Document ZJmr4pVb6rp8evQVpbK1oRYz7

TO: Interoffice Communicotion FROM: DATE: SUB J: Distribution T. G. Grumbles January 21, 1991 RESPONSIBLE CARE WARR CODE Tee: JCL: ERT ; MJR- l - Rr XF: VISTA Attached is the draft of the expanded WARR Code. Four waste management practice elements are being added to the waste and release reduction codes. I'm asking you to review these four new elements and provide any comments you may have to me by March 1. I'll collate the comments and provide to CMA. The attachment is thick, but you need only specifically review the italicized portion of the Code. You've seen the rest before. T. G. Grumbles ^ dlj Attachment Distribution: PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. V. Ware-LCLAB, R. A. Conrad-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Ueiss-Austin T. H. Huffman, J. C. Ledvina YVV 000011655 CHEMICAL MANUFACTURERS ASSOCIATION January 8, 1991 TO RESPONSIBLE CARE COORDINATORS Subject: Review of the Waste Management Practices Dear Responsible Care Coordinator: Enclosed is the draft language for the four waste management practices and preface language that will be added to the Waste and Release Reduction (WARR) Code of Management Practices. We request your review of the four practices and preface language that are found in the italicized typeface in the attached code. NO CHANGES to the existing WARR Code are proposed. As Responsible Care Coordinator for your company, please collect comments from your Environmental Contact and other appropriate reviewers and submit your company's compiled comments in writing to Ann M. Mason, CMA's Associate Director of Waste and Release Reduction. Written comments may be sent to Ann by mail or by telefax at 202/887-1237. The comment period for these four practices ends on March 8, 1991. SUMMARY Over the last year, the Waste Management Code Drafting Work Group of the Environmental Management Committee has worked to write four waste management practices. The Responsible Care Coordinating Group (RCCG) and the Environmental Management Committee (EMC) have approved adding these four practices to the ten practices in the existing WARR Code. These four practices encompass facility assessments, member company assessment of contractors handling wastes, groundwater protection, and member company evaluating past operating sites that are currently owned by the company. When the WARR Code was named, EMC was in the process of writing a second code to address waste management. Since then, the EMC and RCCG have agreed that the name, Pollution Prevention Code of Management Practices, more accurately reflects the scope of the expanded code and indicates that the chemical industry is concerned with protection concepts beyond reduction and waste management. More importantly, the name represents a more positive image that responds to public concerns and is easier to communicate. VVV 000011656 2501 M Street, NW, Washington, DC 20037 2C2-887-11Q0 Telex 89617 (CMA WSH) 2- - BACKGROUND Originally, the Board of Directors proposed two codes to address protection of the environment: 1.) 2.) Waste and Release Reduction, and Waste Management. Based upon input from the membership, the RCCG and the EMC decided to add the four practices to the ten existing management practices in the WARR Code. This membership review requests comments only on practices 11-14 and on the Italicized words (paragraph 4) in the purpose. No changes will be made to the first ten management practices in the WARR Code that the Board approved in April 1990. Management practices 11-14 add four concepts to the existing WARR Code: o Review Waste Management Practices at Member Company Facilities. (Practice 11) o Review Contractor Facilities that Handle Member Company Wastes, Residues, or Recyclables. (Practice 12) o Protect Groundwater. (Practice 13) o Evaluate Prior Sites that are Still Under Your Ownership. (Practice 14) REPORTING REQUIREMENTS Starting in 1991, CMA will mail a three part report for the Pollution Prevention Code to each Responsible Care Coordinator as follows: 1. Self-Evaluation Form. In 1991, the Self-Evaluation Form will address all fourteen Management Practices. 2. Toxic Release Inventory (TRI) Data. In 1991, CMA will encourage members to submit the TRI data to CMA using an electronic submission. Paper, while accepted, will not offer members the benefit of quality assuring the data that will be added to the TRI database. 3. Waste Survey. The Waste Survey becomes mandatory beginning with the 1990 reporting year. As such, CMA has simplified the existing Waste Survey. The 1990 Waste Survey contains some of the data that were included in previous voluntary requests but has been streamlined significantly. Attached for your information only is the 1990 Waste Survey. -3- The revised format of the Waste Survey is a one page table that provides members an opportunity to fill in the appropriate blanks. This format reflects minor changes to the type of information collected. The survey simplification includes using two broad headings: non-hazardous and hazardous. For each of these groups the wastes are divided into solid wastes and wastewater. In addition, the list of management practices represents a consolidation of the practices into 11 types. SCHEDULE FOR MEMBERSHIP REVIEW The official review of the four waste management practices will last until March 8, 1991. The Board is scheduled to have a preview of these practices in January 1991. In September 1990, EMC sent the four waste management practices to a number of CMA's environmental task groups. At the same time, the draft language was sent to Responsible Care Coordinators and Environmental Contacts for their preview. Furthermore, the waste management practices were discussed at the Responsible Care Coordinators National Meeting on September 25, 1990 in Chicago. Also in September, the draft practices were reviewed by the Responsible Care Public Advisory Panel. They supported both the concepts of a single code and the four proposed practices. On February 26, 1991, at the Madison Hotel in Washington, D.C., CMA will hold an Open Forum to discuss the four waste management practices with the membership. Please plan to have a representative from your company attend the Open Meeting. A registration form is enclosed for your convenience. In advance, we thank you for your continued support to make the Responsible Care initiative successful. If you have any questions about the waste management practices, please contact Ann M. Mason (202-887-1180), or Richard Dennis, American Cyanamid, (201-831-3996). Sincerely, i -----------MV Lori M. Ramonas, Ph.D. Director Responsible Care ,, Enclosures cc: (w/out Open Forum brochure) Environmental Contacts Waste Management Code Drafting Work Group Environmental Management Committee Responsible Care Coordinating Group Responsible Care Communications Contacts vVV 000011658 DRAFT POLLUTION PREVENTION CODE OF MANAGEMENT PRACTICES NOTE: Normal Text indicates the language approved 4/90 for the Waste and Release Reduction Code (WARR); text shown in italics and bold is the draft language that adds tbe waste management concepts to tbe WARE Code. Purpose. This Code is designed to achieve ongoing reductions In the amount of all contaminants and pollutants released to the air, water, and land from member company facilities. These reductions are intended to respond to public concerns with the existence of such releases, and to further