

  1. 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.

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
  1. 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.
  1. 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.Regulatory references
B.NCH Global Environmental Health and Safety policy
C.Business Unit Policy references
D.Site Policy references
VI.APPENDICES

Appendix A – Form for Preparing Pollution Prevention/Waste Minimization Plan

Appendix B – Common Pollution Prevention/Waste Minimization Options

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 / Reason for Change
Date: April 15, 2009
Version: Final 1.0 / Authorized by: Regulatory Affairs Counsel
Next Review: April 15, 2010 / Uncontrolled when printed

1

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 PLANTEAM
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 / Department / Responsibilities
Senior Management
Team Coordinator
EHS Manager
Department Supervisors
Employees
Purchasing staff
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 quantity
(lbs/year) / Method of disposal / Cost of disposal
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. Current disposal practices and cost
  2. Current and potential future environmental regulations
  3. Raw material costs
  4. Threat to workers, public, and environment
  5. Handling, storage and disposal problems
  6. Amount of waste generated
  7. 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 / Cost savings / Volume/weight reduction target

See Appendix B for common PPWM options and projects.