Pollution Prevention Integration - P2 InfoHouse · Making Teams Work, and Multi-media Teams II: Increasing the Effectiveness of Multi-media Teams were designed and delivered by Anne

Pollution Prevention IntegrationA Training Curriculum for Environmental Agency Staff

InformationAccess

P2 in theJob Function

EnhancedCommunication

Industrial Process/SectorInnovative Technologies

Multimedia EnvironmentalProgram Awareness: Cross Training

Capacity building in the public environmental agency to promotecleaner, safer and more competitive industry while protecting our

natural resources.

This integrated curriculum was designed under the sponsorship of an EPA EnviromentalTechnology Initiative Grant to the Massachusetts Department of EnvironmentalProtection. The Toxics Use Reduction Institute, as contractor to the MA DEP, coordinatedthe design and publication of curriculum materials in collaboration with the MA DEPBureau of Waste Prevention and the Northeast Waste Management Officials Association.

EPA Project CX 824560-01-1

Introduction

© Copyright 1999 by the Toxics Use Reduction Institute, University of Massachusetts Lowell; the MassachusettsDepartment of Environmental Protection; and the United States Environmental Protection Agency.

ii Introduction

Introduction Contents

I. Feedback Form ....................................................................................................................................... iii

II. Acknowledgments .................................................................................................................................. iv

III. Curriculum Design ............................................................................................................................... vi

IV. How to prepare to deliver courses from the Comprehensive P2 Integration Training ....................viiCurriculum for your agency

V. How to Use this Instructor’s Manual with Participant Materials ......................................................... x

VI. Training Methodology ........................................................................................................................xii

VII. New Course Design to Customize P2 Curriculum Offerings ........................................................xvii

This material is based upon work supported by the United States Environmental Protection Agency underGrant # CX824560-01-1. Any opinions, findings, and conclusions or recommendations expressed in thispublication are those of the author(s) and do not necessarily reflect the views of the United StatesEnvironmental Protection Agency.

This curriculum document has been developed by staff at the Toxics Use Reduction Institute (TURI)at the University of Massachusetts at Lowell. The principal curriculum and instructional designer is JodyHensley, M.Ed., Senior Education and Training Associate at TURI. Principal document editor is AnneBerlin Blackman, J.D, M.A, Education and Training Associate at TURI.

All rights to this curriculum belong to the Toxics Use Reduction Institute (TURI), the MassachusettsDepartment of Environmental Protection (MA DEP) and the United States Environmental ProtectionAgency (U.S. EPA). The material may be duplicated or used with permission. A request for permissionto duplicate and use portions of the curriculum may be made at the TURI website: http://www.turi.org.

The views expressed within this curriculum document do not necessarily represent the statedpolicies of the above agencies nor does citing of trade names or commercial processes constituteendorsement.

The Toxics Use Reduction Institute is a multi-disciplinary research, education and policy centerestablished by the Massachusetts Toxics Use Reduction Act of 1989. The Institute sponsors and conductsresearch, organizes education and training programs, and provides technical support to governments topromote the reduction in the use of toxic chemicals in industry and commerce. Further information canbe obtained by writing the Toxics Use Reduction Institute, University of Massachusetts Lowell, OneUniversity Avenue, Lowell Massachusetts 01854, or e-mail www.turi.org.

© Copyright 1999 by the Toxics Use Reduction Institute, University of Massachusetts Lowell; theMassachusetts Department of Environmental Protection; and the United States EnvironmentalProtection Agency.

DEP

TOXICS USEREDUCTIONINSTITUTE

Introduction iii

InformationAccess



Industrial Process SectorInnovative Technologies


I. Feedback Form

We’d Like To Hear From You!

Comprehensive Pollution Prevention (P2) Integration Training

As you use the materials in this curriculum, we are interested in hearing about your experience.

■ Which course materials have you delivered or reviewed? (Delivered = “D”; Reviewed = “R”)

(D/R — indicate in the space below whether you have delivered or reviewed the following courses from the curriculum)

First Tier: Multimedia Cross Training: Curriculum FoundationMulti-Media Environmental Program Awareness: A Cross Training Program Guide

Second Tier: Industrial Process Sector Innovative Technologies CoursesElectroplating and Surface Finishing Sector TrainingSurface Coatings Sector TrainingGarment Cleaning Sector Training

Third Tier: Enhanced Communication CoursesMulti-media Teams I: Making Teams WorkMulti-media Teams II: Increasing the Effectiveness of Multi-media Teams

Fourth Tier: P2 in the Job Function CoursesP2 in Regulatory Enforcement at Commercial and Industrial FacilitiesP2 in Regulatory and Policy Development

Fifth Tier: Information Access for Continuous LearningHands-On Internet Training

■ Feedback on this P2 Integration CurriculumCreative Use of the Course Materials

Participant Feedback

Editorial Comments

Other Suggestions

Mail this form to: P2 Curriculum Feedback Or comment at TURI’s website: www.turi.orgTURI – UMass LowellOne University AvenueLowell, MA 01854Attn: Jody Hensley

iv Introduction

Pollution Prevention Integration: A TrainingCurriculum for Environmental Agency Staff

II. Acknowledgments from the ProjectManager

The design of this curriculum was a collaborativeproject in the broadest and best sense. This projectbegan as a rather simple idea for developing sometraining to help environmental regulators overcomebarriers to incorporating pollution prevention intotheir daily work. The project evolved into a compre-hensive curriculum design that represents a thought-ful training strategy for almost any environmentalregulatory agency working to shift to pollutionprevention as a central organizing principle.

Conceptual Design Team for the Curriculum At theMassachusetts Department of Environmental Protec-tion (MA DEP), special thanks to Tom Hughes for hisforesight in identifying and writing the grant pro-posal for a training and information project with thevision of learner-centered pollution preventionintegration training. Another portion of this grantestablished an information resource center availableto course participants for continuous learning. LeeDillard Adams, as acting Assistant Commissioner andhead of the transitional office of program integrationduring the time of critical conceptual development ofthis project, provided leadership in taking wide-ranging discussions back to her group and nurturingthe shaping of those ideas into a coherent plan. SteveEdelheit provided the training development wisdom,experience and patience for the circuitous route ofcontracting and course development. Other membersof the office of program integration with input intoshaping the curriculum design were Deb Gallagher,Doug Fine and Laura Rome. Terri Goldberg, from theNortheast Waste Management Officials Association(NEWMOA), with her perspective on the experienceof the eight Northeast states, brought insight regard-ing critical organizational issues and the transferabil-ity of this experimental curriculum to other states. I(Jody Hensley, M.Ed.) served as project manager forthe curriculum, training, and document design anddevelopment portions of this EPA-funded project.

Anne Berlin Blackman joined the team from TURI asassistant project manager as the project moved fromconceptual design to course development, deliveryand documentation.

Agency Management We’d like to thank the follow-ing people at the Massachusetts Department ofEnvironmental Protection for their support andencouragement in seeing this project through to itsfinal stages: Ed Kunce, Dan McGillicuddy, JimColman, Steve DeGabriele, Barbara Kwetz, DougFine, and Bill Panos.

Course Developers The Multi-media I Environmen-tal Program Awareness Cross Training Program pilotwas coordinated by Steve Edelheit at the MA DEP. Hedeveloped the content template, and along with JodyHensley, conducted train-the-trainer sessions for staffpresenters, “dry-run” presentation rehearsals, andfinal pilot delivery sessions. MA DEP presentersincluded: Gene Romero, Sal Resurreccion, AlNardone, Dave Biggers and Asha Shah from thehazardous waste programs; Walter Hope from theToxics Use Reduction Program; Bob Donaldson,Richard Fields, Bob Boisselle, Tom DeNormandie,Fred Civian, Bert Cox, Leah Weiss and NancySeidman for the Air Quality programs; MikeHutcheson from Research and Standards; Roy Willey,Paul Emond, John Crisley from the Solid Wasteprograms; Kim Kreiton of the Office of Enforcementgave an overview of multi-media initiatives. AnneBerlin Blackman from TURI joined me in designingand facilitating a multi-media integration exercise.

The Industrial Process/Sector Innovative TechnologyCourses had the following course developers: Electro-plating and Surface Finishing was developed by ChrisFord of TURI and Lisa Regenstein from NEWMOA.Mitch Shuldman from the media center at UMassLowell took informal home video from the shop floorand produced a narrated video and still images foruse in the classroom and in the manuals. Tim Greinerof Greiner Environmental developed the SurfaceCoating course. Dave Young worked with Tim in

Introduction v

translating classroom activity into a detailed enoughscript for our publisher to work with for this coursemanual, and he helped with the document prepara-tion for other courses in the curriculum. Anne BerlinBlackman developed the Garment Cleaning course.Kim Kreiton, Doug Fine and Bill Panos presented MADEP specific information for this course. A workshopon P2 in the photo-processing sector was also devel-oped under the auspices of this program as part of theMA DEP Environmental Results Initiative, althoughno instructor’s manual was developed. Workshopdevelopers were John Reinhardt of DEP and RickReibstein from the MA Office of Technical Assistance.

Enhanced Communication: Multi-media Teams I:Making Teams Work, and Multi-media Teams II:Increasing the Effectiveness of Multi-media Teamswere designed and delivered by Anne Fitzgerald ofFitzgerald Associates.

P2 In the Job Function: Coordination for the develop-ment of P2 in Regulatory and Policy Developmentand P2 in Enforcement was led by Terri Goldberg. Thedesign team for Regulatory and Policy Developmentincluded Steve Edelheit, Anne Berlin Blackman, PhilWeinberg, Doug Fine, Lee Dillard Adams, TomHughes, Rick Reibstein, Walter Hope, George Franz,Claire LaForce and Chris Harris. Dave Young andAnne Berlin Blackman led course documentation. Thedesign team for P2 in Enforcement included KimKreiton (who also led course documentation), AnneBerlin Blackman, Anita Baltherson, Cynthia Chavez,Jody Hensley, and Tom Hughes. Ed Kunce, JimColman and Gail Suchman made presentations forDEP Management.

Information Access: Hands-on Internet Training wasdeveloped and delivered by Tim Greiner and GregGeyer of Greiner Environmental. Steve Greska ofTURI provided preliminary document edits. GregGeyer of EITEC provided final document editing andon-line course design.

Logistical Support Effective on-site logistics canmake or break a training experience for learners andinstructors. Providing logistical management for themajority of the training pilots for this curriculum wasAnne Basanese of the Toxics Use Reduction Institute.Walter Hope and Steve White of DEP recruited andregistered participants and scheduled follow-uptraining sites.

Administrative Support Thanks to Bill Katcher, JohnO’Brien, Scott Boots, and Geoff Taylor at DEP’sBureau of Administrative Services for shepherdingour paperwork through the administrative complexi-ties of the interagency service agreement with theToxics Use Reduction Institute. Thanks also to UMassLowell Research Foundation staff Louise Griffin, LucyMoody, and Joyce Barton for handling the agreementfrom our end.

Design and Publishing A very complex documenta-tion standard emerged from the work on this curricu-lum. Capturing instructional process in one space,and juxtaposing it against course content in a com-prehensible and visually pleasing work on paper, is nosmall feat. Marc Kaufman and Bill Brinkley at Desk-top Publishing and Design Co. worked for almost twoyears preparing numerous drafts of a number of thesecourses. The manual that resulted was largely theresult of his creativity, patience, flexibility and perse-verance as we settled into a final document look andfeel. The printing of manuals and pressing of CD’swas also facilitated through his expertise. Thanks, too,to Jack Luskin at the Toxics Use Reduction Institutefor the learner-centered training information for thefront-end of these documents. Jack’s many years ofexperience with participatory training and pollutionprevention influenced the design decisions through-out the development of this curriculum.

Course Reviewers and Participants Each of thecourses in this curriculum went through design,formative evaluation, redesign and pilot delivery.With a total of twelve and one-half training days, aformative review, and 20 - 30 participants attendingeach of the pilots, the number of agency staff whoreceived training and offered feedback is too extensiveto mention them individually here. Nonetheless, weare grateful for the time and input that helped infinalizing this curriculum.

Environmental Protection Agency Our thanks toEPA for providing the grant funding for this projectand especially to Jim Loundesbury at the HazardousWaste Minimization and Management office forsupport of our efforts in developing a comprehensiveP2 integration curriculum.

Jody Hensley, M.Ed.Curriculum Project ManagerToxics Use Reduction Institute

vi Introduction

Introduction

III. Innovative Pollution PreventionCurriculum Design

The design of this curriculum began with a broaddiscussion of the organizational challenges faced byany environmental agency shifting toward pollutionprevention as an organizing principle.

Progress in environmental protection has been madefor nearly three decades through a pollution controlapproach which led to organizational structuresshaped around single environmental medium con-cerns: clean air, clean water, and waste management.These organizational structures shape the wayenvironmental officials see and do the work ofenvironmental protection.

A whole-facility, pollution prevention approachrequires an integrated look at what materials are used,and how they are used, throughout the productionsystem. This perspective considers the source as wellas the ultimate fate of those materials, be they re-leased to the air, to water or to land, or lost or trans-formed somewhere in the production process. Thissystems perspective considers what is movingthrough the production process rather than just whatis being emitted to one environmental medium inone place.

What this all means for the environmental official isthat an integrated approach to environmental protec-tion requires an expanded knowledge and skill base. Agrowing understanding of multiple media regulationsand a working understanding of a variety of indus-trial sectors provide a knowledge base from which theenvironmental professional can begin to considerpollution prevention as he/she interacts with regu-lated entities. Since this knowledge base is so vast, theability to work effectively with other experts, to shareinformation and to seek solutions collaborativelybecomes more essential. Because the pollutionprevention approach involves looking across previousprogram and job function boundaries, there will bean ongoing need for a fresh look at how P2 fits intovarious job functions. Moreover, with the rate of

change in our modern world, environmental profes-sionals will need to continuously seek the mostcurrent information on cleaner technology innova-tions.

Following the lengthy series of discussions which ledto the identification of the organizational challengesassociated with a shift toward pollution preventionand the identification of corresponding skills andknowledge required for individuals to do work inpursuit of integrated environmental protection, thiscurriculum design emerged.

InformationAccess





Multi-media Environmental Program Awareness:Cross TrainingA program cross training provides the foundation forthe Pollution Prevention Integration Curriculum. Theprogram is designed to provide regulatory staffhaving little or no experience with other environmen-tal media a basic level of literacy regarding air, water,hazardous and solid waste programs. The MultimediaCross-Training Program uses program staff within anagency working with a trainer to develop presenta-tions of their media programs based on a contenttemplate. The presentations cover a range of topicsincluding: definitions, legal mandates, brief history ofprograms, universe of sources, regulatory mecha-nisms, compliance and enforcement tools/techniques,pollution prevention opportunities and barriers, newtrends/initiatives, role of the agency and otherstakeholders, and information resources. The crosstraining agendas are developed by the agency present-ers and take place over three days. The training days

Introduction vii

can be delivered consecutively, or spaced over weeks.The three-day course concludes with a cross mediaintegration exercise on the final day.

Industrial Process Sector Innovative TechnologiesThis tier contains courses designed to provide regula-tory staff with the knowledge and skills to identify P2opportunities for facilities in specific industries. Thetarget audience is enforcement and complianceassistance staff. The course design assumes that theparticipants are familiar with basic P2 concepts, butmay not be accustomed to applying the concepts in asystematic manner in their job. The sectors for whichtraining manuals have been developed are: Electro-plating and Surface Finishing, Surface Coating andGarment Cleaning. The surface coating course wasdesigned to take place over two days to allow suffi-cient time for a site visit. The other two courses areone day in length. Each course covers the following:industry background, environmental regulation ofthe industry, innovative environmental technology,application of training to the job function, andsources of P2 information.

Enhanced Communications for Multimedia TeamsThis two-part tier is intended to enhance participants’job performance and job-related skills by improvingtheir ability to be effective and productive teammembers in a multi-media team setting as well as toserve as informational resources for their teamcolleagues in their respective areas of expertise. Thecourses assume that participants have a basic under-standing of P2 concepts. The objectives of part one ofthe tier are: 1) to identify the uses and characteristicsof successful teams, 2) to explore roles and responsi-bilities of team leaders and members, 3) to statestrategies and take action on P2, and 4) to develop anapproach to resource sharing with other team mem-bers. The objectives of part two of the tier are: 1) toidentify specific actions a team member and leadercan take to increase group effectiveness, 2) to under-stand and apply a problem-solving method for use onteams, 3) to identify common patterns of resolvingconflicts, and 4) to use a step-by-step approach tonegotiating the resolution of differences.

P2 in Your Job Function (P2 in Enforcement andP2 in Regulatory and Policy Development)The goals of these courses are: 1) to encourage theimplementation of P2 technologies at all levels ofenforcement, policymaking and regulation drafting,

2) to improve enforcement staff ’s and policy/regula-tory staff ’s understanding of P2, and 3) to encouragestaff to explore incorporating P2 into all levels ofenforcement actions, policymaking and regulationdrafting. Both courses examine the structure of theenforcement or policymaking process, methods forincorporating P2 into that process, and sources ofadditional information. Both courses include hands-on exercises to practice integrating P2 into the jobfunction.

Information Access (Hands-on Internet Training)This course is designed to enhance participants’ jobperformance and job related skills by providing anunderstanding of the capability of the Internet as avaluable resource for identifying and researchinginnovative environmental technologies and databases.The course, which can be adapted for beginning oradvanced Internet users, includes the followingcomponents: basic internet hands-on training, anoverview of P2 related Internet resources, successfulsearch strategies, and self-directed learning tech-niques. A paper manual has been developed for thiscourse to assist a new instructor in preparing for thecourse. This material is taught in a computer lab withparticipants logged on to computers so they can pullup a web page and follow the course on-line.

Customizing the CurriculumThe content areas covered among the levels of thisComprehensive Pollution Prevention IntegrationTraining Curriculum address skills and knowledgeneeded by the environmental regulator from a varietyof perspectives. The curriculum represents a well-rounded training strategy. These particular coursesare also created to be customizable for individualagencies with minimal effort. However, the coursesdeveloped within each of the curriculum tiers hererepresent just a sample of what might be the mosteffective coursework to fulfill training needs in agiven agency.

The development of other courses within the curricu-lum tiers may strengthen the P2 training strategy inyour organization. Additional coursework mightinclude industrial process/sector courses for theindustries most prevalent in your area. The EnhancedCommunications tier might include facilitationtraining for making meetings function efficiently andeffectively. P2 in the Job Function might be expandedto courses for permit writers, legal staff, and manag-

viii Introduction

Introduction

ing for pollution prevention. The Information Accesstier could include other course work in efficientresearch strategies and search-oriented thinking.There are many possibilities in each subject area. (See“New Course Design to Customize P2 CurriculumOfferings” later in this section.)

IV. How to prepare to deliver coursesfrom the Comprehensive P2 Integra-tion Training Curriculum for youragency

This is the first edition of Pollution Prevention Inte-gration: A Training Curriculum for EnvironmentalAgency Staff. The documentation specifications forthis “Instructor’s Manual with Participant Materials”are seen here for the first time as well.

The courses in this curriculum were developedcollaboratively with input from subject matterexperts, agency staff and managers, instructional anddocument designers, and experienced event coordina-tors. We recommend that course coordinators workwith subject matter (technical) experts in the area ofcontent covered in a particular course for the bestresults in delivering these course materials.

Course coordinators will also need to customize thematerials for their organization and its present goalsand context. It is critical to brief management andimportant stakeholders within the agency early in theplanning process for these training events. We haveincluded a course delivery worksheet that can help inplanning for the successful delivery of these coursematerials.

Introduction ix

Innovative P2 Course Delivery Worksheet

Course Title::

Course Scoping Meeting (for decision makers and course managers within your agency)

Date:

Attending:

Agenda for the course scoping meeting to include:

Briefly orient decision makers to the course, its purpose and overview of content. (Ideally the coursewill align well with the agency’s strategic goals.)

Identify target audience

Clarify performance objectives for target audience

Identify course coordinator and clarify role

Identify subject matter expert and clarify role

Set target dates for course delivery

Set budget and clarify necessary administrative steps (purchase orders, contracts, etc.)

Ongoing work by course coordinator:

Course Content and Materials

Review materials along with subject matter expert

Review previous course evaluations if they are available and incorporate feedback

Make decisions about how to customize course appropriately

Clarify who will present and facilitate at the course delivery

Prepare participant materials (see “how to use this manual”)

Prepare visuals (overheads/charts) for use in the classroom

Prepare course evaluation forms

Put together attendance list from registration confirmations

Course Logistics

Identify venue for delivering the course

Negotiate contracts for or formally schedule the training venue

Specify room set-up

Invite participants. Schedule through supervisors if necessary. (4-8 weeks notice)

Schedule a room for a rehearsal presentation — optional, but strongly recommended.

Arrange for audiovisual equipment

Arrange for refreshments for breaks and for lunch. (provide or recommend lunch options)

Confirm participants one week prior to training

Know your audience. Check on need for handicap accessibility, vegetarian or special meals cont’d

x Introduction

Introduction

On-site facilities checklist: Audiovisual checklist:

Heat, light, AC working Equipment plugged in

Meeting room well marked Flipcharts, markers plentiful

Know how to darken room Backup equipment accessible

Seating plans/room set-ups firm Overheads/slides legible when projected

Actual registration matches room size Microphones, speakers tested

Water pitchers and glasses available Masking tape, stapler, paper clips

Wastebaskets well placed Scissors, 3-hole punch, available

Coat check room available Copy machine available

Restrooms nearby VCR/ video cued and functioning

Refreshments/Lunch confirmed

Name Tags at participant Sign-in area

Sign-in sheets prepared

Participant Materials ready to distribute

Box or space designated to collect evaluations

Review evaluations and make recommendations for next presentation of the course

V. How to Use this Instructor’s Manualwith Participant Materials

Instructor NotesThis manual is designed so that the left-hand sides ofbinder pages contain notes for the instructor. Theinstructor notes appear opposite the correspondingparticipant material. Various instructions, tips andtalking points are provided for instructor prepara-tion. Additionally, icons appear in the left-handcolumn of the instructor notes to provide visual cuesfor the next instructional element as the instructormoves through course materials in the classroom.

VisualsFull-size visuals for overheads are contained in anappendix at the back of the binder. Instructors cancopy these onto transparencies and use them forvisual support to instruction in the classroom.Reduced versions of these visuals already appear inparticipant materials on the right-hand side (even-numbered pages) of the instructor’s manual.

Participant MaterialsPhotocopying the right-hand (even-numbered) pagescreates participant packages. The backs of these pagesare intended for note-taking space. A blank “note-taking” page is formatted and included for optionalphotocopying on the reverse side of participantmaterials page. (see next page) Several instructionalpoints have been included on some pages so as toreduce the total number of pages needed for theparticipant materials for each course.

Innovative P2 Course Delivery Worksheet (continued)

Participant Notes

ETI Dry Cleaning Training xi

Course

Pollution Prevention Integration:A Training Curriculum for Environmental Agency Staff

InformationAccess





xii Introduction

Introduction

VI. Training Methodology

The courses in the Comprehensive Pollution Preven-tion Integration Training Curriculum were designedto be learner-centered and participatory. This ap-proach encourages and depends on active participantinvolvement. The format of the sessions generallyincludes participant discussions of case studies andsmall group exercises, rather than following a tradi-tional classroom lecture model. This interactivemethod is based on the understanding that people,adults in particular, learn more fully by doing than bylistening passively.

The following several pages lay out general guidelinesfor presenting this type of workshop. These guide-lines were used in the development of the courses inthis curriculum. Each course has a scriptedinstructor’s manual in which detailed notes areprovided for delivery using participatory methods.

A supportive learning environment that puts partici-pants at ease is critical and should be established atthe beginning of the workshop. Participants knowmore about their own workplaces and businessesthan the instructors do. This methodology builds onthe knowledge and experience of participants and letsparticipants learn from each other as well as from theinstructor.

As instructors, we need to avoid the temptation ofrelying too much on the lecture format — eitherbecause there is so much information to cover in ashort time or because of unfamiliarity or discomfortwith participatory group activities. It is essential tothese courses that participants bring their ideas andworkplace experience into the classroom.

In keeping with the goals of this curriculum, eachcourse session allows time for learning new informa-tion, time for applying new skills, and time for keylearnings. The types of learning activities will includelectures, small group exercises, report-back sessions,large group discussions, hands-on exercises, audio-visual presentations, and evaluation sessions.

LecturesThe purpose of a lecture is to convey a basic body ofinformation. It should be brief, and be combinedwith participatory exercises that allow participants towork with and apply information provided in thepresentation. Guidelines for lecturing:

■ Keep presentations short (people can only sit andlisten attentively for limited periods of time)

■ begin with an overview of what the lecture willcover and its practical application

■ end with a similar summary

■ be explicit regarding why this information is usefulor important

■ make lectures relevant by drawing on examplesfrom participants’ workplaces

■ make lectures interesting by using good visual aidsand never reading your notes

■ encourage active participation by inviting ques-tions from the group

■ pose questions which require participants to applythe information being presented to their ownsituations.

Small Group ExercisesThe purpose of getting people to work together insmall groups to solve problems is: 1) to increaseparticipation, 2) to allow people to use their ownexperience and new information presented in theworkshop to answer questions or address complexissues, and, 3) to establish trust and to enhance theconfidence of workshop participants.

Small group exercises can take different forms,including filling out worksheets as a group, brain-storming a list of ideas on a given topic, or analyzingsituations presented. These activities can be adaptedfor relevance to a particular group. Some guidelinesfor designing case studies and role plays:

■ The situation presented should be familiar andevoke strong feelings among the participants sothey will want to act on it.

Introduction xiii

■ The situation should lend itself to in-depth analysisthat requires participants to explore underlyingcauses of a problem and a wide range of possiblestrategies for solving it. Don’t try to limit or directparticipants’ efforts too much; let them explorehow to proceed on the matter for themselves.

■ Enough information should be provided to outlinethe basic problems and issues to be dealt with, butit is not necessary to include every detail about asituation. (Participants can improve on thescenarios, calling on their own experience to makethem realistic.)

■ Make it clear what you want participants to dowith the role-play or case study by posing ques-tions to be addressed or tasks to be achieved by thegroup. A good basic series of questions for mostcase studies includes:— What are the problems in the situation?— How do these problems compare with ones in

your own workplace?— What are the root causes of the problems?— What can be done about them (what strategies

are called for, what obstacles will be faced)?

Facilitating Small GroupsIt is important for the instructor to facilitate smallgroup activities well. Some guidelines for administer-ing small group activities:

Group size and selection: Each group should contain4-6 people. Each instructor can supervise up to 5groups. Each group should work in a separate area.Group composition can be varied during the work-shop for the widest sharing of experience (this alsoprevents dominant people from establishing controlover any one group). One way to break up groups andallow people to mix is to vary the size: for example,start with 5 groups of 3 each and change to 3 groupsof 5.

Groundrules: Review the following expectations andgroundrules for small group work:

■ We are all colleagues — Let’s respect each other

■ It’s OK to disagree

■ Listen as an ally

■ Participation should be balanced among groupmembers

■ Honor time and other agreements

Roles: Explain that there are a number of roles playedby individuals working in small groups. Share this listof roles and responsibilities:

■ Facilitator:— discussion chauffeur— keep group focused on task— keep group on timeline— make sure everyone has a chance to participate— stay neutral

■ Recorder:— capture basic ideas— create group memory— listen for key words— abbreviate when possible— ask group/facilitator for assistance if needed— ask group to ensure entries are accurate

■ Participants/Group Members— focus on task— listen and respect others— seek solutions that work for everybody— contribute ideas— participate— keep facilitator neutral

■ Spokesperson— listen carefully to discussion— get clarity on what you’re expected to report— report out key points at end of discussion

Tell participants to select a recorder/facilitator/spokesperson each time they break into a group. Thishelps organize the group to work efficiently andenables people to learn important communicationand leadership skills. Some helpful techniques toreview with participants include:

■ Keep time to prevent the group from running outof time before completing the exercise.

■ Keep the group focused on one question at a time.Make sure all sides are heard before moving on tothe next question.

■ Encourage participation from everyone. If oneperson dominates, you can say, “thanks for yourinformation, maybe someone else would like toadd something?” Or ask someone who has been

xiv Introduction

Introduction

quiet if they have a different perspective or experi-ence to relate.

■ Be responsible for summing up the discussion(either the consensus reached or the many sidespresented). This requires you to be neutral. Eventhough you have your own personal opinion, yourrole now is to facilitate group discussion.

■ Listen for key words and basic ideas.

■ Check things out: “Is this what you meant?”

Supervising: The role of the instructor during smallgroup activities is to ensure that the groups areoperating smoothly. At the start of a workshop, it isespecially important to get people talking instead ofworking quietly as individuals. Circulate among thegroups and listen in to assess their progress. Makesure a recorder is selected and is fulfilling his/herroles; ask questions that will help them proceed ifthey get stuck and suggest resources they may haveoverlooked.

It is important that the instructor does not provide allthe answers for the groups or distract them fromworking things out for themselves. It is too easy for asmall group to disintegrate into a question andanswer period between the instructor and the partici-pants if the instructor hovers. There is a fine linebetween ignoring and intervening too much. There-fore, make your observations, intervene only whennecessary, and move on to the next group. If thegroups are talking among themselves and makingprogress, leave them alone.

Report-Back SessionsReport-back sessions which follow small groupactivities are more than time for summarizing andrehashing; they are separate and important activities.The effectiveness of small-group work is drasticallyreduced if not followed by adequate report-back.

Report-back sessions are not optional. Always end thesmall groups in time to allow for ample discussionand analysis in the report-back sessions. Groupreports require as much preparation as other learning

activities and need discussion questions to be plannedahead of time. Reports may begin with each groupgiving a summary of findings but the bulk of timeshould be devoted to discussing questions that bringmore depth to the issue.

In a report-back session there is time:

■ to explore what participants learned during thesmall group exercises,

■ to correct answers that are factually wrong,

■ to pursue a deeper analysis,

■ to challenge the participants to defend theiranalyses and conclusions,

■ to allow groups that reached different conclusionsfor different reasons to learn from each other, and

■ to have the instructor summarize and raise anyimportant points that did not come up in smallgroup discussions.

Sample questions for instructors to pose:

■ How did you come up with your conclusions?

■ Why did the groups come up with differentconclusions?

■ Who benefits from the analysis you come up with?

■ What are some of the underlying reasons for theproblems you have identified?

■ What further information would you need in orderto come up with a more thorough answer to thequestion(s) your group addressed?

Do not be afraid to leave some questions unresolved(for example, if different participants express views atodds with each other or are unconvinced by thegroup discussion). Some activities do not have correctanswers and sometimes participants will push to havethe teacher tell what the right answer is when nosingle answer is “right”. However, don’t be afraid totake a stand on factual issues.

Introduction xv

Large Group DiscussionsIt takes preparation to lead an effective discussionwith a large group of people. Two points to consider:

■ How will you initiate the discussion?

■ How will you ask questions and elicit participationto maintain the discussion?

To initiate discussion, you can use a small groupexercise or other activity (film, mini-lecture) toprovide a common experience that participants cantalk about. Plan a few specific questions which ask foropinions of the common experience. After a smallgroup activity, people already will have expressedtheir opinions and should have less difficulty talkingin a large group. Use “brainstorming” as a listeningexercise, where the group is asked to generate as manyideas on a given topic as possible. After a list iscompiled, it is easier to go back and get a discussiongoing on some of the points already raised. Use “buzzgroups”: briefly break into pairs or small groups tocome up with ideas on an issue. Ask an open-endedquestion of the group, or pose a controversial posi-tion to evoke a response. This technique doesn’t workso well early on in the workshop when people are notyet used to talking together.

Once a discussion is off the ground, think aboutkeeping it lively and on track. Pointers for maintain-ing discussions:

■ Be prepared to keep asking questions of the groupthat require them to come up with ideas them-selves (rather than just responding to instructor’sideas). Questions should encourage participants todraw on their own experience to make or illustratepoints. Calling on people to answer may benecessary to keep things moving.

■ If participants direct questions to you, you canredirect them to the group. Ask if others have ideasthat could address the situation.

■ Try to keep everyone involved in the discussion.Don’t allow one or two people to dominate. Ifnecessary, stop the discussion and tell the groupyou will call on only those who have not yetspoken.

■ Set a good example yourself by keeping your owncomments brief.

■ With a class that likes to talk a lot you may have todirect the discussion to make sure the section youare doing is covered thoroughly and does notexpand to take time from later sections. If thediscussion loses its focus, try a couple of things toregain it; for instance, summarize points that havebeen made on the blackboard or break into smallgroups to summarize where discussion stands.

Hands-On ExercisesThe purpose of hands-on exercises is to break up theday so participants are not all sitting at tables doingbook work. People can get up and move around, andthis allows people to learn by doing.

Some pointers on running hands-on exercises:

■ As a rule, more instructors are needed to runhands-on exercises than other activities.

■ Often classes will have participants with a range ofprior experience. Instructors should try to plan forthis by pairing buddies, splitting groups, or havingadditional instructors available to help somepeople.

Audio-Visual PresentationsA variety of audio-visual materials can be used in theworkshop to supplement other teaching methods.The more different ways that information is provided(graphics, audio, print) the more likely that peopleare to retain it.

■ Chalkboards or flip charts can be used for record-ing ideas generated by the group. Having oneparticipant record main points while you lead adiscussion makes it easier for people to rememberwhat was last said. This method introducesparticipants to a “teaching role,” and reinforces thebelief that solutions have to start with them.Flipcharts can be prepared ahead of time toaccompany a presentation; the visual outline helpsparticipants listen effectively.

■ Overhead transparencies can be prepared toaccompany a lecture. Using overhead transparen-cies generally means dimming the lights, so someinstructors prefer to use pictures drawn onflipcharts.

xvi Introduction

Introduction

■ Slides and videos can present information in anentertaining way. Used sparingly, they can stimu-late large group discussions.— Videos should always be short (less than 30

minutes).— Make sure you pre-screen the video to check

that its point of view ties in with what you areteaching.

— Avoid showing videos right after lunch!— Using videos and slides usually means darken-

ing the room and therefore reducing discus-sion.

EvaluationThe final learner-centered teaching technique is theevaluation session. Evaluation is important forensuring that participants’ needs are being met by thetraining. It allows the instructor to make appropriateadjustments of workshop content to respond tounmet needs. Evaluating helps participants to becomemore effective instructors by having them think aboutwhat they would do the same or do differently inteaching the workshop. Evaluations help instructorsto become more effective. Although it can be difficultto hear criticisms or suggestions, instructors canalways improve their ability to provide future trainingby getting feedback from the group.

LogisticsRegistration: Mailing or e-mailing registration formsshould take place three to five weeks before the firstsession. This will give participants enough time toplan for the workshop, but not enough that they putany notice or announcement aside and forget aboutit. Be sure to include a closing date for registrations inany announcement for the workshop.

Confirmations: Each participant should receive aconfirmation of attendance, a workshop agenda, anddirections to the training venue.

Instructor Pre-workshop tasks: Several tasks shouldbe completed before the first session.

■ Reserve space and break-out areas for the work-shop. The room should be set up classroom stylewith round tables or a table grouping which lendsitself to small group discussion.

■ Review registrant names. Knowing the backgroundof participants may be useful in discussion groups.Individuals can be called upon to share uniqueexperiences, thereby adding to the depth ofdiscussion.

■ Review the Instructor Guide and your own notes.While it is true that instructors use different styles,the content of the presentation should remain thesame.

■ Prepare workshop materials. Be sure that there areenough hand-outs, exercises, manuals and evalua-tion forms for all participants. Check handoutmaterial for copy quality.

■ Review prepared overheads. Overheads have beenprepared for the workshop and are referred to inthe instructor notes by title and/or overheadnumber.

■ Gather sufficient materials to support activities. Itis helpful to bring a box supplied with maskingtape, overhead markers, pens, flip chart markers,scissors, paper clips, stapler, ruler, etc.

Introduction xvii

VII. New Course Design to CustomizeP2 Curriculum Offerings

Customizing the CurriculumAs mentioned earlier, the content areas coveredamong the levels of this Comprehensive PollutionPrevention Integration Training Curriculum addressskills and knowledge needed by the environmentalregulator from a variety of perspectives. It represents

a well-rounded training strategy. However, thecourses developed within each of the curriculum tiershere represent just a sample of what might be themost effective coursework to fulfill training needs in agiven agency.

The development of other courses within the curricu-lum tiers may strengthen the P2 training strategy inyour organization. Examples of additionalcoursework might include:

New Course Development BasicsDeveloping an effective course is not a simple task.But when managed well, new coursework can meetimportant organizational needs. A design processincluding input from management, key staff, atechnical subject matter expert and a course designeris best equipped to develop new, relevant courseworkto enhance this curriculum design.

Internal discussion of organizational goals, individualperformance objectives, performance gaps, andcorresponding skill and knowledge developmentissues should form the basis of the discussion forselection of new course content. Once a content orskill area is selected, a new course should be scoped.The scoping meeting should include a discussion ofthe objectives of new coursework, the target audience,the blocks of content to be covered, the selection of asubject matter expert(s) to develop the course indetail, and a draft (very broad and preliminary)agenda.

The course developer and content expert thenproceed with more detailed agenda development,draft participant materials, visuals, exercises andinstructor notes.

A mid-course development checkpoint assembles theoriginal team to review and comment on coursedevelopment. A formative evaluation should then bescheduled. This is a “dry run” or rehearsal of thedrafted course before a small, sample audience. Acritique panel is invited, a training room scheduledand AV arranged as similar as possible to the actualtraining venue. A rehearsal presentation is deliveredand the panel/audience suggests changes for the finalcourse.

The new course is then readied for pilot before anactual audience. Necessary event coordinationincludes selecting a date and location, notifying keystaff, contracting with or scheduling facilities, inviting

Curriculum Tier New Course possibilities

Industrial Process/Sector Courses for the industries most prevalent in yourarea

Enhanced Communications Facilitation Skills for Making Multi-program/Multi-media Meetings Work.

P2 in the Job Function P2 for Permit WritersP2 for Legal StaffManaging for Pollution Prevention

Information Access Efficient research strategiesSearch-oriented thinking

xviii Introduction

Introduction

participants 4-6 weeks in advance and confirmingtheir attendance 1-2 weeks in advance. Finally, there isthe work of preparing evaluations, preparing partici-pant materials and instructor materials, managing allAV needs and then delivering the pilot. (see “Innova-tive P2 Course Delivery Checklist” in and earliersection of this preface).

Depending on the amount of time a course developerand content expert can devote the development of anew course in a focused way, 6 to 12 months shouldbe allowed for the selection, design, development andpiloting of original pollution prevention integrationcoursework. Following you will find a summary ofthis process on the “Pollution Prevention IntegrationNew Course Development Checklist.”