Increase the margin of safety for public health and the environment. The Code is also designed to achieve ongoing reductions in the amount of wastes generated at facilities. These reductions are intended to help relieve the burden on industry and society of managing such wastes in future years. In implementing the Code, each company should strive for annual reductions, recognizing that production rates, new operations, and other factors may result in increases. Despite these fluctuations, however, the goal is to establish a long-term, substantial downward trend in the amount of wastes generated and contaminants and pollutants released. Quantitative reduction goals will be established for giving priority to those pollutants, contaminants and wastes of highest health and environmental concern. This code also includes practices that address tbe broader waste management issues beyond source reduction and waste and release reduction efforts. Each member company must manage remaining wastes and releases in a manner that protects tbe environment and tbe health and safety of employees and tbe public. This Code complements, and should be implemented in conjunction with current and future Codes of Management Practices. Key terms are defined in the Glossary, which should be consulted for assistance in interpreting the provisions of this Code. Relationship to Guiding Principles. Implementation of this Code helps achieve the following Guiding Principles: o To recognize and respond to community concerns about chemicals and our operations; o To develop and produce chemicals that can be manufactured, transporteds used and disposed of safely. VVV Q0Q011659 Pollution Prevention Code (The expanded Waste & Release Reduction Code) Member Review Draft-----January 7, 1991 ----- Page 2 draft o To make health, safety, and environmental considerations a priority in our planning for all existing and new products and processes; 0 To report promptly to officials, employees, customers and the public, information on chemical-related health or environmental hazards and to recommend protective measures. o To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public; o To extend knowledge by conducting or supporting research on the health, safety, and environmental effects of our products, processes, and waste materials. o To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport, or dispose of chemicals. o To work with others to resolve problems created by past handling and disposal of hazardous substances. o To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. o To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. Management Practices (WARR). Each member company shall have a waste and release reduction program which shall include: 1. A clear 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. 2. A quantitative inventory at each facility of wastes generated and releases to the air, water, and land, measured or estimated at the point of generation or release. 3. Evaluation, sufficient to assist in establishing reduction priorities, of the potential impact of releases on the environment and the health and safety of employees and the public. VVV 000011660 Pollution Prevention Code (The expanded Waste & Release Reduction Code) Member Review Draft-----January 7, 1991 ----- Page 3 DRAFT 4. Education of, and dialogue with, employees and members of the public about the Inventory, impact evaluation, and risks to the community. 5. 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. 6. Ongoing reduction of wastes and 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. 7. 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. 8. Ongoing dialogue with employees and members of the public regarding waste and release Information, progress in achieving reductions, and future plans. This dialogue should be at a personal, face-to-face level, where possible, and should emphasize listening to others and discussing their concerns and Ideas. 9. Inclusion of waste and release prevention objectives in research and in design of new or modified facilities, processes, and products. 10. An ongoing program for promotion and support of waste and release reduction by others, which may, for example, include: a. Sharing of technical information and experience with customers and suppliers; b. Support of efforts to develop improved waste and release reduction techniques; c. Assisting In establishment of regional air monitoring networks; d. Participation in efforts to develop consensus approaches to the evaluation of environmental, health, and safety impacts of releases; e. Providing educational workshops and training materials; f. Assisting local governments and others in establishment of waste reduction programs benefitting the general public. ^ o Oil**61 Pollution Prevention Code (The expanded Waste & Release Reduction Code) Member Review Draft-----January 7, 1991 ----- Page 4 draft 11. Periodically evaluate waste management practices associated with operations and equipment at each facility, taking into account community concerns and health, safety, and environmental impacts and implement ongoing improvements. 12. Conduct initial and periodic reviews of contractors' and toll manufacturers' relevant facilities and operations used by the member company and verify that sound waste management practices are used to protect the environment ami the health and safety of employees and the public. 13. Implement engineering and operating controls at each member company facility to Improve prevention of, early detection of, and response to releases to groundwater. 14. Assess prior operating and disposal practices at each active or inactive facility owned by a member company and implement an ongoing program to resolve identified problems, taking into account community concerns and health, safety, and environmental impacts. Industry Trend Data. To develop and maintain statistical industry trends, CMA will collect currently available data. Each company shall report annually to CMA, or its designated agent, for each facility: o Releases of substances as reported under SARA Section 313; and o Wastes generated, as defined and reported In CMA's annual waste survey. Member Self-Evaluation. Each member company shall report annually to CMA, or its designated agent, the stage of implementation of each management practice in this Code. The reports shall be on the member self-evaluation form attached as Attachment A. VVV 000011662 Pollution Prevention Code (The expanded Waste & Release Reduction Code) Member Review Draft-----January 7, 1991 ----- Page 5 DRAFT Glossary of Terms As used in this Code, key terms are defined as set forth below. Note that these definitions may be broader than regulatory definitions, and that adherence to this Code does not relieve a company of the obligation to meet Federal, state and local regulatory requirements. Facility - A site used for chemical manufacturing, processing, refining, packaging, R&D, distribution or related commercial activity. Recycle - A practice which regenerates or processes a material from a process to recover a useable product or material for reuse. Release - Any emission, effluent, spill, discharge or disposal to the air, land, or water, of any pollutant or contaminant, whether routine or accidental, at or from a facility. The term does not include shipment or distribution of chemical product, nor release to the environment as part of normal and