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Corinmonwealth of Massachusetts

Executive Office of Environmental Affairs

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UECUTlVE OFFlCE ol ,,,.,,,, Office of Technical Assistance

A Practical GuideTo Toxics Use Reduction

Benefitting From TUR At Your Workplace

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A c k n o w l e d g m e n t s

O 1992. The Office of Tcchmcd Assistancx for Toxics Use Reduction, Executive Office of Environmental Affarrs. Commoawdth of Massachusetts

This document was ~ ~ U I X I by T a l b Brew- for the Office of Te~hnical Assistance. The following documents have been kdu l sources of i d t z and informatiion:

-The Toxics Use Reductloo Inrtimte. Use R-

-The Oregon kpemart of hvucmmeotzl Quality. B c n c f i W o m Toxic Substance and w o u s w m

15uide to Pobtion Prc -The Minnesota Offvc of W r c v Managarrent. M-ota v e n t i ~

-The Alaska H d t b Rojcs~ Wastc w u In Your Small Business . .

-Various maunrk oa the tinmcul d v s o of TUR projects prepared by Marlene R. Wittman for OTA and tbc Nmbas; Wasu Managancot Officials' Association (NEWMOA).

OTA would Il+r7 Wre LO bank Qc fd lovmg businaspsons. public officials and environmental spccihtr for rrwcwmg and mahng bclpful urmmcnts on carlia drafrs of the manual: Larry Atupan and W d l m L d q a of Neks Jauurbrtry. Robert Chatel of Tbe Robbins Company, Ken Gxa of TUTU. HtUel G r a y ol M-PIRG. kchard Hcrrinj; of the Gloucester Corp.. Ed Jamro of Morumro. S u v c Jcqcman Jr. of M v - Rltmg. Donald Irith of Lgd of New England. George has of Envuaunp. Ray O'Cuuwll of ,AT&T. Suzi Pock and Alissa Katz of DEP. Dr. Robm Pojasek of GEI Coadtanu IDC.. Scar Rmr~ter of Lampin Corp., Peta Szwaja of Aerovox. and Bob Tutunjian of Yamad M d Frarhrng Corp.

Second p M g . 1% Rcgukocos pmmulgatcd after the Eust prinung have been appended. Third printing. 1995. Tbu mfonnu*a u r v u l a b l r lo d m a t e fo~mau upon request

Execunvc Office of En-& Aflam Commonwealth of M l u w b w c n s 100 Cambndgc S m R o a n 21CN Boston. MA 02202 (617) 727-3260 fax (6171 727-3827

The airn of this mariual is to help businesses develop and sustain Toxics Use Reduction (TUR) pirograms which will make sense both in terms of corporate profits and environmental protection. The manual is intended to help industry reduce or eliminate the use of toxics andlor the generation of toxic by-products at the s,ource, before they have a chance to endanger public health and the envirorunent.

This manual i!; designed for the use of all Massachusetts institutions which ilse toxics - both those which are required to do TUR planning by

Tol6cs Use Raducmon otcar makes sun4 borh in terms of Massachusetts Geneml Laws, Chapter 21 I, the Toxics Use Reduction Act of corporate pmfm and 1989 (7ZTRA), and hose smallquantity toxics users not covered by the law. env~mnmenui promcuon. The mznual should prove particularly useful as a do-it-yourself guide for small

and mid-sized firms which lack in-houseTUR expertise yet wish to launch TUR p r o p n x .

The manual has been developed by the state Office of Technical Assistance and reviewed by businesspersons, environmental specialists and others. Our hope is that it will serve as a tool for sharing the valuable lessons derived from the hands-on experience of OTA and these business leaders.

In writing this manual. we have sought to create a document which will prove useful in the everyday work of manufacturing professionals. To this end, we have included practical step-by-step guidance to all phases of TUR, from setnng up a TLR team and setting corporate TUR goals, to identifying, assessing and implennentrng changes which will reduce industrial toxics at the source. Where possible. we have included charts and worksheets designed to save labor and sumd ine the TUR planning process.

At intemals throughout the manual, we have included case studies of actual TCiR activities at Massachusetts businesses. These are included for purposes of illusrmaon only. Mention of any particular equipment or proprietary tcfhnolog~es does not represent an endorsement of these products by the state of Massachusetts nor an assertion that they are appropriate for every process.

How Tb Use This Manual

Each business uill come to this manual with different needs and different levels of' expertise. :For instance:

+Thost! wbo have no previous experience with Toxics Use Reductionmay wish to begin with the mtroduaory Chapter 1 and work their way through the manual sequentially.

+ Thost! who already lknow the basics and are ready to begin launchmg a TLTRprogram may wish 10 cfispcnx with the introductory Chapter 1 and start with Chapter 2.

Those who have bad extensive experience with TUR may find it most convenient to meat the manual as a reference wl. u m g the handy tabs to find ready infoxmation about the particular phase of TLX planmug in whch they are engaged.

The Executive S a m m q provides a handy chapter-by-chapter guide to the manual's contents, and each duper opens with an outline and overview statement which should firrther increase ease of aces. .

The manual includes a number of appendices on reIated topics. The OTA's s=fl of .ogln-n and appendix on the cornonwealth's Toxics G;k Reduction Act explains how the - - lagal and financnl axpam SUMS ready o~ ass~sr general p d e l l n e s presented in this manual relate to the specific requirements Massachusam b u s ~ n u s a s in of the law. Infoxmanon about the requirements of TURA C a t l also be found any m y posseble. in the body of the manual, fl,agged by the words "TURA NOTE". This

information on TLaA should not be viewed as definitive, as this text was written before the regulations were pronnulgated. The regulations (310 CMR 50.00) are included as the Addendum at the end of this volume. Up- to-date informatioa on TtW can be obtained by contacting the Depart- ment of Environmental R o t d o n at (617) 292-5982.

The find appcn&x provldes an annotated bibliography to a wide range of technical. tndustry-specnfic information about Toxics Use Reduction. Many of these dcxntmcnts can be o b u ~ n e d by contacting OTA, which maintains a comprehensive T7JR lib-

WhereToTurn For Help

No manual. how- er weli-conceived, can answer a11 of the questions and problems u411ch might an= In the complex task of TUR planning. OTA's staff, incorponnng e n p n m n g , scientific, legal and financial expertise, stands ready to s ~ s t S i ~ h i ~ ~ e t t s businesses in any way possible. If you have questions or commmts, please call us at (617) 727-3260.

Table of Contents

Executhre Summary ..-.. -. ....................... 7

Chapter I: Answering Basic Questions about N R ..-- ..-.... I I ................................................................ 1.1: What Is Toxlcs Use Reduction? 12 . 1.2: W, hy Should Your Business Pursue TUR? .......................... ... ............ 15

...................................................... 1.3: What Does Thc Law Say About TUR? 16 ................................... 1.47~hat Is OTA and How Can It Help Your Business? 19

? Chapter- 2: Getting Smrted .- -..... - .....-........ .... -- ..-....... 2 I

........................................................... 2.1 : Developing a TUX Poiicy Statement 21 .............................................................. 2.2. Organrzlng a TUX Planning Team 22

2.3. kttmg TL!!Goak ...................................................................................... 25 ................................. 2.4. Or-g Your X J R Efforts: The TUR Flow-Chart 26

............. ....... Chapter 3: Characterizing and Analyzing Processes ....... 29 ........................................................ 3.1. Gathamg and Organrzmg Idonnation 29

........................... 3 2: Choosmg S u b s t a n ~ ~ ~ ~ h c t s s e s for Focused Examination 32 ......... 3 -3 : Cn-g Proces Row hagrams and/or ChemicaI Pathway Analyses 36

..................................... 3.4. Emmaang B)products With Materials Accounting 40 ........................................................... 3.5. Caaducung a Facllrry Walhhrough 44

Chapter 4: Idendfylng TUR Options .- ...-........ ...- .........-....... . 47 4.1 : In-House B m m g .............................................................................. 47 4.2. Thr: Su Kmds o f ' n X ................................................................................ 49 4.3. Co~mmm TUR Fkncrples and T e h q u e s ............................................. 58

............................................................................ 4.4. Bnnglng In OumtJc Help 70

Chapter 5: Evaluating and Selecting TUR Alternatives .......... - ........ 91 ........................ .............................................. 5.1. Sutenmg TUR Opnoas ... 73

5.2. T e t h c a i and Manqenal Assessment .................................................. 74 ........................................................ 53 : Financial Asxsarrent of TUR Options 76

5.4. Se l~cmg and S c c h g Approval for TUR Proposals ................................... 88

.... .... Cha.pter 6: lmplemendng P m j e & Tacking Progress ..-... 9 1 ....................................................................... 6.1 : Impkmenang TL'R Chnges 91

62: Me.asunng TUR Progress ............................................................................ 93 6.3. Dotsumentmg TLX Accompkbments and Sustaining Commitment ............ 97

Appendbt I: N R A Requirements and This Manual ..-. . ..-. - ... I 0 I A1 . 1: llhe T L J Basics .................................................................................. 102 A1 -2: TURA Reporang Rrqutrrmentr ............................................................ 104

............................................................... A1.3: TURA PLannzng Fkqulrements 108 .............................................. A1.4: k e h n g Further Lnfsnnanon about TURA 112

Appenduc 2: GI- of N R Terms and Acronyms ..-............-..... 1 13

Apptndbc 3: Bibl iomhy of N R Resources .... ................................... . 119

Index -- ...-.....-......................................... 129

Addendum: 3 I 0 CMR 50.00 Toxia Use Reduction

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t xecut lve Summary

A Ton- Use Reduction progrun a n help your fim a, improve pmducrion efficiency. cur chemical purchase and dirpoul corm. lower liabiiig riala. improve worker hutch and safecy. raduce regulatory f o ~ and ease compliance headaches.

Chapter I: Answering

Toxics Use Reduction

Basic Questions About

Toxics IJK Reduction n a promising new approach to the management of toxic materials. It has bem lrsed by busrwsscs in Massachusetts and around the counay to reduce emissions of enwlonmentally harmful toxics while often resulting in a boost in profits.

Essa~nally. TUR refocuses antntion away from trearment of toxic wastes which have &re- ken produced and toward the elimination or reduction of toxics at the point of production Because n deals with toxic substances at the source, before they have a chance to beconw pollrrtants a coataminants, TURrepresents the most enviro~lentally responsible approach to Ibe mauagement of indusuiai toxics.

The 2um of cb manual n to help Massachusetts businesses in a variety of indumies to launch successful d t m a ~ f i m v c TUR programs. Such aprogram can help your firm to improw produaon dficmcy. cut chemical purchase and bposal costs, lower liability risks, icapruvc w o k ! health aad safety, reduce regulatory fees and ease compliance headaches

Thrs amnd IS a h h p e d to provide general guidance to businesses subject to the planntng; rrqurrrmeno of (MCL Chap. 21 I) the state Toxics Use Reduction Act (TURA). TUR.4 plzanmg rrg~~~,.meoo applv to all businesses whch meet all three of the following Critcna:

Empky the equivaknt of 10 or more full-time employees ( I employee = 2.000 work h o u d y w ) .

M I ~withirr Scandad IndurtrW Classifition (SIC) Codes 10- 14 (mining); 20-3'9 (nun- 1 0 . 4 4 4 9 (tr;msportzation, communications, gas, electric md ~ c e y wr*ica); 50.5 I (wholesale trade); and 72. 73.75. 76 (cerrJn rcviclr).

Process or rnanuktun at least 25,000 pounds or otherwise use at least 10,000 pounds of w e s reguhted under T i l e Ill of the federal Super- fund Amendment and Ruuthorization Act (SARA). From 199 1 to 1993, the arct r+. cxpMdrd m u a l l y to include all substances regulated under the f;dd Com(wdwrrure Environmental Response and compensation Liability Act (CERClAr

The xnaaual has bcen prrpared by the state Office of Technical Assistance - a non- regulatorr. sup ofice WW pnpose is to assist Massachusetts industry in its TUR efforts. OTA. wihcb IS funded ty tbc natc TURA fee. has worked with several hundred Bay State businesses and promled coacrcte TUR rccommendanons to more than 300 firms. Infoma- tion aborn OTA 'I aonkmccs, workshops. free and confidential site visits and other techical assistantx m c c s can k obmrned by writing to: Office offechnical Assistance, Executive Office of Eov i roomen~d Afiairs, Room 2109,100 Cambridge Street, Boston, MA 02202 or by d l h g OTA at (617) 727-3260 during business hours.

Chapter 2: Getting Started

Sometimes, TUR ideas can come to light immediately, with little pianning or deliberation. More tpically. successfui TUR requires a sustained program spearheaded by an active TZTR planning team. T ~ I S manual is written with the neecls of such a team in mind - though pomons of it can be used by hose who are interested in a less formal approach to TUR.

No TUR team can succecd over the long nm without support from top management. One excellent way to express this support is for management to issue and public*& a statement

NO TUR team a n succeed of its commitment to TUR T l u will also help to build1 awareness of TUR among workers. me. ths long N n *ndxwn eha Once management has commiaed iwlf to TUR, the next step is to create a TUR team. a~~ supporn of m p managc Members ofthe team should be Qawn fbm all sectors of your business. Such adiverse team ment. udl be in an i d d position to g m tbe sort of comprehensive understanding of production

processes needed for dfecnve TUR One of the firs tasks your TUR team d l face is tht: setting of TUR goals. These goals

may have to be aattd m a provisional and rather general way until more research is done into TUR options. Eventually. .your TUR goals should provide a specific quantified statement ofthe short- and lmg-term ndumons m toxics use and/ortoxic by-product generation which you intend to ackuevt.

Chapter Characterizing Analyzing Pro- cesses

One of the keys to successful TUR u gazxung a detailed and comprehensive picture of your chemical use patums. Such lnfamaoon serves as your primary tool for pinpointing wasteful practices. identifying SI;R oppahrmnes. aod calculatmg the costs and benefits of proposed changes.

Perhaps the best place to aan u to p m a general overview of all chemicals which enter and leave your prrrmscs. Thrs can be done by creating a "Chemical Inputs Database" charaaeri2ing the chaxucS your plant consumes ancl a ''Chemical Outputs Database" charaaeri2ing your plax~t's emlrzrocls.

With these two darabases m hand, you will be in a position to focus your TUR research on particular produrnon prcxcsus It IS usually best to rzirget processes which account for a large or pamcularly rouc porno0 of your wane strean.

Once you have focuscd your anaram on particular production processes, you should d q r a m them in such a way as to den* all of the poine; at which toxic substances are lost as byproducts. Th~s must bc done before effective steps can be taken to minimize losses, yet these byproducts are not always easy to spot, as they tm include not only major waste streams, but also krs tangble losses such as spills, leaks, evaporated liquids, spent chemicals, unusable raw mnals . unusable products, and wastes fiom cleaning and mmtenance procedurrs.

These various by-products can be pinpointed witti "process flow diagrams" and "chemical pathway analyses". Process flow d q m m s graphically derail each step of your targeted producnon pmcasa and show the byproducts produced by each stage. Chemical pathway analyses show the path of particular toxic chemicals through these processes.

The firla1 analytical step is the use of rudimentary materials accounting techniques to esamate the magnitude of tach toxic byproduct. Once your analysis is complete, your team can conduct a fonnal uiallahrou@ of your production kil i t ies in order to check the informanon you have collected and begin brainstorming about process changes whichmight reduce reliance upon toxlcs.

It is important to k e q in xnind that the process of gathering data is intimately linked to the process of idcntifylng TUR opnons. The information you gather should indicate to you where toxics arc bemg 10% and each loss provides an opportunity for TUR Often, TUR options will betome apparrnt once you have identifiedthese losses. It might be wise to have

~ h t mom TUR opdom YOU each TLJR pam member keep a notebook during the information-gathering stage in which

comider. dm more likely you to fec~rd 11- about T ' R opaons. a r e m ~ ~ c h s o n d n r b bsrr for your phnr

Chapter 4: Identifying TU R Options

At t . h ~ ~ porn!. your T C R plammg effons enter the creative phase. The object of this phase is to draw up as complete a k! as possible of alternatives for reducing or eliminating your w of tou~c substanccs a d o r your generation of toxic byproducts.

Perhap; th ben way to draw up such a list is to hold a group brabtorming session designed u~ehctt rnplt from as many team members as possible. This will guarantee that your list of TUX opaons wdl reflect a tanety of perspectives and areas of expertise.

Your bvastonnmg can be aruuured to insure that your team considers all six generic types o f n J R produu reformulaom. laput substitution, process redesign, process modern- ization ~m.poved operanoas a d mamrenance, and in-process recycling or reuse.

Of cw-se. n IS aot a necessary to go through a fonnal options-generation process such as the brarnnonnmg vss~oo described in this chapter. You may already be convinced that you blow what nctdr to be done. or you may find that some common TLJR technique or technology - such as solvent rubmtution, metal recovery, drag-out management, chemical llfe exunsron. oQumal process control, or improved storage and handhg - isappropnaIeforyourbmcsr

Howevtr. th most r ) r p ~ d rmsuke at this phase is to settle for an inadequately small list of options. Keep m rmod tha! rh more oprionr you conrider, tk more Iikelyyou are to select he one tku u bccrfor yovr $a.

If your in-house p e ~ a n c l Lack sufficient f a m i h t y with TLJR techniques and technolo- Des, you may wlsh to supplement your brainstorming session by contactmg aade associa- tions and uoduury collagus, conducting some t e b c a l research, or soliciting help from vendors and consultants.

You may also W&I to enroll one or more of your team members in classes on TUR pia,mmg. lJndtr nau law. tbt University of Massachusetts at Lowell has been chosen as the a ' s T o n u Cse Rtducnon L n s t r ~ ~ 0, and has been charged with training industry employees in TUR plannmg. More ~nfonnation about TLTRI's classes can be obtained by w r i ~ g to: To& Use Reduction Institute, University of Massachusetts at Lowell, One University Avenue Lowell, MA 01854; or by calling (508) 934-3275.

Alternarlveiy, you can call upon OTA's TUR specialists to visit your plant, study your production processes, and submit recommendations. You can reach OTA at (617) 727-3260.

Wrrh che nght comb~mmn of enshurtarm and surca~ned comrnlrment your TUR team a n slowly butld corponob a& awarenas of T U R as a rsrpons~ble approach oo indusmal coxta. whllc mabng concrete producoon- bne changes wch a postwe impla on the ennrorunont

C h a p t e r A l ternat ives

Evaluating and Select ing T U R

Once your team has generavd a comprehensive list of TUR alternatives, the next step is to evaluate those optlons and select the best one(s) for implementation.

It is important to make your evaluation as comprehe:nsive as possible by anticipating the possible effects of possibk production changes on all aspects of your business. 'Ibis can be done by using a series of "screens" to set aside those options which are not technically or financially feasible. orwhch might haveadverse effectson worker healthorthe environment.

Usingthese -. your team can begin witha long list oiTURalternatives, quickly weed out the bad ones. and narrow tht field to those which fit lbest with yourtechcal capabilities and capital budge.

Once the most prormsmg opaons have been identified, they can be subjected to a more detailed assessment of theu uchcal and financial meriit, as well as their possible impact on work practices d bunncs goals.

An a d e w f i n a n d aodysu of a TUR project requires an evaluation of as broad arange of costs and benefits as possible, mdudmg some costs which are routinely lumped together under the geacnc hadmg 'ovdxad'. Sometimes, TUR projects with hgh upfiont costs can pay for themselves qutckly by reducing costs of.purch.asing raw materials, treating and wring of touc bqmduas. and complying with envlironrnental regulations.

Once all these coN haw been weighed. the most amxctive option(s) can then be chosen for implementanon.

Chapter 6: Implementing Projects and Tracking

Progress

The implementmoo of a nTt pojea may involve worker retraining, process redesign, procurement of new qupmcnt . umdkmon work, product research and development, or even constmaion of new manufacrunng facilities. These changes must be carefully planned for in order to wrdrnatc rhe efforu o fd l departments and all personnel involved in the change.

The implemcntatloa process does nor end when the new equipment is ~nstalled and/or the new work pracnccs arc m place Successful implementation means makmg the change workable and permanem Your n R team can improve the odds of success by staying in touch with all affected workas. k e e p q abrcan of difficulties and handling any snags h c h arise. One of the most c n u d elements of this follow-up work: is to measure your TUR progress.

Such measurement wll help YOU to document your successes and failures, learn from your experiences, and gam tht sort of data needed to gain approval for future TLTR projects.

Once your team has camed out its first TURproject, it is importantnot to lose steam. Each of your TUR prqects should provide the sort of experience needed to make your TUR team more knowledgeable and more efficient. With the right combination of enthusiasm and sustained commrtmcnt. your TUR team can slowly build corporate-wide awareness of TUR as a responsible and con-effecnve approach to industrial toxics, while m a g concrete production-he changes wth a posinve impact on the environment.

Chapter I : Answering Basic Questions about TUR

1 .O: Toxics Use Reduction -- An Overview The Aluminum Processing Company, a Fall River-based subsidiary of Lighto-

Iier-Genlyte Gmup with about 250 employees, replaced a vapor degreasing pmccn which used toxic Dichloroethylene (TCE) with a non-toxic aqueous degrslring prpcerr. reducing TCE use by 80% while realizing a net p d i of approximatety 5 100.000 over the lifetime of the p r o j e

The I Il O-unployee Kilmutin Tool Company of southeastern Massachusetts puniped frcon out of its degreasen and into sealed containers after each use, cutting its kuses ofozone-depleting chlorofluorocarbons (CFCs) by 83%, while saving $5.000 per year in Freon costs.

The RtDbbim Company. a Wassachusettsbased jewelry manufacturer and plating company with about 350 workers, used readily available meml redamation technology to cut its chemical usage by 8 1.8%. reduce its toxi~c waste generation by 89%. recycle water, and realize annual savings of $7 1.000 - recouping i t s initial investment in less than two yea=

What do these cornpama have m common? They have all pursued a new approach to toxic indmla l byproducts wbcb goes by the name "Toxics Use Reduction" (TUR).

TLTFt is a prormslng new approach in industry thinlung about the use of toxic materials. In essence, n refocuses ancntlon away fYom the treatment and disposal of toxic wastes which have already been produced, and toward the eliminntion or reduction of toxic substances within the production process itself.

Ths refocusing of anention was initiated in 1975 by the 3M Company, which estimates that its worldwide Pollunon Prevention Pays (3P) program has saved it over $537 million whde preventing more than 577,000 tons of pollutants and 1.7 billion gallons of wastewater. In the tnurvenmg yean, 3M's ideas have been embraced by many Fomme 500 companies, includrng DuPont, Dow. IBM. GE, Chevron and the like. Here in Massachusetts, such busina;ses as Monsanto. Digtal Equipment Corporation, W.R. Grace, Polaroid, Raytheon and Texas Insnuments have led the way by launching their own pollution prevention

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JO 3uqm atp qp~ ~le~: rprqfi sa%mcp ssd iuem 3-d pm 'sm&o~d

A succasful N R prognm requires a comprehensive axaminatton of manufacturing p m c u s u and a derailed assessment of the cosu u r w a t d rrich che use of various toxic materials.

TUR also mproves upon other more uachional approaches to environmental control with its h d "multi-m&" scope b b l e traditional pollution control may reduce emissions into ooe mehum. such as the m or the w a r , it often does so by shifting the burden to another mednur~ Such burden-shbg does not count as TUR.

It K 1301 TLU for mstance. to capture a toxic air emission with filters which themselves have to be Landfilled for h does not elrmlnate the costs, regulatory headaches and liability concans associated uatb mxlc wastes. nor does it eiiminate the environmental threat posed by the toxlc substance - ~t ml y shfts the threat from the air to the land. On the other hand, a proceri change wbch reduced or elrminated the use o f h s same industrial toxic would be an exaniple of TUR

B e a u x TLX f m w s oo the use of toxic marerials, a successful TUR program requires a comp~rhens~vc exammanon of manufacturing processes and a detailed assessment of the costs asmaaed u ~ t h tbe w of vanous toxic materials. TUR planners must gain precise knowledge of t h m facihry's processes and operations, and they must consider, evaluate, select arid mplement changes auned at reducing reliance upon toxic substances. l k s manual provides a p ~ d e to dl p k u a of the TUR plannmg process. It introduces a variety of analyucd tools for assesung manufacturing processes and weighmg the costs of alternative processes.

It should be w u d . however. that because TUR requires creative thmkmg about the specific pn>ctsses and tcchnologles appropriate to each manufacturer, the TUR planning process cannot be reduced to a handy, foolproof formula. As a result, thls manual should not be seen as a guamnteed stepby-step gulde to TZTRsuccess. The t echques inhsmanual will have to be supplemented by a thorough and creatlve exploration ofthe alternatives open to your company

FIGURE I A: TUR TERMINOLOGY:

"Toxics Use Reductionw IS one of a family of related tenns. all of which refer to the prarnce of refonnrng manufacturing processes so as to prevent toxic byproducts or reduce toucs use. TUR encompasses in-plant changes which reduce or eliminmr tbc w of toxic m n a l s or the generztion of toxic by-products, so as to reduce risks to the health of workers. consumers, or to the environment, without merely shrffing mks ammg workers, consumers, or parts of the environment.

1 *Pollution Preverrtion Accordmg to the most recent EPA draft palicy stzte- mats , polluma prevtllnoo IS: %e use of processes, practices or products that reduce or elunume tbc p e r a n o n of pollutants and wastes or tbar protect nanrral resources thmugb camm?u1oa or more efficient use." Pollution Prevention is slightly broadcr than TLR IC mdudes agriculture ;and transporrarion, and focuses attention oa nducmg me gtaeratloo of pollutants rather than on reducing use.

Wutc Minimincioo Thu m. used in the: federal RCRA legislation, is broader than Pollunon Rc~rnt lon or Toxics Use Reduction, covering TLJR as well as the off-sltr reqdmg of w-s and b e treatment of wastes once they have been genemd . Waac hhumuanm apphes principally to solid wastes.

S o u m Reductioo. Thu term. which is close in meaning to TUR, is defined under the fcdcral P d u u o n hmnm Act of 1990 as "any p m c e whch - (i) reduces the amount of t l l v substance, pollutant or contaminant entering any waste sueam or otkmtrc rtlcscd into the environment (including fugrive emissons) pna to w d m g . ucsment, or IrJlsposal; and (ii) reduces the hazard to public he& Hd tbc en\rroamcnt arsoclated with the release of such substances, pollutants ar amrammsln '

Bewux TUR u arndn-mcduapproach lo pollutialn, it has alsogiven rise tosome confusion m the appmpnur \c~&ulary for indusrrial pollutants. Td t iona l ly . *dischargew has ;omacd a uaurwater pollutant, "emission" an amospheric pollutant. and % w e g a pollutant & m e d for a landfill or incinerator. TURA ins t l~ tes the followmg acu usages. wbch this manual will follow:

Byproduct: Any loxlc substance w d or mated during the production process whlch does not erad up m thc product - whether it be solid, liquid or gaseous. If the "byproduct" IS mused as IS wthout processing or treatment, it may be regarded as produa.

Emission: h v toxlc subsmice whch leaves the facility and is not part of the product - whether ~t be &me, liquid or solid. and ,whether mated or unmated. Even if mattnals art sect out to be recycled elsewhere, they count as emissions.

CHAPTER I : ANSWERING BASIC QLIESTIONS ABOUTTU R...

1.2: Why Should Your Business Pursue TUR?

In 1986. flassachuserts bur~nasra produced approxi- macdy 250.000 cons of hanrdous warms. and spanc m uurnared $76 mlliion m manage and daposa of chore a m . Slnce chan. hazard- ous warm mnspomuon a d disposal coso have oniy climbad.

The elimination or reducnon of workplace toxics has always made good sense from the point of view o~f workcr safety. public health and environmental protection. In Massachusetts, where hxardous waste dsposal facilnies currently have an inadequate capacity and access to out+f-nau dsposal fachaes is increasingly limited, TUR is an essential element of any responsible hazardws waste policy. Many businesses have been moved by these critical concern to initlate TUR p m g r a ~ ~ s .

%re cut also powerful haom-line reasons for pursuing TUR projectr. In recent years, trearmenr and cfisposal costs for hazardous wastes have risen, while regulatory fees and paperwork aaoclattd with toxic materials have become increasingly steep. In 1986, Massacfiulvm businesses produced approximately 250,000 tons of hazardous wastes, and spent an eaunattd $76 &on 10 manage and W s e of those wastes. Since then, hazardous waste oar~sponanon and drsposal costs have only climbed.

Simultaneously, federal Superfund legislarion has made businesses which generate b a z d c w i wastes poantlally W l e for the full cost of any clean-up which may become necessap ar dsposal s~vs whch they have used. Woburn, Massachusetts was recently the nte of tbc hpea Superfund settlement in New England -- a case whch cost four businesses a total of S i i d l ~ o n . Buslnesses have also been hit with large fines and suits for accidental releases of toua and for worker halth problems arising from exposure to toxics. The resuIt is that busmesxs ukcb connnue to produce large quantities oftoxic wastes incur steep day- M y m w and expose tbcmselva to tremendous financial risks - risks whch they often hd to ap~lrcclav fully until the day when an accident happens.

Agamt the backdrop of the m g costs and liability exposure associated with the use of hazardcnrs maumah. l a has begun to make increasing sense h m a purely economic point of vlew to invest m almnam-e substances and processes which reduce reliance on industrial toxlu. wtrertvtr possible b y 7 t r R changes require little capital and are relatively simple to carry cut. These changes - which may include better storage conuols, inventory managmccnr and spdl p r r ~ n t ~ o o - often begm addmg to profits almost immedately.

Qrute a ~ f t a even the most complex TUR changes such as process modfications or input subsnrunc~ns also pry f a tbtmxlves very q ~ ~ c k l y . Many companies have found that these sorn of projects can gw a pmtlvc boost to bottom-line profits w i h one to two years.

The Benefits of TUR

Since 7- ams u h e redurnon or e l o n of waste, it often helps manufacturers to improve tlwu producuoa effic~tncy and &eve other goals traditionally associated with qual~ty unprovtmcnr programs. For mstance. TUR can help businesses to economize on materials. m producnaa m e , unprove product quality, decrease transport, t r emen t and w s a l c t m . reduce rcgdamry fees and c o m p h c e headaches, improve worker safety, cur worker's c:ompensa.uoa m c e rates, and reduce their Superfund liability exposure. In a t i o n . lLR can unpovz commmty relations and reduce the chances ofpublic litigation.

Full apprccmon of the financial benefits of TUR requires a relatively fine-toothed accountm!; ofthe costs assoc~aud with various productionprocesses. Traditional accounting tools do nor genedl y provide enough d e d to pennit calculations of the costs and benefits of TUR plrojecrs. As a msult. TUR planners have stressed a fonn of accounting which measures LZII of the boaom-he costs and benefits associated with reduced reliance on toxics.

The fedenl Pollution h e don Act d 1990 made thc prevtnwn of pollwar a t chc source che highut pno- opoon for indumal polluoon control.

FIGURE 16: REASONS FOR PURSUING TUR:

* T U R is the most environmentally responsible approach to indus- trial t ox ia

+ N R a n make your work environment safer and healthier.

+ N R can reduce regulatory paperwork, fees and headaches

+ N R a n save your company money while improving production

* N R a n lower your l i a b i l i t y risks and reduce the chance of acci- dental rdeases of t ox ia

+ N R can improve your community relatlions and offer "green produet linew matlcdng opportunities

+ N R can help to Lower your udl-ky bills arnd worker compensation inrur;mcr f t t r

+ N R can help Massachusetts to plan for t:he safe disposal of your huYdousw;rscar

1.3: What Does The Law Say About TUR?

ToxicsUse Reducaoa IS ad cmJv a new busmess practice ar~d anew mindset forthinking about environmental proemon - rt IS also a new approach to environmental leg.rsla&on. As early as 1984, the U.S. Coagms resolved that %e generation oihmrdous wastes is to be reduced or ehinated as expehnousl y as possl ble." The federal Pollution Prevention Act of 1990 built upon t h ~ s earher m o i u ~ o a . mlktng t l ~ prevention of pollution at the source the hghest priority option for dusmal poUunon control. In keeping with this mandate, the U.S. Environmental Roucaon Agency has launched the "33150 Program," which aims to acheve a 33% reduction tn ~ndusmal wastes by 1992 and a 50% reduction by 1995.

Whde the federal government has done much to foster awareness of pollution prevention as an approach to indusrnai toxics. nate governments have led the way in i n t e g m g Toxics Use Reduction into tbr Law. To date. more than one dozen states have passed legislaaon requiring businesses to carry aut TUR initiatives. In July of 1989, the Massachusetts legislame unmmously passed the Toxics Use Reduction Act (TURA, MGL Chap. 21 0, the first and one of the most ambitious of these nate pollution prevention bills.

TWU. wbch was developed in close cooperation with industry leaders, requires large-

quantity Iwn of toxlc marmais: (1) to report annually on their use of toxic substances; and (2) to undergo a p h m n g process that invoives a close examinanon of toxics use patterns, an evaluason of the [NC mst of u n g these toxics, and an effort to idenafy and evaluate TUR options. rURA sets "a stavwlde goal of reducing toxic waste generated by 50% by the year 1997 usulg toxlcs use redualon as the preferred means of meeting t h s goal." (TURA 1.1)

Who Irs Subject to TURA?