Introduction xix

Pollution Prevention Integration New Course Development Checklist

Course Title: ■ = Milestones

■ Meeting on Organizational Strategy

Who is attending?

Discussion items:

Aligning training with strategic organizational goals

What are our organizational goals? (which one are we addressing here?)

What are the individual performance objectives that relate to the organizational goal?

What are the gaps between desired individual performance and actual performance?

What skills and knowledge might help close those gaps?

Once a content or skill area is selected, a new course can be scoped.

■ Course Scoping Meeting

Who is attending? Discussion items:

What are the objectives for the new course? How does that relate to our organizational goals?

Who is our target audience? (Will the course help participants reach job objectives andorganizational goals?

What blocks of content or skill areas do we want covered in the course?

What subject matter expert(s) can help develop the course in detail?

Who is the course developer who will help shape the content into a learner-centered course?

Draft a very broad and preliminary agenda

Set next steps

■ Course Developers Go to Work

Agenda is developed in detail

Exercises, discussions, instructor tools are selected

Visuals are developed

Participant materials are developed

Draft instructor notes are prepared cont’d

Note: This may be an iterative process, with some later steps on this checklistprompting reconsideration of earlier steps. Flexibility is important to developing asolid course.

xx Introduction

Introduction

■ Mid-course Development Checkpoint (formative evaluation)

Assemble original team to review and comment on course development (this can be done prior to the“dry-run” or you can use the team as the critique panel)

Schedule a “dry-run” or rehearsal of the course delivery (date/time/location/critique panel)

Prepare for the “dry-run”: (if separate from the original team review and comment)

Critique panel invited

Room scheduled

AV arranged

Deliver course in rehearsal

Collect comments and feedback during or after the session

Incorporate comments into the final course agenda as appropriate

■ Pilot Delivery of New P2 Integration Course

Date chosen

Key staff notified (supervisors) (before you invite participants)

Facilities contracted

Participants invited (4–6 weeks in advance)

Participants confirmed (within a week of the training)

Evaluation forms prepared

See “course delivery worksheet” from earlier in this section of this manual preface for more detail

■ Follow-Up

Summarize evaluation comments and distribute to training design team and other key stakeholders

Incorporate feedback into course agenda for next course delivery

Pollution Prevention Integration New Course Development Checklist (continued)

Note: This may be an iterative process, with some later steps on this checklistprompting reconsideration of earlier steps. Flexibility is important to developing asolid course.


InformationAccess






natural resources.

*



Electroplating and SurfaceFinishing Sector Training

*Industrial Process/Sector Innovative Technologies

Instructor’s Manual with Participant Materials


2 Instructor Notes Electroplating and Surface Finishing Sector Training

Table of Contents with Overheads

Module 1 Introduction ................................................................................................................................................................................................................ 10Welcome .............................................................................................................................................................................................................................. 11Agenda ................................................................................................................................................................................................................................. 11

Module 2: Straight Talk on Metal Finishing .............................................................................................................................................................................. 12Straight Talk on Metal Finishing ....................................................................................................................................................................................... 13Why Are Things Plated? ..................................................................................................................................................................................................... 15Surface Finishing Processes ............................................................................................................................................................................................... 17Five Basic Processes ............................................................................................................................................................................................................ 19Two types of shops ............................................................................................................................................................................................................. 21Characteristics of Captive Shops ....................................................................................................................................................................................... 21Characteristics of Job Shops .............................................................................................................................................................................................. 23Work Handling Methods ................................................................................................................................................................................................... 25Three General Steps in Plating .......................................................................................................................................................................................... 27

Module 3: Video: A Facility Walk-Through .............................................................................................................................................................................. 28Flow Chart ........................................................................................................................................................................................................................... 33Flow Chart ........................................................................................................................................................................................................................... 43Pollution Prevention Opportunities ................................................................................................................................................................................. 59P2 Opportunities in Solvent Degreasing .......................................................................................................................................................................... 65Cause and Effect Diagram for Drag Out .......................................................................................................................................................................... 67Reducing Drag Out ............................................................................................................................................................................................................ 67Rinsing Over Plating Tank ................................................................................................................................................................................................. 69Common Rinsing Configurations .................................................................................................................................................................................... 71Drip Boards ......................................................................................................................................................................................................................... 73Reactive Rinsing .................................................................................................................................................................................................................. 75Drag Out Prevention .......................................................................................................................................................................................................... 77More on Drag Out Amounts ............................................................................................................................................................................................. 77Estimation of Drag Out ..................................................................................................................................................................................................... 79Solvent Replacement .......................................................................................................................................................................................................... 81Pollution Prevention Opportunities in Processing ......................................................................................................................................................... 85Pollution Prevention Opportunities in Processing ......................................................................................................................................................... 87Some Pollution Prevention Opportunities ...................................................................................................................................................................... 89Hi-Tech Methods for Material Recovery .......................................................................................................................................................................... 93Diffusion Dialysis ............................................................................................................................................................................................................... 93Vacuum Evaporators for Chemical Recovery .................................................................................................................................................................. 95Reverse Osmosis Nickel Recovery Application ................................................................................................................................................................ 95Ion Exchange ....................................................................................................................................................................................................................... 97Metal Finishing Resources ............................................................................................................................................................................................... 105Web Sites ........................................................................................................................................................................................................................... 109List Servers ........................................................................................................................................................................................................................ 111

Module 4: Pollution Prevention Opportunities ........................................................................................................................................................................ 58Pollution Prevention Opportunities ................................................................................................................................................................................. 59P2 Opportunities in Solvent Degreasing .......................................................................................................................................................................... 65Cause and Effect Diagram for Drag Out .......................................................................................................................................................................... 67Reducing Drag Out ............................................................................................................................................................................................................ 67Rinsing Over Plating Tank ................................................................................................................................................................................................. 69Common Rinsing Configurations .................................................................................................................................................................................... 71Drip Boards ......................................................................................................................................................................................................................... 73Reactive Rinsing .................................................................................................................................................................................................................. 75Drag Out Prevention .......................................................................................................................................................................................................... 77More on Drag Out Amounts ............................................................................................................................................................................................. 77Estimation of Drag Out ..................................................................................................................................................................................................... 79Solvent Prevention ............................................................................................................................................................................................................. 81Pollution Prevention Opportunities in Processing ......................................................................................................................................................... 85Pollution Prevention Opportunities in Processing ......................................................................................................................................................... 87Pollution Prevention Opportunities in Processing ......................................................................................................................................................... 89Hi-Tech Methods for Material Recovery .......................................................................................................................................................................... 93Diffusion Dialysis ............................................................................................................................................................................................................... 93Vacuum Evaporators for Chemical Recovery .................................................................................................................................................................. 31Reverse Osmosis Nickel Recovery Application ................................................................................................................................................................ 95Ion Exchange ....................................................................................................................................................................................................................... 97

Module 5: P2 Exercise: Identifying Waste ................................................................................................................................................................................ 100Module 6: Metal Finishing Resources ...................................................................................................................................................................................... 104

Metal Finishing Resources ............................................................................................................................................................................................... 105Web Sites ........................................................................................................................................................................................................................... 109List Servers ........................................................................................................................................................................................................................ 111

Module 7: Exercise: Incorporating P2 into Facilities .............................................................................................................................................................. 116Module 8: Review/Closing ........................................................................................................................................................................................................ 122

Electroplating and Surface Finishing Sector Training 3

Table of Contents

Module 1 1: Introduction ................................................................................................................................ 10

Module 2: Straight Talk on Metal Finishing .................................................................................................. 12

Module 3: Video: A Facility Walk-Through ................................................................................................... 28

Module 4: Pollution Prevention Opportunities ............................................................................................. 58

Module 5: P2 Exercise: Identifying Waste .................................................................................................... 100

Module 6: Metal Finishing Resources........................................................................................................... 104

Module 7: Exercise: Incorporating P2 into Facilities ................................................................................... 116

Module 8: Review/Closing ............................................................................................................................ 122

Instructor Notes


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Trainer needs to

CUSTOMIZE this section to

fit region, agency, etc.Customize

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Transition to NEW TOPIC ORCONCEPT

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HANDOUT, EXERCISE orEVALUATION

referred to in this section




ParticipantExerciseE V A L

Trainer ASKS SPECIFIC

QUESTIONS at this point????

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STOP Video

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“HANDS ON” EXERCISE

“ROUND-THE-CLOCK”

EXERCISE

PAIRED, SMALL or LARGEGROUP EXERCISE

NotesParticipant Notes


Instructor Notes


Electroplating and Surface Finishing Sector Training

P2 Integration: a Training Curriculum for Environmental Agency Staff

Instructional Objectives

Participants will:

1. Gain a better understanding of the plating process.

2. Be able to identify opportunities for electroplating facilities to implementpollution prevention.

3. Be able to work with facilities to encourage pollution prevention through theirtraditional job activities.

4. Develop skills to work with a facility to encourage the use of pollution preven-tion as a tool for compliance.

5. Integrate pollution prevention into their current jobs.

Entry Behaviors and Characteristics

1. Participants are regulatory staff (Federal, state, or local) involved in complianceinspections and/or enforcement.

2. Participants have introductory knowledge of pollution prevention and toxicsuse reduction concepts and are interested in more technical training.

3. Participants are expected to be catalysts for pollution prevention, rather thanimplementers.

4. Participants are regulatory staff who can encourage pollution preventionthrough their roles as technical assistance providers.

Performance Objective

1. Participants will be able to ask specific and clarifying questions during aninspection, permit review, or enforcement action. This will make the facilityaware of opportunities to implement pollution prevention projects that willreduce the use of toxics.

2. Participants will learn how to work with a facility and encourage them to usealternative technologies and techniques.

3. Participants will gain an understanding of the electroplating process andrelevant pollution prevention options.



Instructional Objectives

Participants will:

1. Gain a better understanding of the plating process.

2. Be able to identify opportunities for electroplating facilities to implementpollution prevention.

3. Be able to work with facilities to encourage pollution prevention through theirtraditional job activities.

4. Develop skills to work with a facility to encourage the use of pollution preven-tion as a tool for compliance.

5. Integrate pollution prevention into their current jobs.


1. Participants will be able to ask specific and clarifying questions during aninspection, permit review, or enforcement action. This will make the facilityaware of opportunities to implement pollution prevention projects that willreduce the use of toxics.

2. Participants will learn how to work with a facility and encourage them to usealternative technologies and techniques.

3. Participants will gain an understanding of the electroplating process andrelevant pollution prevention options.

Electroplating and Surface FinishingSector Training

Instructor Notes


Agenda

Module Approximate Time

1 Introduction/Expectations 15 minutes

2 Straight Talk on Metal Finishing 25 minutes

3 Video: A Facility Walk Through 50 minutes

4 Pollution Prevention Opportunities 45-60 minutes

5 P2 Exercise: Identifying Waste 45-60 minutes

6 Metal Finishing Resources 30-45 minutes

7 Exercise: Incorporating P2 into Facilities 60-75 minutes

8 Review/Closing 15 minutes

TOTAL approx 5.75 hours

Instructor Tools

1. Lecture: Much of the technical content will be delivered in an interactive lectureformat. In an interactive lecture, the trainer will introduce ideas or topics andsolicit responses from the audience. (i.e., The trainer introduces a topic such as“anodizing” and asks the audience what it means or how it relates to metalplating operations.) The trainer then gives the technical definitions orinformation about the ideas or topics.

2. A video is used in module three in place of a facility walk through. This videoillustrates the processes that take place in a metal finishing facility. Stills fromthat video are included in the manual. Copies of the video can be obtained fromTURI; call 978-934-3346.

3. Several small group exercises are used in this training. This allows participants toshare their knowledge and expertise with each other. The exercises also giveparticipants an opportunity to practice some of the skills they will need whenencouraging facilities to investigate pollution prevention options.

4. NEWMOA’s “Pollution Prevention for the Metal Finishing Industry” is a goodcompanion piece for this course. Call 617-367-8558 to order.

5. Overhead numbering system: Overheads are numbered sequentially andreferred to (by number) in both the “Instructor Notes” section and the“Participant Notes” section.

6. The student materials may be reproduced by copying the right-hand pages ofthis instructor manual.



Training Agenda

Module

1 Introduction/Expectations

2 Straight Talk on Metal Finishing

3 Video: A Facility Walk Through

4 Pollution Prevention Opportunities

5 P2 Exercise: Identifying Waste

6 Metal Finishing Resources

7 Exercise: Incorporating P2 into Facilities

8 Review/Closing

Instructor Notes


Module 1 1 Introduction

1. Introduction: The instructor begins by introducing himself or

herself and discussing the purpose of the training. (Display and

refer to Overhead 1.)

2. The instructor asks the participants to introduce themselves

and give their expectations for the course.

3. Agenda: The trainer should briefly review the agenda and

highlight the areas the training will cover. (Display and refer to

Overhead 2.)



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Welcomeoverhead 1

By the end of the day, we hope you will be able to:

■ Gain a better understanding of the plating process

■ Identify pollution prevention opportunities in plating facilities

■ Develop skills to work with a facility to encourage the use of P2 as a tool for

compliance

■ Integrate P2 into your current job

Agendaoverhead 2

■ Introduction

■ Straight talk on metal finishing

■ Video: Facility tour

■ Pollution prevention opportunities

■ Identify the waste

■ Resources for metal finishing

■ Incorpoating P2 into your job

■ Review/Closing

Module 1Introduction/Expectations

Instructor Notes


Module 2 Straight Talk on Metal Finishing

Section 1: Overview of surface finishing processes

1. Introduce the purpose of the module:

■ to explain why things are plated

■ to give a basic understanding of the different processes that

take place in a plating facility

2. Briefly discuss the areas that the module covers: types of shops,

characteristics of the shops, and overview of the plating

process. (see Overhead 3)






Straight Talk on Metal Finishingoverhead 3

Overview

In this session, we are going to cover background information on the metal

plating industry.

Information included in this module:

■ Types of shops

■ Characteristics of the shops

■ Overview of the Plating Process

Module 2Straight Talk on Metal Finishing

Instructor Notes


3. Interactive lecture: Display Overhead 4. This overhead gives

several reasons why plating is important.

■ Discuss plating for aesthetic reasons. Display only heading

and ask “Why are things plated?” — use the following penny

example: Hold up a penny or toss some pennies to

participants. Ask “What are these made of?” Then explain:

The penny is generally considered to be made from copper.

However, the government switched to making the penny

from zinc some years ago. The zinc is covered with an

electroplated copper coating. Why would they do this? It

costs too much to make the entire penny from copper! But

is the issue merely cost? If so, why not leave the penny

looking like zinc? The US government (and probably the

citizenry as well) wants to keep it looking like the old penny

for aesthetic reasons.

■ Solicit answers from participants on the remaining topics of

Overhead 4. How do platings provide corrosion resistance,

lubrication, and conductivity? Possible answers include:

Corrosion resistance: protects metal surfaces from corrosion.

For example, chrome plated bumpers, cadmium plated fish

hooks (for marine applications)

Lubrication: some coatings are better able to provide anti-

friction properties, or have a structure that allows oil to be

trapped in the porous surface and provide lubrication.

Electrical conductivity: many metals, such as copper, silver,

and gold, offer excellent conductivity. These metals can be

plated onto a surface to give conductivity. For example,

copper is plated onto a substrate then removed from certain

areas to make printed circuit boards.




????

Module 2



Why Are Things Plated?overhead 4

■ Aesthetics

■ Economics

■ Lubricity

■ Conductivity

■ Corrosion Protection

■ Plating on non-conductors

Module 2

Instructor Notes


Plating on non-conductors: electroless technology allows

non-metal parts, such as today’s ABS bumpers to be plated

with a layer of metal, in this case, for decorative effects. A

thin layer of metal deposited from an electroless bath then

allows the parts to processed in a “full-build” electroplating

bath if desired.

4. Metal plating is just one of many processes in the surface

finishing industry. Overhead 5 shows some of the other metal

finishing processes. These other processes allow us to impart

the desired functionality or aesthetic quality to the surface. We

just discussed plating, which allows us to plate a thin layer of

metal over a metallic or, in some cases, non-metallic substrate.

Other finishing processes include removing metal or changing

the surface characteristics of metal. The next overhead lists

some basic processes used to give the desired characteristics

to the metal.

Module 2






Surface Finishing Processesoverhead 5

PolishingBuffingGrinding

EtchingElectroetching

PVDCVD

SurfaceFinishes

OrganicTechnologies

LiquidCoatings

PowderCoatings

Anodizing Chromating Phosphating AqueousProcesses

PhysicalProcesses

MetalDeposition

RemovalTechnologies

ConversionTechnologies

AqueousProcesses

ElectroplatingElectrolessPlating

DryProcesses

Module 2

Instructor Notes


5. Display Overhead 6: This overhead lists some of the different

techniques that surface finishers use to achieve the desired

properties of the surface. Solicit answers to these concepts

from the audience. Possible answers include:

■ Plating: Depositing metal, as discussed earlier.

■ Polishing/bright dipping: These processes use chemical

formulations that create a smooth reflective surface by

removing some of the base metal. Electrical current may be

part of the process, as in electro-polishing, or not part of the

process, as in copper bright dipping. Example: Electro-

polishing, in a phosphoric/sulfuric acid bath, of a stainless

steel reflector.

■ Passivating: Removal of iron contamination on the surface of

stainless steel to prevent subsequent corrosion. Example:

Passivation of a stainless steel valve body after it has been

cut, ground and buffed.

■ Anodizing: Electrolytic process where aluminum parts are

made anodic, with the resultant formation of aluminum

oxide film that increases both hardness and corrosion

resistance. The parts can also be dyed different colors.

Anodizing will most likely be the process with the highest

toxics use per unit of product in a metal finishing facility.

Example: Anodizing of architectural aluminum window

frames to improve hardness and corrosion resistance.

■ Chromating: Aluminum, zinc, and then chrome is added to

provide a finish, hardness, and corrosion protection.




Module 2



Five Basic Processesoverhead 6

■ Plating

■ Polishing/Bright Dipping

■ Passivating

■ Anodizing

■ Chromating

Module 2

Instructor Notes


Section 2 Background on the surface finishing industry

1. Ask the audience: What are the two general types of shops that

exist in the surface finishing universe? Display Overhead 7.

■ Captive shop: A shop that is owned by the manufacturer of

the parts that they process. The parts may or may not be

manufactured on site.

■ Job shop: A shop that solicits work from outside companies,

and performs any process that it may have in the shop.

2. What are the implications for P2 at these types of facilities? In

other words, what kind of control over the process does each

of these types of shops have? Which is more likely to have

better resources and better communication with the design

engineers? Which is more likely to be doing the same job more

than once?

■ Display Overhead 8 and deliver the following information:

Captive shops may be original equipment manufacturers

(OEMs), and probably have greater resources to invest in

pollution prevention. They may have a great amount of

technical expertise in surface finishing. Some captive shops

have only a one small finishing line that they operate by rote.

Other captive shops have very large and complex finishing

systems that are attended by experienced and knowledgeable

operators, process engineers, and chemical support staff.

Captive shops may have a greater ability to exert influence on

the way that parts are engineered. They can use cutting fluids

that are more amenable to aqueous degreasing, design drain

holes to reduce drag out, and specify finishes that may be

more environmentally friendly.

????







Module 2



Two types of shopsoverhead 7

■ Captive shops

■ Job Shops

Characteristics of Captive Shopsoverhead 8

■ Usually greater resources to invest in P2

■ Expertise in finishing operations varies widely

■ Greater ability to influence how parts are engineered

Module 2

Instructor Notes


■ Display Overhead 9 and present the following information:

Job shops also vary greatly in their technical ability. Many of

the finishing processes that are being used today are only

trivially different from the processes developed in the late

1800’s and early 1900’s. Many of the job shops are family-run

businesses where the finishing knowledge has been passed

down over several generations. Therefore, finishing is

approached more as an art than a science, and formal training

in chemistry and industrial processing has not been pursued.

■ Process control is key for efficient shop operations. Due to

the lack of formal knowledge, process control is not utilized

often or correctly enough. Particularly for the job shop, but

also for captive shops, process knowledge most often comes

from the vendor of the chemistries they use, if they are

using proprietary chemistries. Many finishing processes are

“recipes” that come out of the various surface-finishing texts,

and therefore do not have vendor support. However, for

many processes, metal finishers depend on the chemical

vendors for processing procedures, chemical concentrations,

pre-processing procedures (cleaning, underplate, etc.). They

also depend on the vendors for updated processes and

pollution prevention information.




Module 2



Characteristics of Job Shopsoverhead 9

■ Vary greatly in technical expertise

■ Process controls inconsistently used or understood

■ Process knowledge is usually gleaned from vendors

Module 2

Instructor Notes


3. Work Handling Methods: There are two major ways that work is

handled in a plating shop: (Refer to Overhead 10.)

■ Rack: When work is racked, it is put onto a frame by hanging,

clamping, bolting, or similar means. In this case, part

orientation, draining holes, and work practices are all

extremely important for drag out reduction.

■ Barrel: There are a few reasons why barrel processing can be

efficient. You can process many parts in a small volume of

solution. There are parts that are virtually un-rackable, such

as ball bearings. For parts with complex geometry, you can

get more even plating. The issue for toxic use reduction is

that there is a much larger amount of drag out associated

with barrels. This is due to the interstitial spaces between

the parts in the barrel.




Module 2



Work Handling Methodsoverhead 10

■ Rack

■ Barrel

Module 2

Rack

Barrel

Instructor Notes


4. Overhead 11 depicts the general process flow for plating

operations:

■ Pre-clean: Parts come into the plater (either from in-housemetal forming operations or from outside customers) withcontamination such as machining fluids, oils, and rust(oxidation). This contamination needs to be removed beforeprocessing the parts. There are different methods for doingso, depending on whether the facility is processingaluminum or non-aluminum parts. For the sake ofcompleteness, there are variations within these divisions,but the general approach is similar.

Both situations employ some type of oil removal, oftenvapor degreasing. There are some excellent replacementsfor vapor degreasing, but their use requires careful testingand implementation or the project could be unsuccessful.

■ Processing: The processing step is where the actualapplication of the metal takes place. There are a variety ofmethods, processes, and process solutions for applying themetals. For the purposes of this training, we will discussplating, anodizing, and chromating (in later modules).

The major sources of loss from electroplating operationsare drag out losses and bath dumps. There are many ways tocontrol both of these sources, but elimination of the losses isvirtually impossible. Capture, recovery, and purification ofthese losses are the procedures required for good shopoperation. Note that this is true for all applications, includingpre-cleaning and post processing. However, there may besubstantial differences in implementation of such recoverytechniques in the different operations.

■ Post Processing: This step includes rinsing and stain-freedrying, if necessary. Not all processes or platers will requirestain free drying. Typically the drying step is done only

where the client requires a stain free product.4 Module 3

Module 2






Module 2

Three General Steps in Platingoverhead 11

Pre-cleaning Process

Plating

Post-Process

Instructor Notes


Module 3 Video: A Facility Walk-Through

1. Video presentation: This video gives participants an

understanding of what operations take place in a typical shop.

It also illustrates some of the regulatory issues that might be

encountered in such a shop. Participants should try to notice

pollution prevention opportunities in the video. The video

represents only a few of the hundreds of different processes.

2. Introduction to video:

To give you a sense of surface finishing operations, we have

prepared a video presentation of several different operations

in several different shops. In the different portions of the video,

we will discuss the various sources of waste in the surface

finishing shop and touch on some of the regulatory issues that

affect the industry.

In addition to showing the wastes and regulatory issues, we

will also discuss some of the ways in which pollution can be

prevented in the process. As we go through the video, be

aware of these discussions, and make notes in your workbooks

regarding process inputs and outputs, regulatory issues and

pollution prevention techniques.

Note that the processes that we will see are representative

of the dozens, if not hundreds, of surface finishing operations.

Most of the issues that we discuss will be applicable to the vast

majority of processes.

3. Start the video and show racking and masking sections. Then

stop the video. While the racking and masking sections are

shown, the instructor might give a narrative along the

following lines:

Nex

t…



Module 3

Video Presentation “Shop Floor View of Metal Finishing”

To give you a sense of surface finishing operations, we have prepared a videopresentation of several different operations in several different shops. In thedifferent portions of the video, we will discuss the various sources of waste in thesurface finishing shop and touch on some of the regulatory issues that affect theindustry.

In addition to showing the wastes and regulatory issues, we will also discusssome of the ways in which pollution can be prevented in the process. As we gothrough the video, be aware of these discussions, and make notes in your work-books regarding process inputs and outputs, regulatory issues and pollutionprevention techniques.

Note that the processes that we will see are representative of the dozens, if nothundreds, of surface finishing operations. Most of the issues that we discuss will beapplicable to the vast majority of processes.

Video: A Facility Walk Through

Instructor Notes


■ Racking: The parts must be held in some type of fixture in

order to allow them to be processed. As we discussed

previously, the work can be hung, bolted, or clamped onto

the rack to hold it in place. The rack provides the electrical

contact with the rectifier (power source) that allows the

electrons to flow either to or away from the parts. The racks

also hold the pieces rigidly in the agitated solution. This

prevents parts from falling off the racks, and keeps the parts

the correct distance from the anodes or cathodes during

processing.

The other common work handling method is to load the

parts into a barrel for processing. The barrel rotates

continuously during all operations, which allows the

solution to contact all of the parts, and distributes the parts

equally in the barrel during the processing operation. The

parts are in contact with the barrel and each other while the

barrel tumbles, and this allows the electrical contact to be

maintained with all parts during processing.

■ Masking: When parts are designed, the design engineers

often want finishing only on certain areas of the parts. The

places where finishing is undesirable are then “masked-off.”

This involves some type of physical blockage of the surface

to prevent fluid contact with the surface. Types of masks are:

tapes, waxes, paints. There is an art to masking, and some

shops employ full-time “maskers” while others have the

platers themselves mask the parts.

Module 3



Module 3

Racking

Masking

Instructor Notes


4. Display Overhead 12 and give a brief introduction to the first

process, a Barrel Electroless Nickel Line. Also discuss some of

the processing issues in the electroless process. Suggestions

for the introduction and process issues follow:

■ Introduction: In this process, small valves (about 1 inch in

diameter by 2 inches long) are being processed through an

electroless nickel line by a manually operated hoist

conveyor. There is a pre-clean cycle that consists of alkaline

electro-cleaning and hydrochloric acid pickling. After

cleaning, the parts are immersed in the electroless nickel

bath itself, which applies a thin coating of a nickel/

phosphorous alloy without the use of electricity. Following

the plating operation, the parts are dipped in an organic

solvent that displaces water. Subsequent degreasing in a

chlorinated solvent vapor degreaser removes the organic

solvent and leaves the parts clean, dry, and stain-free.




Module 3



Flow Chartoverhead 12

1. Pre-cleanAlkaline cleaner

1a. Rinse

2. Acid PicklingHydrochloric Acid Pickle

2a. Rinse

3. PlatingElectroless Nickel

3a. Rinse

4. Stain Free DryingWater Shedding Liquid

5. DegreasingVapor Degreasing

NaOH

Water

HCI

Water

NiSO4Organic Acids

Water

StoddardSolvent

Trichlorethylene

NaOH, Oils, Dirt

Spent Rinsewater,Dragout

HCI, Metal

Spent Rinsewater

NiSO4Organic Acids

Spent Rinsewater

TrichlorethyleneStoddard SolventsOils, Greases, etc.

Barrel electroless Nickel Line

Module 3

Instructor Notes


■ Processing Issues in the Electroless Process:

Electrocleaning: The solution consists of sodium hydroxide,

detergents, and wetting agents. The parts are immersed in

the bath, and a current is applied that splits water into

molecular hydrogen and oxygen. These gases form bubbles

on the surface of the parts that travel up the part and then

lift off to the surface. The action of the bubbles on the

surface of the parts provides a scrubbing action and

agitates the solution. This brings fresh solution to the

surface of the parts and allows the chemical reactions to

continue.

Pickling: The hydrochloric acid serves to both dissolve any

surface oxidation from the part and also to neutralize any

remaining sodium hydroxide on the part.

Electroless Nickel: The nickel is plated on the part by the use

of a chemical reducing agent that supplies the electrons

necessary for the plating reaction.

Drying: This particular process, due to customer

specifications for stain-free drying, uses a water-displacing

liquid (stoddard type solvent) to remove all of the water

from the surface of the parts. Next the organic solvent is

removed through the use of chlorinated solvent degreasing.

Module 3



Anode

Cathode

M+2 + 2e– M°ionic, supplied by metaldissolved electricity or deposited at

chemistry cathode

General Plating ReactionElectroplating: electrons are transferredfrom the rectifier to the part via electricalcontacts. The electrons react with dissolvedmetal ions resulting in metal deposition.

Anode

H2

H2

O2

O2

O2

Cathode

H2O H21 + 1/2O21

Electrocleaning (reverse cleaning)Electricity splits water, causing theformation of oxygen bubbles at the anodeand hydrogen bubles at the cathode.

Electrocleaning (Reverse Cleaning)

Elecrtoless Nickel

Module 3

Instructor Notes


5. Restart the video and show Barrel Electroless Nickel Line. Give

a narration during the video which highlights the important

aspects of the video. For example:

■ Alkaline Cleaning: Alkaline cleaning solutions are the

standard for removal of residual oil, grease and dirt

following the solvent degreasing step. In many operations,

electricity is passed through the parts (referred to as electro-

cleaning), which results in better cleaning from increased

agitation. The agitation is caused by the electrolysis of water,

which also causes the formation of the bubbles of H2 and O

2,

which scrub the surface of the parts as they rise. If no

electricity is used, this cleaning is called soak cleaning.

■ Rinsing: The parts are rinsed of the cleaning solution. Rinsing

of sodium hydroxide solutions can be a difficult proposition

due to their tendency to form a hard to rinse film on the

parts. Often, these rinses are warmed and agitated to assist

the rinsing action.

■ Acid Pickling: After alkaline cleaning, the parts are soaked in

a solution of hydrochloric acid to remove any oxidation or

rust that may be on the parts. Oxidation will inhibit the

deposition of metal on the parts, so it must be removed.

■ Rinsing: The rinsing removes the acid, and also prevents

further etching on the surface of the parts. Note that this

rinsing is done in a separate rinse tank. This is done to

prevent cross contamination, and also for waste treatment

issues. Different solutions need to be treated in different

waste treatment operations. Therefore, many rinses are

segregated for the purposes of collection and treatment.

Module 3



As video continues consider:■ Why is this process being done?■ What are the sources of waste for this operation?■ What are the environmental and industrial hygene problems related

to this process?

Alkaline Cleaning: Alkaline cleaning solutions are the standard for removal ofresidual oil, grease and dirt following the solvent degreasing step. In many opera-tions, electricity is passed through the parts (referred to as electro-cleaning), whichresults in better cleaning from increased agitation. The agitation is caused by theelectrolysis of water, which also causes the formation of the bubbles of H

2 and O

2,

which scrub the surface of the parts as they rise. If no electricity is used, thiscleaning is called soak cleaning.

Rinsing: The parts are rinsed of the cleaning solution. Rinsing of sodium hydroxidesolutions can be a difficult proposition due to their tendency to form a hard torinse film on the parts. Often, these rinses are warmed and agitated to assist therinsing action.

Acid Pickling: After alkaline cleaning, the parts are soaked in a solution of hydro-chloric acid to remove any oxidation or rust that may be on the parts. Oxidationwill inhibit the deposition of metal on the parts, so it must be removed.

Rinsing: The rinsing removes the acid, and also prevents further etching on thesurface of the parts. Note that this rinsing is done in a separate rinse tank. This isdone to prevent cross contamination, and also for waste treatment issues. Differentsolutions need to be treated in different waste treatment operations. Therefore,many rinses are segregated for the purposes of collection and treatment.

Module 3

Instructor Notes


■ Plating Electroless Nickel: After the pre-clean steps are

performed, the parts are immersed into the electroless

nickel plating bath. This solution is referred to as “electroless”

because no electricity is used in the plating reaction: M+2 +

2e- => M (In this case, the electrons are provided by a

chemical reaction.)

One of the differences between electroless and electrolytic

plating baths is that electroless baths cannot be purified

and rejuvenated indefinitely, as is the case with electrolytic

types. Therefore, these baths are completely dumped and

remade on a regular schedule.

This bath is run at very high temperatures, generally higher

than 190F, and the bath must be filtered vigorously because

any particles in the solution provide a site for the bath to

plate out.

■ Rinsing: The rinsing removes the plating solution. Note that

this rinse tank is segregated from the others.

■ Stain Free Drying: The parts are immersed in an organic

solution that displaces the water from the part (this is

sometimes called a “water shedding” liquid). There are

various materials that can be used, such as stoddard

solvents, alcohol, and so on.

Drag out reduction is of critical importance here because

the water shedding liquid will quickly deplete the

degreasing solvent.

Module 3



Plating Electroless Nickel: After the pre-clean steps are performed, the parts areimmersed into the electroless nickel plating bath. This solution is referred to as“electroless” because no electricity is used in the plating reaction: M+2 + 2e- => M(In this case, the electrons are provided by a chemical reaction.)

One of the differences between electroless and electrolytic plating baths is thatelectroless baths cannot be purified and rejuvenated indefinitely, as is the case withelectrolytic types. Therefore, these baths are completely dumped and remade on aregular schedule.

This bath is run at very high temperatures, generally higher than 190F, and thebath must be filtered vigorously because any particles in the solution provide a sitefor the bath to plate out.

Rinsing: The rinsing removes the plating solution. Note that this rinse tank issegregated from the others.

Stain Free Drying: The parts are immersed in an organic solution that displacesthe water from the part (this is sometimes called a “water shedding” liquid). Thereare various materials that can be used, such as stoddard solvents, alcohol, and soon.

Drag out reduction is of critical importance here because the water sheddingliquid will quickly deplete the degreasing solvent.

Barrel Electroless Nickel Line

Module 3

Instructor Notes


■ Degreasing: Solvent degreasing, in this case using the

chlorinated solvent trichloroethylene, is often the first step

in the surface finishing process. Here, however, it is being

used as the final step in order to remove the organic water

shedding liquid. This is done in order to provide critical stain

free drying. If the parts were removed from the final rinse

and allowed to dry, there would be many water spots on the

parts, which are unacceptable in this application.

The degreaser has a heating coil in the bottom of the unit

that heats the solvent to boiling. The vapor condenses on

the parts, dissolves the oils and greases and drips off the

parts back into the sump. The oils and greases generally

have higher boiling points, so they stay in the sump while

pure solvent vapor continues to be evolved into the vapor

zone. Near the top of the degreasing unit, there are a series

of cooling coils that create a cold blanket that keeps the

vapors in the unit.

Stop the video; review flowchart.

Module 3

Nex

t…



Degreasing: Solvent degreasing, in this case using the chlorinated solvent trichlo-roethylene, is often the first step in the surface finishing process. Here, however, it isbeing used as the final step in order to remove the organic water shedding liquid.This is done in order to provide critical stain free drying. If the parts were removedfrom the final rinse and allowed to dry, there would be many water spots on theparts, which are unacceptable in this application.

The degreaser has a heating coil in the bottom of the unit that heats the solventto boiling. The vapor condenses on the parts, dissolves the oils and greases anddrips off the parts back into the sump. The oils and greases generally have higherboiling points, so they stay in the sump while pure solvent vapor continues to beevolved into the vapor zone. Near the top of the degreasing unit, there are a seriesof cooling coils that create a cold blanket that keeps the vapors in the unit.

Barrel in Degreaser

Module 3

Instructor Notes


6. Preview the second processing line, Copper/Nickel Plating

Over Aluminum, which corresponds to Overhead 13. Discussthe process issues involved:

■ It is axiomatic that often times the final plate that is desired

is possible only after the parts have received one or more“underplates.” In the case of plating over aluminum, it isalmost always necessary to prep the aluminum with a thin

zinc coating followed by a relatively thin copper layer. In thisprocess, the final plate, and the one that provides thedesired function, is nickel.

■ Soak Clean: The pre-processing of aluminum is similar to thealuminum processing discussed above. This solution doesnot use any sodium hydroxide because aluminum dissolves

readily in basic solutions. The solution consists mainly ofborax, which is a good surface cleaner.

■ Caustic Etch: The aluminum oxide layer that forms on

contact with air must be removed prior to furtherprocessing. Etching can be performed with either sodiumhydroxide or a phosphoric acid. The etching process leaves a

dark film, called “smut” on the surface of the aluminum. Thissmut is removed with a strong acid solution in a processcalled de-smut.

■ De-smut: Nitric acid or a tri-acid (a combination of nitric,sulfuric, and hydrofluoric acids) is used to remove thealuminum smut. As with the etch, the bath loads up with

aluminum and becomes less effective, so it must be dumpedwhen a specified concentration of aluminum is reached.

■ Zincate: The zincate solution consists of sodium hydroxide,

sodium cyanide, and zinc metal. When aluminum isimmersed in the solution, zinc exchanges electrons withaluminum, which results in a thin layer of zinc deposited on

the parts.




Module 3




Copper/Nickel Plating Over Aluminum

Sodium Tetraborate Sodium TetraborateDirt

1. Pre-cleanSoak Clean

Sodium Hydroxide NaOH, Al2. Surface PrepCaustic Etch

Water Spent Rinsewater2a. RinseSame as 1a

Sulfuric, Nitric,Hydroflouric Acids H2SO4/HNO3/HF/Al3. Surface Prep

Desmut

Zinc CyanideSodium Hydroxide ZnCn, NaOH4. Conversion Coating

Zincate

Sulfamic AcidNickel Sulfamate


6. PlatingNickel Sulfamate Plate

Potassium Copper CyanideCopper Cynide

Potassium CyanidePotassium Hydroxide

KCuCn, CuCn, KCn, KOH5. PlatingCopper Cyanide Strike

Water Spent Rinsewater1a. Rinse





Module 3

Instructor Notes


■ Copper Cyanide: Copper Cyanide Strike baths are used as

primers to deposit a thin but complete layer of copper over

the surface of a part. The solution consists of potassium

hydroxide, potassium cyanide, and copper cyanide. The bath

has a relatively low copper content, but a high cyanide

content. The high cyanide content assists the bath in

depositing the copper in all areas. Note that if the parts are

not zincated, they will dissolve in the copper bath.

■ Nickel Plate: The nickel plate is deposited from a solution of

nickel sulfamate. This deposits a thick but ductile layer of

nickel that meets the customer’s specifications.

7. Restart the video and show the Copper/Nickel Plating Over

Aluminum section. Give a narration based on the following

information:

■ Pre-clean, Preparation, Soak Clean: Cleaning of aluminum is

fundamentally different from cleaning non-aluminum parts.