intended use of a product by the consumer. Reuse - A practice that reemploys a material from a process either as an Ingredient in a process to make a product, or as an effective substitute for a commercial product in a particular function or application. Source Reduction - A practice that reduces the amount of any release or waste generated at the source. Including closed loop recycle and reuse before exit from a process. The term includes, among other practices, equipment and technology modifications, process and procedures modifications, reformulation and redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training and inventory control. Treatment - A practice, other than recycle or reuse, that alters the physical, chemical, or biological characteristics or the volume of a waste through a process or activity separate from the production of a commercial product or the provision of a service. Waste - Any gas, liquid, or solid residual material at a facility, whether hazardous or non hazardous, that Is not used further In the production of a commercial product or provision of a service and which Itself is not a commercial product. VVV 000011663 ATTACHMENT A DRAFT CHEMICAL MANUFACTURERS ASSOCIATION MEMBER SELF-EVALUATION FORM POLLUTION PREVENTION CODE OF MANAGEMENT PRACTICES Member Company Name: Responsible Care Coordinator Name: ____________ Address: ____________ Telephone: ( ) Number of facilities subject to Code WV 000011664 WASTE AND RELEASE REDUCTION CODE DRAFT Instructions: 1. Under the Responsible Care Initiative, each member company will submit a Self-Evaluation form annually to CMA. To establish the industry baseline, each member company should complete this Self-Evaluation form and send it to Heiden Associates by August 29,1991. Dr. Edward J. Heiden Heiden Associates, Inc. 1815 H Street, NW Suite 501 Washington, D.C. 20006 2. Indicate on the cover page the number of member company facilities subject to the Code. Each company must report the implementation stage for all facilities subject to the Code on this form. 3. For each Management Practice on the following two pages, indicate the number of facilities that have attained each implementation stage. Each facility should appear in only one milestone stage per Management Practice. That is the total number of facilities subject to the Code should equal the number of facilities across all six implementation stages for each Management Practice. 4. For the Industry Trend Data, show the total number of facilities in each appropriate box. The total number of facilities for each type of Trend Data should equal the total number of facilities subject to the Code. 5. Only subject facilities owned or operated as of the reporting date should be included. 6. The implementation stages are: Stage I Stage II Stage III Stage IV Stage V Stage VI - No action. - Evaluating company practices against Code practice. Developing action plan to implement Code practice. - Implementing action plan. - Code management practice in place. - Implementation reviewed and reaffirmed this year. OOOO!! 665 DRAFT POLLUTION PREVENTION CODE Management Practice Milestones 1. A clear comm itment by senior management through pol icy, communications and resources, to ongoing reduc tions, at each of the company's facilities, in releases to the air, water and land and in the generation of wastes. I II Stagfs III IV IV 2. A quantitative inventory at each facility of wastes gener ated and releases to the air, water and land, measured or estimated at the point of generation or release. 3. Evaluation, sufficient to assist in establishing reduction priorities, of the potential impact of releases on the environment and the health and safety of employees and the public. 4. Education of, and dialogue with, employees and mem bers of the public about the inventory, impact evalu ation, risks to the community and waste and release reduction priorities. 5. Establishment of priorities, goals and plans for waste and release reduction, taking into account both commu nity concerns and the potential health and safety impacts as determined under Practices 3 and 4. 6. Ongoing reduction of wastes and releases, giving prefer ence first ot source reduction second to recycle/reuse, and third to treatment These techniques maybe used separately or in combination with one another. VVV 000011666 DRAFT WASTE AND RELEASE REDUCTION CODE Management Practice Milestones Management ___ ____________ Stages__ ________ ___ __ 7. 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. T TT m IV V Vf 8. On going dialogue with employees and member s of the public regarding waste and release information, progress in achieving reductions and future plans. This dialogue should be at a personal, face-to-face level, when possible, and should emphasize listening to others and discussing their concerns and ideas. 9. Inclusion of waste and release prevention objectives in research, and in design of new or modified facilities, processes and products. 10. An ongoing program for promotion and support of waste and release reduction by others. 11. Periodically evaluate waste management practices associated with operations and equipment at each facility, taking into account community concerns and health, safety, and environmental impacts and implement ongoing improvements. 12. Conduct initial and periodic reviews of contractors' and toll manufacturers' relevant facilities and operations used by the member company and verify that sound waste management practices are used to protect the environ mem and the health and safety of employees and the public. 13. Implement engineering and operating controls at each member company facility to improve prevention of, early detection of, and response to releases to groundwa ter. 14. Assess prior operating and disposal practices at each active or inactive facility owned by a member company and implement an ongoing program to resolve identified problems, taking into account community concerns and health, safety, and environmental impacts. _ nooo VW c II6 67 WASTE AND RELEASE REDUCTION CODE DRAFT Industry Trend Data Report annually to CMA or its designated agent, for each facility: 1. Release of substances as reported under SARA Section 313; and 2. Wastes generated, as defined and reported in CMA's annual hazardous waste survey. Annual report submitted* Annual report not submitted* Annual report not requtred to be submitted* Enter number of facilities for which annual report to CMA has or has not been submitted. NOTES: 1. CMA expects to receive release data only from those facilities that are required to complete the Form R following the requirements in the Superfund Amendment and Reauthorization Act (SARA) Section 313 and EPA's clarifying requlations and instructions. Companies, not required to report 313 release data to EPA, may volunteer to send release data to CMA. These facilities are not required to submit release data to CMA as an obligation of membership. 