The pbnnrng and rrpomng requirements of ?ZIRA apply to firms whch meet the In July of 1989. the Husa- foll0wlIlfg t h m CI l tCT ld

chusercr lepirlarure unant- - mOusl~ puscd the + Employ the equivdent of I0 or more full-time employees (I employee = Reducoon Acr (NRA). the fint and m e d eh. m a r

2.000 hbor hourdyear).

ambmous rare polluoon

prsvenoon ~II IS. + Fall within Sandard Industrial Ckification (SIC) codes I O- 14 (mining); 20- 39 ( r r ~ a c t u ~ ~ 40, 44-49 (transportation, communications, gas, e1ecDr-k. and s m b q sedces); 50.5 1 (wholesale trade); and 72, 73.75.76 (certun wnim).

* Proctms or mufactum at least 25.000 pounds or otherwise use at least 10,000 pound, 04 wbstanca regulated under Title Ill of the federal Super- fund Amendment and Reauthorization Act (SARA). From 199 1 to 1993, the acr was v d e d m u a l l y to include all substances regulated under the ftrderrl Compdmmwe Environmental Response and Compensation Liabillky Act (CERCLA).

Camp- w;hlch mca dl of these criteria are categorized by the law as Large Quantiqr T a x b U r n ( LQTUs) These firms are required by TURA to file annual reports whch &ull bar uu of Lmtd substances and document their ongoing efforts to reduce or ellminrrtlr thCP depDdtOcL oa tbtse substances. By July 1, 1994, each of these businesses must also dcwlcp and c m f s a Toucs Use Reduction plan w i t . specific twcl-year and five- ycar byprodrtct Muam g d s and a detailed implementation schedule.

All M d ~ ~ c u toxjcs W ~ S which do not meet the above three criteria are categorized as Small: Quratle T a w s Curs (SQTUs). Certain SQTUs which fall into designad "priority user segments" m.av .Lso be subject to TUR4 reporting and planning requirements. Under TLiRA. pnonry w wgments cannot be identified until July 1, 1995.

Those t o u a uwrs u-&, are subject to piannlng requirements must submit a plan summary to the stace i)tparzment of Emmamental Protection (DEP). The full plan must be available on facility prcmr~s for rnspccnon by DEP officials.

Plan u~pdaus must k canplertd every two years after the first year in which a plan is due. These plim updatts must c x p h any failures to meet planned goals and schedules. All plans and plan updam rnw be cemfied by the facilny's senior management official and by aaained Toxics Llx Rrducnon Planner.

Secacm A 1.2 of Appench 1 e x p b the annual rURA reporting process, while Section A 1.3 of Appendu 1 dcscribesthe piammgrequirements. The Addendum contains the Toxics Use Rcducuoo A 0 Plannmg Rcgulanons (3 10 CMR 50.00). These plsnning requirements are prcselnted m summary form in Figure IC, which appears on the following page.

FIGURE 1 C: TURA PLANNING REQUIREMENTS

State regulations specify that TeTRA plans m u 3 contain a number ofelements, and not surprisingly these elements coincide with ithe more generic TUR phning steps described m ths manual. For msrance, TURA plans must include:

* A facility-wide management policy on Toxics Use Reduction. (See Chapter 2)

* Two-year and fivc-yur facility-wide projections for the amount of each covered toxic used, and the amount to be generated as byprodurr (Chapter 2.3)

* Two u l d f ive-yw goals for the Byproducz Reduction Index for each c w e n d toxic m each production un i t (Chapter 6 )

A process flow diagram for each production unit, and an account- ing of current and projected coxics use an~d byproduct generation in each production unit (See Chapter 3)

* A list of lltemative pr~ccacr, technologies and training programs that might achieve TUR (See Chapter 4)

A technical 4 financial crtluation of the TUR alternatives comid- ertd by the company. (Sea -ten 5 & 6,)

* An economic impact a r m i p s for each che~nical currently in use. (See Chapter 5)

* A description d a l l TUR chamges to be implemented, together with the urticapatd coro and savings of each, and an estimate of the reductions in c o x k use and byproduct generation associated with each. (See Chapter 6)

* An implemermtion schedule for the choserl TUR changes (See Chapter 6 )

TURA NOTE: More demled mformation on TURA nzquirements can be found in Appendu 1 of this manual.

CHAPTER 1 : ANSWERING BASIC QUI~~ONSABOUT N R..

1.4: W h a t OTA a n d How C a n Help Your Busin less?

The Office of Techcal Assistance for Toxics Use Reduction is a nonregulatory state office whose pmpose is ro assist industry in its Toxics Use Reduction efforts. Though OTA was estabhhed m 1989 \nth the passage of TURA, its precursor - the Office of Safe Waste Management - had by dm time already gathered many years of experience helping

T o d a c z OTA hu worked Massactrusetts bunncsses to reduce their use or generation of toxic substances. To date, OTA S W ~ I - ~ hundred M ~ S S ~ - has worked with several hundred Massachusetts businesses, and has provided on-site

chusem business-. and has consultanon and concrete TUR recommendations to more than 300 firms. It has also held prwtded on-rtt4 consultanon and concreta TUR recomma*

over 100 'Touu Use Rtducaon workshops throughout the state.

danom or, mom chm 60 firnu. OTA cr not an enforcement agency. The office's mandate is to provide technical advice andresourrccs to compaa~es whch are subjectto TURAreporting and planning requirements. It is also ~mpcmible for hclpmg other small businesses not subject to T Z I i to reduce or elimlnsrtr thu r e h c t on touc substances. Under TURA, OTA's services are confidential and the office is r c q d to give pnority in its assistance efforts to b s referred by DEP and to cornparrues m pnonty user groups.

OTA. whch IS frmdtd by tbc TURA fee. offers the following nonregulatory services to Massachisem t o u a uscn at no charge:

+ Performs o ~ i t e Tox ia Use Reduction assessments designed to help you identify N R opportunitias and learn about alternative processes and technobgtcr approprbte to your company.

+ Rcspocds to t~~ and written requests for general information about Toxics Use Reduction and specific information about the legal require- ments d TURA

+ Condum firuncial matps to identify the economic beneftts of TUR p r o j c ~ a

+ Sponu~m ccmferancu. workshops, seminars and trade fairs to disseminate information about N R techniques and technologies.

* Promota atternattve manufacturing processes that reduce toxic substance use. t h o u s waste generation, toxic air emissions and wastewater d k c h a q a

The Olffice m u t a m an uptodate library of resources and publications on all aspects of TLX 1be L h r y mcludes tecbcal donnation on alternative TUR processes and technologies for a number of major industries, including metal k s h m g and plaang, metalwohg. pulp and paper, and chemical manufacturing. A partial listing of these documents 1s reproduced in Appendix 3 of this manual.

In adtirum to I ~ S direct technical assistance services, OTA may be able to help your busmess by pumng you in touch with other companies which have faced srmilar toxics managezoent problems, and whch have solved them through successful TUR.

Chapter 2,: Getting Started

2.0: Getting Started -- An Overview

Sometimts, N R ideas can come to light immedJately, with little planning. For instance, one Somendle !irm rcantl y decided, after a five-minute phone conversation with OTA, that its purchase ofmmc a c ~ d etchant could be cut dramaucally by &g a vacuumdistillatlon unit whch recovers acrds for r e w .

Some Impaxues umg t h s manual may have similar experiences. They may strike upon obvious. tlme-tested process changes which promise immediate reductions in their toxics use and in rhev cbemical purchase and drsposal cost.. A list of some of the most common and widely qlphcable TUR changes K included in Chapter 3 (see Figure 4H).

More typically, successful TUR requires a sustained program headed by an d v e TUR team. ' I h s tern 's task K to take the lead in analyzing production processes, identifying TUR optlons, subrmmng o p u m to careful scrutiny, and implementing TUR process changes.

By cremng such a m. your business will maximize its chances of i den t img and selecting h e TLX opuons most appropriate for i t Perhaps more importantly, the team will stdl be the!re wben the project u h e to help aack progress, draw lessons from successes and fklures, plan &noad TLX proycts. and build worker acceptance oflURprocess changes.

TLus manual K unucn wtb the needs of such a TUR team in mind. This chapter focuses on forming such a team aod pl b u l g it b e management suppon it will need in order to succeed. Subsequent rhaptcrs arc d e s ~ p e d to guide the team in the investigation, identification, assessment and unplemcntanon of TUR options. However, these same chapters should provide useful gudance to t k who elect to pursue TUR more informally.

2.1: Developing a TUR Policy Statement

Much like a quality unprovement program, an effective Toxics Use Reduction program requires a. comprehensive, company-wide shift in the way your business thuds about its producnon proasses. Businesses whch have initlared TUR proprams have found that useful suggestiolns are likely to arise from all quarters. For instance, while engineers may be in the bea positlon to Identify and evaluate the feasibility of alternative technologies, factory

workers are often ben able to pmpoint sources of waste and gauge the effects of proposed production changes cm everyday work procedures.

One of the m m effecnve ways to increase awarene:ss of ?ZTR throughout your plant is for uppermanagementto LSSU aadpublicireastatementofits commifmenttoTtK Suchapolicy statement commmcaus u, workers throughout the plant that their company is receptive to proposals for curtmg toua use.

TURA NOTE: A fanlrry-wide statement of commitment to TUR is required for all businesses m.b)ecl u, TURA planning requirements. See Appendix 1 for details.

Businerres which have inrmmd N R aroenms h v e

- r . - - - - found that useful suggtroons are W y oo yrre from dl quansrs. FIGURE 2A: SAMPLE POLICY STATEMENT:

We tbe azmaganent of XI'Z Company aini to produce the highest-qdty products posslbk u h i c mlnlmlzlng our use of toxic materials. Ln this effort, our bghen plorny wdl be th proactwe purmit of cost-effective process changes which reduce or elrmlnmr &c usc &or gcneratlon of toxics at the point of production. Whae toucf canna be e h m a c d a! tbc source, reuse and recycling ofmaterials will be e x p l o d d unpkmcnvd cvhcrcver possible. These objectives will be incorponvd mto rhe deagn of ~wu. production processes, the redesign of existing processes a d chc of new facilities. We encourage all employees to forward tbar mggcshcms fa k l p ~ n g to reduce our reliance upon toxic substances.

2.2: Organizing a TUR Planning Team

Like any otha n ~ f i - i churyc ur the way a company does business, TUR planning r e q u l r e s a n o r p a n r d foIIDIZdtPUll OTA suggests tbiu YOU assemble a T U R planning team wbch draws h all phscr of v a ~ busmess.

Unlike more udraoaJ to pollution, TLJR affects all aspects of production, and success r e q w s a k n o w kdgc of each of thes: aspects. Team members should be selected lo order to rnnur mil me rram can understand in great detail how your facility operates and how opa;rrxwu mlgbt be changed.

It 1s aifxal to =cure b e nrppxt of a hgb-level manager - perhaps by includmg one on the team. Such m a q m n c n r mvolvement can provitde important insight about overall Corporate goals and un k l p w b t a i t comes m e to see:k approval for TUR projects.

The proper composlaoa of the rest of your TUR =:am will depend upon the size and organizarional nruchlrr of \w busmas. Small firms where each employee wears many hats may tind that a m o d e s t - s d uam - perhaps as small as three to four people - can carry out effective TUR Lager busmtsses u d l find it useful to include representatives of many key depanmenrs.

The folloumg chat 1- possible N R plannlng team inembers and shows how each might conmbuv to a successful TtTR program:

FIGURE ZB: T H E TUR PLANNING TEAM: ( N e k, ,null b m , thc same p-n may w a r swenl of he re ham)

I. MANAGEMENT -Demonsmte corporate commiment -kt and enforce long-term goals. -Have authority to implement changes.

2 DGNEERING AND DESIGN Provide information on current processes. -Convibure ideas for chang~ng processes. -Gauge the technical feasibility of proposals. -Identify panmeten for optimal functioning.

3. BWIRONMENTAL -Glculate treatment and disposal cosa. c:OC9UANcE -Gauge environmental effeca of proposals.

-Ensure compliance with regulations.

4. WNANCYPVRCHASWG -Calcularc cosu of current opuaclons.

I -Calculate cosa and savings of proposals. -Track cosa and benefio of actual changes. -Implement changes in inventory concrol.

5. SJiLES & MARKETING Provide insight into customer needs. -Educate customen about TUR changes. -Market producu as environmenally responsible. -Hon~tor customer ructions to product changes.

6. PI I .OWCllON WORKERS -Provide accunte descripdoru of producr~on pncdccs. -Suggest ideas on new approaches. -Gauge compatibilq of changes wich work pnctices. -Supply feedback on frondine effecu of changes. -Increase worker s u p p n for production line changes.

Larger Companies might consider including:

Q U N W COhmoL -Gauge compatibility of changes with qualicy specs.

LEGAL -Gauge effecu of TUR on regulatory requiremenu. -Gauge off- of TUR on corponte liability.

SAFETY 8 HEALTH Provide &a on hulch and safety effecu of toxics.

-Enluatc effeca of TUR on worker health and safety.

MTlBLU CCNlXCL & Pruvidc information on material storage a d use. INVENrORY -Sugpr methods for improv~ng stonge and handling.

RESLhRCH & DEVELOPMENT -Censider modifications to product dajgn. -Coruider TUR goals during new product developmenr

RIOTE: Adapted from the Minnesota Pollution Prevention Manual.)

By creating the son of brod-based TUR pinnning team outlined in the precedmg figure, your business can ensure that TUR ideas are drawn from a wide variety of viewpoints. This will greatly increase the chances of snilnng upon an option which is optimal in all respects. It shouldalso help to incorporate the TURmindsetinto a l l aspects of your business, including the research and development of new product lines and production techniques.

More On The Teamwork Approach

Your TUR effom may abo be entnnced if you ramrd dm manben of your TUR t a m who emerge as "Causa Champ~ons" due to hair c o m m l m e n f anchur~arm. and abiliry a, make rh~ngs nappen.

The teamwork approach to mocbfymg and improving production techques is already familiar to many finns For maance. those firms with worker quality circles already use teamwork to tap mto the wcll of wful ideas about produ.ction improvements whch can arise fiom the facmy floor. Many o tba f i rm have used atem1 approach to introduce new products or equipment. since such changes can affect all aspects of business. including shipping and receiving. w t t n a o c c . productloa, fmmclal accounting, and sales and marketing. Your TUR program wdl nqurrc tbc same son of wordmanon, as it will lead to changes either in products or in productloo qulpmcnt and techniques.

The teamwork approach ro TLX u.111 also help when it comes time to implement your proposed changes. If all secton of ,your firm have participated in devising the proposal, they will all be more k e l y to dtmoasaatt the flexibihty and commitment needed to make the change a success

Expanding Your Team

You may w-sb to iook orrtndc of your firm for additional TUR team members. For instance, some firms mav unsh to recam a consultant experienced in TUR or process change to help p d e your exploraaoo of altemanve pocesses and technologies. Other firms may wish to include rcpresmwlvcs of rberr nclghboring community, who are likely to be highly suppomve of any effom to reduce tbc use of toxic m a m d s in the vicinity of their homes.

Your TUR efforn Jso be cntwced if you reward the members of your TUR team who emerge as "Cause Clumploas" due to their commitment, enthusiasm, and ability to make h g s happen. These cue cbtmplons can be given responsibility for organizing and chaxnng your team mcemp. x wcll s for bringmg in outside speakers who might sharpen the team's knowledge of 7T.R C w Champions can also prove invaluable in gaining acceptance for TLR process chmga. combatting the idjexible "if it ain't broke, don't fix it" amtude wbch o t b a u w m~ght fwPav the team's efforts to implement rts plans.

Once you haw seleatd a TLR team. be sure to publicize theteammembershp in company newsleners or on bullem M, so that all employees will know who to nun to with their TUR suggenlons I t ts also helpful to spread enthuslasln for TUR by initiating employee training programs. probtdmg uucnnves for those who conmbute to TUR efforrs, and evaluating managers m term of theu 7lJR performance.

TURA NOTE: rU1 cornparues subject to NRA planning requirements must notify e m p l o p s of plan requirements six months before any plan or plan update is due. and solicrt commcnrs or suggestions on TUR options from all employees. The TURA plan mun tncludc adescriptlon of steps taken tomeet b s requirement. Refer to Appendu I for more mformafion.

T U R goats should ba conru- mnt \nth the rnarugernmc's h c ~ l ~ r y - w ~ d e TUR policy. amb~oous enough u, moomce slgnrfiant TUR effom. yet rphsoc -gh UJ -me as an appropnace musure of M C Q S - W *A#fi *rill l l O C

guannme failure from d?e start.

2.3: Setting TUR Goals

One of rbe fira tasks fac~ng the TUR Planning Team is the semng ofTUR goals. These goals should b: grwm a g m n deal of t h & f as they should be consistent with the management's facrltry-u;rdc TLR pol~cy. ambtuous enough to motivate significant TURefforts, yet realistic e m g b to sen* as an a p p p n a r e measure of success - one which will not guarantee fdure from the sun.

Evennually, your TLX goals should provide a specific quantified statement of the short- and loag-urm rcducnons m toucs w wtuch you intend to aclueve. However, it isnotusually possible to fmmulau such spcctfic goals from the very start, before your team has begun to invcsag~v opporrrrmna for TL'R m your plant. In practice, your goals will probably evolve from qual~mve dmcnvcs to quylntanve aims as your TUR program progresses.

For instance. you mav uub to begin with the general goal of achieving a 30% reduction of toxics LUC ads byproduc!~ m two years. and a 50% reduction in five years. In many indumics. mcb rcdumars are emmently achievable. Then, as you pinpoint the most prormsm:p TLX ~~ m your plant, you can make your gods more concrete. For instance. you m&t chose m focus your near-term efforts on reducing your use of cleaning solvents. ubk focusmg your lmg-tcnn efforts on substitutmg aqueous cleaners for solvent- based &pasen

Keep ID rmDd that as you make your gods more precise, you will also want to stnke upon a lUR acnm plan. m p l a e with a timetable for the concrete steps you must take in order to fulfill your TLR goals Th~s action plan should be coordmated with your quality, efficiari. pmduca~m. safety and energy and water consenation programs. This topic will be revlnted m Chapcr 6

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Output- Successfully Implemented TUR pro lea

--

Chapter 3: Characterizing and Analyzing Processes

3.0: Analyzing Processes -- An Overview

One key to successful TLq u gwmg a detailed and comprehensive picture of your toxics use panans. 'The anaiyncal tools and dam which you assemble during t h s stage o m planning are absolutel!~ cntlcal. as they are your pnmary means for pinpointing wasteful practices, identlfylng TLTR oppomrmun. and calculating the costs and benefits of proposed changes.

This dSaptcr walks you through the process of analyzing your production processes - begmmg w~tb the most general dormation-gathering stages, and working towards the h-ghly detailed analysis of mdn~dual processes needed to spot TUR opportunities.

Those firms utuch have alrcdy chosen a particular process for focused examination may wish to nrrn dartctly to 3.3 and bepln construcmg process flow diagrams of those processes.

If your. ream feels. u any stage in the process, that a visit to the factory floor is needed in order to ger a barn pi- of production processes, you may wish to turn ahead to Part 5, which c x p h how to organuc a group wallahrough.

It is important to keep m mmd that the process of gathering data is intunately linked to the process o:f idennfivmg EX opaoas (described in Chapter 4). The information you gather should mdrcvlc how much your toxics cosr you and where they are being used inefficiently. n s alone o h bmgs to mmd alternative techniques and processes. It is agood ideato have each TUR. t t ym member keep a notebook during the information-gathering stage in which to record idas about TL'R opoons.

Cathering and Organizing Information

With a TLiR Pol~cy Statement and tentauve TUR goals already in place, your team is now ready to sharpen its knowledee of the use of toxics on premises. The first data-gathering goal is to gain a general oveniew of the chemicals which enter and leave your facility. This infomanon has uses whch extend far beyond TUR planning. It should prove useful in

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CHAPTER^: CHARACTERIZING AND ANALYZING PROCESSES..

Just as with the first database, this basic information may be supplemented as your TUR program sows . But even before you have gathered any additional mformation, yourtwo lists should give you a relanvely comprehensive picture of the toxic substances entering and leaving your facility. and of how much they are costing your business. In most cases, this will be enough informanon to permit initial discussion of cost-effective TUR opportunities.

Where 1ro Look For Data

Chemlcal Input and C h e m ~ a l Output danbarer have uses wtnch urrend far beyond TUR. For exampic t h y may hclp you ro Improve corm04 of your chem~calr ~ n v c n t o q and keep a b r u ~ c of regulatory c o m p l ~ a n c e .

Some companies may find that all of the information included in these two data-bases is already avdable in lone central place - perhaps in the purchasing or environmental engineem€: department. However, even if your company has not already assembled such data, the basic infonnatlon you need should still be available on premises. The trick is to put your h d s on it.

Your replatory records are a good place to begm l o o h g . Assign ore or more team members tc, comb through these records in search of information about your use of toxics. If your firm emts enough toxics to be subject to federal SARA 3 13 reporting requirements, then your Form R report will have a great deal of the informahon you seek. If you are subject to lLiRA rcrpomng requmments. then your Form S will also include detailed i n f o d o n about your toxics use, anssions. and byproducts.

Addinonal lnformanon about your RCRA hazardous wastes can be found by reviewing your m f e s t repomng records, while your POTW (Publicly Owned Treatment Works) or NPDES (Xmonal Pollutant Lhscharge Elirmnaaon System) permits will contain ready tnformaom on your w a r &charges. Finally, if you have a state DEP Air Source Regmanon. then your appllcanon records will include data on your air emissions.

Asslgn adhnonal team members to mine other sources of data on toxics use. These might include purlchaslng records. Marcrial Safety Data Sheets (MSDSs), stockroom and inventory records, del~very records, marntenance materials records, quality standards and customer product specifications, d o r process flow dragrams prepared by production engmeers.

In adhaon. appropnvc ream members should gather rough information about purchase costs and mamcnt or dsposal cosrs. T h ~ s dara will eventually be used to conduct a thorough financd assessment of the cons associated with your current production processes. (See Chaptelr 5 3 . s c m n 'a' 'Llstmg Current Operating Costs")

Insuring Accuracy

In some cases. the mformahoa you @er at this stage will not be up to date, and will no longer a c c m e l y lrflea your faclhp's production practices and toxics use patterns. You will have a chance to wnfy your dju when you conduct a facility Walkthrough (Chapter 3.5).

The watYrthrough LS dcsmbed at the end of the chapter because it serves as a chance to confirm the dam you @er d u n g other stages described in this chapter. However, you may wish to alter the order, conducting walkthroughs at earlier stages k order to check up on informmon as you gather it.

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As you gather information. you should conanually ask: 'why do w me dla subsuncs or process in quarion?"; "Where might processes be alrard or subtrances subsnruced in o r d a m ~ a r r l 6 e d toxic marsriais?"

Your choice of a focus may also depend in part upon how much TUR experience you have already accumulattd For instance, if you are new to TUR, you may wish to select a project whch is not tcmbl y complicated or which will provide a good learning experience. Success in such a p n ~ j e a a u l d help solidify your company's commitment to TUR

The twin data-bases developed above should prove helpful in your efforts to identlfy substances and processes wbch merit targeted attention. Keep in mind thar a s you narrow your focus. !mu should mmr and sharpen yourpre l imina~ TUR goals (see Chapter 2).

~ ~

'WIRLA NOTE: So far, process characterization has been described in relatively mfonnal tcnns Compames subject to TURA reporting and planning requirements must mcxt more formal requirements. Specifically, they must analyze toxicsuse and comidcr possible rw reductions in each of their "production units". A producnon unir is any process or combinarion of processes which produces aproducr -- where 'producx" may be defined very broadly to encompassfinalproduc~s, intermediate products (poumrail y saleable goods whch are used to create other products), results (e.g. c l d clothes produced by dry cleaners), or families of relaredproducrs or r.c-~la. Tbesc legal sues arc ciscussed at greater length in Appendix 1. The important

thrng to now hcrc IS that. at lean during this prebmary stage, it is not inconsistent wth volur TUR4 t n m p h c e efforts to focus your attention on a particular toxic substance rather than on a pamcular production unit. Once you have determined wtulch pmduchon umn arc responsible for the most significant or most readily avoudable losses of h s substance, then you can meet TURA's requirements by plarantnlg mxlcs use reducnon changes for these production units.

Gathering More Detailed Information

Once you narrow your focus. you cyl begin to gatherthe more specialized data you will need in order to udcrstand dl of the various effects whch the targeted substance or process has on your bunwss and rh cnwwment. Until you have tlus son of understanding, it will be difficult to e d u a r c papoxd changes for possible adverse side-effects.

It is pami*? rmpman! to understand the effects of the targeted process or substance on produmcm ~chnr- and processes, byproducts and emissions, product quality, worker health and safety. and the cnwonment. You will also need as precise an idea as possible of purchase. m ~ m c n t and W s a l costs in order to assess the financial viability of proposed changes.

As you p k r thu jdd~oonal mformanon, you should keep a few key questions continually in mind: "%by do we ux the substance or process in question?"; "What effects do these substances or processes have on public health, worker health and safety, and current or future environmenltal complranur'. "Where might processes be altered or substances substituted in order m reduce our use of toxic matemils or our generation of toxic byproducts?'; "HOW might we save money by opammng production processes and the efficiency of chemicals use?"

. 2 PU0C:ESS SCHEMA7 lCS

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3 YECHlNlCAL DATA ON U J B n A N C C j A N D PROCESSES.

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6 . RNUUCUL REC3RDS

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L

FIGURE 38: IN-PLANT DATA FOR PROCESS

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R a p a n s a to Past Government Surveys

3.3: Creating Process Flow Diagrams and/or

Chemical Pathway Analyses

Tha most c r h a l ctrlng oo keep in mind whik crslong a N R procar flow diagram u m idcnofi. all bypmducu - including such oken over- looked OW as spills. evaporated liqu~ds. spenc chamicals. unusable taw

rnamrials, and subsmndard or unusable products.

At b s point, your examination of your target substance or process may well be a bit confusing. You have gathered a good deal of information, yet it is not: easy to see what it all means or how it fns together. Aprocessjlow diagram andfor chemicalparhway analysis wdi put the data you have m e r e d into ausable form whch will help to clan@ your parterns of toxics use and to plnpomt sources of waste.

If you have chosen to exmine a producnbn process, you should begin by creating a process flow dragram. then create chemical pathway analyses for ithe principal toxic chemicals used m the process. If you have targeted a subsronce, you should create a process flow d.mgmm for each mior process which uses the substance, then proceed to mare chemical pathway analyses tracing tbe substance through each process.

The Process Flow Diagram

Process flow dxqams arc gmpluc sketches of a production unit, depicting all of the steps through whch raw mavnals pass as they are transformed into products. 'The point - at least for 7UR purposes - is to provide a clear picture of all stages of the production process, together with the raw maicna1.s and byjmducts asraciated with each of these stages.

Process flow dugams arc not a new idea; they have long been used by engineers to charactcrizc ~ndusmal processes. For TUR plaumng, you will need process flow diagrams whch differ from more farmliar d m p m s only in that they are a bit broader and more detailed. Tlus does not mean thar exlstrng process flow diagrams are useless for TUR. If you have such -, you sbould meat them as a mining point for creating the diagrams you need.

Before you can mate a process flow dugram, you must define the producrion unit you are analyzing. For TL!R plrposes. the production unit should be defined rather broadly. Your diagram should encompass mt o d y the process itself, but also the storage and h a n h g of raw matenah belure the process. and the storage and handling of finished matenais and byproducts af io the p r o a s s

The intent of the d u g a m i s m demarcate all inputpoinrr; at which raw materials enter the production unit. and all outprpo;nn ax whch prodncts or byproducts leave the unit. In the next phase of analysts. mat tna ls acwuntmg (Chapter 3.4), you d l estimate the magmtude of each of these ~npuu and outputs, thereby gahmg insight into TUR oppommities.

The most c r i n d h g to keep m rmnd whde cre;aing a TUR process flow diagram is to include all output pomts. Tbcsc arc not always obvious. Byproducrs on take a number of forms, including sp~lls. evaporated l~quids. spent c.hemicals, unusable raw marerials, and substandard or unusable products. (Note: evaporated liquids and spent chemicals do not become emirsiom m ni'R~argon untd they leave the plant; priorto that, they are byproducts j All of these should appear on your process flow dmgam.

As noted above, a TLX process flow diagram defines the production unit more broadly, and includes more detatls. ban traditional dugrams. For instance, traditional diagrams often

. h l to represent all fugnve emissions; your TUR di;gmm should include them. Similarly, tndmonal dagxams do not include storage and handling before and after the process; your TUR diagrams should mcorporate these steps.

In adhrion. it is n t l ca l to dtagram periodic operations - such as equipment cleaning, maintenance and repax - wbch might use or produce toxic substances. You may have to create sew* process flow dtagrams to c-rize these operations.

How T o Create A TUR Process Flow Diagram

The thlnhng b e h d ywxr process flow diagram will depend to a large degree upon the kind of produrnon a t you are analyzing.

For innance. connnaonal assembly-line processes are relatively easy to represent with Your TVR diagram should process flow -. as tbcx processes are essentially linear, with raw materials coming lnclude srongc and handling in one end and products comrng out ofthe other. The final diagram can be laid out inthe same phases which cndioon;~l configura~nn as the fartory floor. and a quick visual check of the actual production line can diagnmr o m i t often asccrtam whether any aep has been omitted.

Other g r c ~ e s ~ s m a y provemore difficult to -am. For instance, youmay have targeted a'barch process". m wbch tbc various processing steps occur in a single place on the factory floor. In &us son of cuc. a k processing steps are separated temporally rather than spanally. you must do ! m e careful analpcal thinking to ensure that your diagram captures each acp n r m f a coawmng mcorning raw materials, energy, and labor into products and rmWi bymdms

Whancwrr npc of pnxcss you art analyzing, your final hagram should look roughly like a blucpnnr clf a aadrmid hear ~ s e m b l y process. In most cases, your diagram should take the form of ar lw ofbo la . uch Wled to indicate the production step it represents. and each conneud to other boxes m a scqucnce w h ~ h parallels the production sequence.

?he n u mPtnals m b c b enter the process should be arrayed on one side of this line of boxes. wtb i k s during the pouu at wbch they enter. All products and byproducts should be arrayed oa tbc othcr wdc of tbc lroc of boxes, with lines indicating the point at which they leave tbc pmlucncrr umt

The a p k procai flor b g m n in Figure 3C represents a nickel-plated paper clip manufaaunng proctn Wart f b u ~ domm the page, from the first process (Wire Drawing) to the h ( rhlppng Rr-proJucooa storage and handing steps are -ed in the second coturnn. m h k : b x 8 I f qmsen t s post-production storage of h h e d products.

TUTU Son. L'udc~ T'LRA, produrnon units are defined in a very flexible manna A n y prx;tu a combmanon of processes which produces a desired result or prod~rct ( w tmkr t i nuk l or not) could count as a separate production unit. Thus, the process dugnmacd m F~gurc 3C could be counted as more than one production unit. FIX m e , nncc mplattd paper clips might be sold to a plating shop for compimoa. steps ir i 4 d d constitute an independent production unit.

TLXA also rcqutm each touc substance used in a given facility to be tied to all productloo ~ m ~ o un ubcb it a w d (except for toxic chemicals used to treat toxic byprochmr F a uraance. if thc degreasing unit represented by box #4 in Figure 3C &err! rcicd m ocher production processes, then mchloroethylene use would have to be anmbuud to m& than one-production unit.

TLaA p h m w contam a process flow diagram for each production unit in the fachty See Appendu 1 for more information.

FIGURE 3C: SAMPLE PROCESS FLOW DIAGRAM: (Nickel-Plateti Paper Clip Manufacturing)

t-landling Losses Kagslabsorbenr

Handling Losses

- 3. Bonding Wandling Losses

Handling Losses

Spillsldripslhandling Spenr HCI 8ad-1~ Dng-out (to R i m )

Wasrewater

Spillsldrips (to dnin) Dng-out (m rinse)

8 Doubk Rime Wastewarer

The Chemical Pathway Analysis

A chem~cal pathmy a~nalyses wu perrmr you rD mck a m u c subsnncs from h e moment rr - your plant r~ dm palm at h l c h Ir leaves

- h ~ k hdplng you to I w o dl of & porno a t A rch rr

If you have chosen to target your TUR efforts on a production process, you should now have in hand a process flow d m p m representing that process. If you have targeted a substance, you should have dmgmm representing the principal processes in wbch it is used.

Either may. it IS tlroe to use these cfiagrams to create chemical parhwq anal,vses. The purpose of a charucal pathwxy analysis is to uack the flow of a toxic substance through a process. 7lus udl gwe you a graphc idea of the fate of each toxic chemical under consideraacm.

If you have targned a process. you should create aseparate pathway analysis for each major toxic c8arucaI used or produced by the process. If you have targeted a substance, you should create a separav Hl;ljysls of the chemical's pathway through each of the processes in which it is used.

Your &cmlcaI pathway analyses will permit you to track a given substance from the momcot n cntm your plant. through a given production process, to the time when it leaves

may b ~ o m t a byproduct the process as a product or m i d d byproduct, and even to the polnt it leaves your plant. This along the m y . can help ycu to locatc all of the points at whch portions of the chemical may become a

byproduct. rrduc~lrp efficiency and perhaps causing a threat to worker health and the environmas.