Alkaline compounds will dissolve aluminum (etching). In

order to remove soils, oil, and so forth, a borax type of

cleaner is used.

■ Rinsing: The parts are rinsed of the cleaning solution. Rinsing

of basic solutions can be a difficult proposition, due to the

tendency of bases to form a film that is recalcitrant to

rinsing. Often, these rinses are warmed and agitated to assist

the rinsing action.

■ Etching: In this case, an alkaline solution is used to etch the

surface of the parts. Aluminum tends to oxidize very readily

upon exposure to air, so the aggressive etching removes

enough aluminum and oxide to ensure that only nascent

aluminum remains.

Module 3



Etching

Module 3

Pre-clean, Preparation, Soak Clean: Cleaning of aluminum is fundamentallydifferent from cleaning non-aluminum parts. Alkaline compounds will dissolvealuminum (etching). In order to remove soils, oil, and so forth, a borax type ofcleaner is used.

Rinsing: The parts are rinsed of the cleaning solution. Rinsing of basic solutionscan be a difficult proposition, due to the tendency of bases to form a film that isrecalcitrant to rinsing. Often, these rinses are warmed and agitated to assist therinsing action.

Etching: In this case, an alkaline solution is used to etch the surface of the parts.Aluminum tends to oxidize very readily upon exposure to air, so the aggressiveetching removes enough aluminum and oxide to ensure that only nascent alumi-num remains.

Instructor Notes


■ Rinsing:

■ De-smut: The etching process leaves a film of aluminum and

other metal oxides (from alloying constituents that may in

the particular aluminum alloy) that is called “smut.” The smut

is removed in a tri-acid solution of nitric, sulfuric and

hydrofluoric acids.

■ Rinsing: The acid solution is fairly free-rinsing. The solution

contains high amounts of aluminum and aluminum alloy

constituents, so care must be taken regarding metal

treatment.

■ Zincate: It is not possible to plate any metal directly onto

aluminum. In order to do so, a thin “immersion coating” of

zinc is deposited: 2Al + 3Zn+2 => 2Al+3 + 3Zn (This reaction

occurs with no electricity or intermediate chemicals. It is a

direct exchange of electrons between the metals due to

electromotive issues.) The zinc surface is then able to be

plated upon.

Module 3



Rinsing

De-smut: The etching process leaves a film of aluminum and other metal oxides(from alloying constituents that may in the particular aluminum alloy) that iscalled “smut.” The smut is removed in a tri-acid solution of nitric, sulfuric andhydrofluoric acids.

Rinsing: The acid solution is fairly free-rinsing. The solution contains highamounts of aluminum and aluminum alloy constituents, so care must be takenregarding metal treatment.

Zincate: It is not possible to plate any metal directly onto aluminum. In order to doso, a thin “immersion coating” of zinc is deposited: 2Al + 3Zn+2 => 2Al+3 + 3Zn(This reaction occurs with no electricity or intermediate chemicals. It is a directexchange of electrons between the metals due to electromotive issues.) The zincsurface is then able to be plated upon.

Rinse after Etching

Module 3

Instructor Notes


■ Copper Plate: This is a copper cyanide plating solution.

Cyanides are used for several purposes in plating solutions,

and they have proven difficult to replace. In some instances,

however, it is possible to replace the cyanide solutions.

Electricity is used to drive the plating reaction.

The solution consists of dissolved copper cyanide salts,

free cyanide and sodium potassium hydroxide. The

hydroxide keeps the pH of the solution high — if a solution

containing free cyanide becomes acidic, hydrogen cyanide

gas, a deadly poison, will be evolved.

■ Rinsing: The rinsing of cyanide baths is subject to some of

the same problems associated with sodium hydroxide baths.

Also, rinse segregation is particularly important. Cyanide

solutions must be treated in a separate cyanide oxidation

system and must not be mixed with acid! Mixing cyanide

with acid results in gaseous hydrogen cyanide formation,

which is extremely toxic.

■ Nickel Plate: In this case, nickel is deposited from a solution

of nickel sulfamate. This is an electrolytic plating bath.

An interesting aspect of electrolytic nickel plating baths is

that they tend to be very high is metal content. This means

that, per unit volume of drag out, they tend to lose more

metal than other solutions.

■ Rinsing: Nickel rinses tend to be extremely high in metal, due

to the high metal concentration and high solution viscosity.

Therefore, treatment of these rinses is particularly of

concern.

The fact that these rinses are so high in metal content also

makes these solutions attractive from the point of metal

recovery. In fact, many metal recovery systems are in use on

electroplated nickel solutions.

Module 3



Copper Plate: This is a copper cyanide plating solution. Cyanides are used forseveral purposes in plating solutions, and they have proven difficult to replace. Insome instances, however, it is possible to replace the cyanide solutions. Electricity isused to drive the plating reaction.

The solution consists of dissolved copper cyanide salts, free cyanide and sodiumpotassium hydroxide. The hydroxide keeps the pH of the solution high — if asolution containing free cyanide becomes acidic, hydrogen cyanide gas, a deadlypoison, will be evolved.

Rinsing: The rinsing of cyanide baths is subject to some of the same problemsassociated with sodium hydroxide baths. Also, rinse segregation is particularlyimportant. Cyanide solutions must be treated in a separate cyanide oxidationsystem and must not be mixed with acid! Mixing cyanide with acid results ingaseous hydrogen cyanide formation, which is extremely toxic.

Nickel Plate: In this case, nickel is deposited from a solution of nickel sulfamate.This is an electrolytic plating bath.

An interesting aspect of electrolytic nickel plating baths is that they tend to bevery high is metal content. This means that, per unit volume of drag out, they tendto lose more metal than other solutions.

Rinsing: Nickel rinses tend to be extremely high in metal, due to the high metalconcentration and high solution viscosity. Therefore, treatment of these rinses isparticularly of concern.

The fact that these rinses are so high in metal content also makes these solutionsattractive from the point of metal recovery. In fact, many metal recovery systemsare in use on electroplated nickel solutions.

Copper Plate

Module 3

Instructor Notes


Review the following with participants:

Chrome Plating: Chrome Plating tank

■ Chrome Plating has specific regulatory issues:

Hexavalent chromium (Cr +6) is very toxic, and in waste water

treatment it is reduced to Cr +3 to reduce toxicity & allow it to

precipitate as chromium hydroxide Cr (OH)3.

Hexavalent chromium plating baths, unlike other plating

baths, do have air releases of metals.

This is because the high metal content (33 oz/gel Cr03)

results in a very viscous solution.

M+6 + 6e– = M0

If you remember our electroplating diagram, M+6 + 6e - => M0.

The percentage as elections that go to the plating reaction

= efficiency. Most plating baths have high efficiency, but

chrome plating’s efficiency is very low (17–25 %). The rest of

the electrons go to split H20=>H

2^ +1/2 0

2^ (just like electro-

cleaning). The formation of these gases results in much gas

bubble generation. When they rise to the surface, they “pop”

at the surface, and due to the high viscosity/surface tension,

a mist is released.

■ Hex chrome plating baths are strongly ventilated to control

this mist (for industrial hygiene purposes), resulting in one

of the very few plating operations that have air releases of

metals. Since hex chrome is so toxic, this is one at the first

MACT standards promulgated by EPA under the CAAA.

Module 3



Chrome Plating Tank

Module 3

Chrome Plating has specific regulatory issues:Hexavalent chromium (Cr+6) is very toxic, and in waste water treatment it is

reduced to Cr+3 to reduce toxicity & allow it to precipitate as chromium hydroxideCr (OH)

3.

Hexavalent chromium plating baths, unlike other plating baths, do have airreleases of metals. This is because the high metal content (33 oz/gel Cr03) results ina very viscous solution.

M+6 + 6e– = M0

If you remember our electroplating diagram, M+6 + 6e - => M0. The percentage aselections that go to the plating reaction = efficiency. Most plating baths have highefficiency, but chrome plating’s efficiency is very low (17–25 %). The rest of theelectrons go to split H

20=>H

2^ +1/2 0

2^ (just like electro - cleaning). The forma-

tion of these gases results in much gas bubble generation. When they rise to thesurface, they “pop” at the surface, and due to the high viscosity/surface tension, amist is released.

Hex chrome plating bathsHex chrome plating baths are strongly ventilated to control this mist (for industrialhygiene purposes), resulting in one of the very few plating operations that have airreleases of metals. Since hex chrome is so toxic, this is one at the first MACTstandards promulgated by EPA under the CAAA.

Instructor Notes


Start video. There are several methods to control chrome

emissions which will be discussed in the next section. In this

application a mesh pad mist eliminator scrubber is used.

Note that the scrubbed chromic acid is directed back into the

plating tank. Since the bath operates at 150F there is

significant evaporation. Therefore, the scrubber water can be

directed back to plating tank. Note that you must be careful

that the amount of scrubber water not exceed evaporation or

overflow will result.

Cleaning Line/Copper Plating Line Setup

The purpose of this section is to emphasize that proper plating

line setup will reduce dragout, reduce water use and improve

efficiency.

Start video You may remember that there are 3 ways to clean:

direct current, reverse current & periodic reverse. In this case

each tank providesone type of cleaning. In some set-ups, there

is only a single knife switch which the operator controls.

■ Cleaning is followed by hydrochloric acid pickling. Pickling

removes some amount of metals from the surface at the

parts, and metal build-up contaminates the solution. Here, a

diffusion dialysis unit (discussed in the next section)

removes metals on a continuous basis, purifying the

solution.

■ Copper cyanide strike is a ubiquitous process in metal

finishing. Even when the final plate is copper the parts often

receive a “strike”. A strike is a very thin, very uniform layer of

metal deposited on the surface at the parts. It is analogous

to a primer in painting, and provides good adhesion &

electrical characteristics for the next layer.

Module 3



Module 3

Cleaning Line/Copper Plating Line Setup

The purpose of this section is to emphasize that proper plating line setup willreduce dragout, reduce water use and improve efficiency.

■ Cleaning is followed by hydrochloric acid pickling. Pickling removes someamount of metals from the surface at the parts, and metal build-up contami-nates the solution. Here, a diffusion dialysis unit (discussed in the next section)removes metals on a continuous basis, purifying the solution.

■ Copper cyanide strike is a ubiquitous process in metal finishing. Even when thefinal plate is copper the parts often receive a “strike”. A strike is a very thin, veryuniform layer of metal deposited on the surface at the parts. It is analogous to aprimer in painting, and provides good adhesion & electrical characteristics forthe next layer.

These is no need for a rinse between the strike & the full build plating bathbecause the constituents are the same: copper cyanide, potassium cyanide,potassium hydroxide.

Note the excellent modular set up: temperature control, pump controls,amperage controls clearly labeled & accessible. Drip boards are integral betweentanks.

Instructor Notes


These is no need for a rinse between the strike & the full

build plating bath because the constituents are the same:

copper cyanide, potassium cyanide, potassium hydroxide.

Note the excellent modular set up: temperature control,

pump controls, amperage controls clearly labeled &

accessible. Drip boards are integral between tanks.

■ After the copper plating tank, we come to the best part of

the set up. There are two drag out tanks. A dragout tank is a

still rinse (no running water) into which parts are immersed

after plating. The dragout tanks capture solution which is

“dragged out” at the plating tank.

This has two effects:

1. Reduces the amount of water needed to rinse the parts.

2. The dragout can be periodically pumped back into the

plating tank, recovering potentially “lost” solution.

Each tank has a small pump w/ a “dead man” switch, so that

an operator needs to be present during pumping —

otherwise they might overflow the tank (anti- TUR). The first

dragout tank is pumped to the plating tank, the second

dragout tank is pumped to the 1st dragout tank, at than is

refilled w/ city water.

The double counter flow design of the rinse tank reduces

water usage almost 10X! The vast majority of contaminants

are captured in the 1st chamber, while the fresh water is

added to 2nd, allowing the parts to contact the cleanest

water (more on this in the next section).

Module 3



Module 3

Dragout Control

There are two drag out tanks. A dragout tank is a still rinse (no running water) intowhich parts are immersed after plating. The dragout tanks capture solution whichis “dragged out” at the plating tank.

This has two effects:

1. Reduces the amount of water needed to rinse the parts.

2. The dragout can be periodically pumped back into the plating tank, recoveringpotentially “lost” solution.

Each tank has a small pump w/ a “dead man” switch, so that an operator needs tobe present during pumping — otherwise they might overflow the tank (anti- TUR).The first dragout tank is pumped to the plating tank, the second dragout tank ispumped to the 1st dragout tank, at than is refilled w/ city water.

The double counter flow design of the rinse tank reduces water usage almost10X! The vast majority of contaminants are captured in the 1st chamber, while thefresh water is added to 2nd, allowing the parts to contact the cleanest water (moreon this in the next section).

Instructor Notes


8. This ends the video portion of the training: Break participants

into small groups. Ask the participants the following

questions about each of the processes they have just seen:

■ In your opinion, what are the major environmental issues on

this plating line?

■ What are some of the P2 ideas you saw and do you see any

other opportunities for P2?

■ Have small groups report out answers to the above

questions.

????

Module 3

Participant Exercise


Small Group Discussion

Break into small groups and discuss the following questions. Your group will reportout on the highlights of your brief discussions.

Discussion Questions

In your opinion, what are the major environmental issues on this plating line?

What are some of the P2 ideas you saw and do you see any other opportunitiesfor P2?

Module 3

Instructor Notes


1. Display Overhead 14. Explain that Module 4 covers pollution

prevention opportunities, which are covered in the following

sections:

■ Pollution prevention opportunities in solvent degreasing

■ Pollution prevention opportunities in processing

■ Hi-tech methods for pollution prevention

Module 4 Pollution Prevention Opportunities




2. Next, we’ll be moving into small groups for an exercise.

Direct participants to discuss and complete the multiple

choice quiz “Pollution Prevention Exercise for Solvent Cleaning:

Test on Solvent Cleaning Procedures.” Then, reconvene the

large group to discuss the answers.



Pollution Prevention Opportunitiesoverhead 14

In this section we will cover information on P2 techniques and technologies

for plating. These include

■ P2 Opportunities in Solvent Degreasing

■ P2 Opportunities in Processing

■ Hi-Tech methods for P2

Module 4Pollution Prevention Opportunities

Instructor Notes


Scenario for Exercise One

Tell participants: “Now you’ve seen a vapor degreaser. Think

about where the waste is coming from and ways to minimize

waste.”

This is a sample quiz to demonstrate degreaser operator

competency. How much can you figure out?

Module 4




ParticipantHandout



Exercise One

Pollution Prevention Exercise for Solvent Cleaning: Test on Solvent Cleaning Procedures

General Questions

1. What is the maximum allowable speed for parts entry and removal?A. 8.5 meters per minute (28 feet per min)B. 3.4 meters per minute (11 feet per min)C. 11 meters per minute (36 feet per min)D. No limit

2. How do you ensure that parts enter and exit the solvent cleaning machine at the speedrequired in the regulation?A. Program on computerized hoist monitors speed.B. Can judge the speed by looking at itC. Measure the time it takes the parts to travel a measured distance

3. Identify the sources of air disturbancesA. FanB. Open doorsC. Open windowsD. Ventilation ventsE. All of the above

4. What are the three operating modes?A. Idling, working and downtimeB. Precleaning, cleaning, and dryingC. Startup, shutdown, offD. None of the above

5. When can parts or parts baskets be removed from the solvent cleaning machine?A. When they are cleanB. At any timeC. When dripping stopsD. Either A or C is correct

6. How must parts be oriented during cleaning?A. It does not matter as long as they fit in the parts basketB. So that the solvent pools in the cavities where the dirt is concentratedC. So that solvent drains from them freely

7. During startup, what must be turned on first, the primary condenser or the sump heater?A. Primary condenserB. Sump heaterC. Turn both on at same timeD. Either A or B is correct

8. During shutdown, what must be turned off first, the primary condenser or the sump heater?A. Primary condenserB. Sump heaterC. Turn both off at the same timeD. Either A or B is correct

9. In what manner must solvent be added to and removed from the solvent cleaning machineA. With leak proof couplingsB. With the end of the pipe in the solvent sump below the liquid solvent surfaceC. So long as the solvent does not spill, the method does not matterD. A or B

Module 4

Instructor Notes


Module 4

Answers

General Questions

1 B Eleven feet per minute results in minimum vapor disturbance in a vapordegreaser.

2 A&C To ensure that the parts proceed at the proper speed and to minimize dragout, the parts should be on a mechanized system. A person holding theparts could probably not move the parts at 11 feet per second for an eighthour shift.

3 E Anything that moves the air in a plant could disturb the vapors in thedegreaser.

4 A Idling — the degreaser is on but not operating. Working — the degreaser iscleaning parts. Downtime — the machine is shut off.

5 C The parts should be moved after the dripping stops in order to minimizedrag out.

6 C Every part, except spheres, has an orientation that will allow the solvent todrain freely.

7 A The condenser must be turned on first so that vapors are captured imme-diately once the heater is turned on.

8 B The sump heater should be turned off first. If the condenser is turned offfirst, some vapors could escape the system.

9 D To prevent losses, leak proof couplings must be used or the end of the pipemust be below the surface of the liquid, or both.

10 B Waste must be stored in a closed container.

11 D Because all of the materials would absorb the solvents and later releasethem, none should be cleaned in a solvent cleaning machine.

Control Device Specific Questions

1 D Ideally the freeboard refrigeration device must be 30% below the solventboiling point. Often, they are operated even below the 30%.

2 F The cover can be open during entry and removal, maintenance, andcompliance measurements.

3 D Covers must completely seal the opening.

4 A Parts should always dwell in the vapor zone.

After small groups finishe the exercise, display Answer Key on

overhead. Discuss onswers in large group.

Participant Handout


10. What must be done with waste solvent and still sump bottoms?A. Pour down the drainB. Store in a closed containerC. Store in a bucketD. A or B

11. What types of materials are prohibited from being cleaned in solvent cleaning machines using halogenatedHAP solvents?A. SpongesB. FabricsC. PaperD. All of the above

Control Device Specific Questions

Freeboard Refrigeration Device

1. What temperature must the FRD achieveA. Below room temperatureB. 50 degrees FahrenheitC. Below the solvent boiling pointD. 30% below the solvent boiling point

Working Mode Cover

2. When can a cover be open?A. While parts are in the cleaning machineB. During parts entry and removalC. During maintenanceD. During measurements for compliance purposesE. A and CF. B, C, and D

3. Covers must be maintained in what condition?A. Free of holesB. Free of cracksC. So that they completely seal cleaner openingD. All of the above

Dwell

4. Where must the parts be held for the appropriate dwell time?A. In the vapor zoneB. In the freeboard area above the vapor zoneC. Above the cleaning machineD. In the immersion sump

Exercise One (cont’d)

Module 4

Instructor Notes


3. Lecture: Pollution prevention opportunities in solvent

degreasing. (Overhead 15) After the test, proceed to give the

lecture on pollution prevention opportunities in solvent

degreasing:

■ The degreaser must be covered at all possible times. The

best type of cover is a motor controlled top that can be

automatically closed.

■ The tip of the spray wand must be below the vapor level

during spraying operations.

■ Parts must be moved slowly out of the degreaser unit. The

recommended hoist/withdrawal speed is 11 linear feet per

minute.

■ As with aqueous drag out reduction, parts should be racked

so that solvent drains out of the holes, joints, crevices, and so

on.

■ Use as high a freeboard as practical — drafts and winds will

remove a vast amount of vapor from the unit. As a corollary

to this, vapor degreaser units must be located in the most

undisturbed air flow area in the plant.

■ Refrigeration coils in addition to or as replacements for

water chilling coils can help to reduce vapor generation by

as much as 40%, or even more in some cases.




Module 4



P2 Opportunities in Solvent Degreasingoverhead 15

■ Improve degreaser efficiency

— keep degreaser covered

— spray wand tip below vapor level

— remove parts slowly

■ Use highest possible amount of freeboard

■ Use refrigeration coils

Module 4

Instructor Notes


4. The next pollution prevention option is drag out reduction.

Overhead 16 shows causes for drag out loss. Decreases in drag

out can be achieved by varying the contributing factors in

Overhead 17, as we will discuss in the upcoming lecture. While

displaying Overhead 17, discuss the following drag out

reduction concepts.

There are many low-tech, inexpensive, and powerful

techniques to reduce losses from surface finishing operations.

Solution conservation encompasses a wide range of

technologies and techniques that aim to keep processing

solution in the tank, or to remove process chemicals from the

rinse water and return them to the solution. The concepts we

will cover fall into two general categories — drag out

prevention during work piece removal and drag out

prevention during the processing step.

Drag out Prevention During Work piece Removal

■ Drip times: in manual or automatic plating, it is essential to

allow the parts to drain solution for as long as possible. In

manual plating, drip racks can be installed above the tank,

upon which the plater can hang the racks. In automatic

plating, the hoist can be programmed to hang the rack or

barrel above the solution for longer periods of time.

However, when the solution is heated, care must be taken

that the solution does not dry on the parts. Dried solutions

result in hardened crystal deposits that are very difficult to

rinse.







Module 4



Module 4

Reducing Dragoutoverhead 17

During Workpiece Removal

■ Increase drip times

■ Rinse over the plating tank

■ Run rinses back to the plating tank

■ Use dragout tanks

■ Use drip boards

■ Use reactive rinsing

Board Angle

Board Overlap Drainage Time

Dragout TankTemperature

Evaporation Rate Drainage Boards

Rack Design Removal Rate

Concentration Tank Spacing

Parts Orientation Worker Practices

Process BathConditions

Process LineLayout

DragoutLoss

Cause and Effect Diagram for Dragoutoverhead 16

Instructor Notes


■ Rinsing over the plating tank: (Display Overhead 18). Rinsing

the parts directly over the tank will keep the solution in the

plating tank and replenish lost water. This option is viable if

the evaporation rate is high enough and rinsing can be

done without splashing solution onto equipment. This is

often practiced over electroless plating tanks, which don’t

have electrical equipment (such as buss bars or rectifiers).

However, it is possible to do this over other tanks if care is

taken.




Module 4



Rinsing Over Plating Tankoverhead 18

Evaporation

DIWater

DIWater

Step 1: Plating Process Step 3: Immersion Rinse

Plating Tank Rinse Tank

Evaporation

Step 2: Recovery/Spray Rinse Step 4: DI Water Spray


Module 4

Instructor Notes


■ Running rinses back to the plating tank — again: (Overhead

19.) If the evaporation rate is high, the first rinse after the

process tank can be plumbed so that the water runs into the

process tank rather than to the waste treatment system. A

system of level controls can be used to prevent overflows,

which are costly and dangerous, as well as counter-

productive to toxics use reduction.

■ Drag out Tanks: a tank setup between the plating tank and

the first rinse tank can be used to capture drag out from the

plating tank. At regular intervals, the solution from the drag

out tank is added back to the plating tanks as the plating

tank volume is depleted, either through drag out or

evaporation.




Module 4



Common Rinsing Configurationsoverhead 19

Work Flow

Drag Out

PlatingBath

Rinse

FreshWater

To Treatment

Rinse Type: Single OverflowWater Use Rate: HighApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out

PlatingBath

Rinse

To Treatment

Rinse

FreshWater

To Treatment

Rinse Type: Two Stage ParallelWater Use Rate: ModerateApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out Drag Out

PlatingBath

Rinse

To Treatment To Treatment

To Treatment

Rinse

FreshWater

Rinse Type: Two Stage CounterflowWater Use Rate: LowApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out Drag OutDi Water

PlatingBath

Drag OutTank

Rinse

Drag Out

Rinse

FreshWater

Rinse Type: Single Stage Recovert/Two Stage Counterflow RinseWater Use Rate: LowApplications: Most Heated Baths, Especially PlatingRecovery Rate: Low (70–90F), Moderate (90–120F), High (120F+)

Work Flow

Drag Out & Return Drag Out

Di Water

PlatingBath

Drag OutTank

Drag In

Drag InTank

Rinse

Drag Out

Rinse

FreshWater

Rinse Type: Drag In Drag Out Recovery/Two Stage Counterflow RinseWater Use Rate: LowApplications: Most Process Baths, Especially Ambient to Low Temp. Plating SolutionsRecovery Rate: Low (70–90F), Moderate (90–120F), or Higher (120F+)

Module 4

Instructor Notes


■ Drip Boards: (Overhead 20) A drip board is a generally

plastic board that sits between the top lips of the process

tank and the immediately following rinse tank. The drip

board is angled in such a way that any drag out from the

process tank, which drips off the parts during transfer

between tanks, will flow down the board and back into the

plating tank.

Module 4






Drip Boardsoverhead 20

Plating Bath

Type of Drip Board

Drip Board Rating

Rating

Type of Drip Board

Type of Drip Board

Type of Drip Board

Type of Drip Board

Plating Bath

Rinse Tank

DragOut

DragIn

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Part

Module 4

Instructor Notes


■ Reactive Rinsing: (Overhead 21) This is a very powerful

technique that not only uses less water, but saves chemicals

as well. Most cleaning lines use an alkaline cleaner followed

by an acidic pickle. If the water from the acid pickle is fed to

the alkaline rinse, it will neutralize the cleaner on the parts

and prevent alkaline material from being dragged into the

acid pickle. This will prolong the life of the pickle solution.

This will reduce water usage by at least half, and it is

possible to plumb more than two rinses in series. It is

important to be sure that you never have acidic water

feeding into a rinse that contains cyanide solution!

Module 4






Reactive Rinsingoverhead 21

AlkalineCleaner

AlkalineCleaner

Rinse

To Wastewater Treatment Plant

Fresh Water

Fresh WaterTo Wastewater Treatment Plant

NickelPlate

Rinse

AcidPickle

AcidPickle

Rinse

Nickel Plating Line

RinseRinse

Module 4

Instructor Notes


Drag out Prevention During the Processing Step (Overhead 22)

■ Use the lowest concentration of chemicals wherever possible.:

(Overhead 23) Per unit of solution, this will reduce the

amount of material dragged into the rinses. It will also

reduce the viscosity of the solution, allowing it to drain off

the parts more quickly.

■ Operate the baths on the higher end of the temperature range

whenever possible: Viscosity will be reduced and evaporation

will be increased, allowing you more flexibility in designing

rinsing schemes.

■ Remove racks from solutions slowly and smoothly. It has been

shown that parts will tend to keep a thicker film of solution

(drag out) on their surface when removed quickly from a

solution rather than slowly.

Overhead 23. This table shows gallons of dragout per

thousand square feet processed. Note dragout increases by a

factor of four times (4x) when comparing the 53oz/gallon

chromium to the 33oz/gallon chromium solutions. With a less

than 2x increase in chemical concentration there is a 4x

increase in dragout. This is due to viscosity.

Module 4









More on Drag Out Amountsoverhead 23

gal dragout/1,000 sq.ft. processed

Solution Type Flat Contoured

Brass 0.95 3.3

Cadmium 1.00 3.1

*Chromium (33 oz) 1.18 3.0

*Chromium (53 oz) 4.53 11.9

Copper Cyanide 0.91 3.2

Watts Nickel 1.00 3.8

Silver 1.20 3.2

Stannate Tin 0.83 1.6

Acid Zinc 1.30 3.5

Cyanide Zinc 1.20 3.8

* <2x increase in chemical concentration results in 4x increase in dragout.This is due to viscosity.

Module 4

Dragout Preventionoverhead 22

During the Process Step

■ Use lowest possible concentration of chemicals

■ Operate baths at highest possible temperatures

■ Remove racks slowly and smoothly

■ Rack properly

Instructor Notes


■ Rack parts for minimum drag out: (Overhead 24) All shapes

except spheres have at least one configuration at which

drag out is a minimum.

For instance, a well-drained cup shaped part (8.0gal/1,000 ft2)

has a 20x increase in dragout rate versus a well-drained

vertically oriented part (0.4gal/1,000 ft2).

Module 4






Estimation of Drag Outoverhead 24

Nature of Work Drainage Drag-out Rate (gal/1,000 ft2)

■ Vertical

— Well Drained 0.4

— Poorly Drained 2.0

— Very Poorly Drained 4.0

■ Horizontal



■ Cup Shapes



Module 4

Instructor Notes


Note to Instructor: These two sections “Solvent Replacement” and “Pollution

Opportunities in Processing” are covered in much more detail

than the average person needs. Use your discretion in how much

time you spend on these two sections.

5. Solvent Replacement Mini-Lecture (Overhead 25)

Chlorinated Solvent Degreasing Replacements

Due to the many factors associated with chlorinated solvent

degreasing, including the costs of continuing to use them, the

investigation of replacement systems is at an all-time high. In

fact, this is probably the area with the greatest quantity of on-

going research. The cleaning issue is crucial for all industries,

and the metal finishing industry is no exception.

In order to understand what replacements are appropriate,

we must understand what properties a good degreasing

material must have. Through a combination of chemistry and

mechanical factors, we must achieve these properties in non-

chlorinated solvent systems.

We know that vapor degreasing with chlorinated solvents is

the standard practice. What properties do they possess which

are important?

■ Solvency: They are able to dissolve oils, greases, and other

organic fluids. Since they are used hot, they are also able to

melt waxy substances, which are often used as protectants

or markers.

Module 4






Module 4

Solvent Replacementoverhead 25


■ Solvency

■ Solvent Purity

■ Fast Acting

■ Low Surface Tension

■ Inert to Substrate

Instructor Notes


■ Solvent Purity: Because most of the oils, greases, and other

contaminants that are removed from the parts have a

higher boiling point than the solvents used in vapor

degreasing, the vapor above the liquid sump stays relatively

pure. This allows the solvent to be used until it is so

contaminated that it either re-deposits contaminants on the

parts, or needs a higher temperature to achieve good vapor

characteristics.

■ Fast Acting: In most cases, the parts are degreased within a

minute or so.

■ Low Surface Tension: The solvent must be able to penetrate

into all areas of a part’s complex geometry. Tapped holes,

blind holes, high aspect ratio through holes, and seams

must be completely oil free. If not, areas with oil will not be

plated, and also the oil will continually weep from the

complex areas, contaminating processing baths and other

areas of the part.

■ Inert to Substrate: The solvent must not attack or degrade

the substrate.

The EPA, various state agencies, and others have

developed guides to chlorinated solvent replacement.

Contact these groups for more information. One of the best

guides available is the Solvent Alternative Guide (SAGE)

from the EPA. It asks questions based on substrate,

contaminants, and other factors. It then prints out a list of

alternatives with information on processing, mechanical

systems, and other useful data.

Module 4



Module 4

Solvent Replacement


■ Solvency: They are able to dissolve oils, greases, and other organic fluids. Sincethey are used hot, they are also able to melt waxy substances, which are oftenused as protectants or markers.

■ Solvent Purity: Because most of the oils, greases, and other contaminants thatare removed from the parts have a higher boiling point than the solvents usedin vapor degreasing, the vapor above the liquid sump stays relatively pure. Thisallows the solvent to be used until it is so contaminated that it either re-depositscontaminants on the parts, or needs a higher temperature to achieve goodvapor characteristics.

■ Fast Acting: In most cases, the parts are degreased within a minute or so.

■ Low Surface Tension: The solvent must be able to penetrate into all areas of apart’s complex geometry. Tapped holes, blind holes, high aspect ratio throughholes, and seams must be completely oil free. If not, areas with oil will not beplated, and also the oil will continually weep from the complex areas, contami-nating processing baths and other areas of the part.

■ Inert to Substrate: The solvent must not attack or degrade the substrate.The EPA, various state agencies, and others have developed guides to chlori-nated solvent replacement. Contact these groups for more information. One ofthe best guides available is the Solvent Alternative Guide (SAGE) from the EPA.It asks questions based on substrate, contaminants, and other factors. It thenprints out a list of alternatives with information on processing, mechanicalsystems, and other useful data.

Instructor Notes


6. Pollution Prevention Opportunities in Processing(Overhead 26)

The most widely used cleaning replacements are the aqueous

degreasing systems. In order to be effective, they must exhibit

similar properties to the materials that they are replacing. In

order to do so, they rely on the use of both chemical and

physical components.

■ Chemistry

Alkalinity: Most of these solutions use sodium hydroxide.

Sodium hydroxide is important as a saponifying agent that

turns oils to soluble soaps that are removed from the

surface of the parts. Sodium hydroxide also splits esters and

attacks other organic materials.

Wetting Agents: Wetting agents allow the solution to “wet” or

completely cover the surface of the part. Water has a

relatively high surface tension, which makes it a poor

wetting agent, particularly for small holes. These materials

decrease the surface tension and allow the degreasing

solution to enter the complex areas. Linear alkyl sulfates are

often used for this purpose.

Detergents: These materials emulsify the oils and greases

and keep them dispersed in the cleaning solution,

preventing re-deposition.

Metal Attack Inhibitors: Sodium silicates are excellent

inhibitors that keep the alkaline solution from attacking the

substrates. Sodium silicates are also excellent emulsifying

and de-flocculating agents.

Module 4






Module 4

Pollution Prevention Opportunities in Processingoverhead 26

Chemistry

■ Alkalinity

■ Wetting Agents

■ Detergents

■ Metal Attack Inhibitors

Chemistry

■ Alkalinity: Most of these solutions use sodium hydroxide. Sodium hydroxide isimportant as a saponifying agent that turns oils to soluble soaps that areremoved from the surface of the parts. Sodium hydroxide also splits esters andattacks other organic materials.

■ Wetting Agents: Wetting agents allow the solution to “wet” or completelycover the surface of the part. Water has a relatively high surface tension, whichmakes it a poor wetting agent, particularly for small holes. These materialsdecrease the surface tension and allow the degreasing solution to enter thecomplex areas. Linear alkyl sulfates are often used for this purpose.

■ Detergents: These materials emulsify the oils and greases and keep themdispersed in the cleaning solution, preventing re-deposition.

■ Metal Attack Inhibitors: Sodium silicates are excellent inhibitors that keep thealkaline solution from attacking the substrates. Sodium silicates are alsoexcellent emulsifying and de-flocculating agents.

Instructor Notes


■ Physical/Mechanical Issues

Heat: Higher temperatures help to melt oils, greases, waxes,

and render them more amenable to emulsification. They

also help to decrease the viscosity of the solution, allowing it

to better wet the surface of the parts.

Agitation: Agitation is necessary to remove contaminants

from, and to bring fresh cleaning solution to, the surface of

the parts. Mechanical agitation, such as pumping the

solution around the tank or moving the rack or barrel on

which the parts rest, is often employed.

Module 4






Module 4

Physical/Mechanical Issues

■ Heat: Higher temperatures help to melt oils, greases, waxes, and render themmore amenable to emulsification. They also help to decrease the viscosity ofthe solution, allowing it to better wet the surface of the parts.

■ Agitation: Agitation is necessary to remove contaminants from, and to bringfresh cleaning solution to, the surface of the parts. Mechanical agitation, suchas pumping the solution around the tank or moving the rack or barrel onwhich the parts rest, is often employed.



■ Heat

■ Agitation

Instructor Notes


7. Some Pollution Prevention Opportunities (Overhead 28)

■ Ultrasonic Agitation: Another method that is beginning to be

widely used is ultrasonic agitation. Ultrasonic cleaning can

be used to increase the efficiency of virtually any immersion

cleaning process. The ultrasonic cleaning unit is a tank that

has an attached transducer capable of generating ultrasonic

sound waves in the 20,000 Hz range. These waves cause

cavitation, which creates transient bubbles on the surface of

the part. When they collapse, they exert tremendous

pressure (thousands of pounds per square inch, in some

cases) on the part. This helps to remove oils and greases,

from the parts, particularly from hard to reach areas.

Ultrasonics have allowed aqueous and non-chlorinated

degreasing to be practiced in applications where solvents

had been the only effective degreasing tool. This generally is

due to the fact that the ultrasonic agitation greatly increases

the ability of the solution to clean by lowering the apparent

surface tension of the solution.

■ Low Acid De-smut in Aluminum Cleaning: De-smutting of

Aluminum is a process that is being looked at very closely

today, due to the very high rate of acid usage. There are

several of products on the market currently that are able to

de-smut aluminum using approximately 1/10 of the usual

amount of nitric acid. One typical formulation is the use of

ferric nitrate as a desmutting agent in the presence of small

amounts of nitric acid. The rate and desmutting action are

comparable to the 50% nitric acid bath traditionally used.

■ Cyanide-based Processes

Perhaps the single most toxic chemical in the plating shop

on a world wide basis is cyanide. Substitution of this product

will have a profound effect. However, its use as a complexing

Module 4






Module 4

Some Pollution Prevention Opportunitiesoverhead 28

■ Ultrasonic Agitation

■ Low Acid De-smut in Aluminum Cleaning


■ Metal Substitution

Instructor Notes


agent in many different types of plating solutions and

stripping solutions makes it a difficult material to replace.

Also, it is compatible with a wide range of base materials.

Non-cyanide alternatives have proven to be very base-

material specific, and do not lend themselves to easy

substitution. Also, non-cyanide plating solutions are less

forgiving than cyanide based baths, when cleaning is less

than perfect. With these solutions, it is important to identify

the specific applications where these plating systems are

appropriate. There are several types of non-cyanide

solutions for: Silver, Cadmium, Zinc, Gold, Copper, CN based

Strips

It is important in evaluating these alternatives that

companies are aware of toxic chemicals that the processes

may contain. It would not help a company to rid itself of one

listed chemical only to exceed threshold quantities of

another.


In all cases, function is the key when determining the finish

required for a particular part. In some cases, less toxic metals

can be substituted for metals of higher toxicity. For instance,

cadmium metal, which is extremely toxic, is often used for its

superior corrosion resistance. However, a good zinc plate

followed by heavy chromating can perform as well as

cadmium.

In the case of the job shop, there is less opportunity for this

type of substitution. The customer’s design engineers have

specified the finish, and are unlikely to change it based on

the supplier’s opinion. Even if they were willing to change,

the job shop can not possibly interface with every single

customer in this regard.

Module 4



Module 4

Some Pollution Prevention Opportunities

■ Ultrasonic Agitation: Another method that is beginning to be widely used isultrasonic agitation. Ultrasonic cleaning can be used to increase the efficiencyof virtually any immersion cleaning process. The ultrasonic cleaning unit is atank that has an attached transducer capable of generating ultrasonic soundwaves in the 20,000 Hz range. These waves cause cavitation, which createstransient bubbles on the surface of the part. When they collapse, they exerttremendous pressure (thousands of pounds per square inch, in some cases) onthe part. This helps to remove oils and greases, from the parts, particularly fromhard to reach areas.

Ultrasonics have allowed aqueous and non-chlorinated degreasing to bepracticed in applications where solvents had been the only effective degreasingtool. This generally is due to the fact that the ultrasonic agitation greatlyincreases the ability of the solution to clean by lowering the apparent surfacetension of the solution.