2. The 313 Form R release data are due to CMA on July 1,1990, the same time these data are due to U.S. EPA. These release data cover the calendar year 1989 and form the baseline for the CMA's industry trend data. CMA will issue clarifying instructions about how companies can report these TRI data to CMA. CMA is looking at several options: o Submission of the same data as EPA requires, o Submission of aggregated facility totals by media. Companies are asked to await further instructions before sending CMA the 313 Form R's. VVV G00011668 DRAFT 3. The first year for companies to complete CMA's annual Waste Survey as an obligation of membership under the Waste and Release Reduction Code will begin with the data covering the calendar year 1990. This survey will be sent to the Responsible Care Coordinators in the Spring of 1991. CMA will send the annual Waste Survey covering the calendar year 1989 to members in May 1990. Com pletion of the survey covering the 1989 calendar year remains voluntary. VVV 000011669 WASTE MANAGEMENT PRACTICES QUESTION AND ANSWERS Four practices will be added to the ten existing and Release Reduction Code of Management Practices. As companies Implement Practices 1-10, they should examine their implementation actions and modify them to include wastes and waste management. It is particularly important to recognize the overlap of the employee and community outreach portions and include waste management and remediation concepts when implementing Practices 4 and 8. Question: What are the waste management practices ASSOCIATED WITH ALL OPERATIONS AND EQUIPMENT? The Code envisions companies reviewing all waste management practices at each step of the operation where wastes are generated or released within each facility. This review is within the operating processes not just at the "end of the pipe." Question: How OFTEN SHOULD PERIODIC REVIEWS BE DONE? A review or evaluation should be done on some repeat basis. Timing for follow-up evaluation should be determined by the results of previous reviews, potential impacts, potential liability, etc. Question: What do you mean by a contractor and toll MANUFACTURER? Contractors are any entity a member company uses to handle their residual materials and wastes. This Includes, for example, waste treatment facilities, disposal facilities, tank cleaners, reclaimers, recyclers, and the like. Toll manufacturers are independent parties who perform a manufacturing step for a member company, use the member company's feed stock, and generate waste from the manufacturing step. WV 000011670 Pollution Prevention Code Questions and Answers Member Review Draft-----January 7, 1991 ----- Page Z Question: How DO YOU VERIFY THAT SOUND WASTEMANAGEMENT PRACTICES ARE USED BY A CONTRACTOR OR TOLL MANUFACTURER? Member company verification should at least include a site visit and visual inspection of waste management practices by a company representative. More rigorous inspection may be appropriate based on initial findings. As part of the contracting procedure, member companies should consider including language requiring the contractor to use proper health, safety, and environmental practices and that the member company has a right to inspect for that purpose. Responsible Care covers toll manufacturers operations under two Codes: wastes are covered under the Pollution Prevention Code; other operations are covered under the Product Stewardship Code. Question: What recourse does a company have if CONTRACTOR OR TOLL MANUFACTURER DOES NOT SOUND WASTE MANAGEMENT PRACTICES OF THE COMPANY? the MEET THE MEMBER Sound waste management practices are those that protect the environment and the health and safety of employees and the public. If the contractor or toll manufacturer does not meet the member company's expectations of sound waste management practices then the member company has several options including not using or terminating the contractor or working with him to quickly correct any deficiencies. Question: What do we mean by improve the prevention of RELEASES TO GROUNDWATER? While it is envisioned that a company will have an SPCC (Spill Prevention and Countermeasures) plan in place for a limited number of materials, companies should review the chemicals at the facility and extend the SPCC concepts to other materials. The goal is to prevent releases to the ground and to protect existing groundwater quality. VVV 000011671 Pollution Prevention Code Questions and Answers Member Review Draft-----January 7, 1991 ----- Page 3 Question: What is meant by assessing prior operating AND DISPOSAL PRACTICES? The purpose of the assessment is to obtain sufficient knowledge about a given site to make a judgement regarding what, If any, actions need to be taken to address potential health, safety and environmental concerns. Each member company must develop its own plan for setting priorities and for assessing and identifying sites requiring remediation. Waste operating practices that companies should consider may include: recycling and reuse; source control to minimize generation of waste; effective treatment of waste generated; waste used as alternate fuel and incineration. Waste disposal practices may include: land disposal; land treatment and farming, and deepwell injection. Question: Which member company facilities, active or INACTIVE, ARE INCLUDED IN PRACTICE 14? This practice applies to facilities or property currently owned by a CMA member company. This Includes properties that are still owned, but no longer have ongoing operations. Inactive sites, not owned by a member company where the company has potential involvement, should be addressed to the extent the member company determines feasible. Question: What is meant by implementing an ongoing program TO RESOLVE IDENTIFIED PROBLEMS? Each member company is expected to implement an ongoing waste management program to assess its prior operating and waste management practices. As areas of greatest concern, identified by the initial assessments, are resolved remaining sites should be evaluated, as needed. This evaluation should take into account public, regulatory, and technical concerns, as well as the economic viability of resolving these concerns. WV 000011672 Pollution Prevention Code Questions and Answers Member Review Draft-----January 7, 1991 ----- Page 4 Question: What is meant by taking into account community CONCERNS AND HEALTH-. SAFETYj AND ENVIRONMENTAL IMPACTS? When CMA member companies implement the employee and public outreach of the Code (Practices 4 and 8)t companies should present information about their current and past waste management practices with the goal of identifying the community concerns. Companies should consider this Input when developing plans and setting priorities for waste management and remediation activities. VVV 000011673 Return by 3/8/91 POLLUTION PREVENTION CODE OF MANAGEMENT PRACTICES RESPONSE FORM 1. We have reviewed the Pollution Prevention Code of Management Practices and have no comments. ___________ (Check only if no other comments are provided). 2. Is the purpose of the Code appropriate and/or clearly set forth? Explain. 3. Is the scope of the added practices--manage remaining wastes and releases in a manner that protects the environment and the health and safety of employees and the public--appropriate? Explain. Please return by March 8, 1991 to: Ann M. Mason Associate Director Waste and Release Reduction Programs Chemical Manufacturers Association 2501 M Street, N.W. Washington, D.C. 20037 Ann M. Mason Associate Director Waste and Release Reduction Programs oooox 1674 POLLUTION PREVENTION CODE OF MANAGEMENT PRACTICES ADDITIONAL COMMENTS CMA requests voluntary additional comments from member companies on implementation of the Pollution Prevention Code. Information obtained from these comments will be used to design support activities and other assistance for members. 