How To Create .A Chemical Pathway Analysis

To a- a c h e r m d pathu-av analysis. begin with a photocopy of the relevant process flow dmgmnN o w take a p and aaa the chemical from the point at whch it enters the process to the point lor poms ar wbch 11 laves. Ln many cases - particularly if you are dealing with a vo W e chlcrn~cal - y o u WIU find that the line branches in several places as m e amounts of the h r c a l arc r e l d to the environment. or as pomons of the substance enter into chemcal re;smoas and pbv n u to new products andlor byproducts.

Your Tt'R proct~s flou diagram should include pre-process storage and handling and post-proccsi handbg md treatment. If it does not, then you should expand your chemical pathway anarl ysu to mc!lu& tbev sages. in so doing, be sure to use branchg h e s to indicate all possible losses. u~ludrng losses due to spills and evaporation.

A Sample Chemical Pathway Analysis

The follouu~g cbermcal pubway analysis tracks the pathway of Nickel Planng bath through the meral pbrtlng pomoo of the paper clip manufacturing process diagrammed in Figure 3C:

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Once you tu*. c a l c u h d &e

mourn of h m n rub-

rance A c h you are using

and dw amourn r(rch u conmind In Tour produc~

pu a n duumlnm p u r mcrl byproduma .nrh mmpk ar~chmeoc.

However, you should keep an open mind about TUR alternatives until your team has carried out the formal opaoas generanon procedure described in Chapter 4.

Aside h i iu ~mponance m identifymg TUR opuons, this materials accounting process will serve rs dbe bass for meanrnng the success of your TUR process changes. If you do not detenxlme the volume of touc byproducts which you start with. there will be no way of detennuunp blow effecuvely those byproducts have been reduced.

Thu vcooln bcgm w ~ c h a dscussion ofsome rudimentarymatenals acwunang techniques auned a gwvng a quhtanve picture of your byproduct generanon parterns. These rudun- u : h q u s rquvc httle time anduse readily a W l e dara, yet may be sufficient to pamn you to h u e TUR oppommies. The semon ends with a dscussion of a more complex muchzls uxorunmg tool - the mass balance - whchrequlres more time and greater utpuan A cluss hdamx can provide precise. quantitative measurements of byproducts volumes o b c h saneamrs prove ~nsmunental in identifyms TUR oppommities and which arr n#d td la ortkr to make ~ t u r a t e measurements of TUR progress.

Rudimentary Materi J s Accounting

You sbaJd do a qume aunruls accounang for each subsrance!process combinarion you am lookmg u Ln uch case. rbc frm task is to estmate the total amount of the toxic subnance whcb eodr rq, rr a bqmxba a axussion of the process under consideranon. You cam crlculaxe Lk magmndc of the subsance which ends up as a byproducr by

dettrnuntng ttw mount thu yx yy and subtracmg from it the total amount that ends up in your or 1s dunged rnto a oon-toxic substance by a chemical reacnon:

Bypaduct - Use - (Product + Converted in Reaction)

k h u h -dl g ~ b t *OU LbC volume of byproducts as defined under TURA. Under h s d e h t i o a . rkrr u rw, d lo musure emrrsions in order to calculate byproducts. Thrs is because all emurooas - evrr, Orosc whch are released drrectly from the production unit mto the cnvuwanxw - arc reg- rr byproducts frm. before they become emissions.

The 'probur3 u, rr,qucrulim bm ated nor be afiml product ofthe son whch you sell to your cummen For u s a x e . ym am\ be analymng a production process that creates para whch are uscd u, fatmax J frnrl product lo that case. the "Product" factor would represent that w o n of tbc muc moaul u d e f rnvtmgatlon which ends up in usable parts.

The rnform.o<xr wur w x a brc collected ar earher data-garhenng stages should help you to den= arm@ emm+~ of tbc mwnt of the toxic substance whch you are using and the amount wbcb u am& u, y o u r produa. If you are considering a substance whch ream wth o tha c&mrds d m a y & p u s s . aeanng non-toxic byproducts. then you may need a charuul pofcuw IO bcfp yw emmatt the amount which is being lost in reaction.

G e n d m f t a m u ~ m a h u ~ m x ~ u use should be contamed m the Chermcal Inputs Database descnbed ur Cwpf 3 1 Keep m mrnd bowever. that hs database contam informanon about your ~gl; -gou use of eacb chemical m your planq it may not tell you how much of the toxlc IS k q 14 m Lhc pamabr poccss under consideration. To derive a loose estimate of t h ~ s m m q m f i c magnrnrde, you should review raw marenal purchasmg. delivery and sorage records. mema1 marcnals W e r records, and factory floor records such as job sheets and m ~ l r ackets.

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The data wvhrch your LCUD has gathered may help you to make these sorts of quantitative assessments F a rpaanu. if you have nm labommry tests on your air emissions, water dsdmgm or solid uann, then these test results can be used.

Regulatory recurds way also provide valuable information about the quantities and concmmow of various unra~ons and wastes. Since emissions are notiung more than byprodurn urhrch haw left your plant, this data can be quite helpful. However, since your emissions often come from xvtral production units at once, emissions data may not be specific enough for ycur TUR needs.

There m a y also be s tandd mdusuy measures which can be used to make sound o,,. oc rh. a quantitanrt azmses of by-product magnxtudes. For instance. there are figures for (ul TuR prolryn u rh calculanng ei,apoianvc lbrses fnw &greasers caused by variarions in cooling coils, covers drrm'opmmr accuntm and and horn s p d s . Strmlrrtv, tbcrc art standard equations which can be used to calculate losses complum dam on mmca WL

mmlrrlonr. and b7producxa. of ele&lmtng soluncx& duc to drag-out, e G r a t i o n and spills.

T h e u ~ n of sadad lndusrry measures are sometimes available h m industry trade - groups. & a m d nrppk . and chanrcal enpeeringreferencematerials. xvou have rouble

Jind~ng rhrr xvrt of ~nhonnanon. or b e other dijkdries anal-xzing yourprocesses, you can getprofanond k i p bv conLlrnng OTA at (617) 727-3260.

Conducting a Mass Balance

One of th krll.r to r rucccrsful TL'R program is the development of acmraxe and complete data w mxra use. emr9mas. and tryprodurn. Such data will permit your team to spot TUR opponunm and to mcRsurr rrd document TLTR progress.

One useful tefhPlquc for tmpo\mg your materials accounnng dara is the mass balance. Howe w. k c l u s t mass brl.occs arc rather difficult and time-consuming, you may wish to amduct cbrm odv for th rnm c n n d producrion units. The am of r mu, b a h c c u 00 & a m m e the eventual fate of all of the chexrumls uhch

enter a g~wn ~ ~ c n c m Qumg sane determinate m e period. The total mass of these m n a l IIXPUIS m u be for e~thcr as byproducts, products. or marcnals accumu- lafed m the ptxbmcm wt Tbt .ppfopnarc equatlon is:

M a ~ l a u l lapaa = Byproducts + Products + Accumulated Materials

Before thLI ukukaoa a a k m p t e b the production unit must be defined carefully. For analpul purpscs. fbr pmdumon w t can be thought of as surrounded by an magmay envelope. Tbc task, mceL E o mxwnt for all matcnals which enter the envelope (i.e. raw materials) a Law tbc mvtkipc ( LC. byproducts and products) during the time period set for the mass b a h a crkulrnrm Ranember: emissions a~ a subset of byproducts.

At the cod of Q p m d . Q .mount of mattnal accumulated within the production unit should be mu& Tbr mmrkrs can then be plugged into the fonnula given above. Any duucpacy un b e rrarlang qwmon rrprrscnts elthcr measurement errors or unaccounted- for mannab If mplcs u c far larger than ourputs. funher research may be needed to identify ~vlously unr- sources of b y p m l u ~ .

The m e p o d otr for the mass balance should be a represenfarive period. That is, the operatlous u ~ d processes aandardly associared wrth the production unit should all be performed dururg th pcnod for ryptcal pornons of the total time. If not, the entire exercise mll ~x pronck an accurate p~catrr of the process in question.

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lnpur from workmrs can ba invaluable in d m r r n ~ n i n g how cquiprnanr in your phnr really opcrrm. When in d a r b r u k why thlngs are done way char hq are.

byproducts may be created - including shipping and receiving docks, storage areas, and in- house trearm.ent and recycling sites. While at these sites, interview workers who handle and transport toxic materials to insure that they are properly trained and that they follow sound housekeepmg practices.

Do not skip an area simply because you already know it well. You must look at everything as if you halve never reen it before, carefully reconsidering each part or stage of each produrnon process.

If your tern has already come up with some preilmmary TUR suggestions, make a list of them and &tribute a copy to each member of the team. This will permit you to discuss their feasibihty with workers and other team members as you examine the relevant processes first- hand. You sk~ould also photocopy and dismbute all of the process flow diagrams and chemical pathway analyses which your group has prepared, so that they can be checked against actual produrnon p d c e s during the walkthrough.

Finali.r.. h~sure rhar tk entire team wears whateversafety gear is appropriare for the areas of the plan! !mu will V U I L

Carrying Out Thle Walkthrough

The overall purpose ofthe walkthrough is to subject each detail of your production operations to fresh saurmy. As you examme each production step, ask yourselfwhy it is done the way it is. and hovv rt mght be changed to reduce toxics use. Durmg the walkthrough. team members should check your actual processes agzunst your

group's proc~css flow dugarm and chemical pathway analyses. Often, production units have been modrtied so that they oo longer operate as described in the ori@ operaring manual. Make sure rhm your dugrams correspond to reality, and modify them where incorrect.

input from w o r k c a n be mvaluable in determining how equipment in your plant really opemes. 'Ulben m doubt. ask w41y h g s are done the way that they are. It is important to undernand the huxtian benslons of your production practices so that you can avoid changes whch workers wlll fiocl unpracacable.

It is parncuiarty unpmant to keep your eye out for sources of byproducts which are not represented cm your dugrams. Pay anention to firmes and odors which might indicate that toxic matcnals arc escapmg. Look for possible sources of leaks, spills and evaporative losses.

Some toxl~c bn>roductr wll not be readdy apparent, even during a wallrthrough. For instance. unl~css you schedule your walkrhrough on cleaning day, you may not actually six spent cleamg flu& bcmg produced. even though such fluids can sometimes count as a toxic byproduct. Ek s w to ask worken about equipment cleaning and maintenance procedures. If necessary. revlsrt the produrnon unit when they are being carried out.

Walhhror~gbs often 'Iwd m a number of prelummuy conclusions about where mxics are being lost ml what mghr be done to reduce toxics use. As you ponder alternatives, keep in mind the fu1.l range of TLX methods: product reformulation, input substitution, process mdernuaaoa. process redesign. operanoas and maintenance improvements, and in-process reuse and rec:vchg. (These are described in greater detail in Chapter 4.) Remember also that worker intcn;lews can be invaluable sources of new ideas.

As ideas ;are generated. add them m your group's list of TUR alternatives. Use the walkthrough to b e p to evaluate the feasibhty of these possible changes. With the producnon prrxesses ngbt in front of you, it is easier to visualme the possible side-effects of each proposal on workers, equipment and other production processes.

Chapter 4: ldentifying TUR Options

4.0: Identifying TUR Options -- An Overview

At &IS pomt. !mu have developed a graphic understanding of toxics use parterns in your plant. You haw idnnrified some of the costs of using toxics, located the points at which you lose toxic maanal.s. and dcnrmned w h c h of these losses are most sigmficant - pe-rhps even quantifying them. You cnay also have begun to develop a few ideas about process changes whch would reduce your r c h c e on toxics.

Now your TLX planrnrng efforts enter the creative phase. The object of this phase is to geneme as cmpleu a lia as possible of alternatives for reducing your use of toxics andlor your cxanon of toxic bpmducts .

l&s chapu~ dcscnks; a brarnstorming process designed to elicit input from as many team members as poss~ble, so tbat your TLTR options will reflectavariety of perspectives and areas of expemx 'The brausormtng process is structured to insure that your team considers all possible types, of TLR

Of course. ~t 1s not aiwns oectssary to go through a formal options-generation prccess such as the bmmsmrmmg ses~on described in ths chapter. You may already be convinced that you know wku needs to be done. In that case, all that remains is to implement the change.

Howe\a. tbc m o a r)p~wl m~nake at t h ~ ~ phase is to settle for an inadequately small list of options. Keep m mmd the more oprionspu consider, rhe more likelyyou are ro select the one r h r LF besl/or .wwr planr.

4.1 : In-House Brainstorming

It is not easy to specrfi one opnons-generation procedure appropriate for all businesses. After all. each busmas has a d~fferent corporate culture and different decision-makmg practices. However. n IS !;trongl y rcc:ommendedthat you begin your search for TURoptions with agroup b rams tomg w o n .

Group braunnormlng .is designed to elicit input from all team members and encourage creanve thmhng. Since TUR b m t o r m i n g is very similar to the brainstorming done by quality cucles. many businesses will find it quite famihar.

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4.2: The Six Kinds of TUR

TUR can be adueved by a variety of means, ranging eom complete production unit redesign to srmple changes in work habits and toxics handling methods. Massachusetts state law classifies these various methods into six generic kinds of TUR options.

As noted above. you can insure that your search for TUR options is comprehensive by organizing your bmnsmrmiag so that you consider each of these kinds of TUR options in order. I f you turn to ourside consultants for funher help in generamg TUR options (Chapter

TUR ,ihifc 4.3). you sbouid make sure that these consultants also consider the full range ofTUR options. purormcwnworafrunorn Figure JPI o u t h a the six hnds of TUR as specified under Massachusetts law. m a h n m ~ . b u r h i l m h a d w u byproduco.

FlGUlRE 4& THE SIX KINDS OF TUR UNDER

STATE LAW

I. Input Substitution: H the toxic in question is used in the production process M e r than in the product itself, it is sometimes possible to repkt it with a less toxic or non-toxic alternative.

Z Prod~uct Reformulation: TUR can sometimes be achieved by refor- multin~g a final product so that the product is less toxic or non-toxic upon im use, rcitruc or d i i

3. Prucccss Redesign: T o x b use or byproduct generzltion can some- times be reduced or d~minated by developing and using production machinery of a diMermt design than the machinery currently in use.

4. Process Modernization: N R can sometimes be achieved by upgrad- ing or n w i n g production machinery with other equipment and mcthodb buAd upon the same production technology.

5. lmpnwed Opcrrclom and Maintenance: TUR does not always call for suphaticued technological innovation. Improvements in inventory control m e n a h handling, spill and leak prevention, personnel train- ing, andlor mahterunce p d c e s can often lead to dramatic reduc- tions in the use of toxics or the generation of toxic byproducts

6. In-Pn~ccu Recycling and Reuse: TUR can also be achieved by in- recycling andlor reuse of toxics. TUR recycling units must be to the production process.

Sometimes. TUR alvmanves arc difficult to categorize. For instance, some proposals might involve changes both m operatlons and in equipment design; others may involve both a product reformulanon and a chemical input n~bstitution.

When in doubt. the unponant h g is not to get the category right, but to h o w what counts as TUR and whar does not. It IS PP1 'IUR if you expose workers to increased threats, or if you shft your touc ermsslons from one mediuun to another while failing to reduce overall toxic byproducts. For maance. it woirld not count as TUR to precipitale heavy metals from your wastewater and send thc rrsulmg toxic sludge to the landfill. Such a change would not e h m a t e the regulatory bexiaches or the environmental threat posed by toxics; rather, it would mael y s&ft the t h r a from surface waters to land and groundwater.

Prodm dcimuhoon rr a

*a). a m brm d TUR It IS unportant to note rhat many sound and reqmnsible environmental practices do nor fall

- u K I W I - ~ a ~ ~ ~ l f ~ i a r ~ t under the rubric of TLX. Ttus manual focuses t:xclusively on changes whch cut back on - r e d u n c m i n m x u u m a n d toxics use or bypraiuct p a a n o n ar the source. Tius is not meant to suggest that safe m y urn el~rnrr~m 1 UJXJC tre-ent and hposal pmmces. OR-site recyc:ling, materials exchange, and unproved sub- from p u r phnc emissions maol am unrmportant. W of these goals are worth pursuing wherever toxics -. use or toxic byprductr cannot k eh ina ted entirely.

TUR Alternatives

1. Product Rcfomnlrtioo: Tbt fim L;md of TlJR alternative your team should consider is product rrfonnulvloa Your bmnstorming tcun members should ask themselves: How miphr our proJllrr be njarmui~red In order tcl reduce the amount or toxiciry of roxic ~~bsranccs m rr '

Produa refonnulanoas are mt possible in eve~y plant, as there are some products whch simply cannot be madc without toxic mgrediemts. However, where possible, product reformulauon IS very s ~ a c a v e - as ~t mums a sigmficant reduction in toxics use and may even elrmlnatc a toxlc a lqebcr frcnn your plant. Product reformulation may sometimes permit your company to boon uks by tapping into the growing consumer demand for "green" products

If your product formulanoa IS bcutcd by cusitomer specifications, youmight consider n e g o w g wth your ~woma m dungc those specifications - particularly if you come up with achange wbch eiimlnvl toucs u-hile m e e g all reasonable quality goals. Sometimes, your customers Dccd to k eduutcd in order to see the potential benefits of sound environmental pracnca

Figure 4B provlda m e ra l -wor ld examples of product reformulation.

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CHAPTER^: IDENTIFTING TUR OPTIONS-..

N R product r&uhoon may permit your comparrJ m boost sales by upping into the growlng consumer demand for "green" probd- UCKS.

Input S ~ b r b g ~ t l ~ a l b c chert hnd of TUR for your team to consider is input substitution. The operanvc t n t K C d d any wxic raw materials be replaced with benign or less wxzc SUOSRILIVS '

Input subsnartrom cm be v q attraaive, as they can dmmaacally reduce your liability exposure and a l l e \ w vow en\uonmental compliance headaches. They might also cut your raw marc& prrcharc coru md dqosal fees.

Figure 4C pro\* some d - w o r l d examples of input substitution.

1 FIGURE 4B: EXAMPLES O F T U R PRODUCT

REFORMULATION

I. The l@nt manufacturing industry has made considerable headway in rtpbsingtoxic m i n e d spirits-based paints with alternative water- based fiormulu (Note Not all water-based paints are non-toxic It is impoctmt to make sure that the new formula, however benign it sounds, b mty ksrr toxic than the old.)

2. Pum: manutrcrturen have also reformulated their products to elimi- nate heavy metab such as the titanium traditionally used in white pain- and the cadmium haditionally used in yellow paints.

3. Somte ink rmn-mrr have introduced water-based inks as an aJtemative to rndiciod solvent-based inks.

4. ?%era b a cumcrg-dge trend in the plastics industry to develop biodegvadrbk v-ed plastics as an environmentally sound aJtemative to truditiod petroleum-based plastics.

5. Somtctimes, p d u a reformulations can eliminate a toxic indirectly. For irwmcc. s e m m metalworking manufacturers have eliminated toxic cleaning and pamay processes by making metal parts out of stainless steel S i i a change might be classified either as a product reformula- t i o n a r u r p r c w ~ n r d e s i g n .

CHAPTER^: IDEN~FYINC TUR OPTION s...

Input s u h a n ~ a o n r can be nry accncme. as they can dnrnaacally r d u c e your lubtlrr). exposure. cur your purchase. d lspou l . and compliance costs. and ailenare regulacoq h u d - aches.

FIGURE 4C: EXAMPLES O F TUR INPUT

SUBSTITUTION

I. To date. the mast predominant 501% of input substitution has been the rephcement of solvent-based clea~ners and degreasers with aque- ous-based cleanem This sort of change has wide-ranging applications cutting ;.aocr a v t numkr of industries, including electronics, metahuorking. m d plating, and high-tech manufacturing. (See Chapter 4 3 for more information on solvent substitution.)

2 Some pulp a d paper manufacturers have substituted non-chlori- n a r d bleaches for toxic chlorinated bileaches.

3. A number of metaborking firms have replaced their coolant oils with watercbucd coolants

4. New alhline zinc bath are now being marketed to metal-plating commies as a replacement for toxic :zinc-cyanide platin,g baths.

3. Pr-s Rdcsgn: b h TL'R IS a&ueved by d~:veloping and usingp~roduction machrne.y of a different dalpm &an the madmqr cun-ently iin use, it falls under the category of process redesign. In b c u n n o m g about procxs redesign alternatives, team members should ask themselves: Are rhere alumanr.~ 1c~1.s o/m&ngourproducr which wouldmrroxzcs u s e a d or bpmduu gemanon '

AU cornparues engap pcndcally m process redesign. As techno10,gies change. so must your productloo cqruprnenf. O h . a process redesign can simultaneousfiy acheve your TUR goals and other butloess goals rclPted to prcxiuction costs. efficiency, product quality and production speed.

n e r e is often a fine lrnt bawten process redesign changes and lother, more modest changes whch fa4 tmda the next W g : process modernization. ?Iie &srinction is that a p m s s reden@ changes your fundamental pnAuction technology by introducing new prcxiucaon & q o f abffercnt deslgnthan yonr current machinery. By contrast, process modernizmon merely u p p k s or replaces exisang production machinery with other equipment and m e w s baKd upon the same pmiuaion technology.

Figure 4D pro\-~dts some real-world examples of process redesign.

A pmcus redes~gn char~ges your fundamenul producx~on cachnology. ~nvoducing new pmdumon machlneq of a different des~gn dun your currant mach~nary.

4. Process Mloderoizatnoo: Sipficant reductions in toxics use can often be achieved by upgradmg or rcplaclng produrnon eqmpment to acheve greater producnon efficiency. Where these changes do not mvolve a redesign of the production unit. they fall under the headmg of process modcmuanon.

When poadcnng process modemuanon techques , your team should keep the following quemon m nimd. Are [,here wa-vs to alter, adjust. modifj, or replace existing production equipment In order to n u toxics use andlor toxic byproducts?

Process modcrmzuion is actually ararher broad term, encompassing ar least two different sorts of changes. First, il: can include minor alterations or adjustments to existing production

1 FIGURE 4D: EXAMPLES OF T U R PROCESS

REDESIGN

I. A good example of a process redesign - one applicable to such industries as metaborking and electronics - is the replacement of a solvent-based paint stripping unit with a unit which strips paint with reunbkc abrrrive blast media.

2. A second exarr~ple - this one from the textiles industry - is the repbcecment of an old-fashioned dying machine with a computerized dying qnnt ion which conserves heavy-metal dyes.

3. Soma! pulp millls have achieved TUR process redesign by installing ozone b-hing processes, thus eliminating their use of chlorine in the bluching p r o c a r

4. Somat m d ptat- have installed automatic barrel lines which permits greater control of plating processes. Used with environmental ends in mind, such a line a n significandy reduce the drag-out of huvy nietak.

5. Somadmu, prwcu redesign can go hand-in-hand with other TUR tdniqlutr. For i n w e , the abmsive blast unit described above (example I ) invokes an input substiiution, for it effectively replaces sdvenur with rtr#;lbla b(m, media.

6. Ptocara redaugn myhr also go hand-in-hand with materials reuse (describd bekw). F a instance, some printers have extended the life of their wid etchmts up to tenfold by installing specialized equipment to monitor and cnnadly reconstitute their etchant baths Similarly, some chemiub and punt manufacturers have installed high-pressure wash systems or autonutic squeegee systems to clean away and reuse rntixing trnk d u e s

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--

CHAPTER~: IDE~IMING TUR OPTION s..

ln m a t mmpatua which have yet to pay much amymon m r h ~ r

mlda use p a m r m dnrmbc reducwm-ranaomaastughu 5 O ~ t - a n b e x h m d simply by tmpmnng oprroora

and tlulmrmnce.

companies which have yet to pay much attention to their toxics use patterns, dramatic reductions - sometimes; as high as 50 percent - can be achieved simply by improving operations and maintenance practices. This can mean bottom-line savings without major u p front costs.

At this stage in your group brainstorming, the operative question is: How might we reduce the needless rvaste of [he roxic substances we store, aansport, handle and use?

Improved loperanom and maintenance is a low-tech method for reducing toxics use. It requires relatively little technical research, and does not tend to have a great number of side effects.

All of tius c h s not imply that it is easy to improve operations and maintenance practices. Work habits 'can acqu~~! a great deal of inertia As a resulf successful changes require concerted andl s m e d commitment from worken and managers alike.

Like process modemzmon. improved operations and maintenance is a broad category, encompaEsrng! ~ v d sum of 'ltiR changes. First, improved operations and maintenance can mean a@~ta concro1.s of chemical inventories. Second, it can include improvements in

handling pmacts - both during the production process itself, and during the loading, Im ladmg and .storage phases which precede and follow the process. Third, it can mean changes; m the qulpment operations and maintenance practices.

The follow~ng figure pves examples of the various sorts of changes which can count as impmved opcranons and mamunance.

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Under Marrachuseru law. recycling only counn as TUR d it u done in-pmctu, by a recycling unit whlch u intcgnl m d x produceron unrr In wlucn the roxic substaxe is used.

team to consider here is: Can any of our roxic byproducrs be recycled and/or reused wirhour leaving rhe producn'on process?

It is important to note that not all recycling counts as Toxics Use Reduction. Under Massachusetts law. r q c h g only counts as TUR if it is done in-process, by a recycling unit which is integral to the production unit m whch the toxic substance is used.

The reascln for thrs requirement is that off-site or out-of-process recycling requires additional handhg and transportation of toxics - either within a factory or between two plants, via public hghways. additional handhng and transportation can pose a threat to the safety and health of the public andlor workers. Thus, while recycling toxic substances is usually bmta for the environment than simply discarding them, it is not the sort ofoptimum solution wbth TLJR encowages.

Some ewmples of TUR recychg are offered in the following figure.

1 FIGURE 4G: EXAMPLES OF T U R RECYCLING

AND REUSE

I. One rrewspaper printing operation found it pmfrtable to recycle its waste inks. adding black toner and ink to reconstitute them as usable bhck ink (This is N R under the law if the recycling is integral t o the

proc-.)

2. A number of rnetltworking companies have begun t o recycle their cutting oil by installing closed-loop collection sumps into which spent oil an t~ skimmed af.=ik, treated with biocides, and returned to the proceu.

3. A cmnmm recycling technique, applicable to a number of indus- tries, is the instalkation of a hard-pipe solvent still which is capable of restoring spent udvents by extracting oil sludge.

4. Many m e d phter, have found that by increasing the concentration of metall plating solutions in rinse tanks - perhaps by restricting water flow - tl7ey an muse rinsetank contents as make-up plating solution.

CHAPTER 4: IDEMI~INC TUR OPTIONS-..

4.3: Common TUR Principles and Techniques

OTA's techrucal W h a s found that certain proven TURtechniques are applicable to a wide range of Bav S ~ ~ L C busuusses. Your TUR teani may wish to add to its list of options by considering some of these achques : . which can be organized into fi,ve broad categories: cleaning alternanvcs, coolant alternaaives, metal!: recovery, life extension of chemicals and chemical baths. and g o d housekeeping.

k o n t y do m y organic 1. CLEANING ALTERNATIVES aol*.mr pore a -a1 e h r a c m 4r(U th -public ud th .nwr-nt rhar use

also can burdm compan-s wrch k*r l u b ~ l i n nslu and

A large number of ,Massachwm companies hiwe applied new cleaning substances and rechnolog~cs to reduce tbeu usc of o r w c solvents while cutting cleaning costs and improving workplace safety

smngonc w-1 h u ~ r h m d For instance, L. G. Ehlfour Company - an 1,100 employee ring, emblem and trophy s a f q regulaaona. manufacaurr bcued m Anleboro and North AaJeboro - replaced its chlorofluorocarbon

(CFC) cl-g m t with 3 lou.-bzmd (cleaning system which uses ISC- 108B (manuEaaured by Enwonmend S p e d a a Corporaion of Providence, RI). n i e change - which improved clejnrng qualln. reduced the number of rejected parts, and cut cleaning solution costs by 3S0. - pad for lbclf m 1.6 years.

Likmsc. Potamd Corporaaoo's pack film assembly plant in Walrham devised a new mahod for m n o n r ~ g grease budd-up from its punch presses which reduced its annual use of I , 1.1 t n c h l e (TCA) bv m m than 85%. while saving thousands of dollars in solvent purchase and disposal costs Polmold acheved these reductions by installing two w a s k g marhmes ci.pable of dcanmg pans with water an.d a rust-inhibiting detergent.

Solvents w reductmoo should be a hgb-pnorily goal of all environmentally responsible and worker-Mth coasc~ous cmpama;. Solvents ;are the most commonly found contaminant at federal Superfund clean-up slm .Many solvents are neurotoxic, carcinogenic, volatile and flammable; manv of tbem oocrmburt IO ground-level ozone, while some contribute to the depletion of uppcr-atmmpberr o m e rjot only do these organic solvents pose a critical t.hmif to worka health and safe, publnc health an~d the environment; their use also burdens companies wth hem? lubhn. nrlcs a d stnngenu federal health and safety reguhons.

There arc fcur gcncd appmxbts to toncs use reduction in cleaning operations. These are (in order ofprrfcrabilrt? I ia 1 elmuamon ofc1e:aning operations; (b) solvent substitution; (c) solvent mmrmu=uloa. a d r d r solvent rrcovet-y.

(a) Elimination of Cleaning Operations

Like most o tha forms of T'LR rtduclng solvents \use requires a thorough understanding of yourproduchon processes Ooce vou b o w whaf role your cleaningplays in yourproduction process, you can kgm to dcwrmne whelther some of your solvent cleaning can be elmmaled.

Ask yourself Do we ~ d v need to cl~ean as much as we do? Can we prevent things from gemng dl? m tbe fug place? Are there alternarive production processes which do not require extrnslve pans cleulmg' Arc there dungs; we currently clean with solvents which could be cleaned with a dp rag. vacuum, blower, or with soapy water and a brush?

hlany comparues have found crcanve ways to ehmimte parts cleaning steps while cutting cons andor mcrcumg prcductlon efi~clency. For instance, the Reliable Company, an

Anleborebased elemoplarer with 1 1 employees, was ordering metal parts fiom Southeast Asia The manufacturer covered these parts in grease to prevent tarnishrig during shipping, andReliable nmoved the grease with solvents before usingthem. The firm eventually became aware that when the cost of degreasing was added to the cost of the imported parts, they were as expensive :IS comparable parts made by local manufacturers. Reliable switched to a local supplier whox parts amved clean of grease, thus cutiing its solvents use in half.

(b) Solven~t Substitution

Ask younee Do we really need to dean as much u do! Are there akerruwe! producaon processes which do not require orrtnrne paro clean~ng? Are &re chimp m currendy d u n wich solwno which could be cleaned some other way;'

When clearu~lg opaanons cannot be eliminated altogether, the next best alternative - particularly fi.om a worker safety standpoint - is solvent substitution. T ~ I S techmque is applicable to a wide range of industrial cleaning and smpping operations spanning such indusma as pmtmg. plasacs. metals fimshrig and manufacturing, electronics. vehicle manufanmng and aerospace.

Solvent sul~sunrnon can help to rid your workplace of toxic vapor degreasers - the most common of w b c h arc mchlomethylene, perchloroethylene, methylene chloride and 1,1,1- aichlorcctbre. Many common vapor degreasing operations can be carried out with readily avadable war-bared ckmers.

Thcx new aqueous cleaners typically contain rust-mhibitors and hlghly effecnve organic surfactants ~-tllch clean unmersed metal parts without retaining contaminants in the cleaning solunon. 011s; float to th*. top of the cleaning tank and can be skimmed off, soils sink to the bottom and cam be removed by filmxion. In some cases, the result is an almost indefinitely reusable clearer.

There IS no foolproof formula for chmsing an appropriate solvent substitute; the choice will depend upon the mavnal you are cleaning, the nature of the contaminants, and the technical &man& of your produrnon process. OTA can provide information about aqueous- based cleaners, mcludmg - srudies of successful applications and lists of suppliers. Call OT.4 at (617) 727-3160 for more mfomation.

(c) Solvenit Minimization

As long as v a u plan1 coo,Mua touse any solventsalall, you should pursue low-tech changes in your work pracaces whch can help to minimize your use of these solvents.

You mat kp b> enamllllng your solvent tanks to make sure that they are designed to minimize solvent ux For mnance, each tank should be firted with a cover which should be kept m place tbkn the tank IS not m use. T h ~ s alone can cut evaporation by as much as 50%. You can also 1x1 e\.aponuloo bv using a deep, narrow tank with a small solvent surface area and a bph freeboard (sea above the vapor level). Another method is to add cooling coils for increased vapor coodknsanon.

By p d m g pans from the tank more slowly, you can cut the amount of solvent "dragged out" of the tank If you have an automated cleaning tank, you may be able to reduce drag- out further by adjusmg I[ so that pans are held above the solvent bath and h e d after they are withdrawn. (If your tank 1s operated manually, h s same technique could pose a threal to worker heai,th. ) And ~f you spray solvents, you can cut evaporative losses by using a coarse stream rather than a very fine spray.

You rmght also wish to ask yourself a number of questions about your cleaning practices. For mstance: Are there pans cleaned in vapor degreasing tank which could be cleaned with

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set up a centrid stanon for recychg coolants by filtering and coalescing tramp oils. The equipment cost S20.000 to install, and has resulted in aunual savings of $8,000 in coolant purchase c m ; , S 10.000 ID coolant disposal costs, and $8,800 in machmery down-time.