■ Low Acid De-smut in Aluminum Cleaning: De-smutting of Aluminum is aprocess that is being looked at very closely today, due to the very high rate ofacid usage. There are several of products on the market currently that are ableto de-smut aluminum using approximately 1/10 of the usual amount of nitricacid. One typical formulation is the use of ferric nitrate as a desmutting agentin the presence of small amounts of nitric acid. The rate and desmutting actionare comparable to the 50% nitric acid bath traditionally used.

■ Cyanide-based Processes: Perhaps the single most toxic chemical in theplating shop on a world wide basis is cyanide. Substitution of this product willhave a profound effect. However, its use as a complexing agent in many differ-ent types of plating solutions and stripping solutions makes it a difficultmaterial to replace. Also, it is compatible with a wide range of base materials.Non-cyanide alternatives have proven to be very base-material specific, and donot lend themselves to easy substitution. Also, non-cyanide plating solutions areless forgiving than cyanide based baths, when cleaning is less than perfect. Withthese solutions, it is important to identify the specific applications where theseplating systems are appropriate. There are several types of non-cyanide solu-tions for: Silver, Cadmium, Zinc, Gold, Copper, CN based Strips

It is important in evaluating these alternatives that companies are aware oftoxic chemicals that the processes may contain. It would not help a company torid itself of one listed chemical only to exceed threshold quantities of another.

■ Metal Substitution: In all cases, function is the key when determining thefinish required for a particular part. In some cases, less toxic metals can besubstituted for metals of higher toxicity. For instance, cadmium metal, which isextremely toxic, is often used for its superior corrosion resistance. However, agood zinc plate followed by heavy chromating can perform as well as cadmium.

In the case of the job shop, there is less opportunity for this type of substi-tution. The customer’s design engineers have specified the finish, and areunlikely to change it based on the supplier’s opinion. Even if they were willingto change, the job shop can not possibly interface with every single customer inthis regard.

Instructor Notes


8. High Tech Methods for Material Recovery (Overhead 29)

■ Acid solution regeneration with diffusion dialysis.

(Overhead 30)

Diffusion dialysis is a process that relies on the ability of a

membrane to selectively allow anions and hydrogen to pass

through, while at the same time rejecting metals. A water

stream is passed counter-current to the spent acid stream,

allowing the anions and hydrogen to diffuse through the

membrane into the water. Thus, you end up with an acid

solution at the approximate strength with which you

started, and a dilute acid waste that contains the metal

component. The acid is then reused, and the waste is treated

or sent off-site for disposal. This process can be used for

desmutting baths, anodizing baths, pickling baths, and any

other process where metal is removed from parts in an

acidic medium.

Module 4









Hi-Tech Methods for Material Recoveryoverhead 29

■ Diffusion Dialysis

■ Evaporation

■ Reverse Osmosis/Electrodialysis

■ Ion Exchange

Diffusion Dialysisoverhead 30

FilterWater Filter PumpAcidWater

Acid Module

Stack

Metal Contaminants

to Treatment or Recovery

Recovered Acid

Recycled to Bath

AcidBath

Module 4

Instructor Notes


■ Evaporation (Overhead 31) can be achieved through two

basic means: heating the solution near or to the boiling

point such that water vapors escape as warm steam. This is

an extremely energy intensive process, due to the high

latent heat of vaporization of water. Evaporation may also be

achieved by subjecting a solution to a vacuum. This process,

often called low temperature distillation or cold

evaporation, lowers the temperature required for water to

boil. This concentrates the process salts and reduces the

solution volume.

■ Reverse Osmosis and Electro-dialysis (Overhead 32) are two

technologies that use selective membranes for solution

conservation.

Reverse Osmosis (RO) is a process in which the solution is

pumped into a membrane system under pressure. The

membrane allows water to pass through, but rejects salts.

The normal osmosis process would allow the water to flow

into the neighboring chamber, through the membrane, only

to the point at which both chambers contained equal

concentration of water. In reverse osmosis, pressure is

applied to the solution so that the water continues to flow

out of the chamber (across the membrane), and the salts

build up in concentration. When the solution has been

concentrated to a small volume, it can be added back to the

process tank. The de-mineralized water may be reused for

rinsing.

Electro-dialysis (ED) is also a membrane based process,

except that it uses electricity rather than pressure as a

means to separate the dissolved ions from the water.

Solution is introduced into a vessel with a cathode at one

end of the cell and an anode at the other. Each cell has two

Module 4









Module 4

Heated Process

Tank

To Waste Treatment 10 gph

City Water4 gph

Ni Plate27 g/l Ni

CarbonFilter

3,000 mg/l Ni 333 mg/l Ni 37 mg/l Ni

Rinse Rinse Rinse

Evaporation4 gph

Drag-out 1 gph Drag-out Drag-out

Reject (concentrate)5 gph (5.9 g/l)

Reverse Osmosis Unit

City Water 5 gph

Permeate95 gph

(32 mg/l Ni)Note: drag-in is assumed to equal drag-out (1 gph)

Feed Stream100 gph

Reverse Osmosis Nickel Recovery Applicationoverhead 32

Vacuum Evaporators for Chemical Recoveryoverhead 31

75° F RecoveryRinse

Condensate Return28 gph

City Water

Process Tank(60 sq.ft. ofsurface area)

RecoveryRinse

OverflowRinse

30 gph

2 gph

To Treatment

Vacuum Evaporator

SolutionPurification

Concentrated Solution (2 ghp) to Process Tank

E <1 gph D.O. = 1 gph

DI Water<1 gph

S

C

Open Rinse System

Instructor Notes


membranes; one is a cation membrane, which allows

positively charged ions to pass through, and the other is an

anion membrane, which allows negatively charged particles

to pass. The solution is introduced between the two

membranes, and electricity is applied. The ions migrate

toward the appropriate electrode, through one membrane

but stopping at the next. When many stacks of these cells

are placed together in series, you end up with alternating

sections of water (called the diluting chamber) and

concentrated solution (in the concentrating chamber).

■ Ion exchange (Overhead 33) Ion-exchange (IX) is a process

used to capture metal ions from rinse solutions. The Ion-

Exchange Resin is made of tiny beads (often di-vinyl

benzene) that are coated with a chemical which can

chemically bond with metals from the solution passing over

it. When the IX resin absorbs the metal, it releases a non-

metallic ion in exchange. When the ion exchange resin

becomes saturated with metal, the metal is removed as a

concentrated solution by adding acid or salt, as appropriate,

to the resin column. When this is done, the resin is

regenerated and can be used again. However, this technique

rarely meets the definition of TURA, because most often the

metals are not in a solution that can be reused. These

systems have often been set up with special electroplating

units called electro-winning units that can then plate the

metal out of these solutions. Unless the solid metal is used

as an anode material in the process, or the recovered

solution can be added back to the process tank, this does

not meet the definition of TUR.

Module 4






Module 4

Heated Chrome

TankRecovery

RinseRecovery

Rinse

Evaporation DI WaterDrag-out/Drag-out Recovery

FeedTank

ProductTank

Water for Dilution

Evaporator(if Required toConcentrate

Processed Bath)

Filte

r

Acid Acid

Catio

n

IX Regeneration

Duplex CationColumns

Regenerant toWaste Treatment

or Off-site Disposal

Catio

n

BathReturn Ion Exchange Feed

Ion Exchangeoverhead 33

Instructor Notes


One problem with these methods is that they all tend to

concentrate not only valuable plating salts, but also

contaminants. These contaminants are both organic and

metallic. Plating baths are rarely dumped because it is possible

to purify them of these organic and metallic contaminants.

Organic contaminants are breakdown products of organic

materials that are intentionally added to the bath, such as

brighteners and grain refiners. Over time, due to electrolysis,

heat, and other factors, these organics break down, and they

must be removed. Periodic filtration of the bath with activated

carbon will absorb organics that would tend to degrade the

finish of the plate.

Metallic contaminants are dragged into the solution from

plating processes (and also from added city water). They are

removed by plating a large surface area cathode (called a

dummy) at a very low voltage, thus removing the offending

metallics without depleting the solution.

Module 4



Module 4

ContaminantsContaminants are both organic and metallic. Plating baths are rarely dumped

because it is possible to purify them of these organic and metallic contaminants.

Organic contaminantsOrganic contaminants are breakdown products of organic materials that are

intentionally added to the bath, such as brighteners and grain refiners. Over time,due to electrolysis, heat, and other factors, these organics break down, and theymust be removed. Periodic filtration of the bath with activated carbon will absorborganics that would tend to degrade the finish of the plate.

Metallic contaminantsMetallic contaminants are dragged into the solution from plating processes (and

also from added city water). They are removed by plating a large surface areacathode (called a dummy) at a very low voltage, thus removing the offendingmetallics without depleting the solution.

Instructor Notes


Module 5 P2 Exercise: Identifying Waste

1. Break the group into small groups of three to four people. If

possible, try to get groups with people from different media

programs.

2. Point out the exercise description and flow chart in the

participant handbook. Explain to the groups that they will have

fifteen minutes to identify the following issues:

■ the outputs from the process on the flow chart (fill in the

appropriate spaces)

■ what regulatory issues may apply (also fill in the

corresponding spaces)

3. Go over the completed flow chart using the overhead

provided (p. 103). Solicit answers from the small groups to fill in

the output and regulatory issues.

4. Next, instruct the groups to develop a complete list of

pollution prevention opportunities for this facility. Each of the

groups should rank its pollution prevention opportunities

from high to low priority.

5. Bring the group back together and ask each group to identify

its top-ranked pollution prevention opportunity. Ask the group

participants why they thought that opportunity was the most

important. If a group’s top-ranked pollution prevention

opportunity was already discussed, then they should move to

their next choice.

????

Participant Handout


Exercise Two

Small Group Exercise: This is a small group exercise designed to give attendees a basicunderstanding of pollution prevention opportunities in the plating industry.

Small-guy Metal Finishing Co., Nickelville, USA is a small job shop in the northeast-ern United States. The shop is located in a residential neighborhood in a POTWdistrict. It has been in business for 25 years and employs 27 people. The owner of theshop inherited the facility from his father. The staff consists of 3 people in manage-ment, 2 accountants, 2 salespeople, 1 environmental staff, 4 rackers, 2 maintenanceguys, 9 platers, and 2 scrubs.

The shop is known mainly for its chrome plating operations. The line consists of acopper-nickel-chrome plate. Much of this work is done for decorative plating onplumbing fixtures. The plating line uses 24,000 gallons of water per day. On an annualbasis, the facility uses:

11,000 pounds of chromic acid

3,000 pounds of copper cyanide

15,000 pounds of hydrochloric acid

3,000 pounds of nickel

2,800 pounds of potassium cyanide

31,200 pounds of sodium hydroxide

12,000 pounds of sulfuric acid

12,000 pounds of trichloroethane

A flow chart for the facility’s plating line has been provided to you. Your task is toidentify on the flow chart:

■ the outputs from the process■ what regulatory issues may apply

Module 5P2 Exercise: Identifying Waste

Instructor Notes


6. A spokesperson for each group should wrap up with a

discussion of why the group chose the P2 opportunities and

what factors influenced their choices on P2 projects. Some

sample considerations are listed below:

■ Worker health and safety

■ Environmental media preference

■ Comparative risk

■ Learning curve issues

Module 5

Participant Handout


Exercise Two (cont’d)

Module 5

Inputs Outputs Regulatory Issues

1. Pre-CleanVapor Degreaser

Trichloroethylene

2. Cleaning Periodic/Reverse Electroclean

NaOH

3. Rinse3. RinseWater



3. Rinse12. Polish, Buff



4. Surface PrepHcl Pickle

HCI

6. Plating CopperCyanide Strike

CuCn, Kcn,NaOH

8. Plating BrightNickel Plate

NiSO4

10. Plating HardChrome Plate

CrO3, H2SO4

Instructor Notes


Module 6 Metal Finishing Resources

There are a wide variety of tools for finding information on

pollution prevention in metal finishing facilities. This section

will provide information on where to find hard-copy

information, web-sites, documents, and a variety of other tools

that can assist either you or a facility. Display Overhead 34.






Metal Finishing Resourcesoverhead 34

■ People■ Hard Copies■ Computer Resources

— Listserves— Websites

Module 6Metal Finishing Resources

Instructor Notes


Module 6

Information Clearinghouses

To find hard-copy, technical information you can contact

several centers located in your area. Review the centers listed

in the manual.



Information Clearinghouses

Technology Transfer Center

Toxics Use Reduction InstituteOne University AvenueLowell, MA 01854(508) 934-3275

Northeast P2 Clearinghouse

Northeast Waste Management Officials Association (NEWMOA)129 Portland Street, Suite 601Boston, MA 02114(617) 367-8558

Waste Reduction Resource Center3825 Barrett Drive, Suite 300PO Box 27687Raleigh, NC 27611-7687(919) 715-6500

EPA’s Pollution Prevention Clearinghouse401 M Street, SW MC 7409Washington, DC 20460(202) 260-1023

Fred FriedmanNEEAT Team Research Librarian(617) 565-3282

Module 6

Instructor Notes


The Internet

The Internet allows users to find a wealth of information

quickly. The following sites include a great deal of information

on pollution prevention specifically for metal finishing as well

as a variety of other services.

Web-sites (Overhead 35)




Module 6



Websites

1. Enviro$en$e: EPA’s pollution prevention web site has developed a specific sitefor metal finishing information. This site is located at http://es.epa.gov

2. National Metal Finishing Resource Center: EPA has also developed a site, inconjunction with a variety of trade associations to provide information onmetal finishing. This site is located at http://www.nmfrc.org

3. P2IRIS: This site has been developed by NIST for the Manufacturing ExtensionPartnership program. It provides detailed technical process information onmetal finishing. In order to access information you must subscribe to the site.This site is located at http://www.p2iris.com

4. Trade Association Sites: Many of the trade associations have developed sites thatcontain a variety of technical and product information. These sites are locatedat:

■ American Electroplaters and Surface Finishers web site —http://www.finishing.com

■ Metal Finishing Suppliers Association web site —http://www.metal-finishing.com

■ Products Finishing web site — http://www.gardner.com

Module 6

Web Sitesoverhead 35

■ National Metal Finishing Resource Center http:/www.nmfrc.org

■ Enviro$en$e http:/es.inel.gov

■ ESF http:/www.finishing.com

■ FSA http:/www.metal-finishing.com

■ products Finishing http:/www.gardner.com

Instructor Notes


List-servers (Overhead 36)

A listserve is an Internet E-mail software package that allows a

group of participants to easily exchange information using

Internet E-mail. Individuals subscribe to the listserve by

sending an E-mail message to the listserve owner. Once on the

listserve, participants begin participating in the dialogue in the

following way. A member of the listserve posts a question to

the list address. That question is then sent out to all listserve

members. Anyone with an answer to the question posts their

response to the list. In this way all participants in the list can

follow the discussion. Listserves differ from discussion groups

and bulletin boards in that each subscriber receives a copy of

all the messages and must decide whether to read, save, delete

or respond them. This provides a means for ensuring a

constant level of participation and speed of response when

compared to other forums.

The list in your manual provides information on existing

pollution prevention and metal finishing focused listserves.

See Overhead 36.




Module 6



Module 6

Information on Existing Pollution Prevention and MetalFinishing Focused Listserves.

NBEN Talk: The Northeast Business/Environmental Network hosts a discussionopen to public and private pollution prevention experts and professionals indifferent industries for technical, policy, or management topics to supportpollution prevention and competitiveness.

Subscribe to NBEN talk by sending an e-mail message to the NBEN on-lineengineer, Michelle Thompson, at: [email protected]

P2 Policy: The P2 Policy listserve is a forum for discussing pollution preventionpolicy. Currently, this is a private, unmoderated, closed listserve with 385pollution prevention professionals subscribed.

To subscribe to P2 Policy send a message containing your name, address,phone number, E-mail address and the name of your organization to:[email protected]

Questions about the service should be addressed to Tyrone L. Foster at theabove E-mail address or call the National Pollution Prevention Roundtable at(202) 466-7272.

P2REG: P2REG is a forum for discussing regulatory issues surrounding pollutionprevention technologies and policies.

To sign up for the P2REG listserve, send an E-mail message containingyour name, E-mail address, mailing address, and phone number to the P2REGlistserve at: [email protected]

List serversoverhead 36

■ P2 Tech-subscribe [email protected]

■ P2 Reg-subscribe [email protected]

■ NBEN Talk-subscribe [email protected]

■ National Metal Finishing Resource Center-subscribe http:/www.nmfrc.org

Instructor Notes


Module 6



P2TECH: is a forum for pollution prevention technical assistance providers who areinterested in sharing information on pollution prevention technologies. Thislistserve currently has 371 subscribers.

To sign up for P2TECH send an E-mail message containing your name, amessage noting that you would like to subscribe to the P2TECH listserve, yourE-mail address, your mailing address, and your phone number to:[email protected]

This listserve also archives messages from this forum.

P2 Trainer: The National Pollution Prevention Roundtable, European Roundtableon Cleaner Technologies and Products, and the National Education andTraining Association have started this on-line pollution prevention discussionservice. The P2TRAINER listserve is designed to encourage the exchange ofinformation about up-to-date pollution prevention educational programs andtraining opportunities. The intention of P2TRAINER is to encourage listing ofeducational, and training curricula, and upcoming seminars, workshops, andmeetings. Currently, there are 150 subscribers to this listserve.

To subscribe to P2TRAINER, send a message with the word P2TRAINERcontaining your name, address, phone number, E-mail address and the name ofyour organization to: [email protected]

Questions about the service should be addressed to Tyrone L. Foster at theabove E-mail address or call the National Pollution Prevention Roundtable at(202) 466-7272.

Metal Finishing Listserve: The National Metal Finishing Resource Center has createda listserve for metal finishing specific questions. The listserve is open to anyinterested party. For subscription information on the listserve go to theNMFRC web-site.

Information on Listserves (cont’d)

Module 6

Instructor Notes


Trade Associations

Trade associations are also useful resources. In your manual

you’ll find a list of the national trade associations. Some of the

associations may also have local chapters.

Module 6



Module 6

Trade AssociationsTrade associations are also useful resources. The following provides a list of the

national trade associations. Some of the associations may also have local chapters.

The American Electroplaters and Surface Finishers Society, Inc. (AESF)12644 Research ParkwayOrlando, FL 32826-3298(407) 281-6441

National Association of Metal Finishers (NAMF)401 N. Michigan AvenueChicago, IL 60611-4267(312) 644-6610 ext. 3479

Metal Finishers Suppliers Association801 N. Cass Avenue, Suite 300Westmont, IL 60559(708) 887-0957

Instructor Notes


1,2

1

2

Module 7 Exercise: Incorporating P2 into Facilities

1. For this exercise the instructor should divide the group into

two smaller groups. One of the groups is directed to develop a

Notice of Noncompliance (NON); the other group should

prepare a facility debriefing that incorporates P2 in each of the

items.

2. Group 1: P2 in Notices of Noncompliance

Based on this information, the first group should:

■ Develop a NON that incorporates P2 for each of these items.

Be prepared to discuss with the group the rationale behind

your recommendations.

■ Explain what environmental benefits the company should

expect

■ Determine if any way of the P2 activities could change or

add to the companies regulatory requirements.

3. Group 2: P2 in Facility Debriefings

Based on this information:

■ Develop a facility debriefing that incorporates P2 for each of

these items. Be prepared to discuss with the group the

rationale behind your recommendations.

■ Explain what environmental benefits the company should

expect

■ Determine if any way of the P2 activities could change or

add to the companies regulatory requirements.



Exercise Three

Our friends at Small-Guy Metal Finishing Co. have just been visited for a routine/random inspection. The inspection turned up the following items:

■ The inspector discovers that the company has not sent in any notification toEPA for its chlorinated solvent degreasing unit (required by CAAA). Afterreviewing manifest data, the inspector noticed that chlorinated solvent usagehas increased over each of the past of three years. Upon speaking with theenvironmental compliance manager, the inspector has also found out thatproduction volumes have remained relatively constant.

■ The inspector discovers that the company has wastewater violations for chro-mium, nickel and pH. The inspector asks the plant manager several questionsabout these excesses. He asks the plant manager if the source of the chromiumis the chromium plating tank. The plant manager says he is not sure if it iscoming from the chromium plating tank or the chromium stripping tank. Theinspector then examines the plating line to observe worker practices along theline. While there, the inspector sees an employee walk over and dump 50pounds of nickel salts into the plating tank. Finally, the inspector speaks withthe waste treatment operator about pH levels. The WT operator explains thatpH problems are a result of needing to dump acid cleaning baths frequently.

■ The inspector notices that there are several drums of chromic acid waste in thehazardous waste storage area that are past the 90 day limit. The plant managersays that he cannot afford to get rid of it with disposal costs at $1,000 per drum.Furthermore, he states that his waste treatment system cannot treat it.

■ After reviewing calculations used for TURA reporting, the inspector finds thatthe chemist has been reporting only the parent metal total for Chromic acid(CrO3) and nickel sulfate (NiSO4). When the numbers are calculated includingthe anions, the usage of chromium and nickel compounds are above the 10,000pound reporting threshold.

Module 7Exercise: Incorporating P2 into Facilities

Instructor Notes


Exercise Three Answer Key

1. There are several issues here:

a. The company is out of compliance with the Chlorinated

Solvent Degreasing MACT Standard. They need to notify

EPA according the requirements of the regulations, and

they need to perform the degreaser modifications

suggested and/or mandated in the Standard:

■ Automated Parts Handling

■ Chillers

■ Hoist speeds equal to or less than 11 ft/min

■ Automated Covers

■ others (See MACT Standard)

b. Another question for the groups to ponder is why the

chemical usage has increased if the production volumes

have remained relatively constant. Some possibilities:

■ Parts are more complex, increasing dragout

■ Employee turnover has resulted in poorly trained

employees operating the degreaser

■ Training programs have not been implement/continued

■ Poor Supervision

■ Others

2. There are multiple issues to be dealt with here:

a. The facility needs to determine the source of the

chromium — it is possible that the chrome stripping tank

has a very high concentration and needs to be changed.

Also, the wastetreatment department may need to be

audited to be sure that their processes are appropriate.

Some other ideas: the tanks may be leaking, or the

stripping is being done in batches (lots of parts in a short

time frame), causing large volumes of solution to enter the

treatment system, overloading the capacity.

Module 7



Group 1: P2 in Notices of Noncompliance

Based on this information, the first group should:■ Develop a NON that incorporates P2 for each of these items. Be prepared to

discuss with the group the rationale behind your recommendations.■ Explain what environmental benefits the company should expect■ Determine if any way of the P2 activities could change or add to the compa-

nies regulatory requirements.

Module 7

Instructor Notes


b. While not necessarily a problem, 50 pounds at once is

quite a bit. Are adds being made based on testing and

calculations, or “intuition?” If the tank is high in nickel

concentration, resulting dragout will be more

concentrated, possibly overloading the treatment system.

c. Metal precipitate within a fairly narrow pH range (7-10).

Swings in pH will cause metals to redissolve, and they

won’t settle out as precipitate. Instead, they are

discharged to the sewer and can cause the shop to be out

of compliance. The acid cleaning baths should be

collected in a collection tanks and slowly metered into

the system, preventing overloading of the pH adjustment

system.

As a P2 thought, acid life extension with diffusion

dialysis or acid sorption would reduce the number of

bath dumps required, reducing this problem.

3. The answer here is simple: Too Bad. This is an appropriate time

for regulators to be regulators.

4. This company needs help with Toxics Release Inventory and (in

MA) Toxics Use Reduction Act reporting. They are not

sophisticated in chemical calculations and reporting. The

good news is that this provides an incentive for them to find

P2 methods to reduce chemical usage - and Supplemental

Environmental Project would be to spend a certain amount of

money specifically on these two metals/processes to find P2

solutions. Dragout reduction will be key!

Module 7



Group 2: P2 in Facility Debriefings

Based on this information:■ Develop a facility debriefing that incorporates P2 for each of these items. Be

prepared to discuss with the group the rationale behind your recommenda-tions.

■ Explain what environmental benefits the company should expect■ Determine if any way of the P2 activities could change or add to the compa-

nies regulatory requirements.

Module 7

Instructor Notes








ParticipantHandout

+ ∆

Module 8 Review/Closing

Large Group Exercise: The trainer will use a plus/delta

evaluation to solicit feedback on the training. In a plus/delta

evaluation, the trainer writes a plus sign at the top of one

flipchart and a delta at the top of a second. The plus (+)

represents what worked in the training and the delta (∆)

represents what could be improved. The trainer quickly

reviews the agenda for the training and then solicits remarks

to put on the plus page and on the delta page. Answers should

be recorded in the appropriate column and useful feedback

should be incorporated into the next course offering.

Evaluation: A paper evaluation form should also be provided so that

participants can note feedback specifically and confidentially.

Give participants time at the end of the course to fill in the

forms and collect them as they depart the classroom.

Participant Handout


Electroplating and Surface Finishing Sector Training

Evaluation Form

Please complete both pages of this brief evaluation. Results will be used to improve this program. The goals ofthis process sector training are to provide an industry specific overview (including history, processes andpollution prevention opportunities); and to develop familiarity with and understanding of the operations of atypical shop. Please rate the following elements of today’s workshop, both in terms of their usefulness inreaching the instructional goal and their overall quality. Please provide written comments in the space pro-vided to explain your rating or to offer suggestions for improvement.

1. Introduction/Expectations

Comments:

2. Straight Talk on Metal Finishing Industry

Comments:

3. Video: A Facility Walk Through

Comments:

4. Pollution Prevention Opportunities

Comments:

5. P2 Exercise: Identifying Waste

Comments:

6. Metal Finishing Resources

Comments:

Usefulness: 1 2 3 4 5Quality: 1 2 3 4 5

not useful OK very usefulpoor OK excellent






Review/Closing

Instructor Notes


Module 8

Participant Handout


7. Exercise: Incorporating P2 into Facilities

Comments:

8. Assess the amount of time/detail devoted to each:

Introduction/ExpectationsStraight Talk on Metal FinishingVideo: A Facility Walk ThroughPollution Prevention OpportunitiesP2 Exercise: Identifying WasteMetal Finishing ResourcesExercise: Incorporating P2 into Facilities

Comments:

9. What was the most significant thing that you learned in today’s training?

10. In what way(s) do you expect to apply what you have learned today in your work?

11. What specific types of training would you like to see offered in the future?

12. Additional comments and suggestions for future training:



too little about right too much

This curriculum document has been developed by staff at the Toxics UseReduction Institute (TURI) at the University of Massachusetts at Lowell.The principal curriculum and instructional designer is Jody Hensley, M.Ed.,Senior Education and Training Associate at TURI. Principal documenteditor is Anne Berlin Blackman, J.D, M.A, Education and Training Associateat TURI.

All rights to this curriculum belong to the Toxics Use Reduction Institute(TURI), the Massachusetts Department of Environmental Protection (MADEP) and the United States Environmental Protection Agency (U.S. EPA).The material may be duplicated or used with permission. A request forpermission to duplicate and use portions of the curriculum may be made atthe TURI website: http://www.turi.org.

The views expressed within this curriculum document do not necessarilyrepresent the stated policies of the above agencies nor does citing of tradenames or commercial processes constitute endorsement.

The Toxics Use Reduction Institute is a multi-disciplinary research,education and policy center established by the Massachusetts Toxics UseReduction Act of 1989. The Institute sponsors and conducts research,organizes education and training programs, and provides technical supportto governments to promote the reduction in the use of toxic chemicals inindustry and commerce. Further information can be obtained by writingthe Toxics Use Reduction Institute, University of Massachusetts Lowell,One University Avenue, Lowell Massachusetts 01854, ore-mail www.turi.org.

© Copyright 1999 by the Toxics Use Reduction Institute, University ofMassachusetts Lowell; the Massachusetts Department of EnvironmentalProtection; and the United States Environmental Protection Agency.

DEP




Garment Cleaning Training*Industrial Process/Sector:



InformationAccess






natural resources.

*


Table of Contents and List of Overheads

Module 1: Introduction and Warm-Up Exercise ............................................................................................................. 10Module 2: Overview of the Dry Cleaning Industry ......................................................................................................... 12

Section 1: Definition and Function of Dry Cleaning; Profile of US and State Dry Cleaning Indus-tries ................................................................................................................................................................................ 12Dry Cleaning Definition .............................................................................................................................................. 13Dry Cleaning Industry Profile ..................................................................................................................................... 15Breakdown of Dry Cleaning Shop Expenses .............................................................................................................. 17Section 2: Overview of Dry Cleaning Process, Solvents, Machinery, and Control Technology .................................... 18Garment Cleaning Process Flow Chart ...................................................................................................................... 19Solvents Used [1993 U.S. Data] ................................................................................................................................... 19Perchloroethylene ........................................................................................................................................................ 21Types of Dry Cleaning Machines: Dry-to-dry vs. Transfer Machines ...................................................................... 23Process Flow of Typical Dry Cleaning System ........................................................................................................... 25Vapor Control: Carbon Adsorption ............................................................................................................................ 27Vapor Control: Refrigerated Condenser ..................................................................................................................... 29Water/PCE Separator ................................................................................................................................................... 31Distillation System ....................................................................................................................................................... 33Cartridge Filter (exploded view) ................................................................................................................................. 35Spin Disc Filter ............................................................................................................................................................. 37Powder Filter ................................................................................................................................................................ 39Section 3: Overview of Emissions .................................................................................................................................. 40Process Flow of Typical Dry Cleaning System ........................................................................................................... 41PCE Emissions from Dry Cleaning Shops ................................................................................................................. 45

Module 3: Risks Associated with Perchloroethylene Exposure ....................................................................................... 46Acute Exposure ............................................................................................................................................................. 47Chronic Exposure ........................................................................................................................................................ 47Environmental Effects Associated with Exposure to PCE......................................................................................... 49Pathways of Exposure to PCE ..................................................................................................................................... 51Pathways of Exposure to PCE ..................................................................................................................................... 51

Module 4: P2 Opportunities .............................................................................................................................................. 52Six Ways to Accomplish Pollution Prevention ........................................................................................................... 53Product Reformulation ................................................................................................................................................ 55Production Unit Redesign/Modification .................................................................................................................... 55Production Unit Modernization ................................................................................................................................. 57Improved Operation and Maintenance ...................................................................................................................... 59Input Substitution ........................................................................................................................................................ 61Alternative Garment Cleaning Technologies ............................................................................................................. 61Ultrasonic Cleaning ..................................................................................................................................................... 63Garment Care Test Equipment ................................................................................................................................... 63Ozonation ..................................................................................................................................................................... 65Liquid CO

2........................................................................................................................................................................................................................................................................................... 67

Wet Cleaning ................................................................................................................................................................ 69Process Flow Diagram for Wet Cleaning .................................................................................................................... 69Multi-Process Wet Cleaning ........................................................................................................................................ 71Machine Wet Cleaning ................................................................................................................................................. 71Diagram of a Wet Cleaning Machine ......................................................................................................................... 73Potential Barriers to Wet Cleaning ............................................................................................................................. 75Why Do Garment Cleaners Choose Wet Cleaning? .................................................................................................. 79Cost Comparison of Dry Cleaning and Multiprocess Wet Cleaning ....................................................................... 81

Module 5: Set up for Site Visit/Interactive Exercise ......................................................................................................... 82Module 6: Site Visit to Dry Cleaning Shop ....................................................................................................................... 84Module 7: Wrap-Up and Evaluation of the Training Module ......................................................................................... 86

Table of Contents

Module 1: Introduction and Warm-Up Exercise ..................................................................................... 11

Module 2: Overview of the Dry Cleaning Industry ................................................................................. 13

Module 3: Risks Associated with Perchloroethylene Exposure ............................................................... 47

Module 4: P2 Opportunities ..................................................................................................................... 53

Module 5: Set up for Site Visit/Interactive Exercise ................................................................................. 82

Module 6: Site Visit to Dry Cleaning Shop .............................................................................................. 84

Module 7: Wrap-Up and Evaluation of the Training Module ................................................................ 86

Instructor Notes

4 Instructor Notes Garment Cleaning Training

OVERHEAD (no.)





Icon legend

PAUSE Video

Start Video


STOP Video


EXERCISE

Nex

t…

Transition to NEW TOPIC orCONCEPT

Trainer needs to











FLIPCHART





ParticipantExercise




ParticipantHandout

HANDOUT or EXERCISE



Garment Cleaning Training 5

DRAFT VERSION:

NOT OFFICIAL COPY


Instructor Pre-Workshop Checklist

■ You will need two overhead projectors during certain sections of this training.This will alleviate switching back and forth between overheads on a singleprojector.

■ Prepare handouts, including the warm-up exercise (Dry Cleaning Fun Facts).Prepare flip charts beforehand as necessary.

■ Optional: Research the number and type of dry cleaning shops in your state. Findout where wet cleaning shops are located in your state.

■ Because 92% of the dry cleaning shops in the United States useperchloroethylene as a cleaning solvent, this training module does not addresspetroleum-based cleaning processes.

■ Arrange a site visit in which participants will visit a garment cleaning shop. Meetwith the proprietor and tour the shop beforehand. Be prepared for theproprietor to request some type of enforcement forbearance letter from youragency stating that the site visit is not intended to be a group inspection of thefacility.

■ Obtain a copy of the Wet Cleaning video, to be shown in Module 4, produced bythe Center for Neighborhood Technology in Chicago (773-278-4800).

Instructional Goals

1. Participants will be able to identify and describe innovative environmentaltechnology options available to garment cleaning facilities.

2. Participants will be able to identify opportunities for facilities to implementinnovative garment cleaning technologies.

3. Ideally, participants will be more inclined to work innovative garment cleaningtechnologies into their interactions with facility personnel (i.e., duringpermitting review, compliance inspections, and enforcement actions).


1. Participants are regulatory personnel (federal, state, or local) involved inpermitting, compliance inspections, and/or enforcement.

2. Participants have the capability to understand technical presentations andparticipate in group exercises or discussions.

3. Participants have introductory knowledge of pollution prevention and toxicsuse reduction concepts and are interested in more technical training.

4. Most participants will not have systematically applied pollution preventionprinciples in their jobs.

5. Participants will likely have expertise in one environmental medium, but theymay not have dealt with facilities on a multi-media, sector-oriented basis.

6. Participants may or may not be accustomed to discussing innovativeenvironmental technologies with facilities they encounter in their jobs.



Instructional Goals

1. Participants will be able to identify and describe innovative environmentaltechnology options available to garment cleaning facilities.

2. Participants will be able to identify opportunities for facilities to implementinnovative garment cleaning technologies.

3. Ideally, participants will be more inclined to work innovative garment cleaningtechnologies into their interactions with facility personnel (i.e., during permit-ting review, compliance inspections, and enforcement actions).

Garment Cleaning Training

Instructor Notes


Agenda

Module Format Approximate Time

1 Introduction/Warm-Up Exercise 15–20 minutes

2 Overview of the Dry Cleaning Industry 60 minutes

3 Risks Associated with Perchloroethylene 15 minutesExposure

4 P2 Opportunities in Garment Cleaning 75 minutes

5 Set Up for Site Visit 15–30 minutes

6 Site Visit to Dry Cleaning Shop 75–90 minutes

7 Wrap-Up and Evaluation 15 minutes

Total 5 hours

Performance Objectives

1. Participants will be able to ask specific and clarifying questions during aninspection, permit review, or enforcement action. These questions will identifyopportunities for a garment cleaning facility to implement innovativeenvironmental technologies.

2. Ideally, participants will increase the frequency with which they bring innovativegarment cleaning options to the attention of facilities.

Participant Notes


Agenda

Module Format

1 Introduction/Warm-Up Exercise

2 Overview of the Dry Cleaning Industry

3 Risks Associated with Perchloroethylene Exposure

4 P2 Opportunities in Garment Cleaning

5 Set Up for Site Visit

6 Site Visit to Dry Cleaning Shop

7 Wrap-Up and Evaluation

Instructor Notes


Module 1 Introduction and Warm-Up Exercise

1. Introduction: Begin by introducing yourself. Then discuss the

purpose of this training by reviewing the Instructional Goals,

Performance Objectives, and the Agenda.

2. Ask the participants to introduce themselves and give their

expectations for the course.

3. Warm-Up Exercise

Distribute Exercise #1 called “Dry Cleaning Fun Facts.” This is a

quiz for participants to fill out.

Display Overhead 1 below, which shows the answer key, after

participants have completed the quiz.

Answers to Dry Cleaning Fun Facts Quiz

Column A Column B

L 2 A. Number of shops in the US that offer wet cleaning services (EPA estimate).

K 16 B. Average cost of opening a dry cleaning shop.

C 25C. Desired OSHA PEL for concentration of PCE in ambient air in dry cleaning shops

(in parts per million).

I 27D. Existing OSHA PEL for concentration of PCE in ambient air in dry cleaning shops


A 81E. Approximate number of years ago that humans were using clay soils to remove

stains from garments ( dry clean).

D 100F. Est. number of cancer cases per 1 million consumers exposed to one freshly dry-

cleaned outfit every week for 40 years.

F 150 G. Estimated number of shops in Germany that offer wet cleaning services.

G 600 H. Year in which the first recorded dry cleaning shop opened.

H 1845 I. Percent of dry cleaning shop whose revenues are <$28,000.

E 3600 J. Number of commercial dry cleaning shops in the US.

J 31,000K. Factor by which PCE levels in Cape Cod drinking water samples exceeded EPA’s

Maximum Contaminant Level standard.

B 113,000 L. Garment cleaning shops in Massachusetts that wet clean 100% (1996 data).




ParticipantExercise





Participant Exercise Module 1

Instructions: Match each number in Column A with the correct description in Column B.

KEY

PCE = Perchloroethylene

PEL = Permissible Exposure Limit

MCL = Maximum Contaminant Level

Column A Column B

2 A. Number of shops in the US that offer wet cleaning services (EPA estimate).

16 B. Average cost of opening a dry cleaning shop.

25C. Desired OSHA PEL for concentration of PCE in ambient air in dry cleaning shops


27D. Existing OSHA PEL for concentration of PCE in ambient air in dry cleaning shops


81E. Approximate number of years ago that humans were using clay soils to remove

stains from garments (i.e., dry clean).

100F. Estimated number of cancer cases per 1 million consumers exposed to one

freshly dry-cleaned outfit every week for forty years.

150 G. Estimated number of shops in Germany that offer wet cleaning services.

600 H. Year in which the first recorded dry cleaning shop opened.

1845 I. Percent of dry cleaning shop whose revenues are <$28,000.

3600 J. Number of commercial dry cleaning shops in the US.

31,000K. Factor by which PCE levels in Cape Cod drinking water samples exceeded EPA’s

Maximum Contaminant Level standard.

113,000 L. Garment cleaning shops in Massachusetts that wet clean 100% (1996 data).