1. What size chemical company do you represent (annual chemical sales)? small(<$400million) _____________ medium($400million-lbillion) ______large(>$lbil1ion) Number of facilities? Number of employees/workers at your facilities (range): C low) to (high) Company name (optional): __________________________________________________________ Are you the Responsible Care Coordinator? (yes or no) 2. Are you encountering problems implementing this Code at your facilities, and, if so, what are they? How could CMA help overcome these problems? 3. From the following list, what tools would be most useful to your company to help in implementing the Pollution Prevention Code Mark only 3. Rank by 1-2-3. ______ CMA technical seminars specific to code implementation. ______ Poster series for employee awareness. ______ Technical nhow to" Bulletins issued periodically. ______ Software system for industry trend and self evaluation data collection and manipulation. ______ WARR video for employees. ______ "Resource team" for'on-site training. ______ Clearing house for good implementation ideas. ______ Case histories of success stories. ______ Information "hot line." ______ Assistance in community outreach. ______ Regional issues/self help organization. ______ Other 4a. In June 1991, CMA plans to have four workshops to assist members in understanding the Code. Please indicate the anticipated number of representatives from your company for each workshop. ______ Houston, Texas ______ Newark, New Jersey ______ New Orleans, Louisiana ______ St. Louis, Missouri VVV 000011675 Pollution Prevention Code Additional Comments Page 2 4b. What specific topics do you want covered at these workshops? ______ Review how Pollution Prevention Code fits into Responsible Care Initiative. ______ Review implementation of added practices. ______ Review Industry Trend data submissions ______ Review Self-Evaluation Form ______ Review of topics covered in first ten practices (check appropriate boxes) ______ Management commitment _____ Inventory/measurement ______ Educate and communicate with public ______ Establishing reduction plans, priorities, goals ______ Integrate reduction objectives into product plans and process design and modification ______ Outreach to customers, suppliers ______ Other (specify) 5. What do you see as your most significant problem or barrier to full implementation of the Pollution Prevention Code (check no more than 2) ______ Management commitment. ______ Available manpower. ______ Capital/expense budget. ______ Low on plant priority. ______ Lack of policy or direction. ______ Economic climate of industry. ______ Lack of internal infrastructure to implement. ______ Lack of authority. ______ No barriers. ______ Other 6. What organizational format are you using to implement this code? (Check as many as appropriate) ________ ______ ________ ________ ________ ________ ________ ________ Full time Coordinator. Part time Coordinator. Executive level steering committee. Individual coordinators for each code. Steering committees for each code. Coordinator at each facility. Existing line organization. Existing staff organization. Other 7. Has your company established a waste and release reduction goal (e.g. 50% reduction in SARA 313 emissions by 1995)? (yes or no). If so, please tell us what it is? WV 000011676 Pollution Prevention Code Additional Comments Page 3 8. How else can we help you implement the Pollution Prevention Code? 9, As part of your commitment to Responsible Care, what can your company do to assist other companies ( including competitors, customers and suppliers) to implement this code? 10. Other comments about the Pollution Prevention Code. wv 000011677 CMA WASTE SURVEY 1990 The Waste Survey reporting obligation begins with the 1990 reporting year. Attached for your information only is the 1990 Waste Survey. CMA has simplified the existing Waste Survey. The 1990 Waste Survey contains some of the data that were included in previous voluntary requests but has been streamlined significantly. The revised format of the Waste Survey is a one-page table that provides members an opportunity to fill in the appropriate blanks. This format reflects minor changes to the type of information collected. The survey simplification includes vising two broad headings: non-hazardous and hazardous. For each of these groups the wastes are divided into solid wastes and wastewater. In addition, the list of management practices has been consolidated. VVV 000011678 90CMA Waste Survey Hazardous and Nonhazardous Waste Please complete Information on thla covarpage. Return aurvays to: Dianna Kocurek Tischler/Kocurek 116 East Main Round Rock, TX 78664 Questions? Call: Dianna Kocurek Tischter/Kocurek (512) 244-9056 CONFIDENTIAL INFORMATION Survey Information is confidential and will not be released to anyone outside ofCMAorCMA's contractor, Tischler/Kocttrek, and cannot be accessed by other CMA member companies. Parent Company Name tf the facility was purchased in 1990 from a different company, please give SELLER-COMPANY name. (This allows us to keep track of facilities and their code numbers from year to year.) Subsidiary Name Plant Name Plant Address City EPA Identification No. Contact Name Title Telephone State Zip VVV 000011679 Facility Information ri 1 Facility name............................ 2 City and state........................... 3 Primary SIC............................. 1 Generation 4 Total generation....................... 5 Site cleanup wastes................. 6 Other non-routine wastes....... 7 Special wastes........................ Management Practices 8 Material recovery..................... 9 Burning, energy recovery....... 10 NPDES...................................... 11 POTW...................................... 12 Incineration.............................. 13 Land treatment/application.... 14 Underground injection............. 15 Landfill...................................... 16 Other......................................... 17 Storage at year-end................ 18 Total......................................... ' Major Changes '9CCMA Waste Survey Non-hazardous A Solid Waste B Wastewater Hazardous CD Solid Waste Wastewater Non-ha2ardous A Solid Waste B Wastewater Hazardous CD Solid Waste Wastewater 1 Line Col Reasons for Change (using codes to the right) Codes to Explain Changes in Wastes a-production increase b-production decrease c-equipment and technicaf modifications d-procedural modifications e-reformuiation/redesign of product f-eubstitution of raw material g-improved housekeeping, training, or inventory contol h-reuse/recycie i-regulatory changes or interpretations f-other Comments YVV 000011680 Write any comments or details that you have on the wastes reported here. Continue on the back of this sheet if you need space. Introduction Under CMA's Responsible Care program, CMA member companies are required to follow the Waste and Release Reduction (WARR) Code of Management Practices. One of the requirements of the WARR code is to report wastes generated for each company facility. CMA uses these data to track industry trends, particu larly those in waste reduction. Confidentiality Survey information is confidential and is not released to anyone outside of CMA or CMA's contractor, Tischler/ Kocurek. The information cannot be accessed by other CMA member companies. Facilities will be coded in the database lor confidentiality. The report that will be prepared from the survey informa