Improved cmlants management can help a wide range of metal worlang companies to reduce thelr Liabilrry exposure and tool replacement costs. cut their coolant purchase and W s a l costs, and mprove the workshop environment by elimrnating rancid coolant odors.

On the other hand. poor coolant management can lead to a number of problems. For instance. if coolants arc not properly maintained, bacteria can breed in dead spots w i t h the machmcry. where p t and sludge build up. Valuable production time and dollars can be lost in replacing ctmlants Poorfy maintained coolants can increase tool breakage and decrease product qual~ty. In a d d n o s frequent disposal of spent coolants can often lead to violations of effluent &charge Im~ts .

Then arc a number of proven techmques for improving coolants management, including: (a) coolant subsntunon. (b) coolant recycling; and (c) improved coolant maintenance. These methods can often m m the iife-span of coolants by two to threefold.

(a) Coolant Substitution

Due to recent ed~ances m emuls~on technology, straight petroleum oils can in many instances be rtpW wlth uattr-t& coolants. These new coolants are made from emulsions cmtammg hgh-pressure addrtlves and lubricity packages. hd purclxue conr of t h e ernuls~ons may seem higher, but once diluted to proper

workme Cooanmons . thst water-based coolants can be as much as 50% less expensive. They can also ulsber m rtdumoas m waste oil dsposal costs and liabilityrisks, while reducing your w of solvents for c l u n u ~ g hands and degreasing parts and machmery. In a situation where large quantincs of coolant arc being replaced, this can amount to a significant savings.

Sw~tchmg to an e m S l m coolant can elmmate oil mist and smoke, improving operating concLnons MSS the -1 floor. Many facilities have been able to increase their speeds and feeds after coolvtmng to uw-based coolant. T ~ I S is due primarily to the better heat-transfer propemes and b o r n bwtnny of the water-based coolants. Increased production rates spell funher sabmgs, m m a c b a d labor tune.

(b) Coolant Recydiing

Coolant recvchg u c h q l u a wn stretch the tife of coolants dramatically while helping to exrend tool hfc, rmprove product quality, decrease purchase and &sposal costs and improve w o h g coachnoas for employees.

Then arc manv ttchwlopes avadable for recycling coolants. One of the best techmques is to r e c b coolants thmuph a combination of particle f i l m o n and cenmfugal separation. Filaarion wn bt used t o c l ~ m t h e largermetal chips created by grinding,rnillingandother processes. while mmfugauon can remove remaining metal fines as well as hard-to-extran emulstfied 011s and rome 'bancna

The best place ro tnscall metal c h p screens is at the coolant entrances to work station sumps. Largerend-of-p~pc scmns can be placed at the central collection tankif coolant sumps cannot be m d f i e d .

If your cooLants arc contammated by floating tramp oils, these can be removed by using a belt or disc J . ~ m c r Belt skunmers have the advantage of depositing waste oils d.uectly

into storage containers. wide diu: skimmers are easier to install and operate in areas where space is tight.

It may be advantageous to clean and dry yourreclaimedmetal chps in achip spinner. Spun chips have a tugher resale scrap value than "wet" chips and are less Likely to leak oils or coolants in the socage area In many shops, chips are spun not only to recover valuable coolant but also to decrease envrronmentai liabilrty. Scrap dealers are becoming partial to "dry" ch~ps for ~ I C same Itabhry reasons.

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(c) Coolant Maintenance

Properly mainwed codant should not need to be discarded - only supplemented to make up for drag-out iossts. Three brtr~c operations can save an untold quantity of coolant from depdmg and &g rrpbcemmt:

+ Machines *Id be rigorourty cleaned of all chips, sludge and residue once every year. Shoveling out the sump is inadequate The machine must b e thonwrghty cleaned out All keyways, colrners and troughs should b e flushed c w .

+ The entire machine ought to be washed down with an alkaline-based cleaner to kill ofT m y d u a l bacteria and fungus.

+ Refilled sump must be pumped out on a regular schedule. Maintenance should be performed as part of your routine work schedule rather than frt in as an a d v t t y during s k u work periods

By carrying out these a n d acps md antrxfuging your coolant often, you can keep bactma growttr to a mlnunum Thrs caa reduce the need to "shock coolants with biocides - a process wh~cb IS run always dfcctlve and can cause dermaritis among workers.

A number of other. kss m o d opatnng practices can also enhance cnoiant peffonnance and life-span. For uraancc. a mfmmmeter or titration kit can help maintain manufacturer's recommended &I-@u;ucr NIOS nmply and inexpensively. If you are using water- based coolants mu& uirh pamculuty hard tap vvater, the life of y o u coolant might be extended by ~nstallrng an too e~change column to remove ionic contaminants in the make- up water.

In many ass. a ngmxs machnc mamanance ]program to replace worn seals and hoses can cut h ydcuhc flwd lcrks a d subsequlent contamination of coolant sumps. These oils are the food of cho~ce for a t r h c d anzrobic bacteria Once bacteria begin.multiplying, they feed upon the corrosloo mhrbttas and amulnfier packages in the coolants, leadmg to fluid detenormon. o f f t~ave odon and p r mi perfomlance. A proactive approach to machine maintenance w ~ l l &use m.,rhlne down-time due tr, parts breakage.

In some cases. n m y be mportant to educate machine operators to meat coolants as an extension of che cumng tools and not as a waste basket.

By uslng l u s rinsewater, dnggebouc menis can be concennaced in a smaller volume of mar. making k much ttr ler ro recover meuls or muse metal plaong soluuons.

3. METALS USE REDUCTION I N PLATING LINES

Howard H. Sweet 8: Son. Inc., an Attleboro jewelry manufacturer with 125 employees, responded to p u m g rcguhory pressures in 1985 by investing in a vrrmally closed-loop metals recovery system wtuch dramatically reduced its toxic byproducts. The system, which recovered 263 troy ounces of gold and more than a ton of copper in the first year, paid for itself in less than 12 rnmb and henceforth saved the firm more than 5100,000 per year.

Anorha A t d e b b a s e d silver planng firm has employed a metals recovery system to r e c b more than 5100.000 per year of silver dragged out of its plating solution.

Thesc firnls are two of a growing number of jewelers, metal platers and printed circuitbaud nsanufacnrmrs whch have used TUR techniques to reduce the concentration of heavy metals :m their wancwartr while simultaneously saving on metals purchase, treatment and d q m d cm

Metals rnuumumoa rcchques can be broken down into three general categories: (a) water cownanoa . tb I plaung solutlon recovery; and (c) metals reclamation.

- (a) Water Consemtion

Since water cr oor mxlc w t ~ r coa~rvaaon does not itself count as toxics use reduction. However. m nlany c a v ~ water c d o n is the first step toward effective metals recovery. By usme less n n ~ c u . ~ . . bragged-out me& can be concentrated in a smaller volume of water. makmg ~t much easier to recover metals or reuse metal plating solutions. Tberr arc a1 number of slmpk ways to conserve on rinsewater. One of the easiest ways is

to mnall so-called ---our" tanks (still-water rinse tanks, as opposed to running rinse tanks d w l y ario thc planng barh tank and before the running warer rinse-tanks. llm insures thm pans emcr tbt n m g nnsewater cleaner, with fewer contaminants.

F2nsew-r can a b bc amsend by placing flow-resmctors on running rinses, and by using ncounu~-cumol I-- The idea b e h d counter-current rinsing is to connect running W M n n m a k s PO b t rmvu.%r flows through each of them in sequence - in the oppos~u duetam of producnoa l u x work - before being discharged as wastewater. The relatively clam m a u r bcm tbe final tank is thus reused in earlier rinsing stages.

Before anv ar~mpt u I& to recover metals from rinsewaters, all efforts should be made to prevent p i m g SO~UIIOCI from "draggmg out" into rinsewater to be- with. Some common tcch~arquts for c m c q m g drag-out can be found below, in the section entitled "Life Extension of (Cbemlcds md Chemical Baths."

- CHAPTER 4: IDENTIFYING T U R OPTIONS ...

Enponuve recovery. In

coquncnon w d ~ ocher TUR techniqusr, can somattmas make possible an mneimly doled-loop plaong line whlch d~schargas no rrrstmwater.

(b) Plating Solution Recovery

After drag-our tanks have becn mdaiied, it is solnetimes possible to use their contents as make-up for evapna&vc loses from the plaMg tank. Tbls isone ofthe easienand least costly forms of drag-our rtductmn. If you opt for such a "direct drag-out rerurn" procedure, be sure that your dragan mnks arc Wed urrth deionized rinsewater which will not contaminate your planng wlunoa. and be sure to mmtor and maintain concenuarions of metal plahng soluoon and key &oves m your planng tank.

You can mcrc3sc the amount of drag-out returned to your pianng ranks by running spent nnsewavn through an e\aporatlve recovery unit. ]However, standard evaporative units may increase a rrmss~oas and expose ~~lrktn to health risks. If you opt for evaporarive recovery, you sbould eithcr use an enclosed evap~rator (also known as a cold vaporization urut). or your sbould filter. t r t ~ and rernvcr metalis fiom your rinsewater before fe&g it into the evaporaux

Evaporaave recovery - kn uud Im conjunction with countercurrent rinsing - can sometimes return drag-out a woccnuanons greater than the origrnal plating solution. In fact, it can someames make poss~ble an m m l y closed-loop plabng line wlh~ch dscharges no wastewam. For msance. a Nath C a r o h manfiacturer of nickel-plated keys was able to ehmrnate wastcwscr *ges bv mvning rinsewater to the plating tank and using an evaporator and carbon filter to mamtarn~ the nickel concentration and purity of the plating bath.

(c) Metals Reclamation

Whether or not you aun to acbeve a closed-loop plaMg line, you may wish to investigate the broad range of commercially availablle ionic recovery technologes, whrch can be used to reclaun many common surface-planng metals in a~reusable orrefinable form. Recl;umg these metals can cut back dramancally on sludge generation.

Electrolytic recovery hclauns the positive ions of suchmetalsas gold, silver, tin, copper, nickel, m c and d m l u m . I t is the only metal recovery t e c h q u e that recovers only the metahc content ofthe drag-out. T ~ I S is very attractive because the solid metal recovered by elecrrolysls a n elther be reused or sold to a refiner.

Ion exchange technology uses nanrral or synthetic resins which can recover h g h percentages (90-95O.0 r of chromum, gold, silver, ~III and zlnc from spent rinsewaters. Ion exchange uru~ts are qu~re durable. use little energy and work with relatively dilute rinsewaters. If you wish to innall an Ion exchange unit, make sure that you choose the resin appropriate for your applicanou and tha you install a carbon filter before the ion exchange unit so that it does nor become foul'cd with organic contaminants.

4. LIFE EXTENSION OF CHEMlCAL BATHS

IBM has exta~ded rhc life of ammon~um persulfate e t c h g bath by devising a protocol for the additlon of fresh @&ants m order to maintain constant and precise pH levels. IBM has also begun ro mgenente spcnr jcid etchants by bubbiing ozone through them to revexse the oxidano~redumoa rcunoa whrch normally snips the etchant of oxygen. As a result, toxic etchanr baths 'v. h c h uez: m c e discarded every 12 days have been in continuous reuse for several years. and hasc come to be known among IBM engineers as "immortal erchanrs." Tens of thouurn& of doilars has c been saved m erchanr purchase costs. And because parts are no longer tttcbcd poorlv m the period immediately before baths are discarded, IBM has significantly n:Cuccd cbc number of parts wbch must be rejected, netting another 9 . 5 million in savmgs.

The "unmoW etchanu" c u e 1s one part~cularly dramatic example of a generic lTJR pmciple: w k r c poss~bic. extend the life of chemical baths. T h s can be done by a variety of means. mcl idmg (at dmg-lo and drag-out management; (b) improved bath mamtenance; and (c) bath rcgeocranoa

(a) Drag-In and Drag-Out Management

"Drag-out" refirs to chemlcal solunons dragged out of a b~ together with the parts or marends reared m rhe bath. "Drag-in" refen ro chemicals wbch enter a chemical bath with the parts or maueds reared in it. Together, drag-out and drag-in can quickly deplete or

, ~ ~ . ; . I- .L-. l , r L L . I I I ~ - -

CHAPTER 4: ~DENTIFYINC T U R OPTIONS ...

Careful montmnng of soluoon pung. pH levels. m m p m t u r c wncencnnom and ocher opanung panmet .n may hdp m srnnd dunon lifa It n u good for cost corrad u fur cht ennronrntm m amurc

contaminate chemcal baths. forclng operators to1 discard them needlessly. Drag-m volume is closely related tr3 drag-out, as the solution dragged out of one tank is

quickly dragged m to the next tank. The volum~e of drag-out dependls upon a number of h r s , includmg: surface tension of blath; viscosity of solution; size, shape and orientation of parts or mafenals seated in the bath; the speed ;a whch materials are withdrawn from the bath; and the amount of tune allowed for dramage back into the bath.

Where possible. surface tension should be minimized in order to reduce drag-out. This can sometimes be done by htanng the solution 01: by adding wemng agents to it. Either of these changes must be invtstlgated tmfully before implementation, as it may lead to troublesome side-effects. For mnance, heating the solution may interfere with desired chemical reamons or may umease evaporative losses, while wetting agents can create troublesome foammg m some pnxxssimg baths.

Solution viscoslry can be reduced either by heating baths or by rniniminng their concenuafion. Someames, chemrcal suppliers recommend stronger solutions than are necessary and solutions can be diluted without any effect on product quahty. Again,

tfpr t h a t pncncsr arc assessment of t h ~ ~ son of change requ~res a clear undemanding of your processes. followad. There are a number of othcr low-.uchnolog/ methods for mininlizing or otherwise

managing drag-m and drag-w. As ma3rioned abcbve, still-water rinse tanks can be installed in a processing h e before aod after chemical meatment tanks. Tanks installed before a chemical treafment tank can hclp to muumize drag-in, while tanks installed after a chemical aeatmeot bath can k l p to coatam --out in a siingle concentrated rinse bath.

Drag-our can also be mmrmutd by withdrawing materials slow1 y from chemical baths and by suspending pam and mapnais above processin'g tanks after they have been withdrawn to permlt d m m g c back ~nto the tank. m e can te encouraged by orienting pans properly on racks andor by shakmp or rotanng them after they have been withdrawn. In ad&tion, if your tanks are arranged m a producrmo h e . drag-out can be further minimized by using slanted "drip boards" ro cover the crack; between adjacent tanks and return dripped solution to the tank from wbch ~t came.

You may also uuh to mvatl_gac th: w d e range of generic devices (e.g. squeegees, felt blocks, baffles. au k n ~ v e s a d blower k s ) which are designed to minimize drag-out and drag-in. The appropnvc cbolce ~ 1 1 depend upon ttieapplicatlon at hand. For instance, OTA recently recommended tbaf a company w ~ t h a wire galvanizing line insrall a blower line to blow off m w c acid from w m s before they entered the rinse tank.

(b) Improved Bath Maintenance

Sometimes, baths dcmm because workers do not adhere to proper operaring practices. For tnstance, etchants a n become cxbamed prematurely because pH levels are not monitored and adjwed frequently enough, whde coolants can degrade more rapidly than necessary if sumps arc not kept dean.

Dependmg upon the case at hand, careful monitoring of solution purity, pH levels, temperarure. concenmons md other operaung parameters may help to extend soIuuon life. It is as good for cost control as for the environment ti1 ensure that these practices are followed onaroutine bass. It mavalso be helpful toeducate equipment operatorsahuttheimportance of keeping chemical baths clean and free of liner and other contaminants.

It is somenmes possible to metch the life of chemical baths by using mechanical agitation rather than a.u agitatlon. whrch can contarlIllnate baths with machtne oil and carbon dioxide.

(c) Bath Regeneration

Many companlu undercltl- mate ~ - K J amoum of m x ~ c rubrances whlch escape Into the hccov envlronmenc dur~ng stooge and handling, due to such hcwn u lulu. acc~denal rp~l lr and evrpoo- oon from ~mpmpaly scored chem~calr .

The Life of nnany chemicals can be extended by adding reagents, stabilizers and other key components when needed. For instance, fixlug bathsused in the commercial printing industry can be suached by addmg ammonium thiosulfate, which makes the bath effective at higher s i lve r -mt lon levek.

Chemcal baths can also be sustained through a variety of filtration techniques. In-tank filtraaon is ~lanicuiarly safe and effective, as it does not intempt production processes, nor does it gve ~nse to the spill and leak potential associated with out-of-tank filtrarion. There are a vnde array of nimvely inexpensive (MOO-$1400), commercially available in-tank filters - somlc of whch perform suchadditional functions as bathtrearment, agitation, surface contammant skmmmg and tank bottom vacuuming.

If you m;tall a film. make certain to use the filter carnidge most appropriate for the applicanon at hand. For mnance. it is usually best to use the coarsest filterwhlch can remove the common ~conamlnnnts m your bat . , as these filters will last longer and permit greater flow rates. If ,wu;rre filtering out organ~c compounds, it may be best to opt foracarbon filter which will minrmnr orgarnu budd-up.

In rnanv cases. f i l m should be run even when the barh is not in use, as impurities are often dragged m lr~m rapidly than fihers can remove them.

In addmao to filaanoa. there arc a variety of other means for removing impurities from chemical baths. For mtance, cornmerclal printers can reclaim and sometimes reuse their fixing baths by usmg an e l m l y u c recovery unit to remove silver from it.

Srrmlarty, spent etchants can be regenerated and reused by a number of processes - includmg elemlync re.movaJ of waste metals. If you are discarding such etchants, you may wish to look ;u the cons of make-up chemicals for the baths, pH balancing chemicals to stay in c o m p h c e w~th cischarge h t s . and the value of metals whch might be extracted ffom your spent etchants and sold back to a metals reclaimer. These figures often underline the econormc w:sdom of msvesung in an etchant reclamation system.

5.GOOD HOUSEKEEPING

Many comparlues underemmatc the amount of toxic substances whch escape into the factory environment d w g aolrage and handhg. Slow leaks, accidental spills, and evaporation from impropttrly nored rhrmcds can add up to significant losses. These losses are not only costly and m:ffic~cnt - they may also pose a threat to worker health and safety.

Often. sur~pk and dramancally effective TLJR can be achieved by introducing sound chemical housekuplng pradlces. G d housekeeping is a form of TLJR whch applies to all toxics users - regardless ofthelr nze or h e ofbusiness. It can include: (a) improved chemical inventory management. (b, Improved storage and handling practices; and (c) spill and leak prevenaon. l b e ~ g d s can somenmes be promoted by employee training programs and by htroducnon of incentives for clean practices.

Thrs IS one of many areas m whch worker cmperation can be critical to your TZTR efforts - and one more r e a n to ~nciude workers on your TUR team.

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I . CLEAlYlNG ALTERNATIVES:

(a) D~m~rn~oon d O u n n g Openrions: Clean fewer materials.

(b) Solr*nt Subsuo~oon: Replace organic solvents with aqueous-based cleanen.

(c) Solvent fl~n~mruocm: Cover ranks. Minimize solvent surface area. Use high freeboard. Remove pam slowly and dn in well. Consider rwo-stage cleaning process.

(4 Solvent Rcorr).. Use solvent d~so'llation or other method (decanrarion. filarrion. e n p o o w a . c e n d u g l purifiamon). Consider vapor recovev.

2. COOLANT ALTERNATIVES

(a) C d u r Subsoaronn: Replac. oil coolann with water-based coolann.

(b) balun Recyclln~ Ca\rd.r canarfupoon. f i h t ion , oil skimmlng and chip spinning.

(c) b o h r n Ma-ncc Conduct thorough machine cleaning and regular pumping of sumps. M a ~ ~ n o ~ n cwlanc-wamr nmos. Consider ion exchange.

3. METUS USE m N IN PLATING LINES:

(a) W r r u Gauwvamn: U.. -put rank and counrtr-current rinsing.

@) R . q b(- R u w Uw d r a dng-out return. Consider cold nporintion.

Aim for dosod-100p p b q .

(c) f l d R u h r n a ~ n . Comdr r J r + r o l p c recovery andlor ion exchange.

4. UFE EKTEWSWN OF O(MU BATHS

(a) Dng-In and Drag-Out Mmrymenc Achieve lower surface tension. Reduce viscos-

~ ty . leadl d n g - 0 ~ olrJL drip boards. b a f n u ecc. Remove pam slowly and dnln well.

(b) I m p m r d &rh Ha-r Monrcor soludon punr).. pH. cempenrure and o*er panmaten C m s ~ d w m c h r n ~ c r l rglooon.

(c) &rh & m o o n . UI. mapno. subilcren and o d ~ v addiriva. Consider filtration. elecudpu d o r 0 t h ~ bath mgenennon achniquu.

5. GOOD b4OWEKEE-

(a) Ch.mwal 1nvovm-y Mrnrgemenc Buy chemials as needed. Use in order received.

@) Impruwd Storage and Handling: Minimize rnffic and mainrain proper smnge

condroom. T m n 4 r k ~ ~n rmanais arnsfer.

(c) Sptll and L u k Prw~snoon: Replace laking equipment throughout planr Tn in

workan and offer Incenmva for spill mlnlmtzadon.

4.4: Bringing In Outside Help

Some c o m p m a may tind &ax their group brailnstorming, guided by the TUR options herarchy, will generate as brad a range of TUR crptiom as they need. However, in-house brainstorming can have senous limitations, particularly for those companies which lack u p to-date techrucal knowledge of alternative, environmentally responsible processes and technolwes.

Since it IS ~ t a l to consldcr as broad a range of TUR options as you can, you may wish to

O m d d m k r c \ r r p m l a m a b o ~ N R oeporarnoa u m c o m a tndurrr). c o l k a p u ud a n m d wad. urocnoan mooungs whch much on cumng-ow ormronmonal cochnolog~~r .

look for help fm outsldc your plant. There are a number of ways to use outside resources in order to increase your team's

knowledge of TL?Z alwoanva and supplement yolur growing list of TUR options. One of the best ways IS to learn from mdumy colleagues by contacting them informally to ask them about their expenaces uqtb TUX Professional m d e magazines are ofkin useful sources of TUR lnformanon Lo addma. team mmbers could be sent to hade association meetings and other wnfkrmces whch touch on cumng-edge environmental technologies. You might also consider asngnmg earn membels to conduct some research on common

TUR alumaaws for yw d u r n ) . The state M c e of Technical Assistance maintains a librap of tcshn~d puM~aaons on TUR- A partial annotated bibliography of the library's tcchcal macnak u rrproQccd m Appendu 3 of this manual. OTA's library is open to the public; call (61f) 727-3260 to arrange a visit. You may llso auh to enroll cmc or more of your team members in classes on TLJR

p h m i g . Uodcr szu lau . the Lmvtmy of Massachusens at Lowell has been chosen as the sac's T o n u L'sc Reducrlc;~ kmrdilu :XW, and has been c h g e d with researching tcchmcal TLT ~ ~ ~ r s . and uqtb mming i n d u q employees and enwonmental consultants ur TLiR planmg Mom mfonnaion about TURI's classes can be obtained by u n m g to: Toxicr Use Reduction Institute Uoivarity of Massachusents at Lowell, One University A m u c LorcU MA 01854; or by callkg (508) 934-3275.

Altcmauvel?. you cyl d l upoa OTA's tox~c use reduction speclalists to visit your plant, study your productmn p-. and m h t recommendations on TUR changes appropriare for your plant. You can contact OTA by w n m g to: Oflice of Technical Assistance, Executive Off- el Eawroamard Affairs. Room 2109,100 Cambridge Street, Boston, MA 02202; or by d r n g (617) m-3260 on weekd;nys between 8:45 AM[ and 5:00 PM.

OTA's vchruul coasul- sbould not be seen as a subsrinrte for in-house TLJR planmg and br;unstamurg. but &a as a wful supplement. A s u c c e ~ TUR program r q m s a hgh level o f empiowe rnvolvcmcnt - both bemuse employees know your plant ben. and becausc tbcu coopamoo is needed to malce TUR process changes work. You may also vrlsh ra nrpplcmat your TURbmnstorming by &g in an environmental

consultant. Consultants wth e x p c m x m enwomlental engineering can be particularly helpful in prcpanng enguwenog fcas~bility studres. drawing up plans and specificaaons for process changes. and des~pmg speclalutd equipment whch is not avadable "off the shelf."

If you do retun a coasulunt. be careful to choose one who is knowledgeable about TUR. Since t o x l u lrse reducooo IS a relanvely new approach to induscnal pollutants, many consultants have yet to prim much experience with it.

Chapte r 5: Evaluating and Select ing T U R Al ternat ives

5.0: Evaluating and Selecting TUR Al terna-

tives --. An Overview

Y ourturn hi now gavrated a comprehensive list ofTURalternatives forthe substances and/ or processes rlndcr cona~dcmoa The next step is to evaluate these options and select one or more for unplemcntahm.

Ths chapter pments an evduatlon method which begins with aseries ofi'screens" which any opuoo mlvt m l e m order to be considered truly feasible. The point of these screens K to h i t thc: number of full-fledged analyses which your team will have to do, as such analyses art tune-consurmng However, it is important not to eliminate options too hastily. In many crstr, successful T L R requlres a creative exploraaon of options which seem impractical o firs glance

At any rsu. oau rh field of Jtcrnanves has been narrowed, you can submitthe remaining TLJRpropodls to a m m dmaded scrutiny. examining theirtechnical merits and compatibihty w t h manapnxil gods tad worker practices. Most TUR teams will also wish to subrmt compeung p n m s ro r &led finanual analysis in order to determine whether up-fkont expen&nrm arc ecoaormcall y justified. An adequate financial assessment may require, among otha ttungs. a dtgllcd elalumon of costs which many firms lump together under the generic h e h o g "ormixad" Pan 3 of thLs chapter describes such an assessment technique.

As these eitalusnoas are m e d ou t it will stan to become clear whether the provisional TLJR gcais wtuch your esn has set (Chapter 2.3) are either overly ambitious or overly modest. You m y wish to firm up your goals as you see what kind of improvements are feasible ar yolu plant

The evaluanoo p e a s rrcommended m h s manual is outlined in Figure 5A. Each of the steps s &sc.-ussed m gcslcr detail m subsequent parts o f h s chapter. Of course, the particular series of screens and elaluauons outlined in this chapter might not be appropriate for every company Your eam m y wish to m d f y the process by adding or subtracting criteria to reflect your f%m's envuonmental goals and business objectives. Yournay alsowish toassess your processes mmg the same cntena that wilI be used by upper management to decide whether the project sholnld be funded.

FIGURE 5A: A FRAMEWOlRK FOR EVALUATING

TUR OPTIONS:

+ PRE-SCREEWG Is the propclsed change an example of TUR? ' Is the change clearly impramcal'? Is the chang:e acceptable without review?

+ TECHSICU ' Gwen unlimited resources, can it be done? SCREL!'iiC ' Nlm is the TUR potential of the change?

+ FINAVCLU. ' L the cost a s i h the firm's budget capacity? SCRELWG

+ ' Vu'ill it create environmental problems? SCREL!'i?;YC Will it create risks to worker or public health?

+ TECHMCAL L; equipment commercially available? ASSES34E.M Lb'ha! LS the ~equipment's track recard?

Can equiprn~~nt fit in existing space? Dots the &mge require new utilities? U'd the change have side-effects on quality? Wdl the c h g e affect production rates? ' Will the change affect other processes?

MrtYAGERlAL ' Is the change a sustainable work practice? ASSESS;\fEST ' How much raining dms the change require?

' Can in-house personnel execute the change? ' How easily can the change be implemented? ' How much down-time will the b e cause?

Will it help to insure regulatory compliance? ' Will it help to reduce regulatory papenvork? ' Will it rcqunt new environmental pemuts?

+ FINANCIAL ' What are current operating costs? ASSESME.. ' Whch operating costs might be changed?

' What is the project's total cost differential? ' What is the project's total capital ~:ost? ' What is the project's payback p o d ?

Screening Options

Before yourtrrvn meea to bcgm assessing TURaltemarives, it may be wise to give each team member a kt of all opnons under consideration, together with a copy of Figure 5A. This should provoke thought about the feasibility of various TUR alternatives, helping to make your fim optlous assessment meenng as fiu~tfid as possible.

Your tc&, probably ~~ not be able to completethe evaluation of all options and select - a course of acnon m om atnng. A thorough techcal and financial evaluarion of the most

You might find dut some opnons are so stn~ghdor- ward. inexpens~vc effacr~ve and easy OD implement that no furdrer ussrsmenr IS

needed in orda to approve them.

promising ogaons sill u d v r e v considerable research. The goal of your first options evaluation m~eeang should be to sueen out unacceptable options and narrow your list of alternanvcs ti> those whnch are most deserving of further attention.

As you narrow tbc Lcn of &date TLR changes, you should be able to determine what data you u ~ l l ncad to complete your assessment and choose a course of action. Appropriate team membar cyr be tsslgPCd to wcure thiS information and report back to the group.

It is also a suund &a to k a p a permanent record of the options which you consider, and of your r t ~ n for rqecung that whch you do not implement. Thu may help you to avoid r e inven~g rfu u-hel m turure yeus, as your TUR program grows.

Options P+t-Screening

The fim task IS to _po through vour 11s of alternatives one last time to make sure that each falls under the mbnc of Torra Cse Reduction.

The key qcrcatoa IXTT is u-hrber the change promises to reduce the use of toxics and/or the genervlocl of b ? p d c t s af th source. Screen out any options which merely sbft toxic byproducts fnw one u a r ~ arryn o another, or which meat or recycle byproducts after they have alrwdy leit thc prwfuctwn rma Thex may be worth implementing - but they are not TUR

You mlght also find dw sane opooas are so straightfornard, inexpensive, effective and easy to impbnenr chat DO funfwr assessment is needed in order to approve them.

Technical Screening

The task hcrt a to elrminse opaons which are not feasible from a technical point of view. If you have p r c m coparm on y o u TUR &, they should be able to help you identify these optlons.

Some o p u s can be NJed our u n m e b l y because they simply cannot be acheved - even gven unlrmtred resauces Other opnons can be ruled out because they call for equipment whch IS not c~nnmmrul l lv a\ alabie and cannot be developed in-house.

Financial !icreening

The pomt of ttu s a c a m g IS to eliminate options whch call for capital outlays far beyond the means of your firm. 'This step should not require detailed financd analyses - that will be done at a larn stage. Provided that you have a rough idea of the costs and benefits of each proposal, you should already be m a position to identify and rule out those which are much too c o d y to ment further anention.

CHAPTER 5: EVALUATING AND SELEC~NG TUR ALTERNATIVES..

In estimating the financd \.lability of options, you should consider as wide a range of economic impacts as possible. Beware of elimimring opnons simply because rhqv have high upfionr costs. Some b~g-ucket investments pay for themselves quickly through savings in unliry bills, raw matenal purchases, trearment and tlisposal fees or other c:osts. Others which may be W o r d a b l e now may be worth evaluating because changes in technology or in operating costs mght make them affordable in the near future.

Health, Safety and Environmental Sc:reening

The cechn~cal assessment phase should hdp you to antrclpau and gauge me sevenv of any techrucal or log~sncal ~ m p e d ~ m e n a h a n g chc opoons under com~der- anon. & managerial assessment phase 1s lncended m hdp you fo- any d i f f~culuo whlch managers are Ilksty to h a In lmpla menong and susulnlng TUR process changes

In most cases. TUR changes have n o h g but po:sitive effects on worker health and safety, public health. and the en~uonment However, there are occasional exceptions which must be screened om.

For instance. sol vent-based cleaners can be c0nse:rved by holding parts ;above the tank after they have been cleansed thus mcrcasrng dramage time. However, if this procedure were carried out manually. ~t could Increase worker exposure to toxic solvent vapors. Similar1 y, replacement of a touc solvent urlth an aqueous-based cleaner can have adverse side-effects on wastewavr treatment systems. If these effects are not anticipated and avoided, then solvent subsunmm could solve ow environmental problem only by creating a new one.

It is also tmportant to be surc that the change in question can be carried out without violating any rtatr or federal ennronmenral regulalions.

TUTU Sote: Compames subject to TUU planning requirements must identify a lin of 7LX opnons. dctermrnc whether each constitutes TUR under the law, c d c b the expected reduaons m itoxics use and byproduct generation associated with each. and evaluate the r e h o n s h q of each option to other applicable laws and regulations. Cornpama need eot complete a full evaluation forthose options whch are detammed to k clevly mfes~ble on technical or financial grounds. nor for those opaons wbch art unlkely to result in TLJR progress. However, companies must e x p h thcu rryoas f a rejecang any options whch are identified but not implemented. A full tcchn~d and financial anallysis must be conducted for all other

5.2: Technical and Managerial Assessment

At thrs point. your tcyn has sucened out the opiions which are obviously unworkable. It is tune to submt r e m g optlons to a more detailed scrutiny designed to reveal as many oftheir porentlal kncfits ;ind drawbacks as possible. The time and effort spent in foreseeing and avoiding such d~fficulues u n save you conside:rable headaches and -on later.

The t echca l assessment phase should help you toanticipate andgauge The severity ofany technical or logmcal m p e h e n t s facing the options under considerarion.. The managerial assesnnent phase is lorcnded to help you foresee any difficulties whch managers are likely to face in imp lemen~g and sustaining TUR process changes.

--

CHAPTER 5: EVALUATING AND SELEC~ING TUR ALTERNATIV ES...