Dry Cleaning Fun Facts

1Introduction/Warm-Up Exercise

Instructor Notes


Module 2 Overview of the Dry Cleaning Industry

Section 1 Definition and Function of Dry Cleaning; Profile of US andState Dry Cleaning Industries

1. Display Overhead 2. This definition of dry cleaning comes from

the Code of Massachusetts Regulations. (Feel free to substitute

another state’s definition, where appropriate.) The important

points to get across here are:

■ The process does not use water.

■ Excess solvent is extracted.

■ Machinery is used.

2. Ask participants why people bring clothes to a dry cleaner.

Write responses on a Flipchart. Make sure the following

responses are mentioned:

■ convenience

■ garment finishing/appearance

■ stain removal

■ clothing requires expertise to clean

■ prevent shrinkage

■ garment labels say “dry clean only”

3. Ask participants why people might not bring clothes to a dry

cleaner. Write responses on a Flipchart. Make sure the

following responses are mentioned:

■ inconvenience

■ cost

■ odor of perchloroethylene

■ dissatisfaction with professional cleaning services

■ desire to minimize chemical exposure

■ fear of garment damage or loss




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Module 2



Dry Cleaning DefinitionOverhead 2

“The cleaning of fabrics in an essentially nonaqueous solvent, by means of:

■ one or more washes in solvent,

■ extraction of excess solvent by spinning,

■ and drying by tumbling in an airstream.”

(310 Code of MA Regs. § 7.01)

Module 2Overview of the Dry Cleaning Industry

Instructor Notes


4. Optional: Ask participants how important they think the

environmental impact of a garment cleaning process is to the

average consumer.

■ An industry survey, conducted by the International Fabricare

Institute in 1993, indicates that consumers are willing to pay

up to 30% more for a process with fewer environmental

impacts, but only if cleaning performance is comparable.

5. Display Overhead 3 which gives a profile of the dry cleaning

industry. On this overhead, the trainer may want to include the

most recent census data for the dry cleaning industry (such as

revenues, number of employees, etc.) in the appropriate state.

In reference to the last point on Overhead 3, ask the

participants why the dry cleaning industry’s growth is

predicted to be zero or negative. Make sure the following are

mentioned:

■ intense competition,

■ high barriers to entry,

■ increased number of casual days in the workplaces, and

■ preference for natural fabrics that do not need dry cleaning.




Module 2

Customize



Module 2

Dry Cleaning Industry Profileoverhead 3

■ SIC: 7216

■ highly competitive

■ dominated by small, family-owned businesses

■ 28% of U.S. shops have annual revenues of less than $28,000 (1991 data)

■ Massachusetts shops (1992 data):

— 4,189 employees

— $137 million in revenues

■ zero or negative growth predicted for industry

Notes

An industry survey, conducted by the International Fabricare Institute in 1993,indicates that consumers are willing to pay up to 30% more for a process with fewerenvironmental impacts, but only if cleaning performance is comparable.

Instructor Notes


6. Overhead 4 illustrates the breakdown of a typical shop’s

expenses. In this industry, not a lot of money is available for

technological innovation or even for environmental

compliance. However, the point of encouraging pollution

prevention is not to put garment cleaners out of business, but

to make operations safer.




Module 2



Module 2

Breakdown of Dry Cleaning Shop Expensesoverhead 4

Cost Category, % of Total Annual Expenses

Labor 40–50

Rent and Real Estate Taxes 11–13.5

Utilities 9.5–11.5

Supplies 9.25–11.25

New Equipment 7–9

Compliance w/Gov’t Regs 2.25–4.25Labor40–50%

Rent and Real Estate Taxes11–13.5%

Utilities9.5–11.5%

Supplies9.25–11.25%

New Equipment7–9%

Compliance w/Gov’t Regs2.25–4.25%

Notes

■ individual wages are low■ the cost of electricity depends on the type of machinery and vapor control

technology used■ supplies include solvent, detergents, spotting chemicals, hangers, plastic bags

Neighborhood Cleaners’ Association,Annual Survey Of Member Cleaners’ Expenses (1995)

Instructor Notes


2. Another aspect of the dry cleaning industry is the solvents that

are used in the dry cleaning process.

■ Display Overhead 6 and point out that most shops in the US

use perchloroethylene (92%).

■ Optional: You may want to present the percentage of shops in

your state that use PCE, so that participants will have an idea of

what to expect when they inspect or permit a dry cleaning

shop.

Section 2 Overview of Dry Cleaning Process, Solvents, Machinery,and Control Technology

Although this process involves fewer steps than other

industrial processes we often look at, pollution prevention

opportunities still exist. The dry cleaning process is more labor-

intensive and involves fewer pieces of equipment than many

processes that regulators typically see.

1. Show the Garment Cleaning Process Flow Chart on Overhead

5. There are perchloroethylene (PCE) emissions and potential

human exposures associated with every step in this process

except the first (receiving and sorting clothes). “Offgassing,”

where solvents are emitted from freshly dry-cleaned clothes,

can occur for several days after a customer brings them home.

Module 2









Module 2

Garment Cleaning Process Flow Chartoverhead 5

Receive & sort clothes

Pretreat clothes

Clean clothes

Dry clothes

Press clothes

Assemble clothes

Notes

There are perchloroethylene (PCE) emissions and potential human exposuresassociated with every step in this process except the first (receiving and sortingclothes). “Offgassing,” where solvents are emitted from freshly dry-cleaned clothes,can occur for several days after a customer brings them home.


Pretreat clothes

Clean clothes

Dry clothes

Press clothes

Assemble clothes

Solvents Used [1993 U.S. Data]overhead 6

Perchloroethylene (PCE, perc) 92%

Petroleum Solvents 6%

CFC’s/HCFC’s/Trichloroethane <2%

Perchloroethylene (PCE, perc)92%

Petroleum Solvents6%

CFC’s/HCFC’s/Trichloroethane<2%

Instructor Notes


■ Display Overhead 7 and ask why so many shops use PCE

rather than traditional petroleum solvents. Possible

responses to this question include:

a. High flammability. In general, petroleum solvents are

highly flammable. In the 1930’s and 1940’s, before PCE

was developed as a dry cleaning solvent, dry cleaning

shops were restricted to the outskirts of towns to

protect public safety. With the advent of PCE, dry

cleaning shops began to move into residential areas,

thereby introducing new public health risks.

b. Other potential solvents are prohibited. The production

of CFCs, HCFCs, and TCA has been banned under federal

air regulations (the 1990 Clean Air Act Amendments and

the Montreal Protocol). Consequently, the use of these

chemicals as dry cleaning solvents is being phased out.

■ Note that other industrial uses of PCE include vapor

degreasing and the manufacture of other chemicals.

However, dry cleaning represents the largest single use of

PCE in the US.

Module 2






Module 2

Notes

Other industrial uses of PCE include vapor degreasing and the manufacture ofother chemicals. However, dry cleaning represents the largest single use of PCE inthe US.

Perchloroethyleneoverhead 7

Cl Cl

C = C

Cl Cl

Characteristics:

■ sweet, chloroform-like odor

■ nonflammable under normal conditions

■ low boiling point

■ easily dissolves oils and greases

■ denser than water (sinks)

Instructor Notes


Module 2

3. Display Overhead 8 which shows two of the more common

types of dry cleaning machines. Deliver the following

information:

■ There are two basic types of dry cleaning machines —

transfer and dry-to-dry. Dry-to-dry machines get their name

from the fact that clothes go in dry and come out dry from

the same machine. Transfer machines require that garments

be transferred from washer to dryer.

■ In 1993, 34 percent of dry cleaning machines in the United

States were transfer machines and 66 percent were dry-to-

dry.

■ A comparison of the “solvent mileage” of the two types of

machines reveals that transfer machines consume 12.2 lbs

of PCE per 100 lbs. clothes cleaned, while dry-to-dry

machines consume 8.8 lbs. PCE per 100 lbs. clothes cleaned.

■ There are different generations of dry-to-dry machinery

with different features and control technologies. The newest

machines are fifth generation.

■ It is possible to retrofit both types of machines with

emissions control equipment. Some dry-to-dry machines

have closed-loop technologies, or built-in control devices

that are designed for (but do not achieve) zero emissions.

■ Federal regulations prohibit the installation of new transfer

machines because of the high exposures to PCE associated

with manually transferring clothes from washer to dryer.






Types of Dry Cleaning Machines:Dry-to-dry vs. Transfer Machines

overhead 8

Module 2

Notes

1. There are two basic types of dry cleaning machines — transfer and dry-to-dry.Dry-to-dry machines get their name from the fact that clothes go in dry andcome out dry from the same machine. Transfer machines require that garmentsbe transferred from washer to dryer.

2. In 1993, 34 percent of dry cleaning machines in the United States were transfermachines and 66 percent were dry-to-dry.

3. A comparison of the “solvent mileage” of the two types of machines reveals thattransfer machines consume 12.2 lbs of PCE per 100 lbs. clothes cleaned, whiledry-to-dry machines consume 8.8 lbs. PCE per 100 lbs. clothes cleaned.

Instructor Notes


4. Overhead 9 depicts the process flow of perchloroethylene

through a typical dry cleaning system. On one overhead

projector, show a copy of Overhead 9 (a transparency of

Exercise #2). Keep this overhead displayed on the overhead

projector through the remainder of this section of the training.

As you go through the transparencies showing specific control

technologies, indicate where each specific control technology

is located on Overhead 9. Also indicate which control

technologies participants will see later at the site visit (if

known).

Module 2






Module 2

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yyyyyyyyyyyyyyyy

condensercarbon

adsorber

muckcooker(still)

stillbottoms

lintfilter

filter

separator

steamchargedsolvent

puresolvent

washer/dryer

water

(vented machines only)

Condensate or liquid solventSteam

Solvent vaporWastes

Process Flow of Typical Dry Cleaning Systemoverhead 9

Instructor Notes


5. We will now cover the vapor control technologies that are

available for a typical dry cleaning system.

■ On a second overhead projector, display Overhead 10. This

overhead shows the adsorption and desorption cycles of a

carbon adsorber. An activated carbon bed contains 100–

1,000 pounds of carbon, which can adsorb up to 20% of its

own weight. Carbon adsorption is effective as a “polishing”

step to get the last bit of PCE out of the air exhaust stream. It

is less effective as the primary means of removing PCE

vapor. A dry cleaning system with a carbon adsorber

generates approximately 1500 gallons of PCE-laden water

per year.

Module 2




Nex

t…

Participant Notes


Module 2

��

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yyyyyyyyyyyy

Vapor-ladenair “In”

Condenser

Waste water

Solvent tostorage

Waterseparators

Blower

PneumaticDampers

Solvent vaporstrapped inCarbon Bath

Air “Out” Steam

Vapor Control:Carbon Adsorption

overhead 10

Notes

An activated carbon bed contains 100–1,000 pounds of carbon, which can adsorbup to 20% of its own weight. Carbon adsorption is effective as a “polishing” step toget the last bit of PCE out of the air exhaust stream. It is less effective as the pri-mary means of removing PCE vapor. A dry cleaning system with a carbon adsorbergenerates approximately 1500 gallons of PCE-laden water per year.

Instructor Notes


■ Next, display Overhead 11 which shows a refrigerated

condenser. A refrigerated condenser cools the air stream as

it leaves the carbon adsorber. The condenser liquefies the

water and perchloroethylene in the air stream. The EPA

considers refrigerated condensers to be more effective than

carbon adsorbers in removing PCE vapor. A dry cleaning

system with a refrigerated condenser generates

approximately 50 gallons of PCE-laden water per year.

Module 2






Module 2

��

Water Exhaust Airstream(Transfer Machines Only)

Dryer ExhaustAirstream

RefrigeratedCondensing Coils

Vented toAtmosphere

Condensate toSeparator

Vapor Control: Refrigerated Condenseroverhead 11

Notes

The EPA considers refrigerated condensers to be more effective than carbonadsorbers in removing PCE vapor. A dry cleaning system with a refrigeratedcondenser generates approximately 50 gallons of PCE-laden water per year.

Instructor Notes


■ The next control technology in this sequence is a Water/PCE

Separator as shown on Overhead 12. Display this overhead

and explain how a separator works — because PCE is

heavier than water, it falls to the bottom of the separator,

where it is decanted and reused. A separator is used in

conjunction with a vapor control technology (refrigerated

condenser or carbon adsorber).

■ Participants should be aware that process water does

contain small amounts of PCE (typically 150 ppm) even after

it has been “separated.” A common practice among dry

cleaners is to evaporate off this water in order to separate it

from the PCE. The regulatory status of this “disposal” method

is ambiguous.

Module 2






Module 2

Vapor-ladenair in

Vent

Solvent and water from Condenser

AirWaste WaterOut

Water

Perc

Solvent toStorage Tank

Notes

Process water does contain small amounts of PCE (typically 150 ppm) even after ithas been “separated.” A common practice among dry cleaners is to evaporate offthis water in order to separate it from the PCE. The regulatory status of this “dis-posal” method is ambiguous.

Water/PCE Separatoroverhead 12

Instructor Notes


6. Solvent Recovery/Recapture Mechanisms available for a typical

dry cleaning system:

■ Distillation Systems (Muck Cookers) are illustrated on

Overhead 13. Explain how a distillation system (still) works.

Approximately 90 percent of dry cleaners recover solvent

through distillation or filtration. Point out that in the

diagram displayed, cold water does not mix with PCE —

rather, it absorbs heat.

On older still models, dry cleaners must open a door to

scrape out the still bottoms and muck. This results in high

levels of exposure to PCE. Some newer models minimize this

exposure by automatically dumping still bottoms into a

drum.

Module 2






Module 2

DistilledPerc

Perchloroethylene

Sparge Steam

Steam

Condenser

OutIn

Perc Vapor

Distillation Systemoverhead 13

Notes

Approximately 90 percent of dry cleaners recover solvent through distillation orfiltration.

On older still models, dry cleaners must open a door to scrape out the stillbottoms and muck. This results in high levels of exposure to PCE. Some newermodels minimize this exposure by automatically dumping still bottoms into adrum.

Instructor Notes


■ Filtration Systems: In most filtration systems, filtering is a

continuous process. Filtered PCE is returned to the dry

cleaning machine for reuse. The purpose of filtration is to

remove color from recycled dry cleaning solvent, as well as

items like buttons, pins, and so on.

a. Overhead 14 illustrates one of the three main types of

filtration systems used in dry cleaning — a cartridge

filter. Explain how a cartridge filter works. Cartridge

filters are the most common type of filtration system

used; however, this type of filtration system generally

requires considerable maintenance. Of the three most

common types of filtration systems, this type generates

the most hazardous waste because the entire filter must

be discarded.

Module 2






Module 2

PaperElement

Center Post

End Cap

End Cap

Carbon

Meshed Wrap

OuterShield

CenterCylinder

Cartridge Filter(exploded view)

overhead 14

Notes

Of the three most common types of filtration systems, this type generates the mosthazardous waste because the entire filter must be discarded.

Instructor Notes


b. A spin disc filter is depicted on Overhead 15. Explain

how this filter spins to drop debris directly into a PCE

still. The filtered and recycled PCE will occasionally have

to be distilled to remove soluble oils, greases, and dyes.

Because spin disc filters are less effective at removing

color, they must be used in conjunction with small

cartridge filters or more frequent distillation. However,

this type of filtration system is preferable from a

pollution prevention standpoint because it generates

the least amount of waste. The nylon filter used in a spin

disc filter lasts indefinitely, and does not need to be

discarded frequently like a cartridge filter. Also, there are

powder-using and powderless varieties of spin disc

filtration systems.

Module 2






Module 2

��

��

��

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��Disk Filters

(shaded area)

Venting toButton Trap

Solvent In

Solvent Out

Into FilterValve

Still DrainValve

Still

Spin Disc Filteroverhead 15

Notes

This type of filtration system is preferable from a pollution prevention standpointbecause it generates the least amount of waste. The nylon filter used in a spin discfilter lasts indefinitely, and does not need to be discarded frequently like a cartridgefilter.

Instructor Notes


c. A powder filter is illustrated on Overhead 16. In this type

of filtration system, the powder is discarded into a PCE

still or muck cooker. The use of this type of filter is

declining.

Module 2






Module 2

1. Precoat 2. Filtration(through accumulatedprecoat)

3. “Bump off”filter cake

Clean PercandFilter Powder


FilteredSolvent Filter waste

to muck cooker

UsedPerc

UsedPerc

Powder Filteroverhead 16

Notes

In this type of filtration system, the powder is discarded into a PCE still or muckcooker. The use of this type of filter is declining.

Instructor Notes


Section 3 Overview of Emissions

1. Direct Participants to Exercise #2 (on the next page), which is

the Emissions Pathway Exercise. In this exercise, the goal is to

identify emissions from the processes and controls that we just

discussed. Separate the audience into small groups of 3-4

participants each. Give the small groups up to ten minutes to

complete the exercise. The small groups should:

■ identify all of the points in the process at which PCE could

be emitted, and

■ for each point, indicate where PCE is emitted to air, water, or

land.

2. Overhead 17 below is the finished version of the exercise.

Display it and review the participants’ answers. Do not forget

to mention two PCE emission points not shown on the

handout: solvent spills and PCE offgassing from cleaned

garments.




Module 2

��

yyyyyyyyyyyyyyyy

carbonadsorbercondenser

muckcooker(still)

stillbottoms

disposal

lintfilter

filter

separator

steamchargedsolvent

puresolvent

washer/dryer

water



Solvent vaporWastes

Emissions




ParticipantExercise



2

��

yyyyyyyyyyyyyyyy


muckcooker(still)

stillbottoms

disposal

lintfilter

filter

separator

steamchargedsolvent

puresolvent

washer/dryer

water



Solvent vaporWastes

Instructions

1. Identify all of the points in the process at which PCE could be emitted, and

2. For each point, indicate where PCE is emitted to air, water, or land.


Module 2

Instructor Notes


3. This exercise brings us to our next topic, which is the emissions

from a dry cleaning system. After reviewing the exercise, direct

participants to Handout 1 — a chart showing emissions by

environmental medium.

Optional: You may want to prepare and hand out a diagram of

the back of a dry cleaning machine. Ideally, you may be able to

photograph the machine that will be viewed during the site visit.

Alternatively, you could request a diagram from that machine’s

manufacturer.

Module 2




ParticipantHandout

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Participant Handout


Module 2

Dry Cleaning Shops:

Emissions by Environmental Medium

PCE Emissions to Air, Water, and Land

This handout lists the PCG emissions from dry cleaning shops, by environmentalmedium.

1. PCE Emissions to Air■ Fugitive leaks from piping■ Vapor released when clothes are removed from machines■ Vapor release from clothes dryers■ Residual vapor release from clothes after they are removed from the dryer

2. PCE Emissions to Water■ Water from solvent separator■ Water from regeneration of carbon adsorber■ Wastewater discharge to sewer or onsite sewage disposal system

3. PCE Emissions to Land■ Residue from stills used to evaporate solvent-contaminated water■ Disposal of filters contaminated with solvent residue■ Disposal of carbon adsorbers contaminated with solvent residue

4. PCE Emissions to All Categories: Solvent spills

1

Instructor Notes


4. This training will now focus on the dry cleaning industry’s

emissions into the environment. Display Overhead 18. A shop’s

PCE emissions will depend upon:

■ the type of dry cleaning machinery used,

■ the purity of solvent,

■ the quantity of clothes cleaned,

■ the effectiveness of control technology, and

■ the level of equipment maintenance.

5. Optional: You could present data on PCE emissions to the

environment reported by dry cleaning shops in your state. You

may want to compare these emissions to all reported TRI

emissions of PCE for your state.




Module 2



Module 2

PCE Emissions from Dry Cleaning Shopsoverhead 18

■ 148.5 million pounds of PCE were released to the environment by U.S. dry

cleaners in1994

■ approximately 2/3 of dry cleaning shops’ PCE emissions are to the air

(through process and fugitive loss)

■ a controlled machine might annually release:

— 2200-4300 lbs. of PCE to air

— .07-1.9 lbs. of PCE in wastewater

— 140 gallons of still bottoms, 50 filters

Notes

A shop’s PCE emissions will depend upon:

■ the type of dry cleaning machinery used,

■ the purity of solvent,

■ the quantity of clothes cleaned,

■ the effectiveness of control technology, and

■ the level of equipment maintenance.

Instructor Notes


Module 3 Risks Associated withPerchloroethylene Exposure

1. We have examined how perchloroethylene is used and emitted

from dry cleaning operations. Now we will look at what risks

perchloroethylene presents to human health and the

environment. We will also see how people are exposed to PCE

and why it is subject to environmental regulation.

Optional: Ask participants why PCE is subject to environmental

regulation and record their discussion on a flipchart.

2. Display the overhead showing observed effects of acute

exposure to PCE. (Overhead 19)



asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj????






asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj20 3. Display Overhead 20 which shows possible effects of chronic

exposure to PCE. The debate over whether PCE is carcinogenic

is still ongoing. Participants should see the appendices for

other references, such as studies of PCE-related risks.

4. Optional: Ask participants whether they have dealt with the

remediation of a site that was contaminated with PCE.

Nex

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Module 3

Acute Exposureoverhead 19

Observed effects of acute exposure (high dose, short duration) include:

■ irritation to skin, eyes, nose, and throat

■ superficial burns

■ depression of the central nervous system, slurred speech, impaired motor

functions, loss of consciousness

■ death

Chronic Exposureoverhead 20

Possible effects of chronic exposure (low dose, long duration) include:

■ impaired neurobehavioral function: headaches, dizziness, sleepiness

(reversible)

■ non-carcinogenic liver and kidney damage

■ reproductive disorders (decreased sperm count, increased incidence of

spontaneous abortions)

■ cancer — bladder, cervical, esophagal (possibly liver cancer and leukemia)

Human Health Risks Associated With Exposure to PCE

Risks Associated with Perchloroethylene Exposure

Instructor Notes


5. Display Overhead 21 showing environmental effects of

exposure to PCE.




Module 3



Module 3

Environmental Effects Associated withExposure to PCE

overhead 21

BIOTA:

■ bladder, kidney, and liver cancers leukemias reported in rodents

■ toxic to phytoplankton populations

■ sub-acute and chronic effects in fish

■ bioaccumulation in marine organisms

AIR/WATER:

■ atmospheric half-life of 96 days

■ up to 26% of groundwater and 38% of surface water in U.S. exhibits PCE

contamination

Instructor Notes


6. Display Overhead 22 showing exposure to PCE via inhalation.

Optional: Cover the bottom half of the overhead and ask

participants who else, besides dry cleaning workers, is exposed to

PCE.




Module 3



asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj23 7. Display Overhead 23 showing exposure to PCE via ingestion.

Mention that dermal contact is not a significant source of

exposure to PCE and that no occupational standard exists for

dry cleaners’ dermal exposure to PCE.

Optional: Mention that approximately 70,000 people in

Manhattan live above or adjacent to 500 dry cleaning shops, and

measurements of PCE in the ambient air in these residences in

some cases exceeded occupational exposure standards.



Module 3

Pathways of Exposure to PCEoverhead 22

INHALATION:

■ working in dry cleaning shop

— current OSHA standard = 100 ppm

— proposed standard = 25 ppm

■ living in a household with a dry cleaning worker

■ visiting a dry cleaning shop

■ bringing home freshly dry cleaned clothes (offgassing)

■ residing above or adjacent to a dry cleaning shop


INGESTION:

■ drinking PCE contaminated water

— EPA Maximum Contaminant Level standard for PCE in drinking water

is 5 micrograms/L

— measurements in Cape Cod groundwater are 16 times the MCL

■ eating PCE-contaminated food (especially dairy products and

other fatty foods)

NotesDermal contact is not a significant source of exposure to PCE and that no occupa-tional standard exists for dry cleaners’ dermal exposure to PCE.

Instructor Notes


2. On the second overhead projector, show the list of six toxics

use reduction (pollution prevention) techniques on Overhead

24. Items 1–4 on this overhead represent P2 opportunities that

are available for existing garment cleaning processes (i.e., dry

cleaning). Items 5–6 represent P2 opportunities that are

available for new garment cleaning processes.

Module 4 P2 Opportunities

This section covers the P2 opportunities that are available

within already developed garment cleaning processes (i.e., dry

cleaning).

1. On the first overhead projector, display the diagram of the dry

cleaning process flow chart that was used in the group

exercise (Overhead 9). Keep this diagram displayed

throughout this section.









Module 4

Six Ways to Accomplish Pollution Preventionoverhead 24

■ Product Reformulation

■ Production Unit Redesign/Modification

■ Production Unit Modernization

■ Improved Operation and Maintenance

■ Input Substitution

■ Alternative Technologies

P2 Opportunities in Garment Cleaning

Instructor Notes


4. On the first overhead projector, show the Production Unit

Redesign/Modification information from Overhead 26. Identify

the equipment (on the process flow diagram — illustrated on

Overhead 9) required for the examples listed on Overhead 26.

3. Show the Product Reformulation transparency (Overhead 25).

Ask participants what they think the “product” is in garment

cleaning (i.e., Is the product clean clothes, convenient service,

dry cleaning, or something else). Ask participants how the

product, as they define it, can be reformulated. Discuss the

difficulties in changing a cleaning process. Product

Reformulation may not always be a realistic option for garment

cleaners.







Module 4



Product Reformulationoverhead 25

■ In garment cleaning, the product is _______________

■ Ways of reformulating the product include ___________

Production Unit Redesign/Modificationoverhead 26

Examples of garment cleaning production unit redesign/modification include:

■ hardpiping a PCE still to a carbon adsorber to increase the solvent

extraction rate

■ draining filters more thoroughly before disposal

(over a weekend is recommended)

■ draining filters in a closed casing

■ using multiple emission control devices in sequence

(e.g., carbon adsorber after a refrigerated condenser, a carbon filter

after a spin disc filter)

Module 4

Instructor Notes


5. Show the Production Unit Modernization transparency

(Overhead 27). Identify the equipment (on the process flow

diagram — illustrated on Overhead 9) required for the

examples listed on Overhead 27.




Module 4



Production Unit Modernizationoverhead 27

Examples of production unit modernization include:

■ adding or upgrading emission control devices

— installing a spin disc filter system

— installing a more efficient PCE still

■ using drip-free, airtight couplers to refill machines with solvent and

therefore minimize PCE vaporation

Module 4

Instructor Notes


6. Show the Improved Operation and Maintenance transparency

on Overhead 28. Identify the equipment (on the process flow

diagram — illustrated on Overhead 9) required for the

examples listed on Overhead 28.




Module 4



Improved Operation and Maintenanceoverhead 28

Perform regular maintenance:

■ Change filters regularly

■ Replace gaskets regularly (aeration & deodorizer valves, button trap,

cleaning machine door)

■ Clean button traps, lint screens, fan blades, condensor coils

■ Desorb carbon adsorbers promptly

■ Check refrigerated condenser temperatures

Perform regular inspections:

■ Check for leaks at gaskets, hose couplings and connections, pumps,

air relief valves, storage containers, air vents

■ Check air and exhaust vents for drips

■ Check level gauge on solvent tanks

Correctly size loads

Minimize time that machine door, button trap are open

Provide proper training for employees

Module 4

Instructor Notes


7. Show the Input Substitution transparency (Overhead 29).

Currently, no “drop-in” substitutes exist for PCE, which means

that a different solvent would require entirely new technology

and machinery. “Rynex” is a solvent under development and is

not yet commercially viable. Testing on Rynex’s performance in

two existing garment cleaning operations began in 1997. The

solvent consists of a mixture of glycol ethers, which are

classified by the EPA as Volatile Organic Compounds.




Module 4



asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj30 8. Show the Alternative Garment Cleaning Technologies

transparency (Overhead 30). These alternatives do not include

any home-care products that are new to the consumer market.

With regard to petroleum-based solvents: Exxon has

developed new petroleum solvents with higher flash points

and lower volatile organic compound content. However, these

petroleum solvents may pose their own set of risks to human

health and the environment.



Input Substitutionoverhead 29

■ no “drop-in” substitutes currently available

■ Rynex

■ alternative solvents require alternative technology

Alternative Garment Cleaning Technologiesoverhead 30

■ ultrasonic

■ ozonation

■ liquid CO2

■ wet cleaning

Module 4

Notes

“Rynex” is a solvent under development and is not yet commercially viable. Testingon Rynex’s performance in two existing garment cleaning operations began in1997. The solvent consists of a mixture of glycol ethers, which are classified by theEPA as Volatile Organic Compounds.

Notes

Exxon has developed new petroleum solvents with higher flash points and lowervolatile organic compound content. However, these petroleum solvents may posetheir own set of risks to human health and the environment.

Instructor Notes


9. Display the overhead showing the Garment Care Test

Equipment (Overhead 32) using ultrasonic cleaning

technology, which is defined on Overhead 31. This is a diagram

of test equipment, used by the Department of Energy, to

evaluate the use of ultrasonic technology to clean garments.

Current research projects are examining this technology’s

potential to damage fabric. Ultrasonic cleaning is already

widely used in the metal parts cleaning industry.

Module 4









Ultrasonic Cleaningoverhead 31

■ High frequency sound waves agitate garments in a liquid medium

■ Microscopic bubbles in the liquid medium implode, producing shock waves

that dislodge stain molecules from fabric

■ Mechanical action does not involve large-scale fabric movement that

increases the wear and tear on garments

Module 4

Notes

This is a diagram of test equipment, used by the Department of Energy, to evaluatethe use of ultrasonic technology to clean garments. Current research projects areexamining this technology’s potential to damage fabric. Ultrasonic cleaning isalready widely used in the metal parts cleaning industry.

Garment Care Test Equipmentoverhead 32

32" 48"

48"

32"

Ultrasonic Generator

RinseWater

RinseTank

WashTank

Transducers

FillWater

FineFilter

Heater

Pump90 GPM, 30 PSI

SustainerDrain

Instructor Notes


10. Display the Ozonation transparency (Overhead 33). Explain

the ozonation process. Ozonation is used at several laundry

facilities in the U.S. because of its strong oxidizing, disinfecting,

deodorizing, and bleaching capabilities. Manufacturers of

ozonation equipment claim that ozonation is gentler on

fabrics than other alternative garment cleaning processes.

They also assert that ozonation reduces wash cycle time,

chemical use, hot water use, and labor costs.




Module 4



Ozonationoverhead 33

■ An onsite electrical generator produces ozone gas.

■ Wash water is ozonated (injected with ozone gas), thus solubilizing

garment soils.

■ Filters remove soils from the wash water which is recycled, reozonated,

and reused.

■ Garments remain on hangers throughout the cleaning process to avoid

dimensional change.

Module 4

Notes

Ozonation is used at several laundry facilities in the U.S. because of its strongoxidizing, disinfecting, deodorizing, and bleaching capabilities. Manufacturers ofozonation equipment claim that ozonation is gentler on fabrics than other alterna-tive garment cleaning processes. They also assert that ozonation reduces wash cycletime, chemical use, hot water use, and labor costs.

Instructor Notes


11. Display the Liquid CO2 transparency (Overhead 34). Explain

how liquid CO2 can be used to clean garments.

Optional: Information about the developing liquid carbon

dioxide technologies is proprietary. A generic diagram of the

liquid CO2 garment cleaning process may be found in “A New Spin

on Dry Cleaning,” LA Times, Monday, September 8, 1997, p. D1.

Of the two companies developing liquid CO2 garment cleaning

technology, one company’s technology relies on special

surfactants, while the other company’s technology is based on

high-powered liquid CO2 jets. Both companies claim that

garment cleaning with liquid CO2 takes half the time of dry

cleaning with PCE. Predicted costs for liquid CO2 garment

cleaning machines range from $50,000–$125,000.




Module 4



Liquid CO2

overhead 34

■ A proprietary garment cleaning technology using liquid CO2 as the cleaning

solvent may become commercially viable in 1998.

■ CO2 is non-flammable, non-corrosive, less toxic than PCE, inexpensive

($.50/lb.), and readily available.

■ Liquid CO2 is converted to gas after the garment cleaning cycle. 90% of the

CO2 can be recaptured for reuse

■ Disadvantage: Garment cleaning with CO2 requires high pressure (700 lbs

per square inch) comparable to that of CO2 in soda fountains in restaurants

Notes

Predicted costs for liquid CO2 garment cleaning machines range from $50,000–

$125,000.

Module 4

Instructor Notes


12. Display the Wet Cleaning transparency on Overhead 35.

Explain the differences between wet cleaning and laundering

with respect to level of professional skill required, quantity of

water, types of detergents used, and degree of garment

agitation during process. Ask how many participants have ever

seen the wet cleaning process or had garments wet cleaned.




13. Display and review the Process Flow Diagram for Wet Cleaning

information on Overhead 36. Wet cleaning is widespread in

Europe, and it has been used in the U.S. as a supplementary

process.




Module 4



Wet Cleaningoverhead 35

■ Wet cleaning is the professional cleaning of garments in an aqueous solvent.

■ It is distinct from laundering and hand-washing.

Process Flow Diagram for Wet Cleaningoverhead 36

Water, Soil& Additives

Washer/Extractor

MachineDry

HangDry

FiltrationSystem

RecycledWater Tank

Heated Air

• Inspect• Sort• Pretreat

Stains

Water, SoapsConditionersSoftenersSizings

DirtyClothes

Clean, WetClothes

Clean, DryClothes

Finishing &Assembly

SpentFilters

Water

DirtyWater

Module 4

Instructor Notes


14. There are two types of wet cleaning: multi-process wet

cleaning and machine wet cleaning. Display the multi-process

wet cleaning information on Overhead 37. Explain the

difference between multi-process wet cleaning and machine

wet cleaning.

15. Display the machine wet cleaning transparency (Overhead 38).

Machine wet cleaning is the option that is more frequently

used and has greater potential as a widespread garment

cleaning alternative.

Optional: Mention the number of wet-cleaning shops or mixed-

use shops in the area. Shops are mixed-use if they dry clean and

wet clean. An informal list of U.S. shops that offer wet cleaning

services is maintained at: www.greenpeace.org/~usa/

campaigns/toxics/wetclean.html

Module 4









Multi-Process Wet Cleaningoverhead 37

■ Labor-intensive

■ Relies heavily on manual laundering techniques such as scrubbing and

gentle hand-washing

Machine Wet Cleaningoverhead 38

■ Uses a computerized washing machine designed to minimize agitation

■ The dryer controls heat and moisture precisely through sensors

Module 4

Notes

An informal list of U.S. shops that offer wet cleaning services is maintained at:www.greenpeace.org/~usa/campaigns/toxics/wetclean.html

Instructor Notes


16. Go over the wet cleaning machine diagram on Overhead 39. If

you have a photo or diagram of a wet cleaning machine used

at the facility chosen for the site visit, show it instead. Explain

the differences between a wet cleaning machine, a dry

cleaning machine, and a home washing machine in terms of

the detergents and spotting agents used. Wet cleaning

washers and dryers, unlike dry cleaning machines, are separate

pieces of equipment, and wet cleaning technology involves

computer-controlled agitation and drying cycles. Indicate that

the CNT video to be shown shortly will further clarify the wet

cleaning process.

Module 4




Nex

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Participant Notes


Diagram of a Wet Cleaning Machineoverhead 39

Dirt

Conventional Washer• Strong agitation• Linited controls• Low capital investment

Wet Clean Machine• Gentle agitation• Microprocessor controls• High capital investment

Daewoo• Microprocessor controls• Low capital investment• Air bubbles create gentle agitation• Bubbles help remove soil

Air Bubbles

Air Bubbles

Vibrations ofClothes

Clothes

Module 4

Notes

Wet cleaning washers and dryers, unlike dry cleaning machines, are separate piecesof equipment, and wet cleaning technology involves computer-controlled agitationand drying cycles.

Instructor Notes


17. According to the EPA, in 1997 only 81 dry cleaners nationwide

offered wet cleaning services. To date, only 6 shops in the U.S.

have switched to 100% wet cleaning. If wet cleaning means

avoiding PCE and its associated costs, risks, and regulatory

requirements, why aren’t more professional garment cleaners

wet cleaning? See Overhead 40. Go over the list of potential

barriers to wet cleaning. Many of these barriers arise from

perceptions, rather than facts, about wet cleaning. Mention

that the Federal Trade Commission, which regulates garment

care labeling practices, is revisiting garment care labeling

requirements and may change its regulations to address wet

cleaning instructions.




Module 4



Potential Barriers to Wet Cleaningoverhead 40

■ Lack of expertise with techniques

■ Skepticism about cleaning performance

■ Fear of customer disapproval and loss of market share

■ Increased labor and water costs

■ Garment care labels marked “Dry Clean Only”

■ Disbelief regarding risks associated with PCE

Notes

According to the EPA, in 1997 only 81 dry cleaners nationwide offered wet cleaningservices. To date, only 6 shops in the U.S. have switched to 100% wet cleaning.

The Federal Trade Commission, which regulates garment care labeling practices, isrevisiting garment care labeling requirements and may change its regulations toaddress wet cleaning instructions.

Module 4

Instructor Notes


18. Handout #4: Utopia Report

Distribute copies of the Utopia report and discuss why the

owner of the shop wanted to conduct wet cleaning. The owner

of the shop was motivated to try wet cleaning because of a

dispute over whether he was partially liable for PCE

contamination discovered shortly after the facility opened.

Utopia Cleaners installed four wet cleaning machines and one

dryer with a moisture sensor at its Arlington, MA facility in early

1996. The owner of the shop has observed that wet cleaned

garments have a better odor than garments cleaned in PCE,

but the wet cleaned garments are often more wrinkled than

dry cleaned garments. He has also noticed that the tendency

for garments to shrink or change color in wet cleaning is

comparable to dry cleaning. The installation of wet cleaning

machines at Utopia Cleaners has eliminated the use of 150–

175 gallons (2025 to 2363 pounds) of PCE. They have also

eliminated the generation of 3600 pounds of PCE-

contaminated waste annually. (Since the report was issued,

Utopia Cleaners has added a dry-to-dry PCE machine at its

plant in Arlington — so the facility is no longer wet cleaning

only.)

19. Introduce “Today’s Wet Cleaning” — the wet cleaning video

made by the Center for Neighborhood Technology (CNT).

Discuss the CNT wet cleaning demonstration project. (A final

project report is available.) Refer participants to the list of

resources in the Appendices of this manual for ordering

information.

Show the Video: “Today’s Wet Cleaning” (approx. 20 minutes.)

Allow approximately five minutes for questions about the CNT

video.




ParticipantHandout

Module 4

????