tion will have only data summaries-- no individual facility will be identified. General Instructions You will find the two forms you need to complete at the front of this packet. The forms consist of: (1) a cover sheet and (2) a sheet for waste information. Who Responds All facilities that participate in CMA's Responsible Care Program,musj?i** complete this survey. Complete a survey form for each facility--do not combine facilities on a single form. You may complete a survey for facilities that are not part of the Responsible Care program if you wish, but it is not required. Due Date Survey forms must be sent in by , 1991. It is not neces sary to use express delivery-- shipment by US mail by the due date is fine. Where to Send Send the two completed forms (cover sheet and waste information sheet) to: Dianna Kocurek Ttechler/Kocurek 116 East Main Round Rock, TX 78664 If You Have Questions Call: Dianna Kocurek Tischler/Kocurek (512)244-9058 Llne-by-Une Instructions Briefly review all instructions before beginning to get an idea of what data you will need and how to report It. You may print instead of typing your answers, but please use ink or ball point pen. Definitions Definitions are located at the end of the instructions on pages__-__ . Report all wastes in tons.Below are some conversion factors for other units. 1 ton - 2000 pounds 0.907 metric tons 240 gallons Double-Counting In the Management Practices section of the waste information form, you are asked to divide your waste into different groups like NPDES treat ment, incineration, etc. You must. choose only one of these groups for each waste, otherwise the waste will be double-counted. See the instruc tions under Management Practices for more detail. Form 1 Cover Sheet Complete the cover sheet on page__ . The cover sheet has information that identifies the facility end person to contact in case of questions. Form 2 Facility Information Line 1--Facility Name Enter the name of the facility. Line 2--City and State Enter the city and state in which the facility is located. Line 3--Primary SIC Enter your primary Standard Industrial Classification (SIC). Your primary SIC is the one that is the largest source of revenue for your facility. If you are unsure, ask your company environ mental coordinator or financial officer. If your facility is only research and development (R&D), you may enter the SIC for which the majority of the work is done. If there is no major SIC, enter "R&Da instead of an SIC. Generation yyv 00ooil681 Non-hazardous vs. Hazardous Divide your wastes into non-hazard ous and hazardous groups. If a hazardous waste becomes nonhazardous after treatment, count it as hazardous. Hazardous wastes are defined in federal regulations at 40 CFR 261 (see Definitions on page__ ). In addition, your state may have defined other wastes as hazardous. Any waste that does not fit the hazardous waste definition, is a non* 90 CMA Waste Survey Pagel hazardous waste. Solid Waste vs. Wastewater After you divide your wastes into nonhazardous and hazardous groups, subdivide these wastes into solid wastes and wastewaters. In this survey, wastewaters are separated from other wastes because wastewater is usually a large volume waste. EPA does not have a regula tory definition of wastewater, so for this survey, use the following defini tions: Wastewater--wastes that are treated in an NPDES facility or Publicly-Owned Treatment Works (POTW), injected underground, or any other aqueous waste. Solid waste--any waste that does not fit the definition of wastewater. This definition of solid waste is not meant to be the same as EPA's at 40 CFR 261.2. EPA's definition includes all wastes, regardless of physical form. Again, for this survey, use the above definitions to separate wastewaters from other "solid" wastes. Calendar Year--1990 Your answers must cover only the calendar year 1990, from January '90 through December '90. Line 4--Total Generation Enter the amount of waste generated at your facility during 1990. This will include wastes generated by normal facility activities, site cleanups, and other non-routine wastes. If you are in the ore/mineral processing business, be sure to include Bevill wastes and brine (see Line 7 instructions for more detail). Line 5--Site Cleanup Wastes Of the total waste reported on line 4, enter the amount that came from cleanups at the facility. Cleanups may come from RCRA, CERCLA, or any other remedial action. Examples of cleanups are contaminated soil and groundwater. Line 6--Other Non-routine Wastes Of the total waste reported on line 4, enter the amount that came from other non-routine activities (those besides site cleanups). Examples are: infrequent tank cleanouts, sludge removal from ponds, equipment dismantling, demolition wastes, lab stockroom cleanouts, and disposal of out-of-date stock. Line 7--Special Wastes Special wastes are Bevill wastes from ore/mineral processing (listed below, in Definitions, and at 40 CFR 261.4(b)(7)) and brine from oil and gas production. Enter the amount of these special wastes on Line 7. Be sure to include these wastes in yourtotal generation on Line 4. Bevill wastes 1--slag from primary lead processing 2--slag from primary lead processing 3--red and brown muds from bauxite refining 4--phosphogypsumfrom phosphoric acid production 5--slag from elemental phospho rus production 6--gasifier ash from coal gasifica tion 7_process wastewater from coal gasification 8--calcium sulfate wastewater treatment plant sludge from primary copper processing 9--slag tailings from primary copper processing 10--fluorogypsum from hy drofluoric acid production 11--process wastewater from hydrofluoric acid production 12--air pollution control dust/ sludge from iron blast furnaces 13--iron blast furnace slag 14--treated residue from roast ing/leaching of chrome ore 15--process wastewater from primary magnesium process ing by the anhydrous process 16--process wastewater from phosphoric acid production 17--basic oxygen furnace and open hearth furnace air pollution control dust/sludge from carbon steal production 16--basic oxygen furnace and open hearth furnace slag from carbon steel production 19--chloride process waste solids from titanium tetrachloride production 20--slag from primary zinc processing Management Practices Management practices are what you do with the waste after you generate it. Taking the amount of waste you entered on Line 4, divide the waste among the management practices you used The sum of aU the wastes that you enter in Management Practices must equal the total generation in Line 4. That means that you must choose only one management practice for each waste. vyy 00001i682 It may be difficult to choose only one practice for each waste because you may have used multiple practices to Page 2 *90 CMAWaste Survey handle it. For example, a sludge may be solidified before landfilling. See the descriptions of practices that follow for detail on choosing one practice over the other. In general, the practice last used with the waste is the one you choose. Do Not Switch Columns Do not switch columns when entering wastes. That means if you entered a waste in one column of Line 4 (total generation), then you must keep the waste in the same column when you divide the waste under Management Practices. For example, if you entered a waste under column C (hazardous solid waste), divide this waste in Management Practices only under column C. A typical