Technical Assessment

W e sum & u c each opoon is compatible wtdr your producnon nou a d rode p n c n c u . Also. l n v u o p t e any poss~ble effects on ddecr ntes. produa appearance and produa qual~cy.

If an optiol~ r e q w commercially available machinery, you may want to assign a team member to look into the aack record of the equipment and its vendor. Where possible, it usually pays r c ~ visit a s~ te where the equipment is in use or to obtain the equipment for a trial nm. If t h~s is ~unpossabie., you may wish to contact users by phone to query them about their experience. 11: ma): also be wise to determine whether the vendor handles upkeep, provides technical assxtance. ensurrs the availab~lxty of spare parts, andor offers an adequate guarantee.

This is also the m e IID rule out options which might have adverse side-effects on other productioo mxhmay or processes. Make sure that each option is compatible with your produrnon r a t e and work pramces. Also, investigate any possible effects on defect rates, product appwrance and ~ u c t quallty.

There are dm a otrmber of potentla1 logistical problems which must be foreseen and addressed. For mstance. Px sure that you have or can install the appropriate utilities (electric, process warn. cooling water, coolant fluid, steam, fuel) for any new equipment, and that you have enough space to b o w the eqtupment and store any required supplies. Similarly, if the change reqrunts mbwe laboratory testing or analysis, make sure that you have the facilities to handle tbc !task.

When c l ~ y p m n g vanmu opuons. you may also wish to take into account the amount of produrnon Qown-m ehcb W M cause.

Managerial Assessment

It is cntlcal to assess tbe fit of each option with your firm's managerial goals. This sort of comdcratltm can often be dcc~srvc in choosing and gaining approval for TUR changes.

If your tirnl has laued a TLX Policy Statement or if your team has set TUR goals, you should consdcr urhetbcr the propxed changes are consistent with the statement andlor goals. You may also wub to asses proposed TLJR changes for their compatibihty wrth @ty, efficiency and safety gods. mukmng plans. community relations concerns, and otherrelated management ~ums lad pnorraa

It 1s also un~mrcmt to tbe compatibhty ofeach proposed change with the work habits and talents of tmpioyea Sane N R production changes will require technical consultants or new penoonel m ordrr to be mplemented successfully. Such personnel requirements should be takm mto aceamt when comparing TUR alternatives. Other changes in work practices arc dlfficulr to nrnjun If you are considering a change which requires significant changes m producnoo worker pactlces, you may want to consider an employee training and/ or incenave p ~ q p m ro encourage worker cooperation in malang the change permanent.

Ofttn, TUP. changes ncgu~e sustarned cooperation among different depamnents. If you are considennlg such a change. you should ask yourself whether the cooperation is possible, and whether a ~mght be enhanced by openmg new lmes of communication among departments or by crcanng a new mtcrdepartmental task force to monitor progress.

Fmally, it IS wonh considemg the effects that the change will have on environmental paperwork ml c o m p h t x . Usually, t h s effect will be purely beneficd. However, in some cases a Tt.X cl~ange may require new environmental permits or give rise to new compliance difficulnes. T b s posslbihry should be explored before a decision is made.

CHAPTER 5: EVALUATING AND SELECTING TUR ALTERNATIV'ES-.-

5.3: Financial Assessment of TUR Options

Often, the final selection of a TUR process change will hmge on bottom-line cost considerations. However. it is not always easy to gauge the full financial impact of a TUR project. To do so requires a detaded assessment ofpotential impacts on a wide range of costs - including a number of ~nduta costs which are usually lumped together under the generic category of "overheas'.

The object of the son of financial analysis discussed in this section is to bring out all of

The obpa of dle s a r of the bottom-be costs and benefits of the TUR projects under consideration, and to quantify

financial analrsls as many of them as possible. Such an analysis does; not include "socd costs" - that is, costs bs -on o (D art ol d which a c m to the surrormdrng mmrnemity but whch have no effect on company profits. che b m - l m a cored b.ndrP Of course. the socd cons of avoidable toxic pollution should provide additional reasons for dche~u~ prqec~ unda responsible corporate cmzcns to pursue TUR o m d e n o u n . u d m ~ ~ u my of rhar as pauibk

The sort of &ctal analysis &d by TUR p h n e r s is not at all alien .to today's business environment. It ~s m Ltcpmg wth the general trend toward a closer association of costs with the particular produbloo process or processes responsible for them. Tbis kind of analysis can be quite time-mnsummg. ThLs 1.5 why it is recommended that you weed out all but the most promising projects &!ow ~b jec t lng them to financial analysis.

No financd analysis sbould be rcgzr&d as the final word on the feasibility of a TUR opuon. The con plcture of most busttlesses is i r ~ constant flucnmon, as purchase and hsposal costs go up and down. and as new technologies drop in price. Options whch prove not to be financ~ally feasible taiav may become feasi.ble in the future. Y o u TUR team should revislt such OPOOCIS frOm m e to m e . m order to stay abreast of their economic apped.

Every company has m own appmacb to the financd analysis of internal capital mvestments, and each uses &fFtrtnt etooormc criteria to justify these investments. Before conducting a fhmcul analysis. you &odd determine wbat evaluation b e w o r k is used in your firm. To tbe a a n t possible. you s,hould fit your analysis inm that framework.

The analytical procedure recommended m this c l q t e r involves five essentid steps:

(a) List all operating cosu u t o c i . t d with current processes. (b) Identify operating costs wbub may be changed by the TUR project. (c) Calculate the diflerc0ti.l between current rand altered operatin,g costs. (d) Determine tbe capital costs ef yolur TUR project. (e) Calculate the payback p o d for your TUIX project.

Each of these stcps will be explruned m sequence.

(a) Listing Current Operating Costs

The fim stage of your financial analysis is to lisr d l of the operating costs associared with the current produrnon process targeted for change.

There is no need at h s stage. to quantifi these costs. In order to meamline your efforts. it will prove easler to quannfy only those costs whch will be affected by the TUR project under consideranon. By composing a complete list of the kinds of costs associated with your produrnon prcxess, you will put yourself in a positiorl to identify the costs that will change.

The operating cons whlcb are most relevant to the l b c d viability o f l U R projects faU

C H A ~ 5: EVALUATING AND SELECTIING T U R ALTERNATIVE s...

Inangible costs - such as worker sick days. communiry

relarlonr. corponce Image

and employee monle - have a red b o r n d i n e impacc yet

do nor ksd h s d r a to

prectse measurement.

into two tmbtional accounting categories: direct costs and indirect costs. As the name implies, dmct costs are those whch can be assigned directly to a particular product or p r h c n o n unit. Thu caregory has tnditionally included such costs as equipment purchase and installation, production down-time, labor and raw matenal purchases.

I n k c t (or "overheacl'? costs are those whch cannot be assigned directly to particular products or ducti ion units. T h ~ s category has tmhtionally included such costs as maintenance. waste aearment and disposal, environmental reporting and permittmg, ship- ping and receiving, training, engineering, business planning, quaIity assurance, workers9 compensanon insurance. energy, water, and fuel.

You should. also consider the effect of proposed changes on two other categories of costs: intang.ble costr and llabilily costr.

Intangible t m arc those wtuch have areal bottom-line impact yet do not lend themselves to precise mmsurcment. For instance, since employees respond favorably to clean, safe work environments, your TLR changes should help to improve employee morale. Better employee morale IS an lntanplble benefit. as it usually helps to boost productivity and profits -- though it is wtually lmposnble to quantify t h s boaom-he effect. Other examples of intangible TUR benefits lnciude ocduced worker sick days, improved community relations and improved cqloratc anage

Liability. a n the other hand. is not an aaual cost but a potential one. It is the cost faced by those comFmes wbch arc found M l e for damagmg the environment, or for harming public or worker health. due to accidental releases of toxic substances. Under federal Superfund legslanon, coimpanles can also be held liable for clean-up costs of dsposal sites they have mi.

Because 11 represents a finaDc~al risk and not a concrete cost, liability is difficult to quantify. Hourever, slncc n IS a cost capable of badmpting an otherwise healthy business, it cannot be ignored by an adc- financial analysis.

In ordcr to draw up ,a comprehensive list of the costs associated with your current produrnon processes, you may uxih to b e p with the process flow diagram wtuch you prepared d w g the Recess Charancnzarion and Analysis phase of your work (see Chapter 3.3). T h s wffl help to organm your thought by permitting you to consider in turn the costs associated wltl3 cwh dmnct sage of the production process.

The process flow dugram already contains a full list of the raw materials wtuch are fed into your prodi~cnon process The purchase costs of these raw materials constitute your direcr materials cosn, w h k thr: wages and benefits of the production line workers who run the process are termed drrccr Labor wsrs. At many finns, accountants will already have calculated these costs for eacb produa or production process.

Unfornmau!l y. the ocher costs you are interested in - that is, indirect costs - are not usually measured sepasavly under uad~tlonal accounting practices. For instance, the labor costs associated w~tlh en\uonmental recordkeeping, fines, permits, compliance monitoring and reporting arc usually counted as overhead, yet these costs are o h reduced significantly by successful TLTR. The same mght be said for the costs of treatment, dsposal, worken' cornpensatloo msurulce. worker safety training and protective equipment and water use.

A comprehcns~ve l~st of the costs associated witha given production process should include a l l of the materials. labor and utilities whch conmbute in some way to keeping the process running. The :ample kt provided in Figure 5B should help to get you started.

CHAPTER 5: EVALUATING AND SELECTING T U R ALTERNATIVE s...

FIGURE 5B: SAMPLE PR0C)UCTION COST LIST (tora -rd w d ~ &m paper-dip rmking pr-s diagnmrned in Figure 3C)

DIRECT MATERIAL COSTS (from i n p a cdumn cf pmcers flow diagram):

b = = k P d = = L u b o u o q orl. hydraulic oil and machine oil purchaser Dm and c u m r blade purchases fr~chlomo&ylem purchases Hdrodrlonc ac~d purch,ues NIcU-p laoq sduoon purchases b o x purcharu

DWCT LasdR COZTf;:

~ k m p b l r r y a m d b e n e F i o

HMRECTMAfERIALCOSTS:

Trrmpar and Dspad (4 finer s p m oils. w k n u a d H a a.) Tracment (of outurn n r P M l t e n and placing r imemten) Enrtronmrrol p.rmm. films. uxa and f e u (pardcularly TlJRA feu) 8.cmctr). (la probcuom bne rquipnienr)

Muntmuwe (04 producoon line qu~pment) Lmu-• (~nclu&ng r o d t e n ' compensation)

h n g wpmm (d co JLLCP lin~e and machlney clean) kfuy .qu~prrwr* a d p m ~ ~ ~ v e gai- m c e suppla (* roc--dkwp~ng. environmennl compiiancs. etc) R o c a s r?t.r

Stony and H v d l q (d chemlal supplius, finished produclcs. etc.)

WUIECT L*dOLI c m r :

hronm.nrr1 P.CIO.V).I (mcordkeeping. moniroring. permitting, atc)

Q u d q asrunsum mapacton Maarulr k n d b q and rwdtroom par~onnel fnmq pu-1 (panrularly safety training) L r b o n w r l ~ 0 - d (pamcuhrly anvimnmennl wnng)

I)ICT-tau c m

wataukdm Communq rsaooru and corpona iniage

U I U B m cons

Lab&q br 4- hdrh and safer). ( d e n cmpcnwnon)

Superfund I~abllrcy f o n c mrt l~ab~l~ty ( p n o m l SUIU by cusromers/neighbors)

It should be noted that in smaller firms, the indirect labor costs might be harder to list, as the same pelson might carry out several different tasks whch are related to keeping the production unit in opewon. For mstance, the supervisor might handle quality assurance and environmental c o m p h c e . However these various labor costs should still be listed separately, asareductlon in any ofthese tasks will fiee up time for other productive activities, and thus sho~uld be counted as a savings.

lhs ht also omits several potentially important cost considerations, including produc- tivity and byproduct sales. If you are considering a TUR change which will alter the production nrvs of your cqupment, then this change should be considered when calcularmg

w YOU u e comhrirrg a TUR costs and benefits. Likewise, ifthe change under consideration would create or eliminate a c h a w whch wll alca the saleable byproduct. then ths revenue duft should be figured into your financial calculations. producoon nm of your equlpmenr then thts change should be conradered when 7 I calculaong costa and benefiu. T L R A NOTE: Under TURA, an acceptable Toxics Use Reduction Plan must

analyze 'the econormc unpaa of toxics use in each production unit. All direct and indirect material and labor costs must be considered, including (a least) the follow~ng cost caugones:

( 1 ) Ruchase or manufacaurng costs; (2 ) Storage. accrpmulanon. mamen5 w s a l and handlmg (of toxics materials

and by-products); (3) Costs arsoclatcd with c o m p h c e with federal, state or local laws and reg-

ulaaons (includmg fees. taxes, treatment, disposal, reporting, labelling. etc.); (4) Worker healthand s a f q (includmg protective gear, lost employee time, etc.); ( 5 ) lnsuwce cogfs. (6) Pctcntlal lubiliry costs (need not be quantified); (7) Lcm commwry goodurlll and sales revenue lost to non-toxic competitors

( mttd not be quannficd). Usmg: &us data c o r n y e s arc to quantify the totd annual cost of each toxic used

in each productma u t . and the total cost per unit of product. See Appendix 1 for further drtails.

(b) Identifying Operating Costs Which May Change

Once you have genemd a comprehensive list of the operating costs currently associated with the process q e u d for change, the next task is to identify those costs which might or would be chalnged by the TUR proposal under consideration. In the language of financial accountzng. the task u t~o angle out all of the differential costs.

a s step IS not easy to reduce to a foolproof formula. However, you should be able to identlfy diffelrenual costs by combmg through tbe comprehensive list of costs which you have just g e n e m d and applying your knowledge of your production processes and the TLR alternmve. In the process, you should be able to identify a set of operating costs whch will d e h t e l y cbmge and others whch are relatively likely to change.

CHAPTER 5: EVALUATING AND SELECTING TUR A L T E R N A ~ E L..

The process is perhaps best illumated by an example. Suppose that you were assessing the submtution of an aqueous cleaner for the I,l,l-mchloroethane P C A ) used in the paper clip manufacnnrng process wbose cosu are listed in Figure 5B (the process is -ed in Figure 3 0 . Tlus would clearly affect your TC14 purchase coss - in fact, unless you used the substance in ocher processes. it would eliminate the cost altogether. Of course. it would give rise to the new con of purchasing aqueous; cleaner. but such cleaners are generally cheaper and last longer tban o ~ m c solvents.

The change mght well reduce cksposal costs - a least if youare paying to have yourspent solvenn refined or mcmasrd. If the change reduced your annual use of TCA from above

fome differmil crna am 10.000 pounds to below tbe 10.000 pound threshold, it would lower yow state TURA fee by m~luar m SOOL and rml S 1.100 per year ( d e s s heab.y use of other toxic .cubstances keeps you at the fee ceihg) It rqulm a b a of ~ m a n p w n . would also decrax your firm's potenhai Irabhty for Superfund clean-ups and worker suits,

and might reduce io r l c r illneks. thus helpkg to cut back on sick-days and workers' cornpensarion rosurancc prcnuurns

Some of rbc other chffmnrul costs are mckier to spot, and may require a bit of investimon. For mnance. the muoduction of aqueous cleaning mighit alter the amount of worker nme spent cleaning pms If so. then it would change your direct labor costs. It might also reduce mdmct labor cops for pew~tting, re:cordkeeping and worker safety mimug, wble shghtly mmasmg h e tlme spent on quality assurance and mainf~nance.

Chmcal mvncnoas b e e o thc new pracDce and otherproduction processes might also g v e nx to surpnsmg hffacnhal costs. For i n r a c e , because aqueous cleaners do not emporau as r c d ~ l y as orpu: s o i b t n t s . tbe change might also increase "drag-in" (chemical contvnlnanu borne by parts, loto your etchant tank (see Figure 3C), thus shortening the life of your hydrochloric acid bath and locrcvlng trrzwment costs. Ths potenmlly detrimental n d e i f f m rn~ght be nulhficd by aauung workers in careful dramage practices and by taking other aeps to mlnrmur ckvler b g a t

If the change were commumcvcd to the surrounding community and to potential customers. rt mifit have a pos~tlw mpacr on commmty relauons and corporate image. If it werc pan of a more extcnslw TL'R prognm, it .might also help to create the opportunity for a markeang campgn a m d af r~ppmg into the growing demand for "green products".

The following figurr I F I ~ U ~ C C ) lists all of the differential costs benueen the paper-clip manufacturing pnxess tx fore and a* Ihe aqueous cleaner substitution. It indicates which direction the change rs 13;ely to rake. and whether the change is certain, probable, or only possible

C H A ~ 5: EVALUATING AND SELEC~NG TUR ALTERNATIVES..

FIGURE 5C: SAMPLE DIFFERENTIAL COST LIST (Probable differend costs between the paper-clip manufacming process in

Figure 3C and the same process after the introduction of aqueous-based cleaning)

a Cleaner uslmion purchases (decrease) b Hydrochionc acid purchases (possible increase)

2. DLFFERE.YTUL DIRECT LABOR COSTS:

a Produrnon lux employee wages and benefits (possible change)

3. DIFFERETZAL INDIRECT MATERIAL COSTS:

a lXsposaltdccrrye! b Treatment (pwnble increase) c. bvironmentaltaxeswmayfeedecrease) d. h t t n a n c e (possible increase) e. lnsurana (possible workers' compensation decrease) f. Of ice supphs (probable marginal decrease) g. Process warm (negl~gible increase due to make up cleaning solution)

4. DIFFERENTLU, LNDLREC7 LABOR COSTS:

a Envlroamcntal (Possible decrease'in time spent on Forms S and R) b (Wty asamnu lnspeaors @robable temporary increase) c 'Trammg p m o ~ ~ l (possible decrease in time spent on safety training)

5. DElFERE37lAL X3TANGIBLE COSTS:

a 'A'orlur slck days (possible decrease) b. Gxn~~~unrr l i . ~ b n o n s (possible improvement) c. Corporau mqe (possible improvement)

6. DIFlFERE!?Z.U. LUBILITY COSTS:

a IL~ablllty for worker health suits (decreased exposure) b. !Superfund Lrability (decreased exposure) c. 'roxlc Tort Lnbility (decreased exposure)

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CHAPTER 5: EVALUATING AND SELECTING T U R ALTERNATIYES..

(c) Calculating the Project's Cost Differential

In most cues. you w.11 be able ro quanufy dlfferenuals In d~recc mamnal and labor coso. snvtronmsnal f e u and mxu. and In waste cnnaport dopoaal and our-of-hours vucmenr coru. h e coru uaually represent the pnmary &ecu of your T W R effom. and they should WPM as the core of your q u a n o t l a

financ~al analrr~s

Now that you have a k t of &fferernnal costs in hand, you can b e p to calculate the annual change in opaanng costs wbch would be ushereti in by the TLTR project under consideration This figure n known as th msr difirenrial.

It is usually posslble to perform a precise quantitative evaluarion of only a handful of differenaal costs If you choose to quantify all crf the differenaal costs you have identified, then your fmanclal d-ons vnll gain compr~hensiveness at the cost of precision.

In general. ~t u rrcommedcd that you separate your financial analysis into two parts -- a q u a ~ ~ & ~ d m ~ md a qdiranve analvsis. The quantitative pomon should be an analysis of those drffmotlal cosis wbch can be czkulated more or less precisely. T h ~ s "hard numben" andyrlr can k supplemented by a written assessment of the bottom-he effects likely to a r k from othtr. lcss easll y quantified differential costs.

Before you ulcularc your ~ K I &fFerennal, you should spend some: time tiunlang about which costs should fall u~thtn thc scope of yourq!uantitative analysis. 'Your choice of scope will depend LII pan upon u-h9 you uant to do with your fmancd analysis. If it is to be submined to uppcr uxaagmcnt as s focmal justificarion ofthe capid expenditures required by your nix p p o d . tbcn you r m y wlsh tc~ include only those costs which can be enurneraxed 7 1 , . If .pu aun u mmly to get a loose picme of the project's financial impan: - perhaps rn ortier to canprrt Kr with other competing TUR projects -- then you may wish to mcludc rough en- of a broader range of wsts and benefits.

The Quantit.ovr Analyrr In mosf cases. you will be able to quantify differentials in direct material and kbor cons. ennroamard fees. and waste aanspon, bposal and out-of-house treatment costs l k s c cons M u l l v rcpmcnt the pnmary effects ofTUR effom, and should serve as the ccrrr of your quanombc fmaal analysis. Where possible, you should bring other indtrtcr mttcnal and lPbar am wthm the scope of thls quantitarive analysis.

It IS rclatlvch sample to &LP the dfferenrial in direct material costs. It canbe obtamed by subaacMg yarr cunent mud mu matcnaI purchase costs kom your post-TUR raw matenal purchsc casts (For e u h nu mavnal used by your process, annual purchase costs = cost per ut l l t dumc r v r o d caasumptlon in the same units volume.) Neganve lfferennals rcprc~ot a poenruj u\ mgs. wbde positive differentlais represent added costs.

Wane uaqmn duped. md car-of-how treatment cost differentials can also be calculated in a stra~ghrfcmvzrd mamm You should perform a separate calculation for each lund of waac wbosc t d m r u 9 k duered Onoc you have determine~d the annual change in waste volume u - k b wouW be reahzed by the :lUR change (negarive if the total volume will shnnk). thl' figure u a tr mulaplled by the total cost of nanspon, rreatment andlor &sposai per urut ~dmx to 3mtr the ion M e r e n d for that waste. (Differential = annual change in units volume r twl corr of uanspon. tremnent and disposal F>er unit volume) As above. a neganvc &ffucntul refleas a potenaal savings while a positive differential represenu a potent4 m upcnx.

Cost &ffertnnalr f a cn\uoamental fees and taxes can often be foreseen with a relatively hlgh degm of coaMcncc For mstance, if you reduce your use of a listed toxic substance to less than 1 0.000 pounds per year. then you no longer have to pay a TUX.4 fee on it. Unless you remam ax tbe fee ullmg. th~s w ~ l l spell an mnual savings of S I. 100.

h c t labor c o n &ffercntds arc a 11rtle mcher, as they have two components - wages and benefits In order to calculate them. you need to h o w the hourly wage rate and hourly

You should m bnng u many differmual costs rr pou~bla rndr~n che scow of your quanuauve anrlyslr. R o d e d char your numbera am dependable. &a rnll add to chn c d k l ~ g and urrhrl- n u s of your oven11 f~runcul analys~s.

benefits rate for the sort of work whch would be added or eliminated. (hourly benefits rate =annual cost of benefits per workerhours worked per year) The annual differential can then be figured b:v addmg hourly wage and benefits, and multiplying the sum by the number of extra hours crf work whch would be caused by the TUR change. (Direct labor differential = hourly wages + hourly Benefits) x extra work hours)) If the T U R c h g e would reduce labor hours, then tl~e e x m labor hours should be a negative number, and the resulting differentla1 negaave (i.e. a potentla1 sabmgs).

Where possible, you should uy to bring other differential costs within the scope of your quantitative a n a l p . Rovided d m your numbers are dependable, this will add to the credibihty acd usefulness of your overall financial analysis.

There are a number of m h c t material costs which can sometimes be quantified. For instance, by securrng v c h c a l dataonnew equipment which would be installed underaTUR proposal. *I might be &able to calculate the annual cost differential for elecmcity, water, or other uuhtles. Slrniiarly, if you know something about the rehability record ofthe equipment you are consrdenng. then you mlght be able to gauge maintenance cost hfferentials.

There may also be &ct labor costs whch can be brought within the scope of your quantltanvt ; d v s l s For mstance, if you can determine the amount of time spent by employees m Nlrng ous ~rgulatory reports or applying for permits whch your TUR proposal would rmda' unnecessary. then you can include these indirect labor savings in your quamtaove analyns The same gccs for time spent by laboratory personnel in testing and analysis a arme spent managen in fulfihg OSHA requirements for safety training, hazard comm~lrmcanoo and emerpenc y plammg. In each case, the appropriate mathematical formula u the: same oac used for dm0 labor costs.

T o p w an cxunpk. suppose t b yourTUR projectwouldeliminate a particular hazardous wanc wtuch you w w stod to the landlilI. Your conversations with environmental personnel reveal thg r among other dungs) rhs would eliminate two hazardous waste shpments per month. and that each r h t p t n t q u i r e s two manifest reports w k h take an environmental engrneer I .5 bmxs each [to cornplev - hours whch could otherwise be produmvely used. Suppose furdnt rw tbc w a g e s and benefits ofthe environmental engineer total S3Ohour. The ~ndrrect labor cmst &fkcntul for manifest reports would then equal S2,160 per year ($30 per hour x 1.5 b a n s per auntfca x 48 lnanifests per year)

You mav also have qunfmble con differends arising from changes in byproduct sales revenues, deprmeclatlcm Illow;raccs or production rates. If the lUR project in questlon would create or elmlaaxe saleable bypfducrs. then the change in byproduct revenues must be counted as a & ~ ~ coa If tbe project calls fornew equipment with ahgher depreciation rate than old qrupmmt. then you may wish to count the consequent tax savings as a differend cola Fmally. if your TUR proposal would alter production rates, then you will have to p a i r n o some raibcr delicate calculanons to determine its net effect on your business - as it mfht affect borh yaw operamg costs and your ongoing product sales revenues.

It is not a r v to quanne those costs which traditionally fall withm the caregories of intangible wsrs or llabtlrp In most cases, these costs will be weighed in the quahtative pomon of thc f i c d assessment. There have, however, been some efforts to put numbers to these cons. ]For maance. a 1988 study conducted for General Electric by ICF Technology, Lnc. esnmated the s v q e Lability con of landfilled hazardous waste at S354 per ton. For landfills that h v e a tunory of leaks or are located near urban areas, wells, or groundwater, Lability exponne was esnmated to be higher by as much as 50%.

The esurJlatl!on of potennal Ilabihty has not become awidespread practice in part because the numbers v r ~ d to be mi l ab le , and in pan because companies have feared that they would

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CHAPTER 5: EVALUATING AND SELECTING TUR ALTERNATIVES...

Many bustnesses have recognrztd q u a l ~ ~ o v e cost constdenttons by rlackentng thew s ~ n d a r d c a p ~ u i tnvtrontnt m a n a for Torla Use Reducoon prof-.

The Qualitalive Analysis: As noted above, you should saive to quantify as many cost. as possible w-&out &llmng the liability of your financial analysis. However, most TUR proposals will have some Merentla1 costs whch cannot be quantified accurately.

These quannfiable costs should be included in the qualitative portion of your financial analysis. Thr.s quahtaave analysis may prove instrumental in choosing among othenvise equally amacnw opaons or in justlfylng projects which stand at the edge of your firm's capital budgeung cnvna

The mportance of thcsc costs should not be underestimated simply because a number cannot be pp to them For mstance, it is usually not possible to quantif)r the fines. lawsuits and cnmmal ~xnalncs whch may accompany violations of environmental regulations, yet they can pp a coasderable dent m profits, and continued violations can lead to a forced plant shutdown. S~mhty. n is dfficult to provide a reliable figure for the future costs of Superfund ckao-ups. touc tons or worker compensation settlements - yet these costs can cripple even the hultbcn busmess.

M a n y buaocsscs h v e recognlzed qualitative cost considerations by slackening their standard q t a l urvcament cntexia for pollution prevention projects. For instance, if standard unprovemcntr rn work efficiency must have a three-year payback period, projects whch ruhx toua LLY rnlght oaly be required to pay for themselves in four or five years. Thrs son of lame docs ooc n e d y ~ f l e c t aheightened environmental conscience - it may also be UI m e uitb Qe IDLC~~S~S of corporate profits.

If your TLIR a a a l y ,arc to be subrmned to higher management for review and approval, then your quail~mve analyzu u pamcularly important, as it provides a vehcle for poinmg out the many ~raquannfiable bono<n-he considemions whch bode in favor of TUX. lbs pomoa of tbe finanad d y m s should mention a number of lands of costs:

* Cosa which might tponiw be changed by the project;

* Cortr rhich w i U k dunged. but by an unquantifiable amount;

* Liability apowrcr

The q d m n ve d vru dl v takes the form of a brief written document which e x p h why the projctx IS U t y to lead u, various possible costs and savings, and (where possible) estimavs th likcl) [ ~ ~ l g n m d e of these costs/savings. It might also contain a discussion of the habiiiry m;k rrduct~oa vhrch can be ushered in by successlid TWL

(d) Determining the Total Capital Cost o f y o u r T U R Project

The next atp ID y o w h c u l analysis is to weigh all of the up-front costs associated with q l e m c n m o o of your 'RR project. This is pamcularly important for projects which r e c p ~ ~ subn;lela.d ap~ta l mvemnents in new equipment, research and development, or plant expansum.

The cap~tal costs of your TUR project are those one-time costs necessary to plan and implanent the p r d u m n process change. Figure 5D lists the capital costs which might be assoclaud w ~ t l ~ a flplcal ?-UR project.

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CHAPTER 5: EVALUATING AND S E L E ~ N C TUR ALTERNATIVES...

In wda m de+e dm propct's pyback period (or "braak- even pant"). divrds rhe project's wral differmnd cost by k w d aprtl l cosr

I FIGURE SD: TYPICAL TUR CAPITAL COSTS

MATERIAL COSTS:

I . Equpnent purchase (total equipment purchase and finance charges) 2 Sllddnposal of OM equipment (sales revenues or disposal fees) 3. New rmtncmance cqurpmult neceuitat.ed by change 4. New d a n ~ n g aqurpmcnt necessitated by change 5. New pplng or orher hardware necessitated by change 6. hci&ry axpansan or mnontion necessitated by change 7. P r o b a m n d o m u m e (lost revenues)

LABOR COSTS:

I . Equlpment ~ n d b w n 2. Connexton of new equment to utilities and piping 3. E n p e e m g to prepare for change 4. Worker tnlnmg m new producoon procedures (wagu of uatner and worken) 5. R a a r c h and dmlopmcfit 6. Supa*nary and mrnrgerul m e 7. New permr appllcloons

Once you have tsted dl of the q n d costs assa~ciated with your TLJR project, you should b e p to quannfy hem.

Matcnal coru should be rchvcly dghdorward to determine. In most cases, they can be obfaind sunply by callmg tbe appropriate vendor or contractor. Tbe exception is prcjduuion douro-nmc. In ordtr to gauge the effet~ts of production down-time, you will have to speak with ModorS a d coamaim to determine how long it wi l l take to remove old equipment. instail new equrpment aad get it &lg. Then you wiil have to consult with floor supervisors and sales and maheang personnel to determine howmuch foregone sales revenue (if any) will be caused by the rncermpaoa

Labor wsts arc a b ~ t more complex to calculate. For each category of labor cost, estimate the number of labor bours mbvlvcd d dcmmine the hourly rate of wages and benefits for the employee who u-tll perfom Q labor. Multi~lly these two figures to get the total for the category of labor costs under c o m o n .

AAer quannfyng all ca~gmcs of capital wits, you can determine total caprtal wsts simply by summrng them

(e) Calculating the Project's Payback Period

At b stage. you arc ready to d e t e m e the p:rojea's payback period (or "break-even point"). To denve thrs figure. divide the project's total differential cost by its total capital cost. A payback penod of less than two years is usually considered quute ataactive, while a penod of three to four years may be acceptable.

Your total drffercntlal costs reflect only those costs which your &un has been able to quantify accurarely. However. q d t a a v e cost factors can and do have real effects on the bonom h e . When these cost. are taken into account, your TLTR project is likely to appear

even more aftncnve l h s e x p h m part why many companies have lowered the financial hurdle which -IT-X projects m u s clear m order to be approved.

The basic d n w h c k of a payback penod calcular~on IS

h a t ~t lgnora whrc IS known as rhc dme value of money. As a reru l r payback per~ods are useful for comparing

alternate p r o l e e against

clch orha. bur they a m noc

he mosc accuncm means of

dacermlnlng w k c r h r funds shuld be s m on TUR rn

he first place.

IFocus: Other

OT Ncc Rtcsent V4BLe.

dmmai by amcxzbg OTA at (617) 7'-32m. QTA canalso provi&Massacf#t sem brr- aith htip m p a f i g finan* adyses of TURprojats.

Tbc basic drawback of a payback period cafcuftion is that it igmres what is ~ : ~ ~ t i u w * . l w d n r e x t e y - Asaresutt,paylradcperit3dsarr:useiXfar compsgaEvmascprojects~each~,'bntthey~nottbemart~~ me3nsaif~~~~fundssfiouM'bespentonm~tfKfirst*-

%Wr &a, ts mcim by tbe 'timedueafmonegr? ft is atem fotthe connnoa- anredrthStap~rrrgmnvofmoneyd&vvlllbe&dinttte~~sn& worth as: much as dhe 9me qaaatity of mwrey in band today, Before they can be compaed r o c a c h o c b c r m ~ y ~ s u m s ~ ~ y ~ will be spenrorrecelved at cfi&rcm poinrs in ame must be adjusted for *'dismlmfed") to reflect t€te - . . ixnmmsa* d m m s b g Mhw ufmcmeycmey

As ur! bme rcar eapnal invshneats i n p a W w r m - o n m . e c e typicaify d v c ;nt up- c q x t d attQav fcaptta[ cost) and a gradual series of capitat inflaw ~apcrarmgsrvmg~)ouermaay~. Sincetkxsauings w c u r s t d i ~ mrm m thc fururr, r mxly s c ~ a t e fbawd d y s i s of the muestment should discotax tbrm w rhr hey can aII be cnmpxed .to #e np-front capitai i n s t

~ ~ m ~ m l t ~ t b e ~ e d a t a ~ u r h i c h r e ~ t h e c m p a n y ' s test efalgial T b figme varies from firm to firm - e v e n w W &same in6ustrfr.