Participant Handout


2Module 4

Notes

Utopia Cleaners installed four wet cleaning machines and one dryer with a moisturesensor at its Arlington, MA facility in early 1996. The owner of the shop has ob-served that wet cleaned garments have a better odor than garments cleaned in PCE,but the wet cleaned garments are often more wrinkled than dry cleaned garments.He has also noticed that the tendency for garments to shrink or change color in wetcleaning is comparable to dry cleaning. The installation of wet cleaning machines atUtopia Cleaners has eliminated the use of 150–175 gallons (2025 to 2363 pounds) ofPCE. They have also eliminated the generation of 3600 pounds of PCE-contami-nated waste annually. (Since the report was issued, Utopia Cleaners has added a dry-to-dry PCE machine at its plant in Arlington — so the facility is no longer wetcleaning only.)

A summary of this report can be downloaded from the Internet at http://www.turi.org/htmlsrc/utopia.htm.

Instructor Notes


20. Display and review Overhead 41 which is titled “Why Do

Garment Cleaners Choose Wet Cleaning?”

■ Studies conducted by EPA, the Center for Neighborhood

Technology, UCLA’s Pollution Prevention Education &

Research Center, and others, have demonstrated that wet

cleaning is viable as a profitable commercial alternative to

dry cleaning. For ordering information and executive

summaries, go to www.cnt.org/sus_man/wet_cln.html

Module 4






Why Do Garment Cleaners Choose Wet Cleaning?overhead 41

■ Cost Savings

■ Regulatory Relief

■ Occupational safety

■ Added garment cleaning capacity

■ Market niche

Module 4

Notes

Studies conducted by EPA, the Center for Neighborhood Technology, UCLA’sPollution Prevention Education & Research Center, and others, have demonstratedthat wet cleaning is viable as a profitable commercial alternative to dry cleaning.For ordering information and executive summaries, go to www.cnt.org/sus_man/wet_cln.html

Instructor Notes


21. Display and review Overhead 42 which is titled “Cost

Comparisons Between Dry Cleaning And Multi-process Wet

Cleaning.”




Module 4



Cost Comparison of Dry Cleaning andMultiprocess Wet Cleaning

overhead 42

Dry Clean ($) Wet Clean ($)

Annual Operating Costs 43,920 43,880

Annual Labor Costs 5,000 15,500

Capital Recovery 6,140 90

Haz Waste Disposal 1,390 0

Solvent 370 0

Filters 630 0

Permit Fee 80 0

NOTE: These cost data are for shops that do 100% wet cleaning.

EPA, 1993 (Based On 1992 Data)

Module 4

Instructor Notes


Module 5 Set up for Site Visit/Interactive Exercise

1. When selecting a site visit candidate, you should consider

whether the visit should focus on a company that has made

investments in pollution prevention technologies and

practices or on a company that has not made such

investments. Firms that have made P2 investments offer

participants an opportunity to observe new technology and

efficient work practices. Firms that have not made such

changes offer participants an opportunity to practice their

observation and communication skills (by observing P2

opportunities and communicating them to facility personnel).

2. Site Visit Preparation:

To prepare participants for the site visit, introduce the site visit

by presenting the following:

■ the firm’s products, main processes, and experience with

pollution prevention;

■ any process flow diagrams or input-output analysis available

from the facility;

■ what participants will be observing during the plant tour;

and

■ how to communicate P2 options observed during the tour

with facility staff.

3. Ask participants to fill out the questionnaire on the opposite

page before the site visit.Asdf fklkjas ss a dfkj s fdfk askd fd jkl; thj a jklkjuu fkd. Asdf fklkjas ss a dfkj s fdfk askd fd jkl; thj a jk jklkjuu fkd, asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj.



ParticipantHandout

Participant Handout


Module 5

Industry Process/Sector Training for Environmental Regulators

Dry Cleaning Site Visit Questionnaire

The goal of the site visit is to provide familiarity with and understanding of the operations of the typical drycleaning shop.

Before Site Visit1. What do I expect to see at the dry cleaning shop?

(describe, e.g., employees, equipment, level ofknowledge re: agency, attitude, other)

After Site Visit1. What was different than what I expected?

2. Were any questions left unanswered?2. What questions will I want to get answers toduring the site visit? (list)

3. What compliance issues do I think I am mostlikely to encounter?

3. What compliance issues did I encounter?

Set Up for Site Visit

Instructor Notes


Module 6 Site Visit to Dry Cleaning Shop

1. Site Visit

2. Large Group Discussion: Site Visit Debriefing

Facilitate a large group discussion following the site visit. The

discussion should be tailored to the specific visit, the

production processes observed, and the interaction with

facility personnel. For example, you could lead a large group

discussion to evaluate

■ whether participants identified P2 opportunities at the

facility, and, if so, how they identified these opportunities;

■ successes or frustrations participants had when

communicating P2 opportunities to facility representatives;

and

■ any other observations.

3. Ask participants to fill out the questionnaire on the opposite

page and to hand in this and the previous questionnaire at the

end of the training.




ParticipantHandout

Participant Handout


Module 6

4. What was the most important thing I learned at today’s site visit?

Suggestions or comments which could improve future site visits:


Instructor Notes




forms and collect them as participants depart the classroom.

Module 7 Wrap-Up and Evaluation of theTraining Module

Large Group Exercise: Use a plus/delta evaluation to solicit

feedback on the training. In a plus/delta evaluation, the trainer

writes a plus sign at the top of one flipchart and a delta at the

top of a second. The plus (+) represents what worked in the

training and the delta (∆) represents what could be improved.

The trainer quickly reviews the agenda for the training and

then solicits remarks to put on the plus page and on the delta

page. Answers should be recorded in the appropriate column

and useful feedback should be incorporated into the next

course offering.







ParticipantHandout

+ ∆

Participant Handout


Industry Process/Sector Training for Environmental Regulators:Garment Cleaning

Evaluation Form

Please complete both pages of this brief evaluation. Results will be used to improve this program. The goals ofthis process sector training are to provide an industry specific overview (including history, processes andpollution prevention opportunities); and to develop familiarity with and understanding of the operations of atypical shop. Please rate the following elements of today’s workshop, both in terms of their usefulness inreaching the instructional goal and their overall quality. Please provide written comments in the space pro-vided to explain your rating or to offer suggestions for improvement.

1. Welcome, Intro, Warm-Up Exercise

Comments:

2. Overview of the Dry Cleaning Industry

Comments:

3. Risks Associated with Perchloroethylene Exposure

Comments:

4. Pollution Prevention Opportunities in Garment Cleaning

Comments:

5. Set Up for Site Visit

Comments:

6. Site Visit to Dry Cleaning Shop

Comments:








Wrap-Up and Evaluation

Instructor Notes


Participant Handout


7. Wrap Up and Evaluation

Comments:


Welcome, Intro, Warm-Up ExerciseOverview of the Dry Cleaning IndustryRisks Associated with Perchloroethylene ExposurePollution Prevention Opportunities in Garment CleaningSet Up for Site VisitSite Visit to Dry Cleaning ShopWrap Up and Evaluation

Comments:









Instructor Notes

Participant Handout


I. Pollution Prevention In The Dry Cleaning Process:Selected Bibliography

A. The Dry Cleaning Process: Emission Control

Arthur D. Little, Inc. for NIOSH. NIOSH Technical Report: Engineering ControlTechnology Assessment of the Dry Cleaning Industry, Contract No. 210-77-004.October 1980.

Northeast States For Coordinated Air Use Management (NESCAUM). Workshopon Emission Control Strategies for Dry Cleaners, January 8, 1992-Proceedings.September 1992.

U.S. EPA, Office of Compliance, Sector Notebook Project: Profile of the Dry CleaningIndustry , EPA/310-R-95-001, September 1995.

Washington State Department of Ecology, Waste Reduction, Recycling, and LitterControl Program. Background Document and Technical Assistance Strategy for theDry Cleaning Industry. May 3, 1993.

B. Alternative Garment Cleaning Technologies

Black, Harvey. “Prototype CO2 dry-cleaning process replaces toxic solvent.”

Environmental Science & Technology vol. 29, no. 11 November 1995 p. 497A(1).

Blackler C. A., et al. Comparative Analysis of Perc Dry Cleaning and an AlternativeWet Cleaning Process. Master’s Thesis Project, University of Michigan (Ann Arbor),School of Natural Resources and Environment. April 1995.

Center for Neighborhood Technology. Alternative Clothes CleaningDemonstration Shop (Final Report). September 1996.

Kaplan, Karen. “A New Spin on Dry Cleaning.” L.A. Times, Monday, September 8,1997, p. D1.

Massachusetts Toxics Use Reduction Institute. Toxics Use Reduction InstituteCleaner Technology Demonstration Sites Program, Utopia Cleaners, Arlington,Massachusetts (Garment Wet Cleaning), Technical Report No. 35. Lowell, MA: TURI,1996.

—————. Training Curriculum for Alternative Clothes Cleaning. Lowell, MA: TURI,1997.

U.S. EPA, Office of Pollution Prevention and Toxics. Multiprocess Wet Cleaning: Costand Performance Comparison of Conventional Dry Cleaning and An AlternativeProcess. EPA 744-R-93-004. September 1993.

U.S. EPA, Office of Pollution Prevention and Toxics. Wet Cleaning: A NontoxicAlternative. 1997.

Instructor Notes


Participant Handout


C. Toxicology of Perchloroethylene Exposure

Aggazzotti, G., et al. “Occupational and Environmental Exposure toPerchloroethylene (PCE) in Dry Cleaners and Their Family Members.” Archives ofEnvironmental Health. November/December 1994 (Vol. 49, No. 6), p. 488.

Agency for Toxic Substances and Disease Registry, U.S. Department of Health &Human Services. Toxicological Profile for Tetrachloroethylene, Contract No. 205-93-0606. August 1995.

Aschengrau, A., et al. “Cancer Risk and Tetrachloroethylene-contaminatedDrinking Water in Massachusetts.” 48 Archives of Environmental Health (Sept./Oct. 1993), p. 290.

Consumers Union. Upstairs, Downstairs: Perchloroethylene in the Air in ApartmentsAbove New York City Dry Cleaners (press release). October 1995.

National Toxicology Program. Toxicology and Carcinogenesis oftetrachloroethylene (perchloroethylene) (CAS No. 127-18-4) in F344/N rats andB6C3F1 mice (inhalation studies). 1986.

NIOSH. Occupational exposure to tetrachloroethylene (perchlor[o]- ethylene).Cincinnati, OH: NIOSH, 1976 (reissued 1989).

Rice, Bonnie, and Jack Weinberg. Dressed to Kill: the Dangers of Dry Cleaning andthe Case for Chlorine-Free Alternatives. Greenpeace Pollution Probe, April 1994.

U.S. EPA, OAQPS. Dry Cleaning Facilities - Background Information for PromulgatedStandards (NESHAP) - Final EIS. EPA 450/3-91-020b. September 1993.

U.S. EPA. Response to Issues and Data Submissions on the Carcinogenicity ofTetrachloroethylene. EPA/600/6-91/002A. 1991.

II. FIGURES: Citations and References

Overhead 8: Dry-to-Dry vs. Transfer Machines. US EPA, Enforcement and Compliance

Assurance, Multimedia Inspection Guidance for Dry Cleaning Facilities, EPA 305-B-96-001, August 1996, p. 9.

Overhead 9: Emissions Points From Typical Dry Cleaning System. CalEPA, Air Resources Board,State Source Division, Technical Support Document: Proposed Airborne ToxicControl Measure and Proposed Environmental Training Program forPerchloroethylene Dry Cleaners, August 1993, p. IV-2.

Overhead 10: Carbon Adsorption Units. CalEPA, Air Resources Board, State Source Division,Technical Support Document: Proposed Airborne Toxic Control Measure andProposed Environmental Training Program for Perchloroethylene Dry Cleaners,August 1993, p. II-11.

Instructor Notes


Participant Handout


Overhead 11: Refrigerated Condenser. U.S. EPA, Enforcement and Compliance Assurance,Multimedia Inspection Guidance for Dry Cleaning Facilities, EPA 305-B-96-001,August 1996, p. 24.

Overhead 12: Perc-Water Separator. CalEPA, Air Resources Board, State Source Division,Technical Support Document: Proposed Airborne Toxic Control Measure andProposed Environmental Training Program for Perchloroethylene Dry Cleaners,August 1993, p. II-29.

Overhead 13: Distillation System. CalEPA, Air Resources Board, State Source Division, TechnicalSupport Document: Proposed Airborne Toxic Control Measure and ProposedEnvironmental Training Program for Perchloroethylene Dry Cleaners, August1993, p. II-27.

Overhead 14: Typical Cartridge Filter (exploded view). CalEPA, Air Resources Board, StateSource Division, Technical Support Document: Proposed Airborne Toxic ControlMeasure and Proposed Environmental Training Program for PerchloroethyleneDry Cleaners, August 1993, p. II-20.

Overhead 15: Spin Disc Filter. CalEPA, Air Resources Board, State Source Division, TechnicalSupport Document: Proposed Airborne Toxic Control Measure and ProposedEnvironmental Training Program for Perchloroethylene Dry Cleaners, August1993, p. II-24.

Overhead 16: Powder Filtration. U.S. EPA, Enforcement and Compliance Assurance,Multimedia Inspection Guidance for Dry Cleaning Facilities, EPA 305-B-96-001,

August 1996, p. 19.

Overhead 17: Emissions Points From a Dry Cleaning System. CalEPA, Air Resources Board,

State Source Division, Technical Support Document: Proposed Airborne ToxicControl Measure and Proposed Environmental Training Program forPerchloroethylene Dry Cleaners, August 1993, p. IV-2.

Overhead 32: Proposed Garment Care Test Equipment (Ultrasonic Cleaning). U.S. Dept. ofEnergy, Kansas City Plant, An Environmentally Conscious Approach to ClothesMaintenance: Final Report, KCP-94-1006, December 1995, p. 5.

Overhead 36: Process Flow Diagram for Wet Cleaning. Wet Cleaning Machines: MassachusettsToxics Use Reduction Institute, Cleaner Technology Demonstration SitesProgram, Utopia Cleaners, Arlington, Massachusetts: Garment Wet Cleaning,Technical Report No. 35, 1996, p. 5.

Overhead 39: Daewoo Wet Cleaning Machines. Wet Cleaning Machines: Massachusetts ToxicsUse Reduction Institute, Cleaner Technology Demonstration Sites Program,Utopia Cleaners, Arlington, Massachusetts: Garment Wet Cleaning, TechnicalReport No. 35, 1996, p. 6.

Instructor Notes


Participant Handout


III. HANDOUTS Citations and References

Handout #2: Emissions Pathway Exercise. CalEPA, Air Resources Board, State Source Division,

Technical Support Document: Proposed Airborne Toxic Control Measure andProposed Environmental Training Program for Perchloroethylene Dry Cleaners,August 1993, p. IV-2.

Handout #4: Utopia Cleaners (TURI Report). Massachusetts Toxics Use Reduction Institute,Cleaner Technology Demonstration Sites Program, Utopia Cleaners, Arlington,

Massachusetts: Garment Wet Cleaning, Technical Report No. 35, 1996.

IV. Selected Internet Sites and Telephone Numbers

Note: Mention of an organization or vendor of a proprietary technology in noway constitutes regulatory endorsement, recommendation, or approval.

Trade Associations:

International Fabricare Institute 800-638-2627

Neighborhood Cleaners Association 212-967-3002

Note: these associations offer classes on wet cleaning to their members.

Wet Cleaning:

Center for Neighborhood Technology 773-278-4800www.cnt.org/sus_man/wet_cln.html

Massachusetts Toxics Use Reduction Institute 978-934-3275www.turi.org

Greenpeacewww.greenpeace.org/~usa/campaigns/toxics/wetclean.html

U.S. EPA Garment and Textile Care Programwww.epa.gov/opptintr/dfe/garment/partners.htm

UCLA Pollution Prevention Education & Research Centerww.sppsr.ucla.edu/res_ctrs/pperc/pperc.htm


Instructor Notes

Participant Handout


CO2:

Caled 800-OK-CALED

MiCELL Technologies 919-513-7007

Ozonation:

CYCLO3PSS 800-972-9091

OxyTech 913-894-2828

HYAC Corporation 510-623-0710

Petroleum Solvent:

Exxon 2000 800-252-8835

Rynex:

Rynex Corp. 516-364-8993 www.rynex.com

Ultrasonic:

Garment Care 816-221-1066

Fraunhofer USA 305-863-9096 www.ftech.org






DEP



InformationAccess






natural resources.

*



Hands-on Pollution PreventionInternet Training

*Information Access


2 Instructor Notes Hands-On Pollution Prevention Internet Training

Table of Contents

Module 1: Introduction .............................................................................................................................................................. 12Module 2: Internet Overview ..................................................................................................................................................... 16

Section I: Basic Browser Commands ................................................................................................................................... 16Section II: Optimizing Your Browser .................................................................................................................................. 22Section III: Speed and the Internet ...................................................................................................................................... 20Section IV: Copying and Pasting Information .................................................................................................................... 24

Module 3: Internet Searches ....................................................................................................................................................... 26Section I: Performing Searches ............................................................................................................................................ 26Section II: Boolean Logic ..................................................................................................................................................... 32Section III: Review Copying & Pasting Tips ....................................................................................................................... 32

Module 4: Pollution Prevention Resources ............................................................................................................................... 36Module 5: Individual Searches — Researching a P2 Question ................................................................................................ 42Module 6: Wrap-Up and Evaluation of the Training Module .................................................................................................. 46

Section I: Closing .................................................................................................................................................................. 46Section II: Evaluation ........................................................................................................................................................... 46

Hands-On Pollution Prevention Internet Training 3

Table of Contents

Module 1: Introduction .............................................................................................................................................................. 12Module 2: Internet Overview ..................................................................................................................................................... 16

Section I: Basic Browser Commands ................................................................................................................................... 16Section II: Optimizing Your Browser .................................................................................................................................. 22Section III: Speed and the Internet ...................................................................................................................................... 20Section IV: Copying and Pasting Information .................................................................................................................... 24

Module 3: Internet Searches ....................................................................................................................................................... 26Section I: Performing Searches ............................................................................................................................................ 26Section II: Boolean Logic ..................................................................................................................................................... 32Section III: Review Copying & Pasting Tips ....................................................................................................................... 32

Module 4: Pollution Prevention Resources ............................................................................................................................... 36Module 5: Individual Searches — Researching a P2 Question ................................................................................................ 42Module 6: Wrap-Up and Evaluation of the Training Module .................................................................................................. 46

Section I: Closing .................................................................................................................................................................. 46Section II: Evaluation ........................................................................................................................................................... 46

Instructor Notes


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FLIPCHART





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EXERCISE



QUESTIONS at this point




Hands-on Pollution PreventionInternet Training

This course has been designed as a hands-on Internet training for pollutionprevention professionals. Participants will be able to maximize the Internet as aresearch tool for pollution prevention by learning to conduct better searches,optimize browser use, and link to pollution prevention (P2) resources. Basic toadvanced Internet techniques are taught in a manner that aids participants inovercoming barriers with PC and Internet technology. The course uses a website that is designed specifically for the target audience and maintained throughthe Toxics Use Reduction Institute. In addition to using the web site during thetraining, participants use the site subsequent to the training to performpollution prevention research and to further their learning.

Instructional Goals

1. Participants will understand the capability of the Internet as a resource inidentifying and researching P2 techniques and technologies.

2. Participants will be better able to use the Internet to identify and research P2techniques and technologies.

3. Participants will be more inclined to seek out and use Internet resources whenfaced with questions regarding P2 and guide other staff in using the Internet.


1. Participants are regulatory personnel (federal, state, or local) involved inpermitting, compliance inspections, and/or enforcement.

2. Participants have varied or unsatisfactory experience with the World Wide Webas a research tool for pollution prevention.

3. Participants will have the capability to understand technical presentations andparticipate in group exercises or discussions.

4. Participants will likely have expertise in one environmental medium.

About this Course

This Internet course has been a part of the Toxics Use Reduction Institute’straining curriculum offerings since 1995. It includes a companion web sitemaintained by TURI (http://www.turi.org). The course was adapted for the P2Integration Curriculum for Environmental Agency Staff under an EPA-ETI Grantto the Massachusetts Department of Environmental Protection. These instructornotes were created as part of that project. The training site includes trainingtools, search techniques, and resource links that are periodically updated for usein this course. Instructors are encouraged to use this free resource for coursepreparation and delivery. For more information please contact Janet Clark atTURI at (978) 934-3346.



Hands-on Pollution Prevention Internet Training

This course has been designed as a hands-on Internet training for pollutionprevention professionals. Participants will be able to maximize the Internet as aresearch tool for pollution prevention by learning to conduct better searches,optimize browser use, and link to pollution prevention (P2) resources. AdvancedInternet techniques are taught in a manner that aids participants in overcomingbarriers with PC and Internet technology. The course uses a web site that isdesigned specifically for the target audience and maintained through the Toxics UseReduction Institute. In addition to using the web site during the training, partici-pants use the site subsequent to the training to perform pollution preventionresearch and to further their learning.

Instructor Notes



1. Participants will understand the basic structure of the Internet and the resourcecharacteristics of the World Wide Web.

2. Participants will be able to effectively use a web browser such as NetscapeNavigator or Internet Explorer to conduct Internet research.

3. Participants will overcome frustrations with the Internet and increase P2research efficiency through the appropriate use of the Internet.

4. Participants should increase the frequency with which they use the Internet toresearch P2 options.

Agenda

Module Format Approximate Time

1. Introduction Interactive 30 minutes

2. Internet Overview Hands-on Training 45 minutes

3. Internet Searches Hands-on Training 45 minutes

4. Pollution Prevention Hands-on Training 30 minutes

Resources

5. Researching a Self-Directed Learning 60 minutes

P2 Question

6. Closing/Evaluation Activity 10 minutes

TOTAL: approx. 4 hrs



Agenda

Module Format

1. Introduction Interactive

2. Internet Overview Hands-on Training

3. Internet Searches Hands-on Training

4. Pollution Prevention Hands-on Training

Resources

5. Researching a Self-Directed Learning

P2 Question

6. Closing/Evaluation Activity

TOTAL:

Instructor Notes


Module 1 Introduction

1. Have participants introduce themselves. Solicit a list of training

expectations from the group.

2. Flipchart: List and review the following goals of the training:

■ comfort with World Wide Web

■ understanding of Internet strengths and weaknesses

■ opportunity to use the World Wide Web

3. A survey of the participants to determine the level of

experience and knowledge will be helpful in making the

training more interesting and relevant. To determine the

participants’ familiarity with the Internet, list the following

items on a flipchart, and ask whether participants have done/

used any of the items in the list:

■ e-mail

■ the web

■ gopher

■ ftp

■ html code

■ logged on to Internet

■ used on-line service

■ searched Internet

■ used or preferred a specific operating system: Windows 3.1,

Win 95, Mac

■ used or preferred a specific browser: AOL, Netscape,

Microsoft Internet Explorer

This exercise helps to target the training toward the

participants’ specific needs. For example, if participants are

unfamiliar with Windows, more time should be spent on how

to use the browser. If participants are more familiar with

Windows and the Internet (e.g., they have programmed in html

code), more time should be spent on developing sophisticated

searches.









Instructor Notes


Module 1 Introduction

1. Have participants introduce themselves. Solicit a list of training

expectations from the group.

2. Flipchart: List and review the following goals of the training:

■ comfort with World Wide Web

■ understanding of Internet strengths and weaknesses

■ effective use of the World Wide Web in P2 research

3. A survey of the participants to determine the level of

experience and knowledge will be helpful in making the

training more interesting and relevant. To determine the

participants’ familiarity with the Internet, list the following

items on a flipchart, and ask whether participants have done/

used any of the items in the list:

■ e-mail

■ the web

■ gopher

■ ftp

■ html code

■ used the Internet at work

■ searched the Internet for P2 techniques and technologies

■ used or preferred a specific operating system: Windows 3.1,

Win 95, Mac

■ used or preferred a specific browser: Netscape,

Microsoft Internet Explorer, other

This exercise helps to target the training toward the

participants’ specific needs. For example, if participants are

unfamiliar with Windows, more time should be spent on how

to use a browser. If participants are more familiar with

Windows and the Internet (e.g., they have programmed in html

code), more time should be spent on developing sophisticated

searches.









Goals of the Training:■ comfort with World Wide Web,■ understanding of Internet strengths and weaknesses,■ opportunity to use the World Wide Web

Module 1Introduction

Instructor Notes


4. Ask what kind of experiences the participants have had when

using the web (i.e., successes, frustrations). Typical answers will

include difficulty connecting, waiting for information, and

search results that are too numerous. You can then tailor the

training session to target these areas.

5. Flipchart: List and review the following ground rules for the

participants. Ground rule number one is especially important

since participants have a tendency to jump ahead and not stay

with the class.

1. stay with the class-do not jump ahead

2. ask questions as you go

3. raise your hand if you need help or are lost

Module 1






Module 1

Participant Ground Rules:1. Stay with the class-do not jump ahead2. Ask questions as you go3. Raise your hand if you need help or are lost

Instructor Notes


Module 2 Internet Overview

WWW Go to the training web site: http://www.turi.org/HTMLSrc/net/

Note: Assess the comfort level of the participants with a web

browser and the Internet by asking them to enter the URL for

the course. Demonstrate the options for entering an Internet

address and explain the URL components if needed.

This is the first opportunity to show the basics of using a

browser and entering an URL. When the browser and page

comes up, review basics on how to use an Internet browser. It is

important for participants to feel comfortable with the

browser early in the training.

Section I Basic Browser Commands

HANDS-ON DEMONSTRATION

In order to familiarize participants with the browser,

demonstrate the uses of the pull-down menus and the button

bar, as well as the areas where they overlap (e.g. the Back

button and the Back command under the Go pull-down

menu). When demonstrating the Back and Forward commands

it will be necessary to move between pages on the site,

preferably those pages listed above.

For each section, you should demonstrate the techniques on

the display computer, and the participants should then try the

commands on their own computers.

A demonstration of how to use a browser should cover the

following basic browser commands (you will have to modify

these commands to fit the browser being used — either MS

Internet Explorer or Netscape Navigator):

■ URL — stands for Uniform Resource Locator — which is the

standard way to identify an address or location on the

Internet.



Module 2

Click “Learning”

Click “Internet Toolsand Training”

Enter the following information in the address or location line of your Webbrowser: “http://www.turi.org/”. This is the Uniform Resource Locator (URL) forthe Toxics Use Reduction Institute web site.

Next, select the “Learning” button on the TURI home page. When the learningpage is on the browser screen, select the “Internet Tools and Training” link. You arenow ready to start the On-line training module.

Instructor Notes


■ HTTP — stands for HyperText Transport Protocol — the

protocol for moving Hypertext (web pages) files over the

Internet.

■ Back and Forward buttons — move back or forward in the

sequential list of web pages (history list) that the browser

has visited since it started. Only documents in a direct

sequential line can be retrieved using these buttons.

■ Home button — return to the preset home page (Here you

can review how to set the home page)

■ Reload — load the current page again to update data or in

the event that transfer is incomplete or interrupted

■ Find — using the Find option on web pages to identify

pertinent information.

■ Go — the Go menu in Netscape allows the user to select

from pages recently visited. It also contains the Back and

Forward commands which perform the same function as

the Back, Forward and home buttons for both Internet

Explorer and Netscape Navigator.

■ Followed Links — the color of the text of a link will not

always change after you have visited a link. This is an

opportunity to discuss the browser personalization settings

and page defined colors.

Module 2



Module 2

NetscapeNavigatorbrowser

MicrosoftInternetExplorerbrowser

Back buttonForward button

Reload/Refresh

Home

URL

Instructor Notes


Module 2

Section II Optimizing Your Browser

HANDS-ON DEMONSTRATION:

In this section, discuss browser optimization to aid in internet

research. Discuss bookmarks, or favorites, explaining how

bookmarks work (by saving addresses of frequently visited pages)

and why they are useful (save time in returning to these resources).

Note here the need to organize bookmarks for future retrieval.

Some common options for this demonstration include the

following:

■ Setting Preferences to change the look and feel of the browser

— including link colors, font sizes and browser icons. Newer

browsers continue to add aids in configuring “bookmarks” and

search pages.

■ Font size — some participants may be interested in setting

smaller fonts for computers that have small (640x480) screens.

This setting will allow them to view more data and reduce

scrolling.

■ Bookmarks (Favorites)— adding, deleting, and viewing

bookmarks.

■ Home Page — setting the default home page on the browser

■ Cookies — many participants ask about cookies. Demonstrate

how to turn cookies on or off and discuss the benefits and

drawbacks of cookies to web research.

■ History File — list of recently visited sites.

■ Multiple Browser Windows — Demonstrate the use of multiple

browser windows here or in the research module.

■ Frames, navigation, and URL parsing — Discuss the issues with

frames and navigation for research. Demonstrate the value of

deleting portions of an URL to find information sources etc.

Graphics and Load Time



Module 2

Basic Browser Commands:

■ URL — stands for “Universal Resource Locator” which is also the text on thebrowser address line.

■ http-stands for “Hyper Text Transport Protocol” — the language that is used totransport Web Pages over the Internet.

■ Back and Forward buttons — used to move sequentially through the list of webpages that you most recently visited.

■ Home — return to the preset home page. The home page can be set by you toany internet site or address.

■ Reload — load the current page again to update data or in the event thattransfer is incomplete or interrupted.

■ Go — the Go menu allows you to select from pages you have recently visited.It may also contain the Back and Forward commands which perform the samefunction as the Back and Forward buttons.

Optimizing Your Browser:

Options that can be demonstrated include the following:■ Setting Preferences to change the look and feel of the browser.■ Bookmarks (Favorites) — adding, deleting, and viewing bookmarks.■ Font size — a smaller font can be used to allow more information to fit on a

page.■ Cookies and web site personalization.

Instructor Notes


Module 2

Section III Speed and the Internet

LECTURETTE

■ Describe where information is stored and how information

travels through the Internet. Include dial-up modem speeds,

typical state government Internet connection speeds, the

Internet backbone, etc.

■ Graphics and load time. It is helpful here to briefly describe

the load time that graphics add to web pages. In many

cases when information is slow to load the primary cause is

web page graphics. Turning graphics off on the browser can

speed up research in these cases. On poorly designed web

pages, this can result in loosing navigation information.

■ The following commands can be used to turn images off on

today’s browsers. Be sure to check the browser version you

are using in the course for changes.

—For Netscape Navigator, select Edit > Preferences. The

“advanced”option in the preferences box allows you to turn

images off.

—For MS Internet Explorer, select View > Internet Options.

The “Advanced” tab has image options in the “Multimedia”

section.



Module 2

Most P2 content is contained in text on web pages and documents. To increase thespeed of your research you may wish to load only the text and not the images ofweb pages. Note, however, in some cases it will be much harder, if not impossible,to navigate a site with images off.

Use the following commands to turn images off in your browser:

For Netscape Navigator, select Edit > Preferences. The “advanced” option in thepreferences box allows you to turn images off.

For MS Internet Explorer, select View > Internet Options. The “Advanced” tab hasimage options in the “Multimedia” section.

Section III: Speed and the InternetExample: Graphics and speed


Instructor Notes

Section IV Copying and Pasting Information

HANDS-ON DEMONSTRATION:

In order to use the information found on the Internet, P2

practitioners need to save and highlight portions of

documents and files. These exercises familiarize the student

with the many ways that information can be saved off the

Internet for future review and reference.

■ File menu: saving and printing information

■ Edit menu: copying and pasting information to other

applications (word processor or text editor)

■ Handout 1: “Copying and Pasting Tips”

Have participants practice methods of saving, copying, and

pasting using the mouse, the browser, and keyboard shortcuts.

Note: Keep in mind that taking information off the Internet is just like

taking a photocopy of a published document. Unless stated

differently, the information contained on web sites is

copyrighted and is not intended for re-use, duplication, or

distribution without express permission.




ParticipantHandout

Module 2

Participant Handout


Copying and Pasting Tips

1. SAVING FILES

To save the text on the current page displayed by your browser, from the File pulldown menu select Save As. Give your file a title.

■ Be sure to use the file extension .txt if you will be viewing the file in a texteditor or word processor. To view your file in a word processor, select Openunder the File pull down menu in the word processor. Select the title of yourfile and click OK. When given the File Conversion prompt select Text Only.

■ Give your file the extension .htm if you plan to view it later using your browser.You will be able to read the file while in your browser (minus any graphics) byselecting Open from the File menu and choosing the title of your file.

2. COPYING & PASTING

To save text from your browser into a word processor, highlight the areas you wantto copy by clicking and dragging with the mouse (if you want to copy all of the textpress Control and A simultaneously to select all). From the Edit pull down menuselect Copy to copy the item to the clipboard (you can also copy by pressingControl and C simultaneously).

If you are simultaneously running the word processor, holding the Alt key andpressing Tab will allow you to scroll to that program. Once in the word processor,you can paste the text to the file by selecting Paste under the word processor’s Editmenu.

3. MOUSE BUTTONS

The mouse has some special features in the browser. Clicking once with the righthand mouse button on a file you are viewing (other than a graphic) will give youthe Back/Forward menu. Clicking on a graphic with the right hand mouse buttonwill give you the option of saving the graphic.

4. USEFUL KEYBOARD SHORTCUTS

■ Ctrl+S = save as■ Ctrl+Z = undo■ Ctrl+X = cut■ Ctrl+V = paste■ Ctrl+R = reload■ Ctrl+D = add bookmark

Keep in mind that taking information off the Internet is just like taking a photocopy ofa published document. Unless stated differently, the information contained on websites is copyrighted and is not intended for re-use, duplication, or distribution withoutexpress permission.

Module 2

1

Instructor Notes


Module 3 Internet Searches

WWWThis module covers basic research and search engine

techniques and demonstrates the differences between the

most popular search engines. Go to the training web site and

familiarize yourself with the tools and updates for use in this

and the following sections of the training. We will be updating

the web site and instructor notes to reflect the most current

search engine characteristics.

Have participants select the “Research” tab on the “Internet

Tools and Training for Pollution Prevention” training course

home page. The next page that appears on their screens

contains links to four engines. (See “participant notes” on page

27 opposite.)



Module 3


Instructor NotesModule 3

Section I Performing Searches

LECTURETTE

Give a brief background of each of the search engines and

how they catalog information. Explain why search engines

yield different results.

HANDOUT Search Engines

After reviewing the research page, direct participants to

Handout 2 “Search Engines.” Highlight portions of this

document depending on participant needs and experience.

Sample search module progression:

1. Ask participants to perform a simple search using three or four

of the search choices and the same search terms. After this has

been completed, discuss the differences between search

results.

2. Demonstrate search results and techniques for general

searching and techniques for highly specific searching.

3. Use the search excercises available at the training site to

demonstrate search techniques.

Monitor individual participant progress closely and allow

participants time for exploration.




ParticipantHandout

Participant Handout


Search Engines

The following information is a review of a variety of search engines, which are usefulin finding resources on the Internet. It lists the strengths and weaknesses of each of thesearch engines as of January 1999.

Alta Vista www.altavista.digital.comType of search: KeywordSearch options: Simple or Advanced searchDomains searched: Web, UsenetGood points: Fast searches, capitalization and proper nouns recognized, large da-tabase; Alta Vista searches both the Web and Usenet. It will search on both wordsand on phrases, including names and titles.Bad points: Many results on simple search can frustrate first time users.

Excite www.excite.comType of search: Both concept and keywordSearch options: Simple, refinedDomains searched: Web, Usenet and classified adsGood points: Large index. Good summaries. You can view your hits in variousways — grouped by confidence or grouped by Web site.Bad points: Does not specify the format or the size in megabytes of the hits itreturns, nor does it tell you upfront exactly how many hits there are.

Lycos www.lycos.comType of search: Keyword, but Lycos is gradually becoming less of a search engine,it seems, and more of a Yahoo-like subject index.Search options: Basic or compoundDomains searched: Web, Gopher and FTP sitesGood points: Large database. Comprehensive results including the date of the docu-ment and its size. Lycos indexes the frequency with which documents are linkedto by other documents to make sure the most popular web sites are found andindexed before the less popular ones.Bad points: Not enough options to refine the search. New advanced search is ad-dressing this.

Module 3

2



Participant Handout


Module 3

Search Engines cont’d

Yahoo www.yahoo.comType of search: KeywordSearch options: Simple, AdvancedDomains searched: Yahoo’s index, Usenet, E-mail addresses. Yahoo searches titles,URLs and the brief comments or descriptions of the Web sites Yahoo indexes.Search refining: Boolean AND and OR. Yahoo is case insensitive.Good points: Easy-to-navigate subject catalogue. If you know what you want tofind, Yahoo should be your first stop on the Web.Bad points: Only a small portion of the Web has actually been catalogued byYahoo.

Northernlight www.northernlight.comType of search: KeywordSearch Options: Simple, Power searchDomains Searched: Web, Northernlight’s Special CollectionSearch Refining: Power search supports some Boolean logic,Good points: Organizes results into labelled folders to quickly narrow searches, nobanner advertising. Special collection contains journal articles and publicationsthat can not be found elsewhere on the web. Accurate relevancy rankings.Bad points: Fees ($0–$4) for special collection documents, still indexing web.

Reviews of alta vista, yahoo, lycos, and excite began with information from MonashInformation Services (www.monash.com). Conceived by Linda Barlow. Modified andupdated here by Greiner Environmental

2 cont’d


Instructor Notes

Section II Boolean Logic

INDIVIDUAL EXERCISE

Direct the participants to Handout 3, “Understanding Boolean

Logic.” Coach the participants on Boolean logic. Participants

should now use the same search tool as in Section I narrowing

their previous searches using Boolean logic. Search engines

may provide differing interpretations of the logic used by the

participants. Be prepared to address this issue by reviewing

the search engine notes provided at the training site.

The goal of this exercise is to teach participants to target

searches and choose the search techniques that will yield

results quickly.

Section III Review Copying & Pasting Tips

Have participants use the copying and pasting techniques

discussed in Module 2 to save pertinent results. Also, instruct

participants to bookmark sites of interest on the training PC.

At the end of the training, show participants how to copy

bookmarks to their floppy disk.




ParticipantHandout

Module 3

Participant Handout


Understanding Boolean Logic

Boolean logic is a symbolic logic system invented by French mathematician GeorgeBoole. In 1849, Boole formalized a set of rules in a paper called “An Investigation ofthe Laws of Thought,” which transformed formal logic from a philosophical disciplineto a mathematical one. These rules, known as Boolean algebra, use operators (AND,OR, NOT, and WITH) to create relationships among words and concepts. In addition,the logical operations defined in Boolean algebra make modern binary digital com-puters possible.

In addition to binary functions in computers, Boolean logic is also of supreme impor-tance to the operation of search engines. This formalized method of logical processingenhances searches that would otherwise be impractical in large search engines such asAltaVista Search. We’ll cover the basics of Boolean logic and its importance in searchengines.

