Document O3Z5YDY5Xp1vmNmLN1wVo1Dvp

To: F. G. Jeanson 0 Interoffice Communication From: Date: Subject: K. G. Akins August 21, 1992 RESPONSIBLE CARE POLLUTION PREVENTION CODE SELF-EVALUATION DOCUMENTATION Below is the documentation to support Aberdeen*s scoring on the Pollution Prevention Code self-evaluation. 1. Score is RI. No change from last year. 2. Score is RI. Methods of quantitative inventory of both hazardous and nonhazardous wastes include SARA 313 documentation, CMA waste survey, WRI, MDEQ waste minimization documentation, etc. 3. Score is PP. Actions include planned compliance testing in connections with the air permit, odor reporting system, feedback from the community advisory panel, and groundwater testing in connection with remediation. 4 Score is RI. Score based on work with community advisory panel, meetings with local governmental officials, and employee communications. 5. Score is RI. This was the first year we were required by the MDEQ to submit a waste minimization plan. Elements of the plan included, inventory of wastes, establishments of reduction priorities, goals and plans for waste reduction. 6. Score is RI. Wastes such as VCM emissions, empty lead bags, waste oil, and filter cake continue to be reduced. The Chief Process Engineer*s Natural Team is working on eliminating/reducing hazardous wastes. We are now working with Conex to recycle wastes from certain 7. Score is RI. Yearly SARA 313 reporting, WRI, CMA waste surveys, yearly updated VAB.0001166519 wmm Waste Minimization Plans, and internal VCM emission monitoring all contribute to this score. 8. Score is RI. Monthly meetings of the community advisory panel continue and are well attended. Regular topics include environmental policies and practices at the plant and safety of operations. 9. Score is RI. Our policy continues to be that the design basis for new projects will be to reduce or cause no net increase in emissions. Good example of this is the plasticizer expansion that is being held up until we're sure wastewater effluent won't be affected. 10. Score is RI. Activities include participation in Aberdeen's Keep America Beautiful, Leadership Monroe's Aberdeen recycling program, recycle of scrap for customers, introduction of cadmium free compounds, and search for an alternative to lead stabilizers. 11. Score is PP. We continually assess current and past waste management practices. The drum remediation and Pond 2 reclamation are examples of past practices that were addressed. Before the projects were begun discussions were held with the community advisory panel and local government officials to hear their concerns. 12. Score is PP. Contractors used at the plant are supervised closely and trained ,, on proper environmental procedures. All contractors used outside the plant must go through an environmental audit procedure before being approved for use. However, we have no definite review process once the initial audit is complete. 13. Score is EV. Until recent discovery of the VCM plume in the shallow groundwater, this area received little attention. Some improvement is expected from the remediation of this plume. 14. Score is RI. Sounds like this item was VAB.0001166520 written based on all the work we've done with Conoco, DERS, ENSR, NUS, MDEQ, and the EPA. Press releases, meetings with the community advisory panel and local government officials have kept them informed and allowed them to express concerns. 5.5 Score is IA. We have established dialogue with the public through the Community Advisory Panel, Exchange Club, Local Emergency Planning Committee, etc. If you have any questions about the scores or documentation, please call me at extension 3637. K. G. Akins Senior Environmental Coordinator c: RWS, JEN VAB.0001166521 t POLLUTION PREVENTION CODE OF Management Practices MANAGEMENT PRACTICES NA EV DP XA I- A dear commitment by senior management through policy, communications, and resources, to ongoing reductions, at each of the company's facilities, in releases to the air, water, and land and in the generation of wastes. Comments on Categoiy NA* A A quantitative inventory at each facility ofwastes generated and releases to the air, water and land, measured or esti mated at the point of generation or release. Comments on Categoiy NA* Evaluation, sufficient to assist in establishing reduction priorities, of the potential impact of releases on the environ ment and the health and safety of employees and the public. Comments on Category NA* Education of, and dialogue with, employees and members of the public about the inventory, impact evaluation, risks to the community. Comments on Category NA Categoiy NA. Categoiy EV Categoiy DP Categoiy IA Category PP Categoiy RI No action. If no action taken became the management practice ia not applicable, please Evaluating evicting company practice* mgmlmmt n>* Pniftitfi. Developing plan to implement Management