Net Rcsart Valm MPV) bkmd Rate oi%ehrm @.I€) are twa pmfitabiiity measurrs wheh take imro accmmt tbe h e vafue ofmoney:

Net h a u ~ r Vdrw: Oo#tkfunaecashinflowsassucistedwi&aTURprojea have batl~ disxmd bey can be added together to give fhe present d n e of #e projeds cnb mfkm. Tbc project's tod q i t d cos% (the reqnired upfkunt invesrmart t a n rbeo k rabaaned *&is figureto derive fkprojecr's wpresent valm o. Gcncdv. rht projed is cxmidaed aceeptaMt ifthe W V isgreate~ thal tno .

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--

CHAPTER 5: EVALUATING AND SELECTING TUR ALTERNATIVES..

Your chances of p m n g ibndr for N U prq- w i U be grudy enhanced if you understand dm polioul idiosyncru~es of rhe cap~al budgeong process ar your firm.

assessments of the project(s). In particular, you should recapitulate your findings about the project's effects on marketing plans and qual~ty goals, its compatibility with employee skills and habits. and its role in the company's efforts to comply with current and future environmental regubons.

It may help to supplement the final report with information about health, safety, and environmental effects of aU recommended changes. You might also wish to include atimeline for project implementanon. with estimates of production down-time and projected construc- tion schedule;.

Of course. :success m the capital-budgeting process usually involves much more than just a convincing tM report. Your chances of g e b g funds for TUR projects will be greatly enband ifyou understand rhe political idiosyncrasies ofthe capital budgeting process at your firm. For instance. it may help to enlist the support of key managers by educating them about the potcnual bmefits oftoxics use reduction. It may also be useful to solicit the active support of all deparrmccnt heads who would be affected by the change.

Even when aprojenpromises to pay for itselfrapidly, it may not be funded during a given round of cap~tad b u d w g allocations. This can happen for many reasons. For instance, your firm may have other primtics at the moment, or there may be a temporary shoreage of funds. Ifatedmcally amacnvc and financially sound option is rejected, yourteam should be certain to m b r m t ~t during h e wxt capital budgeting period.

CHAPTER 5: EVALUATING AND SELECTING TUR ALTERNATIVES ...

pnrchseof aflf?$00 mt qpvdl , C& filled out an m-house P q e &

Appiqmatm W r - u b i c h iocfudedauariety of stmiard aaoom- @ c a l & a BythtoeCai*+the~mfect#net over the oen ten y a r ~ Tbougb mderat&~r atactive, &is fef f am^ ptitabthty r e q k fix cqiitai investments.

Howeva, Cahif 1's PAR also incfuded a sl~mmary of the project's 5th kknefiu. fhe#incindaipro~taed~~~iaproducti~d as savings in e q u m mainename and ~Mir,spfiffleakincidentrep

and indudtd rn the PAR &. &jjc ptsent d u e of S 9 3 . w

TLRA SOTE: TLXA p l m WUSI ~dentii]f the TUR proposals which have been selected for unplementauoa and cxp1a.m the rationale for rejecting other competing proposals. See Appcdu I for fwther details. h

Chapter 6: Implementing Projects & Tracking Progress

6.0: Implementing Projects and Tracking Progress -

Your team hs now evall-d. wleaed and - where necessary - secured approval for the implemcnranon of one or more TUR projects. The next steps are to implement the change(s) in a way whcii e w e s theu susamabd~ty, and then to measure and document your progress in achrebmg It% reducnons.

The mplennentanon of a TUR project may involve worker retraining, process redesign, procunment of new equrprnenf mitabtion work, and/orproduct research and development. These change; must be planned carefully, in order to coordmate the efforts of a l l affected departmcntr and personnel.

The unplenncntanm process does not end when the new equipment and/or new work pracaces are ui place. Successful mplementation means makmg the change workable and permanenr Your TLX t a m can mprove the odds of success by staying in touch with all affected workcn and handlmg any difficulties which may arise.

One of the naoa cnhd elemens of your team's follow-up work is to measure your TLTR progress. Such mevurcments will help your team to document and reproduce successes, learn from frulurcs. and gyn the data needed to secure approval for future TLTR projects.

Once your u r n ~ L U camed out IS first TLTR projea, it is important not to lose steam. TLTR is best pursued chrwgb conmucd incremental changes, each r e f l emg the proven technolo- gies and caplul resources available at a given time.

With each ;pro~ect, ,your TUR warn should become more knowledgeable and more effective. By s~mammg your commitment, your TURteam can help to build a company-wide awareness of TUR as a responsible and cost-effective approach to industrial toxics, while making conaa:c producnon-line changes with a positive impact on the environment.

6.1 : Implementing TUR Changes

Some TUR chalnges require relatively little planning and can be implemented as soon as approval'is secured. In general, changes in work procedures and processing parameters fall

CHAPTER 6: EVALUATING AND SELECTING TUR ALTERNATNEL..

within this c a q o r y . On b e other hand TL'R ptqects which call, for significant capital investments usually

require a fau amount of plannmg. and may also jinvolve workerretraining, process redesign, procurement of qurpment. product research and development, or even new construction.

There is no wed here to present a formal procedure for implementing these more complex sorts ofTURproccss changes; thty are implemented inmuchthe same way asany other capital improvement project. However. it may be worthwhile to provide a Sew key reminders.

+When implementing a N R change, it is critical to coordinate the efforts of

& sure (D maru rn dm muc all deparmnamts and dl personnel involved in the change. TO this end, it is

bypmducrr of w s t t n g usually best for the TUR planning team to specify in writing the concrete producr~on p r o c u s o before steps which mun be *en by each department, and to communicate the YOU ~mplomenc any changes nature and i r n m e of the change tlo all affected workerr. If the change

will have a upitlunt &act on the final product, you may also have to coordinatm *neb sales rclll a d notify principal customem.

+ Many TUR changes mquna worker retdning to handle new production techniques and Nch~neq. In order to avoid unnecessary production delays or botdenrds the N R t-I h l d see to it that the training is effective, and that k occun u unm as possible.

+ Remember that the impkmmuation pmwess does not end when new equip- ment is inrt;LUcd and new pdcces are in place. Successful imple- mentatiorr m a s nubng tin change wwkable-and permanent. Your team can improre the odds of success by -ring in touch with workers affected by the c- keep- d diffu:ulties and handling any snags which may a r i n Toam rn- should atso make certain that workerr stick to new procedures, and m u t y hired workers are made aware of TUR- rehtedpmcdures

+ One nuwe co*roc. & - to measure the ltoxic byproducts of existing produc- tion pr~cessu kfom pu unpknncnt any changer. If you do not know the level of toxic bypmduch bdore your TIJR efforts, then you may have no way of detcrminmg du&w your N R changes actually prove effective. (See Put 2 of thLI ~ C I tor more on measuring TUR progress)

Depending upoa w-ha I I X W r you have selected, your implementarion plan may have several phases - perhap r p m m y a number of years. For instance, you may have opted to reduce solvents w m tbc rhar tun covering your degreasing tanks when not in use. while seeking m b e ioag nm to urbsnnne an aqueous-based cleaner for your organic solvents. In that case, your r m p k m e n ~ plan would mclud~e immediate work practice changes aimed ar rcducmg solvcno use. rs well as l a g e r - u r n n~search and planning aimed ar eimunamg solvents from your p h t Once you have dewlopcdan unplementmon schedule. it is time to determine whether you

are likely to m e t tbe goah wtuch you have set fix your TUR progam. (See Chapter 2 for mfomanon on ~ n m g goals.) Ifthe project( s) you plan to implementwillnormeet yourgoals, then you may uuh m delcrmrne what adhnonal TUR changes might meet your goals, and to setk appro\al for tbox changes.

TURA NOTE: Acceptable TURA plans must include an implementarion schedule for all planned TUR changes, together with calculations of the expected redumoiu in toxics used and byproduct generation associated with each change. Biennral plan updares must explain any failures to meet past implementarion schedules. See Appendu 1 for more information. I

Houuromono of TUR proprrrr d l M p you w document your S U C ~ U S ~ and 6.2: Measuring TUR Progress h ~ l u r u . larrn fmm your upanencu . spor fresh opporrunma for TUR. and In order to develop a summed and effective program, it is extremely important to measure ealn the W R d IXSU~U- your propcss m toxlu use reduction. Such measurements will help you to document your - ononad dau d l c h may h.lp SUCC~SS~S and1 failus. lam from your experiences, spot fresh opportunities for TUR, and ~n o h ~ m t v g approvat for gam the son olrcsults-onented data which may help in obtaining approval for additional TUR add~oonal N R pro)-. projects

TUR pogess can k mevurtd in a number of ways. Some measurement methods are relaavely easy and r r q u ~ c hale data-gathering, yet they are imprecise. Other methods are more p e c l x but requrrc mom m e .

It IS posslblle to me- vwr progress in loose, qualitatlve terms. For instance, you might confirm that use of cenun toxlu or production of cerrain toxic byproducts has been reduced slguficantl), wtbout quantimg the precise degree of reduction. For some purposes, a rough csrunatc of rcducuoa permrages might suffice.

The s b o n c ~ m g of such a qualitative measurement technique is that it may not supply acame enough data to fill out Form R's and Form S's, spot new opportunities for TUR or conLmce qppcr management that your TUR efforts have met with success. If you wish to m e w y c w progress unh more precision, you should measure changes either in the quantiry of co:ucs used or m thc quantity of toxic byprodurn generated.

Your cbo~ce of a mcawrment t c c h q u e might lunge on the availability of data If you bave ready access to dau oo the quantity of toxic substances used in the processes you have modified tben~ you rmgfi~ sub to measure progress by tracking use reductions &eel y. On the other k i . 11 ma! be uonh generating addtional data to track reductions in toxic byproduas. as tlm IS t ! ~ mevurtment method mandated by the Toxics Use Reduction Act (IURA).

Webeve r m e w you choose, you will need accurate before-TUR and after-TUR data, and you will halve to adjust yow measuremenu to account forthe effects ofextraneous factors such as changers ID the mes at whch various products are made.

Thls mmual dcsclba a method for measuring reductions in toxic byproducts. This data will not only help you to track 7UR progress - it will also help you to understand the precise effects of your TLX cha~ges, and to spot ffesh opportunities for additional reductions in toxics use. Those firms subject to TURA planning requirements are required to use ths method for qomng their l X R progress.

Dunng the ad)incal phase of your TUR planning (see Chapter 3), you used basic maxenals accolunnng tools to quantify the magnitude of the toxic byproducts created by the processes you were mvesnganng. T h ~ s data will give you the baseline you need to measure your TLTR prqyess. If you have not already quantified your byproducts, make sure to do

so before implementmg any TUR changes - for o~therwise you will never h o w how effective your XTR pr- Ls.

However, unless your T L , change will entirely e l h k i t e the use of some toxic substance, this raw byprcxiucr data done will not be enough to establish a baseline for measuring progress. Before dam on bypmdua mqnihldles (or use maptudes) can be rendered meaningful. it must be related to a "unit of product" appropriate for measuring TUR progress. llus u oececr;w because brute measures of byproduct magnitudes can shift due to factors uhch have nodung to do wiuh TUR - such as changes in production rates or in the average size of products.

Before nw byproduff d a u For inmace. suppox tha d e s slumped and your firm were to cut production rates in half.

a n k used m asublish a This slowdown would probably lead to significant reductions in the total magmtude of toxic blra l~ne for meuunng byprodurn. If you had ~mplemtnted TUR changes and were measuring progress via prograu. ic murt k r d a d byprcduct reductloo aim - without discouniing for reductions arising from slower m an appmpnrce 'uruc of production ram - then ,mu ought mlstake an i n e f y e d TUR change for a hi-ghly effective product. ' one.

Conversely. rf demand were to soar and production rares were increased, you might conduct successful TUR va q s u r an increase in total byproduct magmtudes. Your progress measrPancnts m u a adjua for such extraneous effects, as it clearly should not count against your TL'R program that yarr firm is prospering.

Choosing a Unit of Product

The soluaoe dm. IS to c o m a for changes in pnduction rates by me&-rsuring toxics use or byproduct pencrahon per unrr ofprodur. However, it is no simple master to choose a unit of product w h d will re& meanmgful measures of progress in reducing toxics use or byproduct geaennon.

The key is to b o k fa a m t of product which is associared with a constant per-unit magmnule oftoucs used or p c m e d a b)prducts. Suchaunitofproduct may be measured in unns of number of p~eccs m a d or n may be measured in otherways, such as in terms of area or volume

The select~oa of an appropuv rmlr of prcducz is perhaps best explained by example. h a g m e a r n e d w d m g firm thu u u s me production process for maklng two lands of metal parts - one large and b e other nnall Suppose that the total volume (sf toxic byproducts associated with eacb LPpe pan u sgnificantly b g e r than the total vojlume of byproducts associated with the d l c r pan h thar case. it would be misleading to select individuolparts as the unit of pmdua. be- upf i can t per-unit increases in byproducts might result from extraneous faaors arch as a sharp growth in conslamer demand for large parts.

For the metalworhng h e bcxnbed above, it might be more appropriate to select surface area of parts. or perhaps p u d s of parts. as a unit ofproduct Some research may be required to identify the appropriate urul of product.

Remember ha! In choonng a umr of produc,r. the operative question :s always the following: Is t k m a p n r d r of byproducrr for roxics use) per unit of product relatively consrant for all productr made by r k prodoaion onir? If the answer is Yes," then the unit of product will xn-c as a reliable srandard for measuring TUR progress. Thar is, it will provide a mea.si.ue wbch IS unaffected by hfts in the rare:: ax which various products are made.

Once you lure i d d e d an appmpnate umt of producr you a n use che dam gsnented by the materials accounang you did in Oupter 3 to crate a b l d ~ n e for

rneasunng TUR progress..

Focus Identifying a Unit of Product

Ece tmit OfproducZ H ~ w e v e ~ ~ k r c a l r n a n ~ ~ ~ ~ fonndthat w-itfia vethtnjnnPawOdcaWesdurioncanbeioMd

bc;J semiconductt# aum&x&m began by c c d d a m g "micmchtps in as mrmn ofprodus. ~ e v e r , t h i s p v e d u n ~ f e ~ r a ~ f e a s t t U r ~ F i r % n u t a l l ~ ~ t f # : f m n ~ w e r e ~ c m a l , y ~ a d e ~

wenboofnan-fkmd cfiipssWromas TLTRprogress- S e d , s o n a e a7ze fsr mart complex than atfLes., and the n r a n u f a m of these more

s u b s t 3 n o y ~ rimpkr chrps. Howtw,m these

&aau use of axics. Wawhual chps arc cut fiom krgersificoa w h

coademd 'wafers prodoced' as a possibf e tmit prodoadlbythrrfam\Pnedia~erfrom

sizradccomplcxn?..rbatwas~#) dm p.obncad d tbe mlmbt o

and mnhplymg used Campany

d b y t b t p a r u

Gauging T U R Progress

Once y o u tutc rcknnl5cd an yrpropnare u t of product, you can use the data generated by the m a r x u 1 jc:.xnrmp bou drd m Chapter 3 to creare a baselme for measunng TUR progress )'ots m u c n h acuuncmg data should tell you how much toxlc byproducts your pre-TUR p r o c a s 15 crclrang d S m g a glven penod of m e If you hvlde t h s amount by the total uruts af p r ~ x l u a xsteci d m g the same penod. then you wlll have the before-TUR byroducr me.- uami u hrch your TUR aclevements can be gauged

The after-TI-R ribwe b grnersted m much the same way You w11 need to engage m a fresh a n d \ s s ot \our mc lslincd product~on process, drauvlg up process flow hagrams and chermcsi pasbts 3 b a d \ s e . r&ntlfrmg all pomts ac whch byproducts are released. and usmg marenals xcounrmg dr m u W c e measures to assess the magmtude of those byproducts If you need tc rctrc,h \our memory on how thts 1s done, refer back to Chapter 3 4

Once :ou h ~ b c mplemented ]iourTL'Rchange, youcangauge yourproe~ess by measunng the total mou:r st rt# toxic subsrance whlch 1s released as a byproduct ofthe altered process over agl\en pend ot tune. anddlr~dlng that figure by the numberofunlts of product created over the m e tune p n o d This u111 g ~ k e you your post-TUR byproducts per u t of product.

You can determine the percentage reduction you have achieved by using the following formula (where A = Prc-TLTR Byproducts/Unit Product; and B= Poa-TUR Byproductd Unit Product):

Percentage Reductioln = 100 x L L E A

If you a n document concrete cost ravings a t rhu rmgc I t

may be w& dnwng up a

u s e study of b prolea. wdl a full arulyus of m sffscu. on b u r ~ n a r coro. and arculaong rr among t o p rnamgen whore support may ba crmal to your mm' r furure T U R prolrm.

When measuring post-TLR byprodurn, make sure that you do not inadvertently include byproducts wbch are due to maintenance or cleaning operations which are not performed routinely. If your post-TIX dam refleas waste fm~m these steps and your pre-TUR data does not, then t h s may cause you to understate reductions achieved in produczion-related wastes.

You may have opted. for purposes of internal :analysis, to measure progress by Qzkmg your u of the tox~c substance in quesrion If so, then you can use the above formuh to calculate your perccnrage rrductlon by letting A := he-TUR Use~Unit of Product, and B =

Post-lUR U&mt of Product. Once you have measured your progress, you carn go back to your initial financial analysis

of the l U R projcc! and dererrmoc whether the change has had the predicted effect on profits. If you can documart concrete as savings ax this stage, then it may be worth drawing up a case study of the p o j e a wth a full d y s i s of the effects on business costs, and ~1~cUlating it among managen whose nrppon for TCTR may t~ critical to your team's future projects.

Problems With Byproduct Reduction Measurements

As noted above, mcasunng byproduct reducaons is a relatively reliable way of measuring TUR progress. it s also one measurement method prescribed by TUR4. Thus, any reduction in byprodurn per a t of product conmeutcs W 4 progress as far as the law is concerned. However. thereare ax least rwo hDds of cases in *c:h themethod may not providean accurate reflection of actual nducncms m tbe use of a toxic substance.

Recall that the amount of a r o x ~ c used is equal TD the total of the amount whlch ends up in the producr the amount uhch ~s convened in chemical reactions, anal the amount which ends up as byproduct CErmsaoas arc ma a faaor he:re; under TUR's specialized defhtions, all emissions arc byproducts fm. before they become emissions.) Put more precisely:

Use = B~yproduct + Preduct + Amount Converted in Reaction

Since the amount of a touc subnrmce going into products or lost in reaction is not typically increased by TUR-ple changes. n rs not usually possible to reduce byproducts @er unit of product) withour nmultaneously rtducmg toxics use @er unit of product). However, your XIXplanmng tram should k aware thar m rare cases, decreasing byproduct-per-unit-product ratios might in&wu rim! rnm toxlc subnances are :going into the produa. Process changes wbch have thu effect sbould be pursued with p e a t caution, as they may pose risks to consumer health. and mav mmase the toxicity of a1 product which one day will have to be dqosed of.

There is one other case m whlch byproduct-per-unit-product ratios might be reduced without commensurate reductions in toxics use. f i s case arises when some portion ofa toxic substacce is consumed dunng the production process - usually because it: breaks down into its consunrent parts. A process change whch causeti such a chemical reaczion might reduce

byproducts without actually reducing toxics use. As long as h s sort of change falls under one of the SLX cavgones of TUR techniques, it counts as TUX under the law. It may also be very h ~ d a b l e - pamcularly if the toxic breaks down into benign components.

TUR should not ba a ooashot affair. QUIQ h e oppasm: your fim TUR pmlectx should prow& &NJ aorr of larn~ng experience needed o, make your ~ u n mom proficocm at identify~ng. plannlng and carrying out TUR changu.

TI;'RA NOTE: Measurement of progress is required under 1IZTRA's annual reportlug reqwments (Form S). These reports must identify al l production units a! the facihty. specify the unit of product for each production unit, measure the byprcnhct reducaons acbeved for each toxic substance used in each production unit. and idcnafy the lands of TUR that have resulted in byproduct reductions of 5% or m m . Tkeze reductions are expressed in terms of a Byproduct Reduction Ioder., whch rcpments the percentage reduction achieved in byproducts-per-rmit-

- produtx. These reduction percentages, in.turn. are m e w e d in terms of annual b y ~ ~ ~ i u c t rnagmndes. and mdexed against byproduct ma-enitudes from a base year spec~fi~ed on tbc form.

Form S also calls for the annual reporting of an Emissions Reduction Index for each aoxlc subasocc m each production unit. l h ~ s latter figure represents the pcrm.ugc rcducnon acheved in toxic emissions which are attributable to the produtnoo u t .

77u & w accurate memrement ofprogress under TC'RA lies in the selecrion of clppr~opnatr p r k n o n umu. producrs and unirs o fproduct. The law permits a wde d t p of hntdc m applying these categories to your facfity. Each firm should seek to deslpme production units whose products can be counted in a way wh~ch pcrmlts meanrngful mamrement of TZTR progress. That is, products must be dlvtsible mto m u of product with relanvely uniform toxic byproducts or relatlw:ly mform t o x ~ a w.

F a umancc. h e law pmnto firms to group similar products together as families of prodiucts. wtuch can be trcafed as a single product These groupings will usually tunder the measwnncnt of TUR progress unless each member of the family is produced u-ltb the same technology and can be counted in some way that ylelds a similar pr-umt rate of IOUC byproducts or toxics use.

See Appeodu 1 for more informanon about measurement of progress under TLJRA.

6.3: Documenting TUR Accomplishments and

Sustaining Commitment

From tbe b e g m g . ttus manual has presented toxics use reduction as anew way o f W i n g about your producuon processes - one wh~ch should d o r m all aspects of your production plannmg oo~ an ongolng bas~s. The manual recommends the creation of a TUR team to instiruuonallzc th new way of thmiung by spreadmg awareness throughout the firm, a n a l y ~ g tc~ucs w in production processes, identifying and evaluating TUR options and overseemg h e mplementation of TUR changes.

If TUR E; to take root and prove genuinely successful in your plant, it is critical that your

, .,-7---?-,-7 -- ~- p - , r I - ,

N R raqulru che mnchur~asuc paruclpamon of man7 different departmenu rmhln rhe cyptcal planr By racogruung a w d e n n g e of paructpanu. your firm a n hdp m fasolar

chls sorc of r n d u p r u d o n t h u s ~ a s m

TUR team not lose steam a h it has imp1emente:d a few producrion c lhges . TUR should not be a one-shot a f f k . Qlute the opposite: your first TUR projects should provide the sort oflearning expencnce needed to make yourteam more proficient at identifyng, planning and carrying out TUR changes.

If the changes meet with success, they should also help to build enthusiasm for TUR among workers and management - perhaps making it easier to gain approval and funding for future TUR changes. But even if your f im experience with TUR meets with failure, it should be viewed as an opporrunir]l. to deepen your understamding of your processes and to learn from mistakes.

You can keep your team acnve by holding regular meetings, inducting workers and managers who show an merest in TUR as team members, staying in communication with workers, and mmamhg open to TLJR suggestions from all quarters. A commianent from management to rccognut and reward effective p:llticipation in TUR projects can also help to sustain enthmasm for tbc program.

IfTUR projccr pamclpants arc glven awards or otherwise reco-@zed, make sure to share the recogmtion ulth all those who played a role in Ithe project. TUR requires the enthusiastic partic~pation of many &ffermt kpamnents within the typical plant, and widespread rccoptlon should hclp to foacr thrs son of widespread enthusiasm.

AAer your f i r s prqecr u completed. there are two important kinds of work for your team to do. The fim u to keep track of the changes you have already made, measuring their progress and uuurrng that b e y reman m effect. hodurnon processes which have been changed shouid be revlslted to make cmtam that the changes are still iu place, and that the workers undentand any new poccduns or technologes. For instance, if you have reduced byproducts by rcplaclng leakmg plpes and valves, lnake sure that the problem does not recur by checkmg the new pipes sod halves periodically and replacing them when necessary.

The second son of work your uarn sbouid be engaged in is the search for new TUR oppommities. The analyncal data whch you ha.ve gathered during your TUR research represents a bank of knowltdge wtuch wdl make! it easier to identify and evaluate fresh oppommities for TLU

You can lend f c a s to vour TI-% e f f m by decithg what projects to ,focus on next. You might decide either to punuc adcb t ld h g e s to production h e s whlch you have already worked on, or to address some chem~cal or process which you have not. yet considered

For inslaucp. you may have rakrn tbe first steps toward reducing use of some particular toxic substance. You could follow these steps with1 more concerted efforts to reduce use of that toxic, or you could shxfl vour focus by invesbgating use patterns of some other toxic substance. You may also find that your f h successes with TUR could be: replicated in other Nnilar operarions througbou~ your plant and throughout your companly. These sorts of changesmight be worth pumung. xmamgement ismore likely to fund projects witha proven m k record.

Of course, the mformmm you have gathered m ~ y not be ent~rely sufficient to guide you toward additional TLX succtsses It IS cmcal that yourteam make continuous improvements in the precision and complcvnca of avadable data. IEventually, you should develop accurate dataon toxiw use, byrodurn and emissions for all produrnon units. % will not only help you to spot new TUR oppommines; it should also help your firm to improve the efficiency of its production ptocesses.

To remain effecnve. your team must stay abreasr of production h e changes in your plant, as these might marc k s h oppormnitles for TUR If your plant is planning to construct a new producrion line or a new facility, you shouidl seek permission to parncipate in the

Wkh rhe nght comblnroon of cntnus~asm. parslsrcnce and susn~ned commltmcnr your ream can slowly bulld corporare-w~de awareness of TUR u an em~ronmannlly respons~ble approach to

~ndusmal t o n a r h ~ c h I:r Krnrnre to rhe b o m m i ~ n e concerns of bus~nesr.

plannrng process from the beginning, in order to insure that TUR measures are built into the final result.

Your ream can also enhance its effectiveness by staying abreast of new TLTR technologies and produalon t e b q u e s whch might help to reduce your firm's reliance on toxics. To this end. you should trade ideas with o t h e r h pursuing TUR., send representatives to trade fairs or expositions focuslng on environmental technologies, and stay in contact with OTA and the Toxics Use Reducrion Instmrte at the University of Massachusetts at Lowell.

Remember that TUR alternatives take shape against the backdrop of pending regulaaons, s h i h g costs of raw materials and dqmsal. and changmg public concerns and customer demands. It is mportant to be aware of any changes in this environment which might help you to identify new TLTR opportunities or to make a case for TUR changes which might previously have been unattracave.

In these ways. TLR is closely related to the much-discussed notion of Total Qmhty Management. Lkc Total Quality Management. TUR requires the active and sustained commweni: of a wde range of personnel: f?om top management, to purchasers, to research and develop~nent personnel. to production line workers. Both sorts of pro_g.rams also call for continuous umcmenral improvements, each of which moves your firm closer to the ultimate goal of- possible qual~ry or of least possible toxics use and zero toxic dscharge. And both r e q m connnuous rccmlderanon of new techmques, technologies and cost factors which might make :feasible tbe funher unprovements which yesterday could not be anained.

Witb tbc rlght combmanon of enthusiasm, persistence and sustained commitment, your team can slow1 y bwld corporate-wide awareness of TUR as an environmentally responsible approach to mdurma2 toxlcs wh~ch is sensitive to the bottom-line concerns of business. In the proccn, you can help to maire concrete production-line changes whch will haveapositive impacr on worker health and safety, public health, and on the natural environment we all share.

Appendix I: TURA Require- ments and This Manual

A I .O: TURA Requirements and This Manual -- An Overview

As n o d m the mrroductlon. TUR is not only a new business practice and a new mindset for thrnhng about en\uonmental protection - it is also a new approach to environmental l q i s h o n . To dafe, more than m e dozen states have passed legislation requiring businesses to carry out TUR or o t k closely relared pollution prevention initiatives. Lo July of 1989, the Massachlcias kgslarurr unanimously passedthe Toxics Use Reducnon Act-), the firs and one of the mon amblnous of these state pollution prevention bills.

TUIW. u-h~ch was developed in close coopermon with industry leaders, requires large- quantity u x n of m x ~ c m a v n a l s to report on their use of toxic substances, and to undergo a plannrng proc~tss w e d at rbn fy lng and evaluating TUR options. TURA sets "a statewide g d of reducing toxrc w m generated by 50% by the year 1997 using toxics use reduction as the prcfmaj rnezns of mearng &.Is g d . " Other goals o f I U U include: establishmg TUR as the prefmrd m u m for regulatory compliance, promoting the competitiveness of Massachums mdusq. a d coordwmg state environmental programs. k geacr;iJ-purpose manual is designed to help launch successful TUR programs at aII

Massachuscns mnmoas u k c h use toxics - botb those wbch are required to do TUR planning by the swe's Tox~cs Use Reduction Act (TURA), and those small-quantity toxics usen not covered by the law. The aim of this manual, then, is nor principally to help businesses me:t the lencr of the TURA planning requirements, but ro promote TUR as a new way of thmlung h t mmufacrunng processes and their impact on corporate finances and the envuonment The emphasis is on helping businesses to create and sustain in-plant TUR programs wtuc:h rdennfy and act on TUR opportunities.

However, u;hle &.Is manual is not focused specifically on complrance with TUX-4, it should prove q,mte useful no any firm seekmg to understand and meet the requirements of the law. OTA's elipcnence indicates that forming a TUR team and launchmg the sort of TUR program descnbed in t h~s manual is the most effective way to accomplish the kind of toxics use reducaon e:ncouraged by the law. Tlus remains true whether or not your firm plans (0

retain an enwrxmental consultant to help you comply with TURA.

m~ lapun 'uopnpax asn ssyxo~ se nrmos 3m1262u p ion re^, mo 01 ~aeuodv ? 11

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MU JO aauF3sqns snoprerey J'O >!xoa e ha- ruopupqng mdul -1

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amy hw suo~uv@~~ ayC so *alrallta~-mbar mnj /o JUUO~ pnJo w rs p~ly 2q IOU pays quaddv syu .8ugym q jo arcrp ;3q n prrtrp Aaq~ n 'swmamh 8-d pue Srrprodar aq qzldxa snop3a.s ow lxan aq alqa 'mq atpjo mxuao ne wold quad& aqa JO noprod lsry au .pnem srq~ a! paquxap sdas atp pae nruuzannba asq naarmaq sqrr~[ aq aon a pue jo slnamannbar aq ydxa a n rqxrdde sq~ jo laam aql

.sa8ueqs uasoqs jo nope;mamaldtq JOJ qaw t 8- prre 'hr~qeu ~3ueq pm p!np3n qaqa jo stma rn mmq Srrsenpa po~ moado xu Smpuap! 'asn s3pajo ~3edw 3ponosa aq 3upnssrrr4srp noqnpaxl JOJ sme&q mo~ smlddn %verp 'noperaua8 ~~npo~drCq pm asn sspa zualm2 %d p 3pSi 8mqpsap no Asgod mama%mem ap$-hpsej e %qyi se qsns - paw aq~ rn paqwsap sdw aqajo ICUZUI arepaem Kpu3e nnamaqbar 8-d 'r~sn Drxol &uot?rr()Sq 103

By July I . 1994. each large Qumq Toner Char must

d c r d o p z n d w a Tauer Usa R e b c w n phn lrrch s p c k w

pudf-~rsd-m andadsolkdmplanaroam rchddr

recychg on~lv counts ,as TUR if it is integral to the production unit in whch the toxic subsrance is ,used. The reason for this requirement is that off-site or out-of-process recycling requires hanchg and Pansponatlon oftoxics - either within a factory or between two plants, via public tughu.ays. l3.s handling and transportation can pose a risk to the environment, as well as to pubtic and workerhealth. Thus, whderecyclingtoxic substances is usually better for the envifimmenr thaa sunply &carding them, it is not the son of optimum solution which elimlnarrs the t h m posed by toxics by cutting them off at the source.

It is wortti rnenn-g a few other h d s of production changes whch do not count as Toxics U s Fkdumon. For i m c e , on-premises treatment or incineration of toxics is not a form of TUR Ldcmxe. any production change which shifts risks from one medium (i.e. air. waxer. hxW) to another does not count as TUR

Who l o Sirbject to N R A ?

SURA plannlng and rqpomng requirements apply to firms which meet all three of the followmg cnltcna:

+ Process alr manukcture at least 25,000 pounds or otherwise use at least 10.000 pa~unds of subsnnces regulated under T i l e Ill of the federal Superfund Amendma# and Rcwrhorrnoon A a (SARA). From 1 99 1 to 1 993, the act was cxpvdtd gradually to mclude dl substances regulated under the federal Comprehen- uve Enwronrncntll Rcrparue and Compensation Liabilrcy A a (CERCLA). Addiuonal charclts rnay be added to or deleted from the tin at the rate of no more than I 0 per year u. thc d u r n of rhe TUR Council.

+ Ern- I ID or mon full-unc employees (or h e equivalens where I full-ume

emp&yee =: 2000 work houm per year.)