OR operators

The OR operator broadens searches to include documents that contain any keywordsof a search. The search syntax is simply cat OR dog. OR operators can be useful whensearching for alternative spellings, such as color OR colour, or in order to broaden aquery when searching for synonyms, such as city OR urban. In this case, the combinedkeywords will cover the topic better than a search for either topic alone, because somedocuments may use only one of these words. The OR operator is also helpful whenyou want to search for a keyword that is commonly abbreviated, such as Kentucky ORKY.

AND operators

The AND operator narrows a search to include only documents that contain bothkeywords. The search syntax is cat AND dog. AND operators are a great way oflimiting the numbers of search results because they link two subjects to create acompound subject…only those documents in the database that include both subjects.AND operators in AltaVista Search are also denoted by a plus sign (+) before akeyword.

NOT operators

The NOT operator narrows a search to exclude certain keywords. For example, if youwant to search for synonyms of the keyword ghosts, you might use the OR operator tobroaden the search and submit the query phrase ghosts OR apparitions OR spirits, butthis search would also result in documents about moonshine. You can use the NOToperator to restrict the search, like this:

ghosts OR apparitions OR spirits NOT moonshine NOT alcohol

NOT operators in AltaVista Search are also denoted by a minus sign (-) before akeyword.

NEAR operators

NEAR operators are not found in true Boolean logic, but AltaVista created them toserve special needs in Internet searches. NEAR operators work similarly to ANDoperators, retrieving only documents that contain both keywords, but NEAR opera-

3Module 3



Participant Handout


Module 3

tors further limit the search results by requiring that the keywords be within ten wordsof each other. This is especially helpful when searching for names. For example, thesearch john NEAR doe will also retrieve documents containing Doe, John, or John A.Doe.

Nesting Boolean operators

Nesting is a method of combining Boolean operators in a logical order. Occasionally,you may need to use more than one Boolean operator, but the hierarchy of Booleanlogic might cripple your search unless you know how to nest operators in the orderyou want. AltaVista Search evaluates Boolean operators in the order NEAR, NOT,AND, and OR. So if you enter the search hardware OR software AND Internet, thesearch results would include all documents that contain the words software andinternet, and then as almost an afterthought, all documents containing the wordhardware. But you can avoid this problem by nesting the hierarchy of Boolean opera-tors with parentheses. The nesting query for retrieving documents about Internethardware and software is (hardware OR software) AND Internet

Automatic Boolean operators

If you don’t include Boolean operators in your search queries, most searchengines(including AltaVista Search) use Boolean operators even when it isn’t obvious.For example, if you enter the search query ben jerry, most search engines will interpretthe keywords as if they contained an OR operator, as in ben OR jerry. The search willcontain all results for the word “ben” and all results for the word “jerry.”

In addition, Boolean operators are often implied in search queries using uppercaseand lowercase keywords. When you type a query in all lowercase letters, AltaVistaSearch conducts the search with an OR operator, which opens the search to include allinstances of the word in uppercase and lowercase.

For instance, when you search the keyword ben, you also get results for Ben, BEN, Ben,and so on. However, when you enter the query Ben, AltaVista Search conducts thesearch with a NOT operator to restrict the results to documents that include thekeyword with the first letter capitalized. The search ignores documents containing thekeyword in lowercase or other variations of uppercase and lowercase.

Uppercase Boolean operators

If you use Alta Vista, make sure you type Boolean operators (AND, OR, NOT, NEAR)in uppercase letters so the search engine can recognize them. About 5 percent ofsearches submitted to AltaVista Search include these Boolean operators in lowercaseletters, which makes them “stop words” instead of operators. Stop words are wordsthat a search engine ignores because they create false hits (irrelevant search results)when included in a search query. For example, if you search the word Internet inAltaVista Search, the search engine will respond with no documents match the query.That’s because the word Internet appears so often in the AltaVista Search database thatthe index administrators instructed the query program to ignore the words in SimpleSearch. Stop words are indexed, but you can’t access information with them outright.

Source: From February 1998 issue of The Cobb Group’s “Power Searching With AltaVista” article by

Bruce Spencer.

3 cont’d

Instructor Notes


Module 4 Pollution Prevention Resources

WWWDEMONSTRATION:

In this module, review various P2 resources on the net

including government sites, process-specific pollution

prevention pages, industries, and trade associations. Here you

can do a tour of certain sites of your choice to show the type of

information they contain.



Module 4



Direct participants to Handout 4, “Pollution Prevention

Bookmarks,” in their manuals. Please check the training site for

an updated version of this set of bookmarks prior to the

training. Addresses change often and print versions of URL

addresses can become outdated.

The bookmarks provided with this manual and at the

companion web site are intended as samples to aid in the

training. If you feel a site should be added or deleted from this

list, please contact TURI through the training site or by calling

Janet Clark at (978) 934-3346.




ParticipantHandout

Participant Handout


Module 4

4

Sample Pollution Prevention Bookmarks

Federal/International Government SitesEPA’s Pollution Prevention Homepage http://www.epa.gov/opptintr/p2home/Envirosense — EPA P2 Site http://es.epa.govUNEP-IETC Homepage — UN’s Cleaner Production Site http://www.unep.or.jp/Manufacturing Extension Partnership http://www.mep.nist.gov/Environmental Technology Initiative http://www.epa.gov/oppeinet/oppe/eti/eti.htmlEPA Waste Minimization Homepage http://www.epa.gov/wastemin/

Sample Non-Profit P2 SitesNational Pollution Prevention Roundtable http://www.p2.org/ILSR WWW Home Page http://www.ilsr.org/Northeast Business Environmental Network http://www.nben.org/Pacific Northwest Pollution Prevention Resource Center http://www.pprc/org/

Sample University SitesUniv. Michigan National P2 Center for Higher Education http://www.umich.edu/~nppcpub/index.htmlTechnology, Business and Environment at MIT http://web.mit.edu/ctpid/www/tbe/UC Berkeley CGDM Home Page http://euler.berkeley.edu/green/cgdm.htmlUCLA CCT Home Page http://cct.seas.ucla.edu/

Sample State Sites and ResourcesListing / Map of Regional P2 Networks (P2Rx) http://www.epa.gov/p2/p2rxdir.htmIllinois Waste Management and Research Center http://www.wmrc.uiuc.eduGreat Lakes Regional P2 Roundtable http://www.glrppr.uiuc.edu/wrmc/great1/index.htm1Waste Reduction Resource Center Home Page http://wrrc.p2pays.orgTURI Home Page http://www.turi.orgOhio Technical Assistance Resources for P2 http://www.epa.ohio.gov/opp/tarp/tarp.htmlKentucky Pollution Prevention Center http://www.kppc.org/

Sample Industry SitesMonsanto Home Page http://www.monsanto.com/Interface, Inc. http://www.ifsia.com/

Process/Sector-specific SitesNational Compliance Assistance Centers —

Agriculture, Auto, Finishing, Printing, Chemical, Local Government, Transportation,Paints & Coatings, Printed Wiring Board http://es.epa.gov/oeca/mfcac.html

Paint Coatings Net — Main Menu http://www.paintcoatings.net/pcnmain.htmSAGE — Solvents Alternative Guide http://clean.rti.org/CAGE — Coatings Alternative Guide http://clean.rti.org/cagefinishing.com — Metal finishing http://www.finishing.com/P2GEMS - Search by Process, product, waste, or management tool http://www.turi.org/P2GEMS/

Sample ISO 14000 ResourcesISO 14000 InfoCenter http://www.iso14000.com/TC 207 Environmental management http://www.iso.ch/meme/TC207.html



Participant Handout


Module 4

4 cont’d

Other Related Bookmarks

Water SupplyEnvironmental Protection Agency’s Water Protection Homepage http://www.epa.gov/OW/Welcome to the Water Quality Association http://www.wqa.org/National Drinking Water Clearinghouse http://www.estd.wvu.edu/ndwc/ndwc_homepage.html

AirEPA OAQPS Technology Transfer Network Page http://www.epa.gov/ttnAir & Waste Management Association http://www.awma.org/EPA OAR Office of Air Quality Planning and Standards http://www.epa.gov/oar/oaqps/California Air Resources Board Information System http://www.arb.ca.gov/homepage.htm

GroundwaterNational Ground Water Association http://www.h2o-ngwa.org/Groundwater.com http://www.groundwater.com/Groundwater Remediation Technologies Analysis Center http://www.gwrtac.org/

Government Technology Transfer SitesHazardous Waste Clean-Up Information — USEPA technology innovation office site http://clu-in.com/GNET: The Global Network of Environment and Technology http://www.gnet.org/EPA Mixed Waste Home Page http://www.epa.gov/radiation/mixed-waste/EPA Superfund Innovative Technology Evaluation Home Page http://www.epa.gov/ORD/SITE/ATTIC — EPA database of innovative clean-up technology http://www.epa.gov/attic/

About This List

This sample list is intended to provide some starting points for P2 Research. Please provide suggestions,additions, and comments through the TURI Internet Training site at http://www.turi.org/

An updated list of sites for use both during and after the training is available at the above address.


Instructor NotesModule 5 Individual Searches—

Researching a P2 Question

INDIVIDUAL EXERCISE: Researching a Pollution Prevention

Question

Participants will use the search engines and web techniques

learned earlier in the training to research a question that they

brought to the training.

Direct participants to Handout 5, “Internet Search Tips,” in their

manuals.

Highlight any areas in the training and/or Handout 5 that you

feel should be stressed prior to the exercise. Have participants

search the Internet and raise their hands when they are not

finding satisfactory results.

Apply the search techniques discussed in this training to help

individual participants find results as needed.

An Internet search related to the individual participant’s area

of expertise will allow them to judge the results of their search

better.

Verify that searches are producing results and provide

assistance to participants who need more help.

Walk around the room and ask participants how they are

doing. Verify that searches are producing results and provide

assistance to participants as needed.




ParticipantHandout

Customize

????

Participant Handout


Module 5

5Internet Search Tips

A. Basic Search Tips

1. First Examine Resources and Networks You Are Familiar With: Before you jumpon the Internet, ask colleagues, call P2 professionals (technical assistance staff,consultants, vendors, or folks from industry), and look through printed material.These resources may provide you with the information you need.

2. Search Content-Rich Sites Before Using General Search Engines: Content-richsites (such as EPA’s Envirosense) may contain the P2 information you are lookingfor.

3. Bookmark or Favorite It!: If you find it, and you plan to use it again, bookmark it.Bookmarks are the easiest and most convenient way to get to resources you planto visit more than once.

4. Read Search Engine Directions: Always read the instructions for a site you aren’tfamiliar with or haven’t visited in a while. Spending a few minutes reading direc-tions will save you hours of fruitless searching.

5. Every Tool has Different Rules. Never forget that every search engine is different,which means that every search engine has unique rules for constructing searches.Also, every catalog has its unique schematic and index vocabulary.

6. Early to Rise: When possible, avoid searching at the busiest times (in the NortheastUnited States, that’s mid-afternoon).

7. Use the Right Search Engine for the Job: Before launching off on a search, con-sider which search tool to use first. Excite and Northernlights use synonymmatching and help you to find sites with lots of content on your search criteria.Alta Vista’s advanced search tool is comprehensive but the search results mayoverwhelm you. For example, don’t use Alta Vista to locate the Federal Registerenvironmental subset—even if you forgot to bookmark it. EPA’s search tool,primitive as it is, should find it for you easily.

8. Caveat Surfer. Remember that the Internet has plenty of champagne and snake oil.Prepare to be disappointed by sites you were sure would be good and surprised bysites that don’t appear to be much at first glance. Finally, the best way to staycurrent on what’s happening on the Internet is to communicate: reading, talkingand sharing sites with colleagues is really where it’s at.

9. Be Logical: The more you know about Boolean logic, the easier it is to use searchengines. “Dogs AND cats” means “find me every document that includes refer-ences to both dogs and cats.” “Dogs OR cats” means “find me every document thatEITHER has the term ‘dogs’ OR has the term ‘cats’”.

Courtesy of Greiner Environmental (developed using content from the US EPA Region 2 Library,http://www.epa.gov/Region2/library)



Participant Handout


B. Advanced Search Tips

1. Use Logical Extensions: .com for commercial,.gov for government, .org for non-profit, .net for service providers, .edu for educational institutions, .mil for military.For example, to search for the US EPA you might try: www.epa.gov

2. For Searching by Topic, Use Book-Length Concepts: Particularly in smallercatalogs, it is often useful to construct your search terms as if they were the title ofa book, magazine article or videotape. A search for “dog grooming” or even “pets”may retrieve more useful sites than “cocker spaniel”; “Chinese Cooking” will bebetter than “steamed dumplings”. This approach will also help you maintain asense of orientation in your searching through retrieving links to top-level siteswhere you can then search for items in context.

3. To Zero in on a Specific Item, Use the Term Itself: If, on the other hand, you arelooking for a person, place or thing—a hotel, for example—using that specificterm will often be most effective. Try this in a catalog such as Yahoo—look foryour alma mater, or a hotel you recently stayed at.

4. Find Out What Level the Search Engine or Catalog Indexes: Some search engines,such as Alta Vista, index every single document on a site. Other search engines andall catalogs seek and index top-level documents. If you are looking for an ex-tremely obscure document with a distinctive term, and you remember nothingelse about it, Alta Vista could really shine at this search, particularly if you’rewilling to invest the effort to learn how to construct advanced searches. If you’relooking for the Sheraton Hotel or some new resources on coatings, you may wantto start with Yahoo, Excite, or Northernlights.

5. Understand Search Engine Defaults: Are terms strung together without Booleanoperator (for example, “dog cats”) treated as if they are connected with OR (“dogsOR cats”)? Or does the search engine string these together as “dogs AND cats?” Oris that considered a phrase, as in “United States?”

6. Find Out How the Search Engine Indexes Documents and Returns “Hits”: Is itsearching the entire document, the first paragraph, the URL, the title...? Does ithave stopwords (words it won’t search for, usually because they occur very fre-quently, such as articles and prepositions)? Or would a search for “The Silence ofthe Lambs” search for two words or five?

7. Find Out How to Customize a Search in that Particular Tool: How are date rangesconstructed? What about truncation or wildcarding? Exact-phrase searches can beextremely precise, as well (many, but not all, search engines support exact phraseswith quotation marks, as in “Silence of the Lambs”).

8. Organize your bookmarks: When you begin gathering many, many URLs, useyour browser to organize your bookmarks or consider some of the commercialtools to enhance and maintain your bookmarks.

5 cont’d

Module 5

Instructor Notes



WWWHave Participants Return to: http://www.turi.org/HTMLScr/net/

Section I Closing

Make sure to remind students to revisit the Internet within a

week, so that they can remember what they have learned. For

more practice or help, participants can visit the training site in

the future.










course offering.




+ ∆

Section II

Encourage participants to go to the online “Course

Evaluation” (refer to page 47 screen shot). (See next page.)

Nex

t…



Module 6

➞

On-line CourseEvaluation


Instructor Notes

Optional: Ask participants to complete the course evaluation on

the Internet training site (refer to page 47 screen shot of the on-

line evaluation form) and submit it by e-mail. Check the correct

URL for the evaluation form.

If you do not ask participants to complete and submit a course

evaluation electronically, ask them to fill out the printed

evaluation form on the opposite page and hand it in before

they leave the training.

Evaluation


Participant Evaluation

Hands-On Pollution Prevention Internet Training

Evaluation Form

Please complete both pages of this brief evaluation. Results will be used to improve this program. The goals ofthis training are 1. to improve participant understanding of the Internet as a resource in identifying P2 tech-nologies, 2. to improve participant ability to use the Internet for P2 research, and 3. to increase participantinclination to seek out Internet resorces when faced with P2 questions. Please rate the following elements oftoday’s workshop, both in terms of their usefulness in reaching the instructional goal and their overall quality.Please provide written comments in the space provided to explain your rating or to offer suggestions forimprovement.

1. IntroductionsComments:

2. Internet BasicsComments:

3. Internet SearchesComments:

4. Pollution Prevention ResourcesComments:

5. Researching a P2 QuestionComments:

6. Closing/EvaluationComments:









Instructor Notes




IntroductionsInternet BasicsInternet SearchesPollution Prevention ResourcesResearching a P2 QuestionClosing/Evaluation

Comments:






cont’d


Instructor Notes






DEP



InformationAccess






natural resources.



Media Cross-Training


2 Media Cross-Training

Media Cross-Training Contents

Why A Media Cross-Training Program? ................................................................................................................ 3What Does an Environmental Media Cross-Training Program Look Like? ......................................................... 4Initiating a Media Cross-Training Program ........................................................................................................... 6Should Your Agency Do A Media Cross-Training Program? ................................................................................ 6How to Assess Whether Your Agency Will Benefit? ............................................................................................... 7Some Final Tips for Executing A Successful Multi-Media Cross-Training Program ........................................... 7

AppendicesA. Pollution Prevention Integration: The Media Cross-Training Content Template ........................................... 9B. Annotated Agenda — Media Cross-Training Developers’ Meeting ................................................................. 12C. Train-the-Trainer Handouts

1. Key Concepts In Adult Learning .................................................................................................................. 162. Do’s and Don’ts for the New Trainer ............................................................................................................ 173. Survey: Evaluate Your Training Practices ..................................................................................................... 214. Interactive Methods ...................................................................................................................................... 235. Visual Support ............................................................................................................................................... 25

D. An Integration Exercise: Putting It All Together: The Multi-Media Context ................................................ 27Scenarios 1–4 ..................................................................................................................................................... 30

This curriculum document has been developed by staff at the Toxics Use Reduction Institute (TURI)at the University of Massachusetts at Lowell. The principal curriculum and instructional designer is JodyHensley, M.Ed., Senior Education and Training Associate at TURI. Principal document editor is AnneBerlin Blackman, J.D, M.A, Education and Training Associate at TURI.

All rights to this curriculum belong to the Toxics Use Reduction Institute (TURI), the MassachusettsDepartment of Environmental Protection (MA DEP) and the United States Environmental ProtectionAgency (U.S. EPA). The material may be duplicated or used with permission. A request for permissionto duplicate and use portions of the curriculum may be made at the TURI website: http://www.turi.org.

The views expressed within this curriculum document do not necessarily represent the statedpolicies of the above agencies nor does citing of trade names or commercial processes constituteendorsement.

The Toxics Use Reduction Institute is a multi-disciplinary research, education and policy centerestablished by the Massachusetts Toxics Use Reduction Act of 1989. The Institute sponsors and conductsresearch, organizes education and training programs, and provides technical support to governments topromote the reduction in the use of toxic chemicals in industry and commerce. Further information canbe obtained by writing the Toxics Use Reduction Institute, University of Massachusetts Lowell, OneUniversity Avenue, Lowell Massachusetts 01854, or e-mail www.turi.org.

© Copyright 1999 by the Toxics Use Reduction Institute, University of Massachusetts Lowell; theMassachusetts Department of Environmental Protection; and the United States EnvironmentalProtection Agency.

DEP


Media Cross-Training 3

Media Cross-Training for PollutionPrevention IntegrationA Guide to Developing a Cross-Training Program for Environmental Regulatory Staff

Why A Media Cross-TrainingProgram?

Once upon a time there was a group of people whowere tasked with trying to identify an elephant whileblindfolded. The story goes something like this: Theone who grasped the tail said, “This must be a rope.”The one who grasped the trunk said, “This must be ahose.” The one who felt the side said, “Well, surely,this is a large leather–covered wall.” The one whotouched a tusk said, “I know this is a spear.” The onewho felt a leg said, “I am standing before a great tree.”The lesson – your perception of the whole dependson which part is closest to you.

In order for this group of people to clearly identifythe creature before them, they have to take off theirblindfolds and examine not only the portion of thebody before them. They must see the whole animal.Manik Roy, Ph.D., cited this parable in an early articleon pollution prevention in the late 1980’s. It is also ametaphor for systems thinking – the ability to see thewhole system and to understand one’s own signifi-cance in it and the relationship of one’s part to theother parts of the whole. (“Grasping the LearningOrganization”, Training and Development, pp. 38 – 42,June 1994.)

Environmental protection faces these same challengeswhen trying to identify and solve environmentalproblems from a single-medium perspective of eitherair quality, water quality, or land related issues.Granted, progress in environmental protection hasbeen made for nearly three decades using a pollutioncontrol approach implemented through single-medium statutes and regulations. However, thatapproach had led to organizational structures inenvironmental agencies shaped around single envi-ronmental medium concerns. These organizationalstructures shape the way environmental officials seeand do the work of environmental protection.

It has been widely accepted that an approach thatconsiders all the environmental media simultaneouslywhen working to solve environmental problems is themost effective way to make progress in one areawithout adversely impacting another.

A whole-facility, pollution prevention approachrequires an integrated look at what materials are used,and how they are used, throughout the productionsystem. This perspective considers the source as wellas the ultimate fate of those materials, be they re-leased to the air, to water or to land, or lost or trans-formed somewhere in the production process. Thissystems perspective considers what is movingthrough the production process rather than just whatis being emitted to one environmental medium inone place as does the traditional single-mediumframework.

This integrated approach to environmental protec-tion requires changes in work design for the environ-mental official. Integrated environmental protectionrequires an expanded knowledge and skill base for theindividual and improved links among individualprograms in the organization. A growing understand-ing of multiple media regulations - regulationsoutside one’s own program - and a working under-standing of a variety of industrial sectors provide aknowledge base from which the environmentalprofessional can begin to consider pollution preven-tion as s/he interacts with regulated entities.

Cross-training among existing programs in anenvironmental agency can help form the foundationfor integrated environmental protection. The envi-ronmental media Cross-Training program describedin this guide is designed to achieve the followingobjectives:■ to provide an introductory overview of each of an

agency’s regulatory programs for staff working inother programs

■ to develop staff skills in developing and presentingprogram background and content


Pollution Prevention Integration: The MediaCross-Training Content TemplateA content template was developed for use by present-ers from each environmental media subject area. Thepurpose of the template is to help in the developmentof each cross-training module’s content and to try toensure consistency of subject coverage across mediaprograms. (See the content template developed in theMassachusetts Pilot program in the Appendix.) Ofcourse, all categories on the template may not applyto a particular program, or there may be someadditional special areas for a given program that needto be included.

Cross Media Train-the-Trainer: PresentationDevelopmentOnce each regulatory unit has selected presenters fortheir programs, those presenters gather at a Cross-Training Developers Meeting. This is a day fortraining staff presenters in how to design and deliverinformation from their environmental program in away that is engaging and effective. Training specialistswill need to design and organize this one-day (or ½day) meeting. The following agendas and materialswere used in the pilot cross-training program at theMassachusetts Department of Environmental Protec-tion.

■ Sample Agenda for Train-the-Trainer

Bureau of Waste PreventionMedia Cross-TrainingDevelopers’ Meeting

9am – Noon

9:00 Introductions and Expectations for the Day

The Purpose of the Media Cross-TrainingProgram and this Train-the-Trainer Experi-ence; Schedule for the Media Cross-TrainingProgram – from development through delivery

9:30 The Cross-Training Content Template

Questions and Answers

10:15 Break

10:30 Training Tips and Interactive Training Tech-niques

11:30 Logistical Considerations and PresentationSupport


Noon Adjourn

■ to improve peer communication among agencyprograms

■ to help staff develop an integrated perspective onenvironmental protection

What Does an Environmental MediaCross-Training Program Look Like?

Pollution Prevention Integration: A TrainingCurriculum for Environmental Agency StaffEnvironmental Media Cross-Training Program(for basic cross-media literacy)

This Media Cross-Training Program was piloted atthe Massachusetts Department of EnvironmentalProtection in January and February of 1997 andrepeated three additional times in April, May andJune of 1997. The three days of training were devel-oped to provide a level of basic cross-media literacy(air, water, hazardous waste and solid waste) amongstaff in the Bureau of Waste Prevention. Since pollu-tion prevention and cleaner production options aregenerally whole system in nature, environmentalmedia Cross-Training is considered a foundation forother courses in the Pollution Prevention Integrationcurriculum.

The Media Cross-Training Program was developedusing in-house agency program staff rather thanoutside trainers. Media subject matter experts(SME’s) were selected from among the air, water andwaste programs. These presenters worked withtraining specialists to develop presentations andtraining exercises. The training specialists developed across-training template for media presenters to use inbeginning to develop their presentations. Presentersattended a train-the-trainer session conducted bytraining specialists who then convened severaladditional working meetings and coaching sessionsfor providing help in developing training talks andexercises. Agendas for each of the three daylongtraining sessions were developed in these workingmeetings. All program presentations were covered inthree days with a cross-media integration exercise onthe concluding day. A formative evaluation (dressrehearsal) was held for each of the training days. Thetraining series was offered to groups of 25–35 partici-pants.


(See annotated agenda with instructor notes for the“Media Cross Training Developer’s Meeting(Train-the-Trainer) in the appendix along with handouts fortrainees)

After an initial train-the-trainer session, individualpresenters begin to develop their presentations. Oneof the challenges for cross-training program coordi-nation is fitting the various presentations together inan overall program agenda. Following are the agendasfrom the three days of training done for the pilot ofthis training program.

■ Sample Agendas From the 3-DayMassachusetts Cross-Training

Massachusetts Department ofEnvironmental Protection

Bureau of Waste PreventionDay One

Environmental Media Cross-Training

9:00 Welcome and Introduction

9:05 Overview to the Massachusetts Toxics UseReduction Act

9:40 Industrial Wastewater

10:50 Break

11:00 Industrial Wastewater continued

12:00 LUNCH

1:00 Hazardous Waste Programs

2:30 Break

2:40 Hazardous Waste Programs continued

3:10 The Toxics Use Reduction Program

4:30 Adjourn


Bureau of Waste PreventionDay Two



9:05 Public Health Based Standards

9:55 History of State and Federal Air QualityControl

10:15 Assessment and Characterization of AirQuality

10:35 Break

10:45 Program and Planning to Comply with theClean Air Act

1) Stationary Source Program

2) Mobile and Area Programs

12:15 LUNCH

1:15 Inspection and Maintenance Program:Emissions Checkup

Introduction, Technology, Scenarios,Conclusion

3:05 Break

3:15 Programs and Planning to Comply with theClean Air Act

3:00 Administrative Compliance

3:40 Regional Air Quality Activities

4:05 New and Future Initiatives

4:30 Adjourn


Bureau of Waste PreventionDay Three



9:05 Overview of Solid Waste Management

9:50 Compliance, Enforcement and Regulations

10:35 Break

10:45 Composting

11:15 Recycling

12:00 LUNCH

1:00 Putting It All Together: The Multi-MediaContext* (interactive exercise – see appendixH)

1:45 Scenario Activity Reports (from the exercise)

2:45 Break

2:55 Multi-Media Initiatives at the MassachusettsDEP

4:30 Adjourn

* Notes for this P2 Integration Exercise are included inAppendix H.


Initiating a Media Cross-TrainingProgram

More than any of the other courses in the PollutionPrevention Integration Curriculum, the Cross-Training Program requires cross-program manage-ment alignment. Managers and supervisors will notbe devoting just one day of their staffpersons’ time asa participant in each day of training as with the othercourses. In cross-training, staff are selected from eachprogram to develop and present the content. Thismeans someone is selected from each regulatoryprogram to:■ participate in a cross-training developers

conference (1/2 to one day),

■ to spend time drafting materials and designingtheir presentation,

■ to go to presentation coaching sessions, and

■ to rehearse their near-finished presentation at a“dry-run” of their training day.

This work is done before presenters actually delivertheir presentations to 25-35 other staff members fromprograms throughout the agency. And if the programis especially successful, the cross-training agenda willprobably be presented more than once.

The “Innovative P2 Course Delivery Worksheet”provided in the Part IV of the introductory section ofthis manual can help in generating a task list forproject management of this Media Cross-TrainingProgram.

Should Your Agency do a Media Cross-Training Program?

There are advantages to developing and offering amedia Cross-Training program:■ staff become motivated and re-energized at the

prospect of telling the story of their own programto others in the agency

■ experts from within the media programs who haveyears of experience often have more credibilitywith their peers than an outside presenter

■ staff gains new skills and experience in deliveringthe message of their programs

■ new connections and relationships within theagency are built and those contacts continue afterthe training. This often results in morecomprehensive information being brought to bearon the inquiries environmental regulators dealwith on a daily basis.

■ cross-training speeds up the organizationallearning process. Participants gain perspective onthe big picture and how various units andfunctions relate to one another.

■ staff people find it useful: “I got a great deal out ofthe meeting and interacting with the live humanbeings from other programs. Being able to askquestions in an interactive forum is extremelyvaluable to me.” “By being better versed in thenames, faces, terminology of other programs, Inow know where I can go for information and Ican ask better questions.” – comments fromevaluations of the cross-training pilot inMassachusetts.

There are also challenges in delivering a cross-training program:■ Developing presenters and presentations takes a

fair amount of time for program staff memberswho are giving the training talks and for trainingstaff who are helping develop the presentationsand exercises.

■ Achieving brevity, conciseness and clarity ofpresentation requires effort, especially for staffmembers who don’t do presentations regularly.Train-the-trainer sessions and coaching will berequired to various extents depending on theexperience and comfort level of the presenter inorder to make training time most worthwhile fortraining participants.

■ Providing a tangible link between the cross-training and day-to-day activity can be tricky.Cross-training is a capacity building endeavor. Assuch, its application to staff work is less concretethan some staff are accustomed to. Seniormanagement must support and explain thesignificance of the program, connecting it tobroader agency goals and giving examples of dailyusefulness.


How to Assess Whether Your AgencyWill Benefit?

Cross-training is a step on the path to what contem-porary management theory calls the learning organi-zation. Peter Senge of the MIT Center for Organiza-tional Learning has advanced this notion mostrecently and widely. Learning is considered to be theprocess of enhancing our capacity for taking effectiveaction. Levels of learning include individual, groupand team, organizational and societal. Learning at theorganizational level can be advanced through five setsof practices or “disciplines” which include systemsthinking, personal mastery, mental models, sharedvision, and team learning. Though difficult to definesuccinctly, Linda Honald, a human resources execu-tive with Johsonville Foods, describes the learningorganization as follows: “A learning organization isone whose members are continuously, deliberatelylearning new things. They apply what they learn toimprove: a) the product or service quality, b) theprocesses involved in making the product or provid-ing the service, c) the quality of the environment inwhich the employees work, and d) the performanceof members of the organization.”

A training program in and of itself will not createor guarantee improved organizational learning. Whendeciding whether to embark on a multi-media cross-training program, an agency should consider what itwants as an outcome for such a program and assesswhether it is likely to be successful. Some conditionsfor successful cross-organizational learning aredetailed in Learning Organizations, DevelopingCultures for Tomorrow’s Workplace, Chawla andRenesch, Productivity Press, 1995. (pg. 398, 401)These items might be useful to consider when assess-ing the likelihood of success for a multi-media cross-training program:

The following questions point to some conditions forthe success of collaborative learning across organiza-tional boundaries:

■ Is there recognition in the organization of thevalue of cross-organizational experiences and oflearning by teaching?

■ Does the organization have some level of maturityon the learning continuum? (i.e., experience withvision building)

■ Will senior executives and line managers committo a long-term program and involve themselvespersonally in the learning sessions?

■ Can a non-competitive atmosphere be created sothat the learning environment is safe for sharingall relevant experiences and information?

■ Will a core team of facilitators combining generaland specialized skills be involved in and betweenthe meetings to help structure a cumulativelearning experience and increasingly involve theparticipants in designing and co-leading thesessions?

■ Is there a willingness to experiment in content andformat from session to session and a commitmentto dialogue and collaboration? (i.e., to publicrefection on the experiments and learnings.)

■ Will participants be encouraged to take time forexchanges through computer networks and sitevisits between the general sessions?

■ Is there a focus on personal development and onchallenging one’s mental models or can one beadopted from the beginning and throughout thecross-training program?

Some Final Tips for Executing ASuccessful Multi-Media Cross-TrainingProgram

■ Management and Scheduling of the Cross-TrainingProgram

It is highly recommended that you refer to theworksheets in the introductory section of thiscurriculum manual to as you begin to plan thecross-training program. They include the“Innovative P2 Course Delivery Worksheet” andthe “Pollution Prevention Integration New CourseDevelopment Checklist”. The preliminary steps oneach of these worksheet involve includingappropriate agency stakeholders from the outset ofthe program and setting realistic expectationsabout the commitments required from eachprogram.


■ Dry-Runs: the importance of rehearsal time

Don’t skimp on rehearsal time. Presentationpractice sessions are important as individualportions of the training program develop. But arun through of the entire training day in front of asmall audience which is similar in nature to thefinal target audience will vastly improve thequality of presentations and therefore theseriousness with which participants will considerthe information and intent of the program.

■ Evaluations: In Course and written

Getting feedback from participants directly isimportant for continuously improving the cross-training program. The feedback on evaluationscan also be an important tool for agency

management to use to get a sense of theknowledge, skill, attitude and even importantstrategic information from the staff perspective.

Both in-class feedback and written evaluation areimportant. See samples of these at the conclusionof any of the courses in the Pollution PreventionIntegration Curriculum.

■ Creating a Summary Document

Presenters will be pulling information togetherfrom programs across the agency to prepare forthis multi-medium Cross-Training program.Pulling these handouts and presentation notestogether can produce a binder which is a valuableorientation of the work of the agency.


Instructor NotesThe Content Template for Presentation Development

Pollution Prevention Integration: The Media Cross-TrainingContent Template

The purpose of the following template is to help in the development of each cross-training module’s content and to try to ensure consistency of subject coverageacross media programs. Of course, all categories on the template may not apply to aparticular program, or there may be some additional special areas for a givenprogram that needs to be included. It’s important to remain flexible rather thandeveloping a firm agenda from the beginning. The presentations develop and fittogether over time and may be readjusted several times along the way for the bestresults.

Some points to keep in mind:

■ Generally these media training modules are intended to be a half-day in length(approximately three hours). Each half-day will include several programs withineach media. In some cases where the programs are particularly complex (air forexample) more time may be necessary to cover the information adequately. Asprograms select their presenters, and as presentations develop, an overall agendafor the cross-training will emerge which will include time allotted for eachmodule. Presenters need to remain flexible as this process develops.

■ The staff who will attend these modules may know something, but probably nota great deal about environmental media programs other than their own. Theaim is not be comprehensive but to provide a working knowledge of the basicsfor participants from other programs.

■ Where possible, it would be helpful to include case examples or real-worldanecdotes to illustrate the facts being presented.

■ Provide the audience with handouts that capture key points. (Copies ofoverheads, roadmaps of media contacts, further information resources, etc.)The training specialists working with this cross-training program shouldprovide production help with these materials.

■ Make sure to build question and answer sessions into each session and find waysto using interactive learning exercises in your module.

Appendix A


Instructor NotesContent Template Outline for Media Cross-TrainingPresentation Development

Welcome and Introduction

Objectives of the module

Key information that the audience will gain

The Agenda for the session

Definitions and Background

What’s covered in your media program?

What is the nature of the pollution regulated in your program?

What are the environmental and health implications being addressed by yourprogram?

What do we regulate?

Why do we regulate it?

Legal Mandates

State and Federal authority

Legal requirements, thresholds, etc.

Universe of Sources

Generator status: facility types, mobile or other sources

Major kinds of violations

Major kinds of treatment systems, control equipment, recycling processes

Potential media transfers through pollution control or treatment

Quick Overview of Applicable Regulations

Regulatory Mechanisms

Overview of permit categories

Regulatory requirements such as reporting and/or planning requirements, recordkeeping, management practices, labeling requirements, certification,modifications, etc.

Compliance and Enforcement Tools and Techniques

Overview of compliance inspection protocols

Other inspection tools (sampling, monitoring, planning, certifications, etc.)

Overview of enforcement mechanisms

Compliance assistance and incentive programs

Major agency initiatives

Pollution Prevention Opportunities and Barriers

New Trends and Initiatives in the broad perspective, i.e., regulatory, technical,political, etc.

Appendix A

Content Template Outline


Instructor Notes

Agency role and other stakeholders

State, local federal interaction

Environmental groups, industry associates

Consumer and public concerns

Sources of Information

Within the agency

EPA

Regional Organizations

Other library and Internet resources

Wrap-up

Agenda review

Closing Questions and Answers

Additional handouts

Additional points to keep in mind when considering the Content Template:

The content template above is very detailed and can guide your research. Much ofthe information can be provided in writing, however, and does not have to becovered orally in the training session. Since this cross-training session is intended toprovide basic literacy for your peers in other programs, the level of detail in thepresentation need not be overly deep. Too much unnecessary detail will overwhelmparticipants and they will lose interest in the presentation. Participants can pick upthe extra information they are immediately interested in during the question andanswer time. This training is intended to help others in the agency gain perspectiveon your program and its relevance and relationship to their own program. Work todesign your module to be concise (only include what you must to make your point)and engaging (pique the participant’s interest and let them interact with theinformation).

To gain perspective on your program, some information on the history of theprogram and the issues it was created to address may be interesting, but keep thisbrief. Some illustrative descriptions of the work that actually goes on in the fieldcan bring the regulatory content to life. Actual props that can be easily transportedto the classroom are another way to bring the information alive, as are photos,videos and stories. Just remember to be mindful of the time allotted and be selec-tive about what you include.

When drafting the agenda for an individual presentation or module within thecross-training program, ask, “What would I want to know when being introducedto someone else’s program?” “What questions would I ask?” Let the answers to thesequestions be a guide in creating each presentation.

A participant in the pilot of this cross-training program in Massachusetts suggestedthe following on his evaluation form: “I would like to see every program in theagency described in the same format, such as: 1) What is the environmental con-cern?, 2) What is the desired outcome after you address the concern, and 3) Whatare the tools used to get the desired outcome? I’ll bet there are “tools” used in oneprogram which might be just as useful or better than those used in another program.”

Appendix A

Content Template Outline


Instructor NotesAnnotated Agenda: Media Cross-Training Developers’Meeting (Train-the-Trainer)

9:00 Introductions and Expectations for the DayBe sure to start the meeting on time. Begin with a welcome and introduceyourself to the group. Express your expectations for the day and for thisprogram and let developers know that they will have a chance to do the same ina moment.

(This would be an ideal time for a significant senior manager to voice theirvision and support for the program since the people here will probably beputting in time and effort beyond their routine duties.)

Review the agenda and elaborate a bit on how the day will proceed. (If you areoff-site, point out facilities along with break times.)

Next, invite participants to introduce themselves, name their programs, andshare their expectations for the day. (Capture expectations on a flip chart.)

The Purpose of the Media Cross-Training Program and this Train-the-TrainerExperience

Next, review the expectations for the day and see how they align with the purposeof today’s meeting. This will allow you and the other developers to adjust expecta-tions at the beginning of the day if necessary.