problem would be a hazardous waste (column C or D) that is made non-hazardous before landfilling. Even though the waste is made non-hazardous, keep it under the same column you used to enter its generation. Balance Generation with Man agement Practices The wastes that you enter under Management Practices must balance with the wastes you entered under generation. Example: Yourfacility generated 10.000 tons of non-hazardous waste (8,000 tons were wastewater) and 5.000 tons of hazardous solid waste in 1990. You treated 7,000 tons of the non-hazardous wastewater in your NPDES facility; the other 1,000 tons of wastewater you sent to the POTW. You landfilled 1,800 tons of the nonhazardous solid waste and stored the rest. You incinerated 4,000 tons of the hazardous waste and stored the remaining 1,000 tons at the end of the year. Here's how your numbers should balance on page__ . Non-hazardous Solid Waste Tons Generation 4A. Total Generation 2,000 Management Practices 15A. Landfill 1,800 17A. Storage 200 18A. Total 2.000 Non-hazardous Wastewater Tons Generation 4B. Total Generation 6.000 Management Practices 10B. NPDES 7,000 11B. POTW 1,000 18B. Total 8,000 Hazardous Solid Waste Generation 4C. Total Generation Management Practices 12C. Incineration 17C. Storage 16C. Total Tons 5.000 4,000 1,000 5,000 Note: Notice how the same column is used within each waste group. See Do Not Switch Columns for details. Waste Piles and Surface Impoundments Waste piles and surface impound ments are considered storage--not disposal practices--In this survey. This view is taken from the RCRA hazardous waste regulations where these types of units must be closed as landfills when they are no longer in use. If you use waste piles or surface impoundments as the final disposition of your waste, you must enter it under . Storage on Line 17. Exceptions to this rule are wastewater treated in NPDES and POTW facilities. See the instruc tions for NPDES (Line 10) and POTW (Line 11) for more detail. Line 8--Material Recovery Material recovery is the reuse/recycle of a waste, except those that are burned for energy recovery. Even though a waste may be treated before reuse/recycle, enter it under material recovery. Line 9--Burning for Energy Recovery Burning for energy recovery should include only those wastes with high enough heating value (more than 5000 Btu per pound, Btu/lb). If a waste that was burned had a lower heating value, enter it under incineration. Facilities that bum wastes for energy recovery include boilers and industrial furnaces. If your waste goes to a fuel blender, indude it K it had a heating value greater than 5,000 Btu/lb. LlnelO--NPDES NPDES facilities treat and discharge wastewaters by permit. NPDES stands for National Pollution Dis charge Elimination System and is a federal program under section 402 of the Clean Water Act. if a state has assumed authority for the NPDES program the name may change slightly (for example, Wisconsin has a WPDES program, the W* being for Wisconsin). POTWs are also permitted under NPDES programs. If you discharged to a POTW, however, enter your wastewater under POTWs. See the following section on POTWs for more detail. VVV 000011683 If your wastewaterwas treated In surface impoundments at an NPDES facility, enter the wastewater under NPDES. Using surface impoundments '90 CMA Waste Survey Page 3 for other wastes is considered storage in this survey. See Waste Piles and Surface Impoundments for more detail. If a surface impoundment is used fora sludge from an NPDES facility, the sludge should be entered under Storage (Line 17) as a solid waste. Llnell--POTWs POTW--or Publicly Owned Treatment Works--usually means a municipal (city) wastewater treatment plant. EPA defines a POTW at 40 CFR 260.10 as "any device or system used in the treatment (including recycling and reclamation) of municipal sewage or industrial waste of a liquid nature which is owned by a 'State' or `municipality* (as defined by Section 502(4) of the CWA}." There are other facilities that are not city treatment plants that meet this definition, for example, Gulf Coast Waste Disposal Authority in Texas. POTWs are also permitted under NPDES programs, however if you discharge to a POTW, enter your wastewater under POTW, not NPDES. If your wastewater was treated in surface impoundments at an POTW facility, enterthe wastewater under POTW. Using surface impoundments for other wastes is considered storage in this survey. See Waste Piles and Surface impoundments for more detail. Line 12--Incineration An incinerator is a unit that is not defined as a boiler or industrial furnace (see Definitions for details). If the waste had a heating value less than 5,000 Btu/lb, however, and was burned in a boiler or industrial furnace, enter it under incineration. If the waste was treated prior to incineration, enter it under incinera tion. If you can estimate the amount of ash left after incineration, subtract this amount from the waste incinerated. Enterthe ash under the appropriate management practice. Example: You incinerated 500 tons of hazardous solid waste. Ten (10) percent of the waste remained as ash. The ash was solidified, then landfilled. Enter 50 tons of ash under hazardoussolid waste-landfill (Line 15, Column C). Enterthe remaining waste, 450 tons (500 minus 50 tons), under hazardous-solidwaste-incineration (Line 12, Column C). Une 13--Land Treatment/Application Enter the amount of waste that was treated in or applied to land. If the waste was treated prior to land treatment/application, enter it under land treatment/application. If the waste was removed and disposed in a landfill after treatment, enter It under landfill. Line 14--Underground injection Enter any waste that was under ground injected. If a waste was treated before injection, enter it under injection. Line 15--Landfill Enter any waste that had landfill as its final disposition. If a waste was treated before landfilling, enter it under landfill. Line 16--Other Enter any waste that does not fit in any other category. These wastes would not fit any of the other listed management practices (recovery, NPDES, POTW, incineration, land treatment/application, injection, and landfill). Remember that you should considarthe final disposition of the waste before you enter It under Other. For example, H you dewatered a sludge before you landfilled it, enter it under landfill. Example: Practices that could be other: 1--Explosives that are detonated 2--Open burning of wastes 3--Wastewater treated and returned to process with no NPDES permit required Une 17--Storage Enterthe amount of waste that remained in storage at the end of 1990. Waste piles and surface impound ments are considered storage--not disposal practicas--in this survey. This view is taken from the RCRA hazardous waste regulations where these types of units must be closed as landfills when they are no longer in use. If you use waste piles or surface Impoundments as the final disposition of your waste, you must enter it under Storage. Exceptions to this rule are wastewater treated in NPDES and POTWfacilities. Seethe instructions for NPDES (Line 10) and POTW (Une 11) for more detail. vVV 0000116^ Line 16--Total Add the numbers in each cojumn and enterthe total on Line IB.