+ Fall withub Scandad Industrial Classification (SIC) codes 10-14 (mining); 20-39

( m a n u h ~ n g ) : 40.4449 (rnnsprtation. communiczlrions. gas, electric, and annary services): 935 1 (*mdaJc crade); and 7273.75.76 (certain services).

Companrcs utl~cb met dl rhree of these criteria are categorized by the law as Large Quantity T O X I I ~ LLBI ( LQTUs). These firms are required by TUR4 MGL Chap. 2 1I) to file annual reports uhtch h l ther use of listed substances and document their ongoing effons to redurx or elunumc thelr dependence on these substances. By July 1, 1994, each of these busmesses mua dewlop and certify a Toxics Use Reduction plan with specific two- year and five- ycu rt6umcm goals anda detailed implementation schedule. These plans must be u p d a d every w o vears. Semon A 1 3 of thls Appendu e x p h this plaxuung process in some d d The contams the TURA Planning Regulanons (3 1 0 CMR 50.00).

AU Massachuseas tons usen whrch do not meet the above three criteria are categorized as Small Quurtic Tosics U s e n (SQTUs). After July 1, 1995, certain SQTUs wtuch fall intodcsgnacd "pnonty user segments" may also be subject to TLTRAreporting and plannmg rcquiremmts.

The irnplemc:ncanon ofn;RA IS funded by an a ~ u a l fee levied on all LQTUs, based upon the number of people they employ and the number of chemicals they use at above-threshold levels. a s fee covers DEP's regulatory and enforcement costs associated with TURA,

APPENDLX I : TURA REQUIREMENTS AND T H I S MANUAL..

supports the Ottice of Technical Assistance in its (efforts to provide t e c h c a l TUR help, and funds the research and m m m g s e ~ c e s providedl by the Toxics Use Reduction Institute at the University of Massachwts at Lowell.

A 1.2: TURA Reporting Requirements

T[IRA requrm all Mawchrrrats LQTUs to subunit one or more Form S reports each year

lht Form rcporr pronb a on or before July 1 (-g rn 199 1 for LQl'Us in the 20-39 SIC codes, and m 1992 for denlled plcarrt of con= UK all other LQTLTs) These aanual rrpons provide a detailed picture of toxics use patterns for plr-m for u c h produrnon each p d u c u o o ut and for tbe faclLrry as a whole, and serve as an mstniunent for measuring unn anti dre hu'lr). a annual propen m r c d u ~ g touc byprodurn and lemissions through TLR process changes. &It. anti setvu as an Instrument for rneasunng

The Form S u cssentdly an expanzron of the federal Form R reports required under

Dronrur In rduorrP Sectlon 313 of t&e federal Emergency Plannulg and Cornmututy Right to Know Act . " - m u c byproducts and (EPCRA). A cocnplcte mud rcpon for a single faciLity should include: a copy of all Form emusions chrough TUR R reports filed by tbc firm. a completed Form S for each listed chemical used, manufactllred process changer. or processed m abovcthresboM amounts; a Form S cover sheec afee workrsheeq anda TURA

fee payment h a a l l y . TLR4 rcquurd fxhrra to report on all chemicals re_dated under Title 111 of

the federal S-d Amendment and Rtauthoriidon Act (SAK4). From 199 1 to 1 993, the act was expanded paduallv to rnclude all substances regdated under the federal Comprchcns~ve Enw~nmcntal Respoase and C~ompensation LiabiLity Act (CERCLA). Adhnonaf chcmrcals may be added or deleted ar the rare of no more than 10 per year. at the drscrenon of tbe n;R Counc~l

TUR rrpomng packages - wtuch cootam all relquired forms, reporting instructions, and up- h oicovaed t o u u - can k obtained by contacting DEP at (617) 292-5982.

The Form S Cover Sheet

The Form S cob= sbta lacludu r mprchensive List of all those production units in your fachty in u h c h some lined & e r n i d s used. A production unit is defined under the law as a produrnon h e . metbod acnnp a t c h q u e , or a combination or series thereof, used to produce a product In othr words. a is a combimnon of a producr (or service) and rhe processes (or acnvlnu) use3 to produce ir. rather than merely a production line or a piece of production marbmq Thus. ~f two producrs arc made by one single production h e , the entire operancm could be counted ls two production units.

Since prcducnoo itmu arr ptlrtd combmations of products and processes, there are three neps u h c h you must out rn order to desipate them: (1) divide up your plant into discrete producnoo proces=. ( 2 specify your prcducts; (3) pau your :processes together with tbe products poduced by them. As you carry out these steps, keep in mind thar all products and processes wh~ch use or generate TUFA chemicals must be included in some pduct lon ut. In tbe same vein, each prcduction un i t must include all discrete steps which use or generate toxrc substances - inciudmg such often-overlooked steps as degreasing, equipment cleanmg. and materials n o m e and han'dling.

Each firm has a w~dc degree of lantude in dividing production activities into production us. The flexibi11t-y anses m pan because produclts can be specified in a number of ways.

A ludiclous d i s ~ c m of your plant lnoD producnon unla can hslp make your TURA planning ef fom more effecuve and your annual measuremenu of progrus more meaningful.

Under the law. aproduct IS defined as "aproduct, family ofproducts, an intermediate product, afamily of i n t e n n t h products, or adesired result or afamily of results." It is worth giving a good deal of thought to the appropriate specification of products and production units, as these groupmgs wdl provide the framework for your TUR4 planning and your annual progress reports. A judmous division of your plant can help make your TURA planning efforts more effecnve and your annual measurements of progress more meaningful.

Essentral1;y. there arc nvo ways in whch firms can gain flexibility in dividing their plant into producnc~n m u Thc !irst is by deciding whether to consider related products singly, or to group ttum togaher mto a family of products. By considering each product singly, a firm can &v~de lu plant mto a large number of distinct production units. On the other hand, by groupmg products mto W e s , the number of production units can be minimized.

Firms an <also p i n fleubllity m designaang production units by counting desired results and btermccliate products among their products. These categories are broad enough to include tbc cxrpurs of many prelunmary manufacturing stages. Thus, by specifjmg producncm uuts la vrmr of mvrmediate products and desired results, firms can achieve a more fix-tocshed a n d y n u l & \ u ~ o n of their processes. Alternatively, they can reduce the number of pnxiuctlon unlu by considering only final products and results.

From he p m t of \xu. of papcnvork simplification, it may appear artractive to ignore inrtrmadratc products and p u p tinished products into asmall number of large families, thus mhunrnag the number of producnon units on whch you must report each year. However, broadly defined pratumm unns which encompass several different toxic chemicals and technologes art k l y to c o n f u x your efforts to analyze processes, pinpoint wastes and gene= TLT. altananves M a c mporcantly, broad production units are likely to make it impossible to musure TLX progress in any meaningful way.

Ln & \ d m g yourplant mto production units, it isespecially critical to designate production units for d ~ c h relanvtl~ coasaut comelaxions exist between the volume of toxics used or generated zl byprduc, a d tbc mount of product produced. As was explained in Chapter 6. &IS u he key to mcl~sayful measurement of TUR progress. Of course, the constancy of &IS oomlanoo nlll d q a d m pur upon how you decide to count your product - that is, on what unit of prodwt y o ~ r xtcrr However, if you draw your production units too broadly, includtog w d l m tbcm pdu,u n hch are made through disparate production technologies, then thee be n, m a \ of counting products which will render a relatively constant correlatioo kruccn mucs uu or toxic byproduct generarion, and units of product prduced.

Ln general. you uo proup products together in one family of products if they do not differ significandv ua the v c h w b e s used to produce them, the amount of toxic che~~llcal used in producrng k m . and the amount of toxic byproducts generated while producing them. One way that propess IS m e v u h f under TURA is by tracking reductions in toxic byproducts, so it is especdly c n t i d tbu v c u proup together only those products which produce particular toxic byprodurn u sunrlv rucs

The final crsk m rh d~vrs~oo of your plant into production units is to specify a unit of product for wtch p x h c t ~ o n u ~ l l t . Thls must be done because your TUR progress cannot be measured rnummgfullb through raw measurements of toxics use or byproduct generarion. Such maurcments a shfl due to facton having nothing to do with TUR - such as changes in producnon lam or m the average s u e of products. In order to render your byproduct d m useful. you m u n rche it to the total number of units of product produced. For TURA r cpomg purposes. this is done by keeping tabs of toxic byproducts per unit ofproduct.

The key helr IS s e i e c ~ g a unit of product which produces a constant per-unit magnitude of tox~c b~prolducts. Such a unit of product may be expressed in tenns of pieces produced,

APPENDIX I : TURA REQUIREMENTS AND MIS MANUAL..

For TUR repomng purposes. the key m d a d q a unit d product is to choose one which yields a c o m o n c per- unit m a g n d e of m u c byproducu.

or it may be measured in other ways. such as total product surface area or total product volume. Most importantly. it mun be a measure that reflect. the level of producrion or activity associated with toxics ux or toxic byproduct generation. (For more on the selection of an appropriate unit of product, see Chapter 6.2.)

State regulanoas previously required that the unit ofproduct be a physical measure of the product. and mt a related productivity m e m z such as labor-horn; or elapsed production time. However. DEP now allows lixms to use n~n-physical measures if no physical measure is feasible. Finns whch choose a non-physical unit of product must supplement their Form S with a lener exphmmg why a physical measure cannot be used, and stating how the non- physical measure has been adjusted so as to reflect production level changes accurately.

The F o m S Report on TURA Chelrnicais

LQrUs must fill out a separate Form S report for each listed chemical used, manufactured or processed m quantines of more than 10,000 pounds per year. Each Form S requires fachty-wide mfwmaam about the amount of the chemical manufactured, processed, or othenuise used. and the amounts sh~pped in prcduct and created as byproduct. The Form S also requires more specific mformanon about toxic byproducts and emissions ofthe chemical in each of the p d u m o o u u m which it is used.

Where TLX effom hare led to rdumons in toxic byproducts, the report asks for generic information atrout how the reductions were achieved. T h ~ s infomarion is provided in the form of a marnx which shows whrch of the six foms of TLR (See Chapter 4.2.) were unplementtd at whrch sages of production (i.e. materials storage and handling, processing operarions. or finrshed goods handlmg). Only those TUR changes which account for ar least a five percent rcductlon m the B>podua Reduction Index are to be mcluded in the mamx.

The meanrng of byproduct and emission un~der TURA is the same as the meaning which has been assigned lo h e x tcnns tbou@out this manual. In brief, a byproduct is a non- product outpuf of a toxic or h.azmbus substance prior to handling, transfer, aearment, or release into tbe enbuonment. An emission is a byproduct whch is released into the environment or othcruw leaves the plant.

The materials zcounmg t cpbques described in Chapter 3.4 ofth~s manual should prove helpfui in mmsunng the maprude of toxic byproducts created by your production units. Once you have sclecwd an appopnatc unit of product, you can use: these raw byprodua measurements to cai& tbe Byprodua Reduction Indices required by the Form S.

The first thmpth3t you -111 nced to do Is to specify a base year against which TURprogress will be measured T?x base y u r for each listed chemical/production uni t pair is the larmof (a) the firs year thy vour p h r -.as required ID file any infonnatlon regarding the toxic chemical under EPCRA or RR4. or (b) the fim year about which youjrfacilrty has sufficient inionnabon abouf tbe prcdumon u n ~ t to complete the Form S.

To complete thc Form S. you will need to derive the following figures for the base year the total amount of the chanlcal whch ended u:p as a byproduct of the production unit, the total amount uhlch ended up as an emission of the production unit, and the total number of units of product created. With these figures in hand, you will be in a position to calculare two figures q m n whch improvements can be indexed: (1) byproducts per unit of product for the base yur . and (2) emissions per unit of product for the base year.

The next step IS to calculate the same two figures for the year in which the report is being filed. If you have camed'out TUR changes, ths niay require afreshanalysis of your modified

production process; that is, you may have to draw up process flow diagrams and conduct chemical pathway analyses in order to identify al l points at which byproducts are released. Then, you w i l l be in a position to use materials accounting to measure the magnitude of those byprodurn. Provided that you have mformation about treatment efficiencies, you can use these byproduct magnxmdes to gauge youremissionsmaptudes. (If you need to refresh your memory on1 how thtse svps are done, refer back to Chapter 3.)

Once you have calcuiattd yourannual byproduct and emissionmagnitudes, you can divide them by the total ~ u o f p r o d u c t producedduringthe reporting year to gauge your byprodum per unit of product. and your emissions per unit of product. You now have the informarion

Om sf dw ,rnporPm needed to fill om ywr Form S. rrrpr your firm a n a k e ro The foU~m-tng formula *ill yield your Byproduct Reduction Index (where A = Base Insure long-cam TLJR Year Byprcducts/l;'a~t Produc~ and B = Reporang Year Byproducts Per Unit Product): progress u to supplernenc your current record-koep~ng rc due you have cornpleca and accunce dau on mua

Byproduct Reduction Index = 100 x A

uc and on byproducr and ernlsslons genenuon. The ermssrcms rrducnon ~ n d e x can be measured with precisely the same formula (where A - Base Y a r Ermss~oas*Ua~t Product; and B = Reporting Year Emissions Per Unit Product).

When m c m g v n m g year byproducts, keep an eye out for byproducts or emissions arising fm m w u or clearung operations which are not performed routinely. If your repomng-vcar data r d k c r s wasu from these operafions and your base-year datadoesnot, this may caux vou to undmtav your progress. Such anomalies can be noted in section 1.4 of the Form S

n i R 4 docs not q u ~ c firms to d l new monitoring equipment to gather the data r e q d for TUFU rrpsmng head, firms are asked to use the best information they have on hand However, w e of th m m unportant steps your firm can take to insure long-term TUR progress is to supplement your m n t record-keeping so that you have complete and accuratc d s a oo toxlcs use. and on byproduct and emissions generation. Whatever your record-keeptag tcchqt#5.7LXA requires all firms to maintain on-site records of the data used to perform the calcvlrmoas required by the Form S report.

Trade Secrets

Any infomamoo ~ncludtd on the Form S reports is available to the public unless the firm requesrs Padk st- status for that specific piece of information. Then, it will be kept confidennal unless DEP dtcamlaes that the infoxmation is not a aade secret.

There is a s p a for requesang uade secrer status on the Form S Cover Sheet. In order ro quaI~fy as a trade secm. laformanon m w meet specific crireria spelled out in D e p m e n t of Environmental Rotemon rcgdat~ons (3 1 OCMR 2.30).

In generall h e form should reveal nothmg of interest to competitors, as they include neitha the quann? of @ucf or byproducts or emissions produced. They contain only percentage dhgcs m byprodum and emissions per unit of product, and these numbers cannot in gerieral be used by competitors to determine how much of any gwen chemical is be~ng used by or released from your plant.

APPENDIX I : TURA REQUIREMENTS AND THIS MANUAL..

A 1.3: TURA Planning Requirements

Thu appendix should nor be undenamd u a defin~ave gu~de to compliance wrh TURA planning requ~remeno. Wore you a-pc w dnw up a TURA plan. you sbuld dmc p u r set of DEP phmmg reguh- d o n r a l J p 0 3 h ~

By July 1, 1994 or July 1 of the yeat after it is first required to file a Form S, each LQTU must prepare a certified TUR plan whch provides a clear and detailed account of their TUR policies, research results, and implementation schedules. This plan must be updated every two years.

Unlike the annual Form S report, the TUR plan is not submitted to the Department of Environmental Proternon. However. a summary of the plan must be submitted to DEP, and the entire plan must be a\-adable on premises foi: inspection by DEP personnel.

Ths appendu. k c the "WU Notes" in the body of the manual, is based upon the general piannrng requirements wim mto the law, together with the regulations available from DEP at the Clme of ttus wnnng. The Addendum contains the Planning Reguianons (3 10 CMR 50.00). Thrs appendu should mt be understood as a definitive guide to compliance with ?ZTRA planxung requranents. Before you attempt to draw up aTURA plan, you should contact DEP at (617) 292-5982 m order to confirnl that you have an u p t h e set of TUU regdanons.

The followmg xctioa outllws the required e:lements of a complete TUR4 plan, and provides a brief descnpon of the required contents of each of them. Not surprisingly, these elements colnclde with the more genenc TURplanning steps described i n b s manual. These correspondences arc noted where appropriate.

(a) Facility-Wide Information

( i) The Management Policy Statement: ?he xnanagement's facility-wide TUR policy statement mua mdude a dcscnpnoo of the ways in which the firm encourages TUR and of any policies appbcable to the fad? whch encourage or discourage TUR. The statement may also include ~nfonnanoa about how TUA nffects research and development efforts, cap~tal lnvesrment dtcns~oas. humg. promotions, bonuses and worker incentives. (See Chapter 2.1)

(ii) Statement ofscope: The sutcment ofscope must include adescription ofeachproduction unit included in tbe p h . Lch such dtsaiptionshall include the following informarion fiom the Form S repon: the numberrsslpcd to the production unit, the process(es) associated with the unit, the product produced by the unit, and the chemical name and CAS (Chemical Absuact) number of each covmd toxic manufactured, processed or otherwise used m the produaion unit. (See Chapter 6.2 for linfonnatiori on production units.)

?he statement of scope must also mclude a surmnary of the process used to identify TUR alternatives for each productroo m t . (See Chapter 4 on identification of TUR options.) Finally, it must contarn bncf dacnpaons of the TUR alternarives whch have been chosen for implementanon. as well as those whch have bee:nrejected and those which will be studied funher. (See Chapter 5 on ekaluaring and selesin:g TUR alternatives, and Chapter 2.3 on setting TUR goals.)

(iii) Expected Changes in Toxics Use and Byprolduct Generation: For each listed toxic wtucfi is used or generated at the facility, the plan must include two-year and five-year projecnons for: change m pounds used, c h g e in pounds ofbyproduct generated. percentage

change in toxics use, and percentage change in byproduct generation. (See Chapter 2.3 on god-settmg and Chapter 3 on marerials accounting)

(b) Production Unit Information

(i) Process Flow Diagrams: For each production unit, the plan must include a process flow dmgram whch provides a v w d representation of the movement of toxics within the produrnon unit - both those which flow into the process as raw matenals and those whch exit the process as byproducts. emissions or products. The diagram must represent each step

F~~ mch producnon urur h in the m . a ~ ~ ~ f ~ - g ~I'OCZS, mcluding waste treatment activities and recycling activities that plan must ~nclude a process are not integral u, the production unit. The number assigned to the production unit for Form flow diagnm which pr0nd.s S repornng purposes must appear on the process flow diagram. (See Chapter 3.3 on Process a wual repraancroon of rhe movement of mucs *in

Row r)lagram~s.)

h producoon wt - bo+d chose which flow inm chc (ii) Current and Projected Toxics Use and Byproduct Generation: The plan must include process u n r r miarenais- and the foloumg rn& accountlag figures for &h production unit (i) the total amount, and

which P - a the amount per un~t of product. of each covered toxic manufactured, processed or othenvise u byprodurn. emlsslons or used; (ii) tbe told amount and tbe amount per unit ofproduct, of each covered toxic generated produca.

as a byproduct; (iii) tbc total amount, and the amount per unit of product, of each covered toxic rcleaKd c3r transfend off-ntc as an emission. (See Chapter 3.1 on data-gathering and Chaptcr 3 4 on, mavnals accountmg.)

(iii) Unit of Product: The m t of product wluch has been chosen for each production unit must be ~dcnafied in the plan. (See Chapter 6.2 and section A1.2 of this Appendix.)

(iv) Purpose Smed by Toxic: The plan must contain a statement explaining the purpose that each touc m e s in cad^ u t of product.

(v) Byproduct Measures: For each byproduct identified on the process flow diagram, the plan must include th a m o ~ t txwd on-site, treated off-site, recycled on-site, recycled off- site, d q m d of oa-sitc, cfisposcd of off-site, or released. (See Chapter 3.3 and 3.4)

(vi) Emission 3rleuures: F& each emission identified on the process flow diagram, the plan mun include, for each cn~uonmental medium, the amount released to the environment. transferred off-site. arated off-nu. recycled off-site, or dqosed of on-site or off-site. (See Chapter 6 2 )

(vii) Cost of Toxia Use: The planmust include the cost ofthe use of each toxic, as calculated in the financial analysts pwaon of the plan. (See below, A1.3, section 'c?

(viii) Byproduct Reduction Coals: The pian must include tweyear and five-year goals for the Byproduct Rducnon Index. reflecting the expectedimpact of the TURtechniques chosen for implemenunon. (See Chapter 2 3 )

(c) Financial1 Analysis of Toxics Use

For each toxlc used m each production unit, the plan must include the total cost per year and

APPENDIX I : TURA REQUIREMENTS AND THIS MANUAL..

The plm should alm state chs sromamd financ~al impacr o f lost communtry goodwill. u l rr lost m c o m p o n g non- muc pmduco. and porwol l babiliry +uocntsd rnrh use of eh mx1c

the per-unit-of-product cost of using the toxic. In this calculation, direct and i n h c t labor costs and matcnal cosu must all be considered, .and such costs must k specified in the plan. (See Chapter 53. especially Figure 5B.) All calculations should reflect cost figures for the calendar year precedq the date on which the ]plan is due.

Other costs wh~ch must be considered incicrde: purchase or manufacturing cost of the toxic; storage, accumulanon. treannenL disposal and handling costs associated with toxics and by-prcducts; costs associaud withenvironmental compliance (See Chapter 5.3, especially Focus on "The Cons of Environmental Compliance."); worker health and safety costs; insurance prrmnuns; and any otha relevant costs. If any of these cost categories are not re lev an^ the plan must explam why not.

The plan shouid also state the esamated impact of, but need not precisely quantify, the costs of lost commrmie goodvnll. d e s lost to c~ompeting non-toxic products, and potential liabd~ty assoctattd -7th w of the toxic. (See Chapter 5 3 for a discussion of intangible and liability cosa.

The plan mua also e x p h how costs associated with the use of' covered toxics were allocated to th production w t . (See Chapter 5.3 on the Financial Assessment of TUR Options. N o u that thrs seraon focuses on cost comparisons between existing practices and TUR alternanm. However. its ducussion of h i e various kinds of costs associated with the use of toxla should prow belpful in comp1etin:g this part of the pian.)

(d) Technical and Economic Evaluation of TUR Techniques

(i) Options Identification Procedure: The plan, must describe a proc,edure for i d e n t i w g TLTR options for each producnoa wt. (See Chapter 4.1 on TUR brainstorming.) The procedure shall mctude, but not be l1m11.4 to, a cc~nsidemon of each ofthe six kinds ofTUR techxuqucs set fonh under TURA. (s& Chapter 4.2.) It must also include a list of p e r s o ~ e l involved in the procedure, an ?ccwnt of the sources of infomation consulted, and a descnptlon of mformaaotl-gsbenng techmques used. (See Chapter 4.34.4.)

(ii) List of Optiom: Tbe plan must Brst the TLTR options - including TUR technologes, procedures. and m m m g programs - whch were! identified through the options generation procedure dcxnbed above

(iii) Options Evllmatioo: Tbc plan must containan evaluation ofthe technicaland economic feasibility of each proposal on th ahve-described list of options. The evaluation must include at lean the foUonmg elements:

*A deterrninanoa as to wbctbcr the option repR!jents TLTR as defined under the law. (See Chapters 1.1 and 5 1 . )

*Calcuhons of reductloas LO toxrcs use, toxlcs use per unit of produc~ toxic byproducts, and toxic byproducts per unrt of product. (See Chapters 3.4 and 6.2 for related infomanon.)

*Costs and sakmgs assoclatcd with the option. (See Chapter 5.3) If applicable. this pomon should include a aatement of the discount method or cost of capital used, the depreciation rate used. and the project's payback period. (See Chapter 5.3, section 'e?. The discount method. deprecianon rate, and payback period milst be consistent with the facility's current

--

APPEND~ I : TURA REQUIREMENTSAND THIS MANUAL..

capital budgeting procedures.

*An examination of the relationship between the option and other applicable laws and regulauons., includmg but not limited to whether implementation of the option will violate any other hws or regulaaons.

(iv) Evduz~tions Which Need Not Be Completed: Toxics Users need not complete evaluations of opaons whch are clearly technically mfeasible, clearly financially infeasible, or which an: not likely to resuit in reductions in toxics use or by-product generation per uuit

The phn murr describe each of product. o p o n chosen for irnpkrnen- n o o n dcoil th~ C O S ~ and (v) Options Not Chosea for Implementation: The plan must describe each listed option savings asr0cla-d with ic. which will not be impllemented, and explatn why the option was not chosen for implemen- and list dw raducuom in tation. mxics use and byproduct genenuon wh~ch are - m r a u j c fmm he (Yi) O p t i o ~ ~ i Chosen for Implementation: The plan must describe each option chosen for opcton. implementar~on. dew1 the cons and savings associated with it, and list thereductions in toxics

use and byplrodua generanon which are expected to result from the option. (From above- described Qmons Evallrratlon) The plan must also include an implemenmon schedule. (See Chapter 6.1 )

(vii) Lncomp~lete Evaluations: If the evaluation of a particular option cannot be completed m time to be subrmned with the plan. the plan must include a description of the option, an explanaaon 2 ~ s to why tk evaluation remains incomplete, and a schedule of steps which will be taken IO ciomplete the evduanon.

(e) The Plan S u m m q

TURA plans arc not subm~ncd to DEP but remain instead on the plant premises, subject to DEP mspeculw. Howem, a plan sunmmy must be submitted to DEP by July 1 of the year in which the plan IS due The summary must include:

(i) A copy of tbe plan catlfication statement.

(ii) Expected Facility-wide Changes in Toxics Use and Byproduct Generation: Tweyear and five-year prqecaons mun be made for expected change in poundsused, expected change m pounds of b,yproducn generared. expected percentage change in use, and expected percentage cttaage m byprcducts. (See Chapter 2.3 on goal-setting and Chapter 6.2 on measuring TLIR progress )

(iii) Byproduct Reduaicrn Goals: Two-yearand five-yeargoalsforthe ByprodnaReduction Index. Thex goals mun reflect the expected impact ofthe TUR techmques which have been chosen for mlplementaaon. (See Chapter 2.3)

(iv) TUR Mat7ices: For each production unit listed on the Form S, the plan must include a mmix of the son whch accompanies the Form S report The m h should indicate which of the six hCls of TUR (See Chapter 4.2.) will be implemented over the next five years,

APPENDIX I : TURA REQUIREMENTSAND THIS MANUAL...

provided that the techque IS expected to account for a gain of five points or more in the Byproduct Reduction Index for that production u n i t . (See Chapter 6.2,.)

(f) Plan Updates

At larr m momh bafora dw plan or a phn updra IS due. h firm must nody JI anploy- of dw rmqulm- m r a o l h p h o r p h n u p d a u and r d m ch.lr t n p a on TUR optmu.

A plan update must be completed by July 1 in thr: second year after the initial plan is due, and every two y e s thereafter. If implementation^ or options evaluation schedules have not been met, the update must e x p h why not.

(g) Employee Input

Six months before the p h or aplan lrpdate is due., the firm must notify ,d employees of the requirements of the plan or plan update, and solicit their input on TUR options. (See Chapter 2.2.) The completed p h must mclude a description of steps taken to comply with this requirement.

(h) Plan Certification and Deficient Plans

Eacb plan d u c b updatc m u a contain a written statement by a cemfied Toxics Use Rcductloa PLPIIICr wbcb ;~ntsts that he or she be.lieves - based upon inquiry of people mmcdmcly nsponslble for dcvcloprng the plan -- that the infonnatlon in the plan and any suppomng documentacloo cr a. rccrrratc. and complete, and that the plan meets the rquuunents of the law A amtln w r i m statement must be signed by the senior management oficlal ar rhe fachry and tncluded in the plan.

Toxlcs Use Reducaoo Planners are being certified through a training program at the Toxics Uu Rtducnon Lemattc 0. whch is l~xated at the University of Massachusetts at Lowell. F a mfonnaaoo a h cbc program. c'ontact TURI at (508) 934-3275.

If. upon rc\#u., DEP dctmmxs that a plan, summary, update, or any supporting plan documentancm coatam an ~lntennonal deficienc:~, the toxics user will be given 90 days to correct the plan. after wbcb enforcement amon may be taken. Deficiencies which are deemed ~nvntloaal u ~ l l be subject to unmedme enforcement actions. Deficiencies can ~nclude matcn?l filubaxk fa~Jwa LO meet applicable laws and regulations, and bad faith efforts to develop plans

A1.4: Seeking Further lnfolrrnation about TURA

No manual, bowever well-cooctlved. can answer all of the questions and problems which might anx m the cocnplex cuk of TUR piannlng. OTA's staff, incorporaring engmeering, sciennfic, legal md h c u l expemx. srands ready toassist Massachuserts businesses in any way possible. If you haw qucsaons or comment;, please call us at (6117) 727-3260.

The Depamnent of Emuonmental hotemon is the place to tum for reporting forms, up- W e k s of covered chemcals. and for the latest reporting and planning regulations. DEP can be reached at (617) t92-5982.

For fiuther ad\-~ce on where to turn for help vvith your TUR planning efforts, turn to Chaptcr 4.4 of dus manual.

Appendix 2: Glossary of TUR Terms and Acronyms

A Anodizing: A pro- that coats aluminum with a hard, corrosion-resistant oxide coating.

B Byproduct: Under TIURA. "All nonproduct outputs of toxic or hazardous substances generated by a produrnon unit, prior to handling, transfer, Eeatment or release." If the "byproducr" IS reused as is without processing or Eearment, it may be regarded as product.

Byproduct Reduction Lodex: A calculation used for TUTU repomng purposes which represeoc d v percentage reduction achieved, over a specfied baseline year, in byprodurn per unn of p c t u c t See Appendix A12 and Chapter 6.2.

Capital Costs: One-me costs of planning and implementing a production change. See Figure 5D

CERCU: ~Comprebennw Enwonmental Response and Cornpensanon Llabhty Act (federal I AIl t o x l a Lad unda CERCLA will be included in ?ZTTC4 by the end of 1993.

Cbemicll Inputs Databrsc: A database which lists the chemicals in use in a plant and specrfies the amount wd. the cost of the substance, the waste w a r n s in whch it appears, the regulu#>crs to wbcb 11 IS subject. and the processes or operations in which it is used. See Chapter 3 1

Chemical 011rpotl Database: A database that lists each chemical leaving a plant, and specifics the runount released. tbe Pcarment and disposal costs, the waste smams in which it appears. rrgulatloes to u-hlch it is subject, and the processes in which it is used. See Chapter 3. I

Chemical Pactbwsy . b a r n u : A dragram which graphcally depicts the pathway of a toxic chemical through a prodwma umt. and locates all points at which portions of the substance are released as bgmdwu See Figure 3D.

Cost Differential: The amual change in operaring costs reahzed by a TUR project or any other cap~tal project

DEP: Deparm~cnt of En~mumental Protection (Commonwealth of Massachusetts)

Differential Closts: Operanng costs which would be changed by a l U R project or any other capital projecr. See Figure 5C.

Direct Costs: Operanng costs wbch can be assigned directly to a particular product or ~ ~ ~ U C I I O I I ucur. See F ~ p e 5B

Drag-ou t: Thar pomon of a chermcal bath whichis lost during production because it adheres to parts treated m the bath.

E Emission: Under TtW "A release of toxic or hazardous substance to the environment or a uansfer of touc or hazardous substance in waste to an off-site location."

Emissions Rpdoctioo Index: A calculation w:d for TURA reporting purposes which represents the pacentage redurnon acheved in enlissions per unit of product. See Appendix A 1.2.

EOEA: Execunve Office of E n ~ ~ ~ e n t a l Al3ku-s (Commonwealth of Massachusetts)

EPA: Enwwmental Rolccnoo Agency (federal:)

EPCRA: Emrgmcy Plvvlrng ?ad Community F!ight-To-Know Act (federal)

F Family of Predu-b: Unda TtTRA, reiated products andlor intended results can be grouped to@e as a farmly of producshesults, and mated as one product for repomng purpo=s.

Form R: Tbe annual t o u a w reprang fonn mandated under the federal EPCRA lqgslatron.

Form S: The mnual TLX progrrss rtport mandated under the state TUIRA leplation. See Appendur A 1.2.

H Hazardous W m c : Sold w a t a W under RC:IU, 40 CFR Part 261 whch are either iptable, corrosave. reacme or toxic.

1 Improved Opcntioo and 3luatemance: One of the six techniques of TliR under TLTRA. Acheved by "modrjmg a ddrng to exlsrmg ecppment or methods including, but not h t e d to, such teci~~qucs as unproved housek:eeping practices, systems adjustments, product and process mspcnans. or production unit control equipment or methods." See Figure 4F.

Indirect Costs: Opaanng costs wtuch cannot be aisigneddirectly to apamcularproduct or producnon uxut Also known as "overfiead costs. See Figure 5B.

Input Substitution: One of the six fonns of TUR, under TURA. Achieved by "replacing a toxlc or hazardous substance or raw matcnal useld in the producrion unit with a non-toxic

or less toxlc substance." See Figure 4C.

Intangible Ca~su: Opcratmg costs whichhave areal bottom-lineimpact yetwhich do not lend themselves to precise measurement. See Figure 5B.