Practice, Implementing action plan Management Practice in place. Reassessing Management Practice implementation. - VAB.0001166522 2 % NA EV DP IA PP RI Establishment of priorities, goals and plans for waste and release reduction, taking into account both community concerns and the potential health, safety, and environmental impacts as determined under Practices 3 and 4. Comments on Category NA: Ongoing reduction ofwastes arid releases, giving preference first to source reduction, second to recycle/reuse, and third to treatment. These techniques may be used separately or in combination with one another. Comments on Category NA: Measurement of progress at each facility in reducing the generation of wastes and in reducing releases to the air, water, and land, by updating the quantitative inventory at least annually. Comments on Category NA: Ongoing dialogue with employees and members of the public regarding waste and release information, progress in achieving reductions andfutureplans. This dialogue should be at apersonal, face-to-face level where possible, and should emphasize listening to others and discussing their concerns and ideas. Comments on Category NA: Category NA Category *V Category DP Category IA Category PP Category RI * - No action. If no action taken because the management practice is not applicable, please explain. Kralnatlng existing compary practices against the Management Fraction. Developing plan to Implement Msnsgem ant Practice. Imnfomantiitf action Manatfament Pnctlco in oUco. Reassessing Management Practice Implementation. * +_ 3 VAB.0001166523 Categories NA EV DP IA PP Inclusion of waste and release prevention objectives in research, and in design of new or modified facilities, pro cesses, and products. Comments on Categoiy NA: RI 10. An ongoing program for promotion and support ofwaste and release reduction by others, whichmay, for example. Include: a. Sharing of technical information and experience with customers and suppliers: Support of efforts to develop Improved waste and release reduction techniques; c. Assisting in establishment of regional air monitoring networks. Participation in efforts to develop consensus approaches to the evaluation for environmental, health, and safety impacts of releases; Providing educational workshops and trainingmaterials: Assisting local governments and others in establishment of waste reduction programs benefiting the general public. Comments on Category NA: Periodic evaluation of waste management practices associ ated with operations and equipment at each member com pany facility, taking into account community concerns and health, safety, and environmental impacts and implementa tion of ongoing improvements. Comments on Category NA: Category NA Categoiy EV Categoiy DP Categoiy IA Categoiy PP Categoiy RI No action* If no action taken because the management practice is not applicable, please explain. Evaluating existing company practices against the Management Practice, Developing plan to implement Management Practice. Implementing action plan Management Practice in place. Reassessing Management Practice phm , 4 VAB.0001166524 V I * NA EV DP 1A PP RI CMA recognizes that companies mayImplement Practices 12 and 14 on a company-wide or even corporation-wide basis rather than on a facility basis. Therefore, CMA.asks companies to complete the Self-Evaluation Form using percentages that represent company-wide Implementation for these two practices. In adding up the total percentages across all ofthe six categories, the number must equal 100%. Also, please use only whole numbers. For these two management practices the number offacilities used to calculate the percentage may exceed the number of facilities shown on page 1. Companies may use any appropriate method to calculate these percentages. One caution, companies will want to carefully consider how this calculation is performed and use it on a yearly basis so that the data from year to year can be compared meaningfully. Implementation ofaprocessforselectfog, retaining, and reviewing contractors and toll manufacturers taking into account sound wastemanagementpracticesthatprotectthe emdromnentandthe health and safety of employees and the public. Comments on Category NA: Categories DP Implementation ofanongoingprogram foraddressingpastoperat ing and waste management practices and forworkingwith others to resolve identified problems at each active or Inactive facility owned by a member company, taking into account community concerns and health, safety, and environmental impacts. Comments on Category NA: Category NA Category EV Category DP Category IA Category PP Category RI No action. gao action taken became the managamant practlna U nat *--1-------- pirnr rniTtlrnt egahiet ffie Minijnnunt Developing plan to implement Management Practice. Implementing action plan Management Practice in place. Xteesaeeeing Management Practice , 5 ri. s VAB.0001166525