^neseTotals must be the samejas the total generation on Line 4 for each column. If they are not the same, you have made an error and must correct your numbers. Page 4 90 CMAWaste Survey If the total on Line 18 is greater than the total generation on Line 4 (and your math is correct), you may have made either of these two mistakes. Balancing Errors 1--you chose more than one management practice for a waste (you double-counted) 2--you carried over waste that was in storage at the beginning of 1990 If your mistake is carrying over waste from previous storage, you need to subtract this waste from your manage ment practices. Make a reasonable estimate If you do not know exactly. Major Changes Major changes in your generation or management practices affect data trends used to track industry perform ance in waste reduction. Therefore, it is important that you explain these changes. A good example of a major change for 1990 is the definition of Toxic Characteristic (TC) organic wastes as hazardous. Use these rules to identify major changes: Solid Waste--if a change from the previous year is 50% or 10,000 tons Wastewater--if a change from the previous year is 50% or 1,000,000 tons You are given codes for changes on the form on page__ . Use as many of these codes as you need to explain changes from the previous year. For each waste group that had a major change, enterthe line and column numberfromthe Generation or Management Practices sections, then enterthe codes explaining the changes. If a change in your waste does not meet the rules above, but you consider it important, you may enter it also. Comments Use this section to write any com ments or details that you have on the data that you have entered. Definitions These definitions are of a general nature and are only for the purposes of this survey. Interpretation and compliance with local, state, and federal regulations is the responsibility of the reader. BevHI Wastes--any of the following 20 wastes from ore/mineral processing, listed as solid wastes by EPA at 40 CFR 261.4(b)(7). 1--slag from primary lead processing 2--slag from primary lead processing 3--red and brown muds from bauxite refining 4--phosphogypsumfrom phosphoric acid production 5--elag from elemental phospho rus production 6--gasifier ash from coal gasifica tion 7--process wastewater from coal gasification 0--calcium sulfate wastewater treatment plant sludge from primary copper processing 9--elag tailings from primary copperprocessing 10--fluorogypsum from hy drofluoric acid production 11--process wastewaterfrom hydrofluoric acid production 12--air pollution control dust/ sludge from iron blast furnaces 13--iron blast furnace slag 14--treated residue from roast ing/leaching of chrome ore 15--process wastewater from primary magnesium process ing by the anhydrous process 16--process wastewater from phosphoric acid production 17--basic oxygen furnace and open hearth furnace air pollution controidust/sludge from carbon steel production 18--basic oxygen furnace and open hearth furnace slag from carbon steel production 19--chloride process waste solids from titanium tetrachloride production 20--slag from primary zinc processing yyv 00001168i> Boiler--an enclosed device using controlled flame combustion and having the following characteris tics: (1) recovery and exporting of thermal energy, (2) combustion chamber and primary energy recovery sections of integral design, (3) thermal energy recovery efficiency of at least 60 percent, and (4) use of at least 75 percent of the recovered energy. This definition is summarized from the RCRA hazardous waste regulations. For more detail, see 40 CFR 260.10(a). CFR--Code of Federal Regulations Facility--A site used for chemical manufacturing, processing, refining, packaging, research and development, distribution or related commercial activity. ' 90 CMA Waste Survey Pages t Hazardous Waste--a waste meeting the definition at 40 CFR 261.3. A waste is either characteristically hazardous or hazardous by listing. There are four groups for characteristically hazardous wastes: ignitable, corrosive, reactive, and toxic. Listed hazardous wastes are wastes from specific processes or wasted chemicals. See 40 CFR 261.3 and 261.21-33 for more detail. immobilization of metals. Landfill--a disposal facility where waste is placed in or on land and which is not a pile, land treatment facility, surface impoundment, underground injection well, salt dome, salt bed, underground mine, or a cave. Non-hazardous Waste--a waste that does not meet the definition of a hazardous waste. product, or as a substitute for a commercial product. Solid Waste--any waste that does not fit the definition of a wastewa ter in this survey. Note that this definition is for the purposes of this survey and is not meant to be the same as EPA's all-encom passing definition of solid waste t 40 CFR 261.2. EPA's definition includes solids, liquids, and gases. Incinerator--any enclosed device using controlled flame combustion that is not defined as a boiler or industrial furnace. Industrial Furnace--anyofthe following enclosed devices that are integral components of manufacturing processes and that use controlled flame devices to accomplish recovery of materials or energy: 1--cement kilns 2--lime kilns 3--aggregate kilns A--phosphate kilns 5--coke ovens 6--blast furnaces 7--smelting, melting, and refining furnaces B--titanium dioxide chloride process oxidation reactors 9--methane reforming furnaces 10--pulping liquor recovery furnaces 11--combustion devices used in the recovery of sulfur values Irom spent sulfuric acid Land Treatment/Application-- placement of a waste onto a soil or incorporation into the soil. Treatment is usually biological degradation of organics and NPDES--National Pollution Discharge Elimination System. A federal program controlling wastewater discharges under section 402 of the Clean Water Act. A state may have assumed authority for the program. POTW--Publicly Owned Treatment Works. A POTW is usually a municipal (city) wastewater treatment plant. EPA defines a POTW at 40 CFR 260.10 as "any device or system used in the treatment (including recycling and reclamation) of municipal sewage or industrial waste of a liquid nature which is owned by a `State* or 'municipality' (as defined by Section 502(4) of the CWA).* There are other facilities that are not city treatment plants that meet this definition, for example, Gulf Coast Waste Disposal Authority in Texas. Recycle--a practice that regenerates or processes a waste from a process to recover a useable product or material for reuse. Reuse--a practice that usas a waste from a process either as an ingredient in a process to make a Special Waste*--Bevill wastes from ore/mineral processing (see Bevill wastes in Definitions) and brine from oi! and gas production. Treatment--a practice, otherthan recycle or reuse, that alters the physical, chemical, or biological characteristics or the volume of a waste separate from the produc tion of a commercial product or the provision of a service. Underground Injection--the injection of waste through a bored, drilled, or driven well; or through a dug well, where the depth of the dug well is greaterthan the largest surface dimension. Waste -- any gas, liquid, or solid residual material at a facility, whether hazardous or nonhazardous, that is not used further in the production of a commercial product or provision of a service, and which Itself is not a commer cial product. Wastewater--wastes that are treated in an NPDES facility or POTW, injected underground, or any other aqueous waste. VVV 000011686 Page 6 190 CMAWaste Survey