Intermediate Product: Under TURA, "(a) in chemical manufimumg, any chemical substance that s coarsned. m whole or in part, in chemical reactions used for the intentional man- of an& chcrmcal substance or mixture, or that ~s intentionally present for the purpose of d m g tlx rate of chemical reactions. . . ; @) in any other setting, any manufacanrd substance that is consumed, in whole or in part, in a chemical or physical process for t&c mtenhonai manufacture of another product, becomes a component part of another produc~ or that ~s lntentlonally present for the purpose of aiding the manufacture of another poduct. "

L Liability: In ttre ccmvxt of n;R. llabhty is the potential cost whch may arise from being found h b l c for damymg th cawronment or for harrmng public or worker health.

LQTU: large {Quanap T o x t a User Under TURA, this category includes "any toxics user who manufamucs. processes. or otherwise uses any toxic or hazardous substance in an amount thc same as or gc~tcr than the applicable threshold amount in a calendar year at the faciliry " See ( h p c r I I

M MSDS: hbcnirl S&ty Dam Sha (required by OSHA Communication Standards).

Materials kcooatmg: h v d > a c a l techmque aimed at identifying and quantifying the materials which mttr ad c u t r pvcn production process or production facility. See Chapter 3.4.

Medi f l ed~urn: Tbc three mnroamental meda are air, water, and land.

N NPDES: Nsucmd Pollrrno~ h c h r g c Elimrnarion System (NPDES) &charge permits are issued by tlx f h M EPA uDjer the federal Water Pollution Conuol Act.

0 OSHA: O c c u p a h d Safery and Health Aclmmmmnon (federal)

OTA: Office of Techn~cal Ass~nance for Toxics Use Reduction, the nonregulatory state agency whtch autbmd thrs manual, was esfablished by TURA to provide confidential tecbcal TLT assstance at no charge to Massachusetts toxics users. OTA can be reached dunng busmess lbours at (617) 727-3260. See Chapter 1.4.

APPENDIX 2: GLOSSARY OF T U R TERMSAND ACRONYMS ...

P Payback Period: A relanvely simple profitability measure which can be used to calculate the time a TUR project (or any other capital project) will take to pay for itself. a s measure does not involve drxmnring to reflect the time value of money. See Chapter 5.3, Part 'e'.

POTW: Pubilcly Owned Treatment Works. Refers to any system owned by the state or local govemment whch is used for the collection, awmen t or W s a l of sewage.

Process Flow Diagram: A visual representatio~~ ofthe movement of covered toxics through the process or p o c ~ s e s w i t h the production unit, demarcating all input points at which toxic substances enter th process as raw W:nals, and all output points at whch toxic substances leave tbe process as byproducts or emissions. See Figure 3C.

Product: Under TUR4. rhs term encompasses products, families ofproducts, lntermediate products, or &sued results or familacs of such results.

Product Reformulation: One of the six techniques of TUR under TURA. Achieved by "substxtung for an e x m g end-product an end-product which is non-toxic or less toxic upon w, release or drsposa." See Figure 4B.

Production Unit: Under TLTU. "a process, line, method, activity or technique, or a comb~nanon or senes thereof. used KO produce a product." See Appendvc A1.2.

Production Unit biodernization : One of the six techniques ofI-URurader TURA. Achieved by 3pgradmg or replacing exlmng productioin unit equipment and methods with other eqmpment and mabods b d upon tbe same pduc t ion unit." See Figure 4E.

Production Unit Redesign: One of the SIX techniques of TUR under TUR4. Adueved by "developing and usrng produmoo unm of a diffelrent design than those currently used." See Figure 4D.

R RCRA: Resource Coa~nanoo and Recovery Act (federal)

F2ecydingReuu: One of tbc sax t t c h q u e s of'TUR under TURA. Achieved by "using equipment or methods uhlcb become an inregal part of the production unit of concern, includmg but not h l t t d to filtranoo and other closed loop methods." See Figure 4G.

S S M : Superfund Amendment and Reauthoriimion 'Act (federal). Toxics listed under SARA Title III arc covered by TURa.

SIC Code: Standard Indusmal Classification Code. The SIC coding system was developed by the U.S. Chamber of Commerce.

APPEND= 2: GLOSSARY OF TUR TERMS AND ACRONYMS ...

SQTU: Small Quanary Toxics Users. Under TURA, all toxics users which are not classified as LQTUs (See LQTU defimtion above).

Superfund: The federal program authorized by CERCLA and SARA which carries out EPA's sollid waste emergency response and long-term remediation activities.

T Toxi f lor i c Substance: Under TUR4, any chemical on the toxic chemical ht under EPCRA n:mw 3 13. By 1993. all chemicals regulated under CERCLA sections 10 l(14) and 102 WLU a h k comdcrrd toxic under TURA.

TUR: T o ~ u a U x Rducaon. Under TITRA, "in-plant changes in production processes or raw matrrlals tha~ reduce. avo~d or eliminnte the use of toxic or hazardous substances or generanon of harardous byproducts per unit of product, so as to reduce risks to the health of workers, consumen. or the enbuonment, without s h i h g risks between workers, consum- ers. or parts of the env~roament." TUR can be acheved through six techniques: product reformu\ar~oa. pnxru mkslgn. process modernization, input substitution. reusdrecychg, and unpo\rd operanaa and mamtcnance. See Chapter 1.1.

TUR4: M ~ s a c h u ~ ~ Toxlcs Lx Reduction Act (MGL Chap. 211, Regulanons: 3 10 CMR 50.00) See Chapter 1 3 and Appendix 1.

T U U : To:ucs Use Rrductlon Insacute (state) . TURI was established by TURA to research and pubhaze TUX oppommtnes. offer courses and seminars on TUlZ certify X J R Planners, and carry cm u t r rclattd m w a e s . The Inshtute, which is located ar the University of Massachuscm s Lowell. can be reached at (508) 9343275.

U Unit of Pr~Dduct: Unckf TLaA regulaaons (3 IOCMR 50.10), "A measure that reflects the level of pducnoo or arn\riry associated with the use ofthe toxic or the generation of the toxic as byproduct' See Chqnm 6.2 and Appenk A1.2.

w Wakthrou~gb: An oa-site rnspecnon of production processes aimed at solidifjmg under- standmg of produaon processes and launchmg the search for appropriate TUR proposals. See Chapvr 3 5

Appendix 3: Bibliography of TUR Resources

Note: The ibllowing is a list of resources and publications on Toxics Use Reduction. Inclusion of any information whch features particular products or proprietary technologies does not represent an endorsement of those products or technologies by the Commonwealth of Massach,usens, but simply an indcation of their availability.

All of the following materials are available af the OTA library. Some of the materials can also be ordered from other sources, and where possible we have listed these sources. If you are intercsu:d m perusing or obtainrng a copy of these materials, contact OTA at (617) 727- 3260.

A G e n e ~ d Information on Toxics Use Reduction

I . The U S Pdlution Pm*cnrion lnbrnution Ckv inghouse (PPIC) The U.S. Ennronmental Procuuon Age- mainains a free telephone senlce t o handle inquiries abouz pdlvoon pmwamon. and m u r o t in document searches. The PPIC has a I ibnry of more d u n 400 curt scud~as c4 ruccurful polludon prevention projects in a w ~ d e variety of indusmes. Many of d u u t a w rrudts fall rrttwn the aregory of Toxlcs Use Reducuon. The EPA l ibnry atso includes mora &an 600 M t q a on f d c n l . r a r e and l o a l pollunon prevenuon projects. induscry programs a d r r u m m t n m r u w n ruruments. The PPIC can be reached by al l ing eicher rhe RCRA Suparfwd H o d w rr (800) 424-9346 o r che Small Businus Ombudsman Hodinc ar (800) 368-5888. Ttuhntcal queaoonr a n k addrused co u p e m at the PPIC Technial Assistance Hotline rt (703) 821-4600

2 EPA W m c n , n , m f i m i o n - e n t Man . . u a . 92 pp. AvrihMe from:

Hau~rdour Warm Engtnoormg Rosearch b b o n w r y Offua of R a u r c k and D d o p m e n t US Envtrmmonal Proacuon Agency

Cmc~nnao. Ohlo 45268

3. & m f t m m p o u s Waste Reduction: A Plannine Guide f o ~ gpeeon b- 44 pp * r u e hwn:

Absrrrcc A p4a1nnu-q m a d (or - r d u c d o n with worksheeo which may prove useful to

some Marrachurom bustnosros

. . P m t i o n Plu, 4.-C- nine 108 pp. A n i h b k from: Th. IM~nr r roo Tochmcal Asrtsnnce Program Box 197 Hayo Bu~Mtn t 420 De la~ r l r e Sr. Urnrerr tv of H ~ n n u o o H~nntupol t r . UN 55455 (6 12) 625-4949

Absmcc A p lu rmy manual for pollunon prevennon which is similar to &IS manual in scope and inrent.

VOW-N V VLO JQJ Thh Y sLD(ICW 4 - e' uo ,-!nb3 uO!J -mAad UoFllod du~lr- Pa rpq) WMg 'JS 'w-3 brpu( WuM.. -t

I6LP8U (~19) 9OISS NU 'InW 3s

10-S VRB 006 .9O-MZ-IZ k1~lgn8 Ionuo3 uomllod put 8-w I-rruwq

*uona!cu!u!cu msw JO~ qqrlrr*t smtolouqm meu jo Lrcuuns t VIM xtoaua~o~d uopnllod oa op~d m-rroq put uownpaan @map y -qv

APPENDIX^: BIBLIOGRAPHY OF TUlR RESOURCES ...

Abstncc A comprehrawa pi& - complete wirh worksheets and software prognm - t o alculaang dse w w C - l ~ of was- management alccrnadvu and w identifying cosr-effecdve waste mlnlrrltraoon s m r e p a .

5. ' M e t W s Used to W e e Control Options," I I pp, by Dougllr W. bopv Abstract: A look at cosr/b.nefir analyses and risk assessmenu of hazardous w u t e marugemenc opoons u d r condmors of unceminq.

6. 'Huudous Wrrte Reduction - M e s u m m a t of Progress," IS pp, by M i d u J R. Overash. Available from:

M~chad R. Overcash 0 q ~ a r r m . n ~ d C h m ~ a l Engineering NOI* C u o l ~ n r Sam Un~ven iq . Raleigh. NC 27695-7905

A b s t n c t A I* U O n ~ m ~ - b u e d method for measuring waste reducmon progress

7. '-g In- Torvd Waste Minimization and Clean Technology." I I pp, by Richard W. M a c h Avarbble h m .

D. Alternative Processes and Technologies: Metal Finishing

I. -psd Metal F i n s h g m" I I pp, by Tim* Greiner. OTA

Z Wut. Roikrtkr, in tho M Finahme a d )3ccrl Plating Industries Drag-out and Rinse Tuhnobps , ' I p- f t u ~ m a OTA Brochure.

3. W&a lldluRion in th Flnbhing and Metal Plating Indusbia: Recweq Technologies," 1 p, flasuchulrem OTA kochure.

4. 'W&.rortr Trunwm d hawuy System at thc Robbins Company." 2 pp, OTA Case Study.

L 'Zinc Dhdr.r]~. m th LorrrP C o r p o h n , " 2 pp, OTA Case Study.

6. 7aunt~m S i i h r Lun~rd" 2 pp, OTA C u e Study

7. Howard H. Srrc d Sa. k" 2 pp, OTA Case S a d y .

8 S a r r t e Rrrluamm Rromrmnduiorts for Precious Mctll Platers," 20 pp, prepared by the Massachuaerrr O T A

9. T m Assistance P m e m and the %gardous Waste

Rcductlonm of Orwon: - . . . 40 pp. AnihMe from:

T h Po l luwn Pmnenoon lnformaoon Ourlnghouse (800) 424-9346

la 'ax P l i o m e lnfonnation Clearinnhouse Electroolafine 23 pp. GI1 (800) 424-9346

I I. EPA Project S u m m y : Watr Minimization Audit Report: Case Studies o f Minimization o f Cyanide W& tom DcrmQlrckg Opcrrrion5" 5 pp.

I2 EPA PI-ow E m %.re MinimirPion Audits at Genetaton of Corrosive and Heavy Metal W-" 5 w-. bT M. M n md E. R k m m

13. EPA Pmjaa Smm- 9.k icr tbn and Pilor Scale Testing o f a Prototype Dontun Dialyzer 6w the krmovd of T a r Phtab Corn ~ m p l a t i n ~ g Rinse Waters," 6 pp.. by Huay F. Hamll.

14. EPA Pro)wr Summary - and Recovery c~f Fluobontes and M e d Ions fmm El- plating Wast.rurr.' 5 p, by )om W. bkowro. Vincenr N. Ggmu Ternnce Hunter and Ray Hanlton.

IS. EPA Prq r r t fvmmy %amoval d Chromium t b m Ion Exchange Regenetant Sdution." 7 pp, by Suaan L. Sqa l d Duma A CMord.

16. EPA Projrcr Smunuy -..a HhmuzAon in tire P r i n t4 Circuit Board Industry -Case kudks," 7 pp. h fkomu h- S - M Palmer. Mark Ar~ena m d Marc Breton.

17. W m m I*rrrr*r b Ebctmphbmg and Printed Circuit Board Manufaduring Openti*rrM 25 ee. by v r a a WL.rm. +om j h y d Annual Wassachusem Hazardous Was&

Source - 18. Toppu. Mkkd u d Ckrormr h a Jolb Shop," 21 pp.. by Tom Naduu m d Mlke Depk. from I h m ! hut --dous 'Waste Source Redualon Conference

P r o c e c i h u

19. 'P- br OlrJopy mn b CyanickConcaining Electroplating Baths," 6 pp, by LE. Vaakr. from -ous Wasre Source Reduceon Conferen- Proce-

20. 'M R.aorr)r br t-' 7 19 A Case H ~ t m y by d-ie Minmsw Technical h i s - nnce Prqect

21. "Rcdudng r rJ T i Plating." SO pp, by Richard Bowiurdt Min- t o n Techn~a l Arw8or.r. P-t

22 "kasibiUq Ow d r - Evapomtiva Recovery Applicarion t o a N i c M P l u i n g Opcmtkn." 25 pp- )~pvrd h hr € Wdh for dc N . C Dept of Nawnl Raourca and Communlry 0 m - m ~

23. War -~.r, b V Counchlrcumnc Rinsing." 4 pp-by Cry Hunt of dm Pollwon Prwmeom hr, hqctrr N C Depamunc cd N a w n l Resources and Cornrnunlcy Development.

24. %nu bnsr*.aol, br Qlct-rr Rime Water Reuse" 4 pp, by Gary Hunt of rhe Polluoon Pmv- h v f i v m . N.C hp i r rmunt of N a a n l Resources and Cornrnun~cy Developmanc.

U. %raw br Ekarophters." 6 pp- by Gay Hunt of h Poiludon P m a d o n Pap P r g m . N C. W a c d Naarnl Reources and Communiry Development

16. waste &-SNdu: fi- . . by the Cilifomu Dept of H& Sences.

Available from:

Dupwvnern d kiaalch Semlces T o w Subrunca Conuol Division A l ~ u m n a ~ v ~ Tmchnology Section 7141744 P Scrm8,c P.O. Box 942732 bcnm8nco. CA 94234-7320

27. 7 0 Ways I ~ D CIlr W l t a Usage in Plating Shops" 7 pp, by Ted MOT. Available fmm.

hntshlnt Technology T d tloo y 14 Ficldla's Elbow K~nndson. NJ 07405 (201) 838-1346

2a 'Remod ad M o d tPiom born Chromium Plating Solution." 17 pp, by George C Cushnic Jr. of CAI Engm- and Wayne Andenon of Harper and Thtel Inc

29. -- h-! of Chromic Acid Sdution~," 10 pp, by Daniel J. Vaughn Willurn E. % h w & d Eovwty V &haw& d ths lomep Corpondon.

3a ' W S n - rosubr, Prr*sntion for Metal Finishers," 3 pp, by bwph J. Werbicki. M t m & m C g m o o r \ . Rwmdur RI.

31. md h o r r r b n d Chromic Acid M n g Solutions," 4 pp, h e p Corpora= Brochurm

3 2 riood Oprrmdq Pncthca ia Ehcuoplating: Rinse Water and Waste Redudon." 10 pp, b Pear A Gaknnr. p r u d r m d lngrrd Tachnologru. Inc.

33. a c k o a r r d Timknt Chromium Plating Baths" 8 pp- b foreph M. kgosp. PhD and Dma DamJL ChD d L k R u o v e q Sysarns and Vincent C. Opaslur of Engelhard b r p o n w n

34. ' P W N L L P d RUT hPyct' 5 pp, b Jeff Cdlins ud Chnstopk Cer*ucio of PMF Inc

E. Alternative Processes and Technologies: Solvents

1. G & b u r Conputt. hc' 2 pp, OTA Case Study.

2 W a s t e wpm-t Opqorrvlitirr Sohnts and Waste Oi l s " I p, OTA Brochure.

3. -- P e n f o r m a t i o n Cl-ouse Solvent Recoverr, 3 1 pp. Gll (800) 424-9346

4. W a s t e ?Ummtr&mn k #uaJ PytJ Uaning." P A Document #530 SW-089049. W1 (800) 424-9346

% 'Menuto Cmrrd Tuhnobgy Documcm - Hdogeruted Solvent Cleaners" F A PuMicldon t14SO13-89-030. C:a11 (800) 424-9346.

6. -Waste m d k e n t ~ 44 pp. A publiadon of rhe Oregon Hazardovs Warm Rducoon Pmgnm. Call (800) 424-9346.

7. 'New S e a t q h br VOOCFC Reductions." 2; pp, by Raymond P. h o r n jr, Michael J. El l io t t and h n c l r j. V . r k jr d T o u r I n s w m e m s . Available from:

T k ~ r I n s w m m u Incorponoad Maoarulr and Conrrdr Group 34 F o r a t S r r m MIS 10-04 Atdeboro. MA 01703

R "Solnmr T- rd hsidue knagemcnr." 2 pp, by Roberc 5. Cpaccio. from M rce S d u c r i o n C:onference Proceedines.

9. Tt-i-Ch&- LPm*urion Cur ku+ Ekd,ric Furnace #2 Bright A n d L i n e of Texas Instruments.' h klrcrm. trom Jhird h ~ u a l Mass. k k a r d o u s Wasre Source

10. "Souma R.Qrt ion The Substitution. Waste Exchange and On-Si te Distillation." 3 pp, by Lea j. Tra- W t bhmo and k r v ~ c e Chemical Corp, f rom T-%

dour Walt* -erence Prq-

F. Aiternative Processes and Techn~ologies: Metaiworking

I . T h e Cod CIcu om -* Cao4ants." 4 pp- OTA hct S k

2 W o e u a Codurcr and C d ?la&rnance," 3 pp, by Mmchell L Kennedy. OTA

3. "Poll- m W MamAadng," 23 pp, US. EPA. Call (800) 424-9346.

5. "Madha CooCI* h h t a w u m W g ro W a e Reduction." 10 pp, by B a h Lo& D o m r Paruram a d 1- k k e d ch. M l n n u o u ~ Technical Asristlnce P r o g n m

6. ' R e c o r n w l a n br dr Crr Hd C m m l of C o o l a n t Sumps." 3 pp, by A h d p IU of dm rlasar Omsv Carpnoor .

7. Xaaifuge Dovblr Cod.n bk' I pp, by h i m C a r r ~ n of OMC jjohmon.

R "Ccntrihgd -om.' I S p ) . h D a P l d C Romm. president of Rcnman Associates.

9. rd H r k h Umd m g Oil." 110 pp, Nanorul Screw Machine Produco A s r o c ~ r r ~ o n .

10. ?%fey and M h W W l e c ~ U 1:luids." I 2 pp, Nanonal Sa-ew Machne Products Assocl roon

G. Alternative Processes and Techn~ologies: Puip and Paper

1. Waste Red- lor Paper Products Manutraumrs," 8 pp, fmm Waste Redurnon Asses- menr and T m h T& r p u b l ~ a o o n of rhc Unlvemry of Tennessee Center for lndustrlal S e r v ~ c e r .

2 "Pulp m t d Papmr." 17 pp.; and "Ay AsY 5 pp.. from profirc from Pollution Prwenri- Available fmm:

7 h 1 Pdluoom Prok Foundanon I 2 f lad~son A.rnve Tor- Onono G r u d a PlSR 2SI

3. 'Pdlutha h.mdon T.chniqws kr the Wood Pmvving Industry," N.C Pdlrrdon P m a d o n Prognm. AvarhMm horn :

Tk N.C. k r d ~acu"l Resources and Community Development p.O Box 27U7 Rabqh. N C 2761 1-7687 (?I(#) 733-7015

4. 'W* Cocnpocwrr( +pm Sultlte Ev;lporator Condenser," by W. A Sherman uf dw US. EPA. GPI (800) 424-9344.

5. '- **I -1 6md and Uecorrry in the Pulp and Paper Industry," by G.W. G m v r j ) M c K m Md A j G r b n of h e U.S. EPA. GI1 (800) 424-9346.

6. W WIW Loop m )SS3C b r m g a t i n g Medium Hanubcturp" by G.O. Wdnvaa ct 11. of the US ETA GIl(8001 424-9346

7. '-d Fikmcbm d Cgl Wzsc-" by US. P A . Gll (800) 4249346.

8. "Tuxkn7 kducsha Tlrpqll, C*micJ and Bidogial Modification of Spent Pulp Bkaching Uquorr' h l J 5 €PA CS (800) 424-9346.

9. 'A Nd br tIm CIrnufiQure of Bleached Hardwood Pulp" 16 pp, by AMd Woqt ud jm T l h d Arbdam Inc, Vancouver. Gnada.

10. 'RuocJ !Lbq. L- T d the Emuent-Fm Mill." 6 pp, by R C o e a a ud CJ. Dariusd Id. r d .d E M a d LK. Swift of Cu. T. Plain. Inc.. from "TAPPI Jourrul," April. 1985. n 91.7

I I. 'Yiw LJa W h tL.crc LoYd With a Rcaure Diffision Washer," by J.CW. Evua. from -* - 411 .CD 4. 1985. p. 100. Nore: N o t Avarlabie at OTA Lib-.

12 'Recych A- I b a d Pulp Mills," 3 pp, by J.C Wyvill and J.C Adunr. hwn Wacer*rw(d w n : - 5. hptnnber10coDba 1985. pp. 18-20. ,Nor*. N o t Ava~iable at

L a u l k c u

1 3 . 3 u k t t ~ t - hrd. br Ocmmcll Chlorine Maka che Bluch P h t EtRumt Las Toxic." br f Asaprd tpn wf h ~ & -1. 69. no. 10. 1986. p. 54. Note: N o t Available a QTA I i b

H. Alternattive Processes and Technologies: Other Industries

I. )tory: W ~ c ~ ~ r z r c r Treatment and Source Reduction at L Fvber Co, Inc" OTA Care Study

2 -Im- Etduntr" I p, OTA Tatndogy Rcporr

.(rn~ppr emqr wr) maw5 yrlra~ 10

wo#m w luol) wrl!ur 'Xllsnpul amlrlnmrqjd -V a- M 'LI

'(SSDJppt o~oqr us) qalta~ 40 aueuurde~ cuo+qq q q .aq ?UU.UtSq put

J P -11

OztL-tCZb6 V3 '=''-""s ZILZt6 O'd '**J1S d nutif

uoq Oqoqml .*o.uran uonuq lolruq) amsqy n-01

ma- WFH P mwsd.a

-p!~ra .a oauurrq pur rllraoay uqo[ uoluo~u!

Xq a-rd -m 40 uopd!==a 'dd 9 ,%=-3vrc(u3 =q qn3 JIM --d au!~333 1934, 's

APPENDIX 3: B IBLIOCRAPHY OF T U R RESOURCES ...

Sebutian R. S1,erb.r. Available for $4758 fmm:

INFORM 381 Park Av.nua SW Nn Yo& N Y 10016

24 Proff<- Cdlu<kn A GuiQfg Industrial Waste Reduction and Recycling, 234 pp, by h m a E G m p b d a d Wdliam M. Glenn of & Polludon Probe Foundation. Available from:

21. %n&ummntJ)I W Rusty of S i b w from Phoco Waste Material." 10 pp, by Bcnn H a r r n a n w ~ A n w a n Fordromc. Inc. from MunchuJsm Huardous Waste Reducaon Confer-

-~r~..dlnl~~ 19.4.

Index

S-vrn bols

3M Company 1 1

A

Acids 21, 34 etchants 21. 53, 65. 66 muriatic 66 nimc acid 21

Aerospace indusay 59 Aluminum Processing

Company 11 Ammonium thiosulfate 67

B

Batch processes 37 Biodegradable plasacs 5 1 B-mg 44, 47-49 B yprodua

defimtlon 106 Byproducr Reducnoo

Index 97, 106107 B y p d w s 36. 37. 39, 40. 41, 42. 45

defirunon 14. 1 13 emmaang magni- tude 4 2 3 3

formula 4 1 sales 79. 83

Cadmium 51 Capital budgeting (for TUR

projects) 88 Carbide bin 54

Chp spinners 62 Chlorofluonxar-

bons 11, 56.58 C l e a n e r s l d e ~ ~ 1 1, 43, 52. Set! also Solvents

CleaningMegreasmg 43 TUR alternatives 1 1, 37, 54, 545. 58-60

Community I&-

tions I S . 80 Consultants 24. 48. 70 Coolants 52. 54, 66

TURAltcrmves 60- 62

water-based 52

Datagathamg 31, 35 Data venficaaon 45 Degreasm. lee Clean='

degrmxn Deparanent o:f Envi.oo-

mental P1-oaction @EP) .31. 35

Bgital Equpnent C q ration 35

hposa l 13, 50 Disposal costs 15. 30. 31, 32, 82

Drag-in 46-67 Drag-out 43,. 53. 54, 56, 65-66 metal plaang 63, 61 solvents 55)

Dnp boards (33

closed-]COP plat- ing 63, 64

counter-current rim- ing 63

drag-out reduc- tion 54, 56, 63, 64

evaporative recov- ery 64

filaation 64 general TUR tech-

niques 64-65 gold plating 64 nickel plat-

ing 37, 39, 64 plating solution re-

use 57, 64 electrolytic recov- ery 64, 65 ion exchange 65

d v e r plating 63 water conservation 63 zrnc phosphatmg 64

Emtssion dcfimtion 14, 106

Ermssions 30, 31, 42, 43

Emss~ons Reduction Index 97, 107

Exqloyee incentives (for TUR) 24, 67, 68,

75, 98 En-~lental Protection

Agency 16 Eqpment clean-

ing 37, 45 E \*aiuarion (of TUR

F a , oils and grease (FOG) 25

Filtration 59, 61, 64, 67 in-tank 67

Final product (under TURA) 33, 41

Financial accounting for TUR 15

Financial Analysis (of TUR Opnons) 7 6 4 6

capital costs 85-86 cost differential 82-84 differential corn 79-8 1 direct costs 77 induect costs 81 intangible costs 8 1 liability

costs 77, 84, 85 operating costs 76-78,

78 overhead 76 payback period 86 quahtanve analysis 85 quantitative analy-

sis 82-83 social costs 76

FIowchan (for TUR projects) 27

Focusing TUR re- search 32

Form R (SARA 313) 31. 35. 93. 104

Form S 93 Form S

W) 31, 35, 104- 107

Cause Champions 24 E options) 72 Freon 12 Chemical bath Life exton- financial assess- Fugitive emissions 36

sion 65-67 E l e ~ v s ~ s 34 ment 76-86 Chemical Lnputs Dara- Electrolyac recov- screening options 73 G

base 30. 41 en: 64, 165. 6 i cchca l and managenal hair (for Chemical Outputs Dara- Electronics ~ndus- assessment 75-76

base 30 try 52, 53. 59 lUR) 25, 33, 71, 75 EvVOra~on 431 451 64 Gold plating 63. See also

Chemical Pathway Analy- E l e m o ~ h - ing 12, 43, 52. 59 F Elecaoplating ses 39

sample 40 Chemicals manufactur-

52 Family of produco/redts H amomatlc barrel

hes 53 (under

ing 53 TURA) 33, 105 Hi-Tech Gold Plating

Corporation 65 Kgh-tech manufkm-

ing 52 Housekeeping 45, 67-

68. See aiso Improved Operatiom and Marnvnmce

Howard H. Sweet 8: Son, Inc. 63

Improved Opcrmons and Malntcnancc 49, 55- 56. 102

lnks rccychg 57 ~atcr-bastd 51

Input S U ~ U I U O O 49. 5 1- 52. 102

Invrmedmc prod- uct 33, 105

Internal Rate of Rmrrn 87 Intemanonal Busrness

Machmcs(IBh.T) 65 Inventory ( cheml-

cal) 30, 55. 68 Ion exchange 62, 65

Khamn Tool Com- pany 1 1

L. Faher Corporaoon 25 L. G. Balfour Company 58 Lamp~nCorporaaon I t Laundcnng 53 Llabihty 32, 77. 0-4

Malnvnance 31, 37, 35, 55, 62

Manifests 35 Matenal Safery Data Sheets

CMSDSs) 31, 35, 84 Mmnals Accounting 40-

42 Materials exchange 50 M-g TUR

pegs 41, 42 91s 93- 97. 98

byproduct rtdurnons 96 use redurnom 96

Metal manufactmug 59 Metal piaang. See Elcare

P M ~ Metal r e c ~ o n 1 1 Metals Use Rnfuctlon 63-

64 Metalworhng

51, 52, 53. 54 cutring 011 Ecy- clrng 57

h i n g tanLs 55

Na~~onal PoUutaat DIS- ChargeEllmlMtloo S y a n m m 31. 35

Neles-lamesbury Corpora- non 63

Net Present Vdut 87 Nldul p l m g Sce

Elemophang

Occupational SrC? and Health Admmsuawm (OSHA) &

Office of Techmcal AsisranrnOTA, 19- 20, 70. 99

Ozone 58

Paint manufacn~mg 5 1 . 3 Paints

abrasive-blast m p ping 55

solvent-bared nnp pmg 53. 60

--based 51 pH momtonng 66

Plasncs in* 51, 59 Policy statement 21-

22, 75 Pollution Prevenrtion

defmition 14 Pollution Prevenlion Act of

1990 16 Pnnvd Circuitbalard

Manufacming lndusay 6:3

Pnnmg indus- try 57, 59, 68

Process Row Dialgram 77 M e s s Row DEL-

gIams 36-37 sample 38

Recess Mod&rl- aon 49. 53-54

RocessR~dtsign 49, 52- 5 3

Roducr 33, 41, 97, 105 Roduct Reformulla-

noa 49. 50-51, 102 Rodurnon unit 33, 36,

38. 97, 104-:I05 Rodurnon Unit Fviodern-

vaam 102 Roducaoa Unit Flede-

n p 102 PubLclv Owned Tr-ent

Works(POl7V) 31, 35 Pulp and paper m;muf%crur-

mg Meach managanent 54 ooo-chlormaxecl bleach-

mg 52 ozone bleadung 53

Purchase costs (chlemi- cals) 31. 3.2

Purchasing (chemi- d r 56

Quality (and TLX) 15, 3 1, 32, 75

W r y Circles (and TLX) 23. 37. 99

Raymond Corporation 60 Recycling 13 Recycling and Re-

use 49, 57, 102 Reguhory compltance 32 Regularory

records 3 1, 43 Rel~able Company 58 Research and develop-

ment 24 Resource Conservarion and

Recovery Act (RCRA) 14, 31, 84

Results (under TURA) 33

Safety, employees 15.45, ss, 59, fi7, 68 74, 75, 7. 80 Screening TLTR Op-

tiom 73 financial screening 73 health and safety

screening 74 technical screening 73

Shpping and receiving 45 Silver plating 63. See

aiso Electroplating Slammen 63 Solvents 1 1. See dso

Cleanenldegreasers drag-out 59 -on 59 recovery 60

disltillatlon 60 vapor recovery 60

recyc:ing 57 safety considerations 74 solvent-based paint

stripping 53 substitution 11, 52, 59

Source Reduction definition 14

Spds and leaks 43, 45, 56, 62, 67, 68

Storage and han- dling 36, 45, 55, 68

Sump cleaning 62 Superfund 15. 58, '77. 80 Superfund Amendment and

Reauthorization .4ct (SARA) 31 35. & l(0 104

Surface tension 66

Testing and analy- sis 43, 75

Textiles industry 53 Titanium 5 1 Toxics Management

Hierarchy 13 Toxics Use Reduction

WX) buildmg awareness

among employ- ees 22. 24, 44, 97

common prrnciples a d t e h q u e s 5846

dcfinitlon 12, 14, 50 documennng accomplish-

ments 97 financial accounting for TUR projects 15

flowcbart 27 focusing research 32 gaals 23 implemennng

projects 91 incentives for punlung

TUR 1516 measuring

progress 41. 42 multi-mediascope 13 policy statement 21-22 six h d s of

mR 12. 49 the TLJR team 21

benefits 24 composition 23 organizarion 23

Toxics Use Reduction Act -1 16- 17. 101-109

facilines covered by Worker involvement 24, 'TURA 103 45, 48, 55, 67, 70, 98

fees 80,, 82. 84, 103 Worker training 49, goals 17 56, 67, 68, 70, 75, 92 m-l:progrrss

under 1KJR.A 93. 97

Unit of product (under %%A) 42. 93. 97.

105-106 UtizItics 75

walkthrou_eh a 5 key questlals to ask 46

PurpoS Waste h ~ z a n o n

&&tion 14 Waatwatcr 25

amnon 25 Water consm-imon

elenroplanng 63

Zinc phosphing 64

Ztl