Schedule for the Media Cross-Training Program — From developmentthrough delivery

A project plan with prospective training delivery dates should have been developedwith managers of all participating programs. That schedule should be reviewedhere so that developers can manage their time accordingly. Six to eight weeks ofdevelopment time is not too much to plan for given that the cross-training devel-opers are generally still responsible for their routine duties during that time. Theschedule should also include any other presentation clinics or coaching time beingmade available by training specialists while training days are being developed. Adry-run or rehearsal presentation should be scheduled before the actual training isdelivered.

9:30 The Cross-Training Content TemplateA sample “Content Template Outline for Media Cross-Training PresentationDevelopment” is provided in an above section of this guide. This template, orone that has been developed for your agency, should be reviewed at his time.Developers will likely have questions and will want to discuss the template. It isimportant to communicate that this is a “content” guide, which is different thanwhat will necessarily be presented during their training. An engaging and usefultraining presentation will selectively choose the information and skillsappropriate for the participants and purpose of the training. The cross-trainingis aimed at basic literacy in regulatory programs other than one’s own. Detailedinformation can be presented as a handout. Training sessions will address keyconcepts in an interactive manner.

Appendix B

Annotated Agenda: Train the Trainers


Instructor Notes

10:15 BreakGive participants 10-15 minutes to stretch their legs and get refreshments beforethe meeting continues.

10:30 Training Tips and Interactive Training Techniques■ Adult Learning Basics (Individual exercise, then group discussion)

The basics of adult learning theory are covered here. This section was openedwith an exercise in which participants took a few minutes to reflect on theirmost meaningful and memorable learning experience from any point in theirlife and to think about what made this lesson so powerful. Participants weregiven a few minutes to write down their thoughts. Next, recollections wereshared in the large group. A recorder captured on the flipcharts what it was thatmade these learning experiences so memorable. From this list generated on thechart, the facilitator moved into 4 concepts in adult learning.

■ Key concepts in adult learning (review and disucss appendix Handout #1)

■ Learner Styles (present and discuss the following information)

Reaching trainees may mean adjusting to the various ways people learn. Hereare just a few ideas for appealing to differing learning styles:

• Visual learners: these learners are well served with text and graphics.

• Auditory learners: read information aloud. Talk about key concepts even if theyare already written down. Include discussion.

• Kinesthetic learners: give exercises or papers to participants and make sure theyare assigned something to do with them and required to produce a response.For these learners its best if they have to move about the room or completesome other physical task while taking in the information.

• Tactual learners: encourage these learners to highlight written materials andmake notes in margins. A cutting and pasting exercise to connect ideas willallow these folks to really get their hands on the information. (post-it noteswork wonders for these learners.)

—Based on “Different Strokes: Learning in the Classroom” by Bob Filipczak,Training, March 1995

■ Do’s and Don’ts for the New Trainer (large group discussion, see AppendixHandout #2)

This portion of the session lends itself to a brainstorming session. Prepare twoflip chart pages, one with a header which reads: “The Do’s”, and one whichreads, “The Don’ts.” Let participants offer suggestions for each list based on theirexperience. (Check out the groundrules for brainstorming in the Introductionsection of this manual.) Review the responses that are generated and see howthey compare with the information provided in the handout “Do’s and Don’tsfor the New Trainer” located in the appendix of this guide.

■ Survey: Evaluate Your Training Practices

The questions on this survey – which is located in the appendix to this guide —can be used to evaluate your training practices by identifying your strengths and

Appendix B

Annotated Agenda: Train the Trainers


Instructor Notes

weaknesses. Presenters are encouraged to ask a trusted colleague to sit in on oneof their sessions and review their presentation. This extra feedback can assist inachieving and maintaining confidence in one’s own performance.

■ Interactive Methods

Participants have already learned that exercises where adult learners activelyparticipate in the instruction are the most effective. At this point, seven methodsfor active learning are presented (see appendix – T-T-T Handout #?) The trainershould present each method and give an example. If time allows, it is mosteffective to let small groups experiment with each of these methods and thenreport back to the large group on the learning experience. To do that, thetraining specialists will need to develop questions or facts that participants canexplore via each method.

■ Methods covered here:

—Small group discussion

—Brainstorming in groups

—Journaling

—Dyads

—Role Plays

—Fishbowl

—Case Teaching

■ Exercise Development

Advise staff presenters that when considering what exercises to prepare,remember not to put the cart before the horse. Develop the agenda (or lessonplan) for your session first. Steps for agenda development include: 1) review theobjectives of the presentation or course, 2) consider what blocks of content orskill areas you want to cover in the time allotted, 3) the draft a sequence forthose content or skill areas, and 4) consider what methods or activities you wantto use for each block of content or each concept being presented. Put together adraft agenda. Consider the flow of the information, the balance between lectureand activities, and the amount of time it will take for the session. It’s importantto get feedback at this point before drafting a final agenda.

■ Materials

Participants generally like copies of overheads as handouts to take notes on atthe time of the training. Be sure to take the time to create copy materials for theparticipants attending the session.

■ Visual Support

Overhead projectors, slide projectors, computer projectors – all these media givehigh visual impact with both small and large groups. Refer to the tips providedin the Appendix – T-T-T handout #?.

Appendix B


Instructor Notes

11:45 Logistical Considerations and Presentation Support

Many logistical issues are covered in the “Introduction” section of this manualbeginning on pg. viii, Part IV. “How To Prepare To Deliver Courses From TheComprehensive P2 Integration Training Curriculum In Your Agency.” Also onpg. ix, see the “Innovative P2 Course Delivery Worksheet”. Refer to the sectionsentitled, “Course Logistics” and “On-Site Facilities Checklist.”


This is time to respond to any questions program presenters have aboutpresentation development issues, schedules, support, etc.

Noon Adjourn

(Note: A full day of train-the-trainer would allow presenters to practice some ofthe techniques covered in this agenda. This practice can take place in follow-uppresentation development session, however.)

Appendix B


Train-the-TrainerAppendix C Handout

Key Concepts In Adult Learning

■ adults learn best from their own experience

■ experience is values both in self and in the trainer

■ lessons should apply to both life and work

■ content is discovered by the learner and discussed

■ thus, learning activities structured to draw on the experience of the learner arethe most effective.

How we learn:

■ We learn:

1% through taste, 1.5% through touch, 3.5 % through smell, 11% throughhearing, 83% through sight.

■ We remember:

10% of what we read, 20% of what we hear, 30% of what we see, 50% of whatwe see and hear, 80% of what we say, 90% of what we say as we act.

It may be relatively recently that we have confirmed these facts scientifically andstatistically, but intuitively we have known them for a long time. There areancient Chinese proverbs that read: “I hear and I forget, I see and I remember, Ido and I understand.” And, “One picture is worth a thousand words.”

■ Methods of Instruction:

Studies have been done on the influence of using sound and sight, separately orcombined, as a teaching tool. Results of a R.Benschofter study concluded:

Telling, when used alone, results in 70% recall three hours later and 10% recallthree days later.

Showing, when used alone, results in 72% recall three hours later, and 20%recall three days later.

A Blend of telling and showing results in 85% recall three later and 65% recallthree days later.

Results of each study, of course, are situation specific. But similar studiesproduce similar results. This leaves little doubt about the power of audiovisualsto connect with learners with the message being communicated more effectivelyand to provide for both short term and long term retention of the content.

—adapted from materials by the National Safety Council, Itasca, Illinois.

83% through sight.

11% through hearing

3.5 % through smell

1% through taste

1.5% through touch

1


Appendix CTrain-the-TrainerHandout2

Do’s and Don’t for the New Trainer

Do’s:

■ Prepare everything in advance

This means from opener to evaluation and how every piece fits together. Beingwell prepared communicates a commitment to the needs of the learners and theplanning provides the trainer with confidence and quiets any jitters.

■ Make the objective clear

Participants must know what to expect from the presentation and what newmight be expected of them because of the training. Participants may even helpdefine the objectives either before or during the session.

■ Make the session participatory

If learners take an active role in their own instruction they will retaininformation better. They must experience or reproduce the content in anexercise. Participation allows learners to take responsibility for their ownperformance.

■ Review the agenda at the outset and stick to it

The trainer minimizes distractions by providing an agenda. Include one in thematerials or post one on the wall.

■ Encourage questions

Questions mean that a trainer has succeeded in creating an open supportivelearning environment and allow the trainer to see if the audience is grasping theinformation. At the outset, make clear that questions are welcome and stopperiodically and directly solicit questions.

■ Have an opening and a closing

Your first words create a first impression and can mobilize the audience. Useyour own style. Some possible openers include a dramatic statement, ananecdote, a question, a joke or a statistic. Closing statements summarize themain objective of the program. Possible closers include an anecdote, a videoclip, an exercise, or some other inventive close to encourage enthusiasm aboutwhat participants learned.

■ Gear the session toward learners’ needs

Assess the audience to determine expectations and desires. Even if training ismandatory, you may find some personal requirements or benefits of the session.Frame the content in helpful, solution-oriented ways to increase learnermotivation.



■ Promote networking among participants

Give participants a chance to meet each other and connect so that they canshare valuable information. Conversations about the content promote learning.Use simple introductions or shared learning goals.

■ Use visuals and varied learning techniques

Comprehension and retention increase dramatically when visual aids are used.Other interactive methods include group discussion, role-plays and games. Afew of these methods will be detailed in a following section.

■ Survey the facility in advance

Check and recheck the physical environment. (Remember Murphy’s law.) Checklights, pens, computers, cameras, audiovisual equipment, chairs, tablesflipcharts, materials, refreshments. Have backup equipment available.

■ Dress appropriately

What you choose to wear communicates that you take the trainingresponsibility seriously. A rule of thumb is to dress one step above how youexpect your participants will dress.

■ Market your training program internally

By alerting employees to the value of your training program you ensureadequate attendance. This also advertises the role you play in yourorganization’s success.

■ Incorporate transfer of training techniques

The real impact of training happens when new skills and knowledge are appliedon the job. Partner with managers and supervisors to promote transfer oftraining. Ask how they will support or reinforce what was taught in theprogram?

■ Evaluate

Evaluation is closely tied to learning objectives. You can use surveys, large groupfeedback sessions, tests, observations or other methods to ascertain whatworked in the training and what could be improved.

Don’ts:

■ Start late

Open on time and proceed after breaks on time. Some tips for gettingparticipants back on time include: setting an unusual duration for the break,i.e., 8.5 minutes, declaring that all stragglers will have to sing to regain entry,assigning one or two people to be responsible for bringing in latecomers,bribing participants with a reward.

2 Do’s and Don’ts continued



■ Antagonize, condemn, loose patience with or otherwise embarrass aparticipant

This is self-explanatory. Don’t engage when antagonized. Return the focus to theintended learning. Volunteer time to answer questions outside the session ifsomeone is struggling with the content.

■ Fake it

If participants ask questions for which you don’t have the answer, acknowledgethe value of the question and promise to research the answer. You can alsopresent the question to other participants who may have insights into theanswer.

■ Imitate a statue.

Move about the training space. Your movement helps participants stayinterested.

■ Let discussion stray

Keep the objectives of the program in mind and intervene with questions thatpoint back to the main point.

■ Indulge your quirks

Consider working with another trainer to help spot some of these often-unconscious habits. Some may include clicking your pen, swaying back andforth, saying “um” and “y’know”. Identifying these quirks is the first step ineliminating them from you presentation.

■ Saturate learners with information

Deliver one segment of information at a time and do not exceed 20 minutes ofpure content delivery at one time. Follow each segment with and exercise,activity or questions.

■ Confuse the means with the end

Don’t get so carried away with the method of delivery that it overshadows yourcontent.

■ Rely one method of delivery

Vary the training methods and make the session interactive.

■ Get stale

Even if you’ve offered a training numerous times, it is new information for thelearners so its bound to be fresh and interesting for them. Let that insightrefresh your approach.

■ Try to go it alone

Work with and learn from others with more experience, both with content,training materials and training methods. It also helps to work with others whoare tasked with creating the same kind of training.

Do’s and Don’ts continued


Train-the-TrainerAppendix C Handout2

■ Worry

When you become anxious about new challenges, relax. There are plenty of resources available to help you gain the knowledge and experience you need. Ifyou are enthusiastic and sincerely interested in helping your participants, theguiding principles contained among these “Do’s and Don‘ts for the NewTrainer” won’t steer you wrong.

— based on ASTD Infoline Training Basics

Do’s and Don’ts continued



Evaluate Your Training Practices

■ Survey: Evaluate Your Training Practices

The following questions can be used to evaluate your training practices by identifying yourstrengths and weaknesses. Ask a trusted colleague to sit in on one of your sessions andreview your presentation. This extra feedback can assist in achieving and maintainingconfidence in your training performance.

Did you prepare everything? ❏ yes ❏ no

Did you make the objective clear? ❏ yes ❏ no

Did you make the session participatory? ❏ yes ❏ no

Did you tell your learners the agenda at the outset and did you stick to it? ❏ yes ❏ no

Did you encourage questions? ❏ yes ❏ no

Did you avoid antagonizing, condemning, losing patience with or embarrassingparticipants? ❏ yes ❏ no

Did you have an opening and a closing? ❏ yes ❏ no

Did you gear the session toward learners’ needs? ❏ yes ❏ no

Did you promote networking among participants? ❏ yes ❏ no

Did you use visuals and varied learning techniques? ❏ yes ❏ no

Did you survey the facility in advance? ❏ yes ❏ no

Did you dress appropriately? ❏ yes ❏ no

Did you market your training program internally? ❏ yes ❏ no

Did you incorporate transfer of training techniques? ❏ yes ❏ no

Did you evaluate learners’ performance? ❏ yes ❏ no

Did you start on time? ❏ yes ❏ no

Did you admit when you didn’t know the answer to a question? ❏ yes ❏ no

Did you move around the room? ❏ yes ❏ no

Did you keep discussion on track? ❏ yes ❏ no

Did you avoid your quirks? ❏ yes ❏ no

Did you give learners just the right amount of information? ❏ yes ❏ no

Did you focus on the end, not the means? ❏ yes ❏ no

Did you vary your method of delivery? ❏ yes ❏ no

Did you stay interested in the material? ❏ yes ❏ no



Did you structure your role appropriately for the situation? ❏ yes ❏ no

Did you position yourself as an essential asset to the organization? ❏ yes ❏ no

Have you asked seasoned practitioners for help in developing your role? ❏ yes ❏ no

Did you remain calm? ❏ yes ❏ no

—from Job Aid: Evaluate Your Training Practices, ASTD

3 Survey continued


Appendix CTrain-the-TrainerHandout

Interactive Methods

We’ve already established that when adult learners actively participate in theinstruction, learning is enhanced and retained more effectively. Below are sevenmethods for active learning.

Small group discussionPutting participants into groups of 5-7 encourages more active participation from agreater number of learners. The smaller group is more intimate and less intimidat-ing. When using the small group method, break the class into small groups andallow them time few minutes to get acquainted with one another. Give clear in-structions regarding the work of each small group. Watch the time allotted for theexercise and monitor discussions to see if you are needed to help some groups get“unstuck” and keep groups focused. Encourage a summary of the results from thegroup discussion and use flip charts for the report out. (For more information, seeIntroduction section of this manual, part VI, Training Methodology.)

Brainstorming in groupsThe purpose of a brainstorming exercise is to open up a group’s creative energy andproduce a large number of ideas in a short amount of time. The guidelines for thisactivity are: 1) all ideas are OK; 2) there should be no evaluation or comment onideas at this stage; and 3) participants should build on one another’s ideas. To beginthe activity, you might say, “Let’s come up with about 20 ideas on (your topic orquestion) in the next 10 minutes.”

JournalingThis activity allows participants to think on their own and encourages everyone inthe group to participate thoughtfully. For this exercise, you pause the session forabout 5 minutes while participants write down their thoughts in response to aquestion or an issue. It’s important to adhere to the time you’ve set aside and togive clear instructions about what group members should be considering as theywrite. At the end of the writing time, ask for volunteers to share their thoughts inthe large group.

DyadsBreaking into pairs is a quick and efficient way to promote participation and it’s aneasy way to achieve rapport within the group. This activity may be initiated bysaying, “Turn to the person next to you, introduce your self and talk about (yourtopic, issue or question).” Another tool for using dyads regularly to reinforcelearning is called “Around the Clock Learning Partners.” At the beginning of thesession hand out a paper prepared with a clock face and a space next to all num-bers, i.e., 1:00_______, 2:00______, etc. At the opening of the day, have participantsmill about and make an appointment with someone else in the class for the twelvedifferent time slots on their clock. Remind learners not to make an appointmentwith a partner unless they both have the same time slot open. (There must be atleast 24 in the class for all spaces on each person’s clock to be filled with different

4



people.) Tell the group, “Every-so-often throughout the day we’ll stop to check-inwith a learning partner to consider a question about the content presented.”

Role PlaysThe role playing activity is intended to examine a problem, explore solutions andprovide insight through acting out a given situation. In role playing a hypotheticalsituation is clearly defined including the roles of the people involved. Individualsare selected to play the various roles and to act out how the situation may proceed.After a set of participants have role played for a short time, the instructor allowstime for the rest of the class to discuss and process what happened in the role play.For example: what was done well or realistically in the role-play? What rang true?What might be handled another way? After discussion, the role-play may be done asecond time incorporating feedback from the rest of the class.

FishbowlsA fishbowl exercise allows one small group to observe and learn from another smallgroups’ discussion. It also allows the observing group to offer feedback to theparticipating group. This is a useful way to gain the increased participation of asmall group discussion while allowing all participants access to the same discussiondata. To do this exercise, 5-7 chairs are placed in an inner circle. Another ring ofchairs is placed around the inner group. The inner ring “A” is the discussion group.The outer ring “B”, is an observation group. Group “A” discusses a question for agiven time. Then discussion is stopped. Group “B” then offers comment andfeedback on Group “A’s” discussion.

Case teachingIn the case method, a comprehensively developed problem is presented for studyand solution. This method is used often to improve problem-solving and strategy-related skills. In the case method, a case study must thoroughly and clearly presenta problem and include roles, responsibilities and situations which must be consid-ered in light of issues left unresolved in the case. Questions are then put before thelearners about the implications and best course of action in the case study. Encour-age participation from all class members and gear tasks associated with the case toparticipant’s backgrounds. Allow time for debriefing after a case study. Cases areopen-ended and there is often no right answer. Participants learn from each other’sthinking.

4 Interactive Methods continued


Appendix CTrain-the-TrainerHandout

Visual Support

When preparing transparencies for projection, keep the following in mind:

• keep them simple

• use keywords, phrases and numbers

• use large lettering so they can be seen from the back of the room

• bring them alive with color, cartoon, and pictures

• sketch a draft before the final projection

• use a border within the frame – it looks good

• split the frame into more than one section – it makes it easier to revealinformation step-by-step

• make sure they say exactly what you mean

Following are some helpful hints on using an overhead projector.

(Some of these hints apply to computer generated presentations also.):

• Before the presentation make sure people in the back row can see the screen.When you use it don’t stand in front of it.

• Don’t point with your finger – use a pencil. Place the pencil on the screen of theoverhead projector and use it as your pointer. (for computer projectedpresentations, use the cursor.)

• Don’t allow the unit to go out of focus. Check this before you begin.

• Don’t leave the transparency (or computer image) on all the time. Use it tostimulate thought. When you have finished with an idea, turn it off.

• Don’t have the room so dark that the audience can’t see you.

• Don’t become too casual and start talking to the screen or turn your back on theaudience.

• Try using two projectors, one for your main agenda and the other for detail ofyour subpoints. (this takes a bit of practice)

• Use overlays to add dimension and progression to you message.

• Rather than exposing all your information at once, have a sheet of paper overthe transparency and slide the paper down to reveal information one line at atime.

• Use pens to highlight prepared transparencies and actually fill in blanks whileyou’re talking.

5



Flipcharts are another active and effective visual.

A flipchart can be use to record and present information and ideas during presen-tations; to outline and reinforce key points; and to present illustrations, sketches,graphs, diagrams and other visuals. When using a flipchart, keep the following inmind:• stand to the side of the chart so it is always visible and so that you face the

audience

• place a blank sheet between each prepared page to keep pen marks comingthrough to the next page

• write clearly and quickly when creating “live” charts

• turn pages smoothly with minimum distraction

• have the easel high enough for everyone to see

• place tabs on the side of the charts you want to refer to again in your talk

• don’t reveal a chart until you are ready for it

• don’t remain silent while you present a flipchart

5 Visual Support continued


Appendix DP2 Integration Exercise

P2 Integration Exercise: Putting It All Together

An Integration Exercise: Putting It All Together:The Multi-Media Context

(an exercise developed by Jody Hensley and Anne Berlin Blackman of theMassachusetts Toxics Use Reduction Institute)

Outline of the Training Exercise:

Overview of the Exercise:

“Putting it All Together: The Multi-Media Context” 5 minutes

Background Information 10 minutes

Small Group Discussions 30 minutes

Small Group Reports and Discussion 40 minutes

Recap and Conclusion 5 minutes

Learning Objectives:

After completing this exercise participants will:1. understand and articulate several cross-media pollution transfer issues

(knowledge based objective)

2. begin to identify cross-media issues while conducting regulatory activities (skillbased object)

3. consider working with facilities to undertake source reduction where possible(attitude based objective)

4. work with colleagues in other agency units to begin to build integratedapproach to environmental issues at regulated facilities (strategy basedobjective)

Background:This activity comes at the end of the individual cross-training program presenta-tions. It is assumed that an introduction to pollution prevention has been given. Atthis point briefly review the philosophy of pollution prevention and integratedenvironmental protection.

Some Key points:There should be a review of the source reduction hierarchy, from incineration, todisposal, to recycling, to reuse, to source reduction with pollution prevention (P2)being the preferred method for environmental protection. (Don’t get hung up onoverly precise definitions, but emphasize that the point is to move toward the P2end of the spectrum.)

Instructor Notes


Appendix D P2 Integration Exercise


Participants will be asked to consider the impacts of a given regulatory action fromseveral perspectives, i.e.,• Regulatory issues: relevant regulations, permits, reports, inspections, notices

and plans;

• Environmental issues: air quality impacts, water quality impacts from use anddisposal, hazardous waste transfer and disposal impacts, and solid wastedisposal impacts;

• Related issues: worker health and safety, consumer impacts, other parts of theenvironment, and general public health.

Some scenarios will ask the group to consider a regulated facility’s point of viewand the options that plant management may have to consider in moving towardpollution prevention. For example, the facility personnel may want to explore:

• Process characterization: to better understand where toxic substances and othermaterials are used and how they flow through the production processes.

• Materials accounting: to decipher just how much of each material in theproduction process is: input, consumed or transformed in-process, becomesnon-product output or by product, becomes finished product, or is emitted tothe environment.

With new information from these analyses, facility personnel could look foropportunities for input substitution, process modification, processmodernization, operation and maintenance improvements, productmodification, and integral recycling.

The broader questions intended to be explored through these scenarios include:

■ How can the agency’s regulatory actions be best coordinated to promoteintegrated environmental protection, such as whole facility waste prevention,source reduction, and toxics use reduction?

■ What media programs and staff functions would have to interact in order togain an integrated perspective? How might such interaction favor the selectionof the most appropriate regulatory actions and yield the best environmentalresults?

Group Exercises:Break out participants into several small groups. Groups should arrange themselvesso that each group has representatives from as many different regulatory programswithin the agency as possible.

Each group will be given a written scenario. (See the following pages for copies.)During the small group discussion period, participants should prepare for a reportout to the large group.

Instructor Notes




Group #1 Exercise: introduces the idea that an approach to compliance with oneregulatory program (here, retrofitting a source with a scrubber to meet air emis-sions standards) can cause increased emissions to other environmental media.Participants should be able to define the problem as multi-media in nature. Thisgroup exercise is also designed to encourage participants to formulate a multi-media solution to the problem. This exercise highlights the possibility of regulatorybarriers to taking a cross-media approach, i.e., many laws and regulations aresingle-medium and/or prescriptive with regard to acceptable compliance options.

Group #2 Exercise: points out the disconnect between the single-medium orienta-tion of the environmental regulatory framework and the multi-media nature of theproblem. This group exercise introduces the idea that a cross-media approach isbetter equipped than a single-medium orientation to analyze comparative risk andrisk-shifting (from air to water, from worker to consumer, etc.) This exercisehighlights the challenges of analyzing potential environmental impacts associatedwith the implementation of innovative technologies.

Group #3 and Group #4 Exercises: focus on changing the way regulators view oneanother and their own organizations (whereas #1 and #2 focus on changing the wayregulators approach regulated facilities.) These exercises highlight institutional andorganizational barriers that may prevent agency staff from viewing a facilityholistically.

Debriefing after the Small Group Exercises

After all small groups have reported on their discussions of scenarios #1 through#4, stimulate some discussion which might bring insight regarding the power forreaching better solutions by looking cross- media when considering environmentalproblems.

Some open questions might include:■ Why is it important to do cross-media analysis?

■ What new insights did you gain through these small group discussions andreports?

■ What are some of the information-sharing challenges associated with a multi-media perspective?

■ Is it easy or difficult to communicate with staff in other programs regarding anenvironmental problem? Tell me more about that.

■ How would you apply what you’ve learned here today in your job? What will bethe challenges in doing so?

Instructor Notes




Putting It All Together: The Multi-Media Context—SmallGroup Exercises

Scenario #1A manufacturing facility in this state must comply with stringent air emissionregulations that will take effect within one year. The facility’s chief environmentalengineer has indicated to your environmental agency that the facility plans to meetthe new emissions requirements by installing a scrubber. While the Clean Air ActAmendments of 1990 identify scrubber installation as an acceptable option forcomplying with this new emission limitation, the statute does not appear to pre-clude facilities (or state agencies) from adopting alternative approaches.

1a. What are some of the environmental impact issues that might arise as aresult of scrubber installation at the facility?

1b. What are some of the regulatory compliance issues that might arise as aresult of scrubber installation at the facility?

2 a,b. Imagine that you are the facility’s primary contact within your agency.In order to view the facility’s emissions holistically, what are some of thequestions you should ask of, a) the facility personnel, and b) your contacts inthe regulatory agency, about technological alternatives?

Scenario #1




2 c. What additional information would you want regarding the costs of suchalternatives, and the potential for cross-media pollution transfer?

3. How might this additional information affect your recommendations toand regarding the facility?

4. Can you identify any regulatory barriers to integrated pollution preven-tion solutions?

Scenario #1





Scenario #2

Your manager has asked you to look into the following situation: A dry cleaningfacility with which you have worked this year (i.e., a facility that you have inspected,permitted or whose compliance questions you have answered) has indicated that itwishes to switch to “wet cleaning”. “Wet Cleaning” is a professional launderingprocess that uses water instead of perchlorethylene as a cleaning solvent. Althoughyou are not very familiar with the details of the wet cleaning process, you know thatswitching to wet cleaning would greatly increase the volume of water that thefacility uses. You also know that the facility is located in a densely populated,sewered urban area.

1. List the advantages and disadvantages of wet cleaning vs. dry-cleaning atthis facility.

2. Identify the existing environmental regulations or regulatory programsthat apply to:

a) Dry-cleaning, and

b) Wet cleaning

Scenario #2




3. Does the current regulatory framework favor one type of technologyover the other?

4. Are there any regulatory or organizational barriers preventing the agencyfrom taking a holistic approach to this facility’s emissions?

5. Describe the ideal working group, composed of agency staff, to work withthis facility in evaluating the environmental, human health, and economicimplications of these two garment cleaning technologies.

Scenario #2





Scenario #3

A town in this state has asked the Environmental Agency Commissioner to draw upa list of all facilities within its borders that are in full compliance with environmen-tal regulations. The town is launching a publicity campaign to pressure facilities tocome into compliance with applicable environmental requirements. The Commis-sioner has asked you to compose the list that the town has requested.

1. Identify the agency resources that you would consult in order to gatherthe required data.

2. What information will these resources give you with regard to emissionslimitations, operating practices, reporting requirements, etc.?

Scenario #3




3. Is there any relevant information that you will not be able to obtain fromthese resources?

4. What procedures might you ideally recommend to the Commissioner thatwould enable the agency to view facilities’ compliance profiles in a holisticmanner? (Address inter-divisional communication and information sharingprotocols.)

Scenario #3





Scenario #4

A member of upper manager has successfully negotiated a pollution preventioncommitment in your environmental agency’s strategic planning process. You havebeen asked to recommend policies and procedures for more firmly integrating apollution prevention ethic into the agency’s operating practices.

1. Generate a “wish list” of changes that you would recommend in agencypractices that could pave the way for a more integrated pollution preventionapproach.

2. State the basis of our recommendations: i.e., what existing needs do yourrecommendations address, and what benefits do you expect the proposedchanges to bring?

Scenario #4




3. Identify any barriers to implementing the changes you recommend.Suggest strategies for overcoming these barriers.


InformationAccess






natural resources.



Multimedia Teams I:Making Teams Work

*Enhanced Communication


*


2 Instructor Notes Multimedia Teams I: Making Teams Work

Table of Contents Including Overheads

Module 1: Program Introduction ................................................................................................................... 14

Module 2: Pet Peeves on Teams ...................................................................................................................... 20

Module 3: Differentiating Team vs. Teamwork .............................................................................................. 22

Team........................................................................................................................................................... 23

Teamwork .................................................................................................................................................. 23

Module 4: Task, Process, Relationship ............................................................................................................ 24

Team Success Depends Upon… ............................................................................................................... 33

Module 5: Setting Goals and Developing Action Plans ................................................................................. 34

S.M.A.R.T. Goals ....................................................................................................................................... 35

Stakeholders .............................................................................................................................................. 41

Examples of Stakeholders: ........................................................................................................................ 41

Decision Making Authority ...................................................................................................................... 41

Module 6: Focusing the Afternoon Session.................................................................................................... 44

Module 7: Communication Skills on Teams .................................................................................................. 46

Module 8: A Team Exercise ............................................................................................................................. 48

Module 9: Teaching and Learning on the Team............................................................................................. 54

The Peer Resource Relationship ............................................................................................................... 55

Methods For Peer Resources — Concepts ............................................................................................... 59

Methods For Peer Resources — Skills ...................................................................................................... 59

Module 10: Decision-Making on the Team.................................................................................................... 60

Four Methods of Decision Making .......................................................................................................... 61

When Selecting a Decision Making Method ........................................................................................... 65

Criteria Rating Chart ................................................................................................................................ 69

Module 11: Ending a Team and Program Conclusion .................................................................................. 70

When Ending a Team or Team Project: ................................................................................................... 71

Evaluation: ....................................................................................................................................................... 72

Multimedia Teams I: Making Teams Work 3

Table of Contents


Module 2: Pet Peeves on Teams ...................................................................................................................... 20

Module 3: Differentiating Team vs. Teamwork .............................................................................................. 22

Module 4: Task, Process, Relationship ............................................................................................................ 24

Module 5: Setting Goals and Developing Action Plans ................................................................................. 34

Module 6: Focusing the Afternoon Session.................................................................................................... 44


Module 8: A Team Exercise ............................................................................................................................. 48

Module 9: Teaching and Learning on the Team............................................................................................. 54

Module 10: Decision-Making on the Team.................................................................................................... 60

Module 11: Ending a Team and Program Conclusion .................................................................................. 70

Evaluation: ....................................................................................................................................................... 72

Instructor Notes


Icon legend

Trainer needs to



Nex

t…





ParticipantExercise




ParticipantHandout












FLIPCHART





OVERHEAD (no.)


PAUSE Video

Start Video


STOP Video




EXERCISE




The Culture of Cross-Functional Teams

The diversity of cross-functional team players creates a new culture. Therefore, it isimportant to understand that in creating a cross-functional team, you are fashion-ing a potentially powerful organizational vehicle. While it lacks the simplicity of afunctional team composed of, for example, six engineers all reporting to theengineering manager, a cross-functional team has a greater chance of realizing thepotential of that old axiom, the whole is greater than the sum of its parts. Thisgroup of allies, enemies, and strangers can weave together a cross-functional designthat is an amalgam of many cultures.

Glenn M. ParkerCross-Functional Teams: Working with Allies, Enemies and other Strategies


Multimedia Teams I: Making Teams Work

Learning Objectives

Participants in this workshop will be able

1. To identify the key elements of successful teams,

2. To explore roles and responsibilities of team leaders and members,

3. To listen for understanding and to speak in ways that build agreement,

4. To develop skill in providing peer resource assistance to team members, and

5. To identify appropriate decision-making methods for team use.


1. Participants are regulatory personnel (federal, State, or local) involved inpermitting, compliance inspections, and/or enforcement.

2. Participants are willing to participate in group exercises or discussions.

3. Participants have had some experience working on project teams or in smallgroups with colleagues, and are interested in how to improve the effectivenessof these teams.

4. Participants will likely have expertise in one environmental medium, but theymay not have dealt with facilities on a multi-media, sector oriented basis.



1. To identify the key elements of successful teams and how to improve a team’sfunctioning.

2. To define roles and responsibilities of team leaders and members.

3. To listen for understanding and to speak in ways that build agreement.

4. To develop skill in providing peer resource assistance to team members.

5. To select appropriate decision-making methods for team use.



Multimedia Teams I:Making Teams Work

Learning Objectives


1. To identify the key elements of successful teams,

2. To explore roles and responsibilities of team leaders and members,

3. To listen for understanding and to speak in ways that build agreement,

4. To develop skill in providing peer resource assistance to team members, and

5. To identify appropriate decision-making methods for team use.


1. Participants are regulatory personnel (federal, State, or local) involved inpermitting, compliance inspections, and/or enforcement.

2. Participants are willing to participate in group exercises or discussions.

3. Participants have had some experience working on project teams or in smallgroups with colleagues, and are interested in how to improve the effectivenessof these teams.

4. Participants will likely have expertise in one environmental medium, but theymay not have dealt with facilities on a multi-media, sector oriented basis.

Instructor Notes


Target Audience This program is designed for those individuals who are beginning to work on

teams or have been working on teams but with no formal training in team skills.

It is designed for participants who have expertise in one environmentalmedium, and have been or will be increasingly working with colleagues onteams with expertise in a medium other than their own.

Course length 6 hrs including (2) 15 minute breaks

Number of participants 20

Room Set-Up A room large enough to accommodate a U shape set-up with participants

sitting around the perimeter is ideal for discussion and participant involvement.

The breakouts (4 teams of five) can occur at the four corners of the U, using both

sides of the tables. If the room will not accommodate this arrangement, you will

need space for two teams to work in the main presentation room and another

classroom that will two teams to work separately without interfering with each

other.

Supply Materials neededOverhead projector and screen2 flipcharts: one to the left and right of the open space in the UColored markersMasking TapeProgram Materials Needed:Overhead SlidesHandout packets for each participant (20)2 page handout of directions and supply list forMountain Adventure Exercise (20)Do not duplicate answer sheetProgram Evaluation sheet (20)

x x x x x x

x

xx

x

x

x

x

xx

x

x

x

x x





1. To identify the key elements of successful teams and how to improve a team’sfunctioning.

2. To define roles and responsibilities of team leaders and members.

3. To listen for understanding and to speak in ways that build agreement.

4. To develop skill in providing peer resource assistance to team members.

5. To select appropriate decision-making methods for team use.

Instructor Notes


Agenda


1 Program introduction 45 min

2 Pet peeves on teams 30 min

3 Differentiating teams and teamwork 10 min

Break 15 min

4 Key elements: Task, Process, Relationships 65 min

5 Setting goals and developing action plans 15 min

Lunch

6 Focusing the afternoon session 10 min

7 Communication skills on teams 10 min

8 A team exercise 70 min

Break 15 min

9 Teaching and learning on the team 25 min

10 Decision-making on the team 25 min

11 Conclusion and summary 15 min

Plus/Delta 10 min

Total 6 hrs.



Agenda

Module

1 Program introduction

2 Pet peeves on teams

3 Differentiating teams and teamwork

Break

4 Key elements: Task, Process, Relationships

5 Setting goals and developing action plans

Lunch

6 Focusing the afternoon session

7 Communication skills on teams

8 A team exercise

Break

9 Teaching and learning on the team

10 Decision-making on the team

11 Conclusion and summary

Plus/Delta

Instructor Notes


Some suggestions for the trainer

1. This program is designed to be highly interactive and to build on theexperiences of the participants. The “lecturettes” are contained in quotationmarks. Seek to draw out information from the group, and build the learningfrom the knowledge and experiences of teams they already have.

2. During the training day, reinforce those issues you have heard the participantsidentify as important to them.

3. When good questions are asked, open them for the group to respond ratherthan giving you own opinion first.

4. Be willing to go with the flow if it meets the learning objectives for the program.

5. If comments or discussion are taking the class away from the learningobjectives, acknowledge the importance of the comment or issue to theparticipant. Then refocus on the program agenda and goals, and proceed. (Youare modeling how to get things back on track at team meetings as well as atraining class.)

6. Prepare any flipchart information before the program begins.



1Module 1

Basic Definitions

Group:A collection of individuals who have something in common.

Team:A group of people who work in concert to achieve a shared goal.

Successful Team:A team that achieves its desired results, manages to work processes well, andmaintains functional team member relationships.

Program introduction

Instructor Notes


Module 1 Program Introduction

a. In introducing yourself, tell something about yourself -

particularly your experience working on teams, consulting to

teams, teaching team skills, etc.

b. Introduce the focus of today’s program: Working on

Multimedia Teams.

Our beliefs and understandings of teams goes back to when

we were children. Ask participants to remember entering a

playground with a number of games going on. What were the

questions going through their heads? Record on a flipchart:

What is the game we are playing?

How do you win?

What are the rules?

How do you play?

Is this any fun?

Who are these kids?

Do I like playing with these guys/gals?

Ask participants to think about how many of these same

questions are relevant to our participation on teams today

(project teams, intact teams, management teams). This is the

purpose of our workshop today: to review and learn how to be

effective and responsible team members.




????



Module 1

Working on multimedia teams

Our beliefs and understandings of teams goes back to when we were childrenentering the playground. Some basic questions would come to mind:

What is the game we are playing?How do you win?What are the rules?How do you play?Is this any fun?Who are these kids?Do I like playing with these guys/gals?

How many of these questions are relevant to our participation on teams today?

Purpose of Today’s WorkshopTo review and learn how to be effective and responsible team members.

Instructor Notes


Flipchart: Agenda

Review the agenda and then post somewhere in the room.

c. Participant Introductions

On teams people want to know who you are. Introductions are

an important part of how team activity begins. Do not assume

everyone knows each other. For this workshop we will

introduce ourselves by

Flipchart: Name

Position

Bureau/Division

One thing you want to learn about teams

Go around the room with each person introducing himself or

herself in turn. Record the learning needs on the flipchart.

Place a check next to any item mentioned more than once.

d. Review with the participants the instructional goals found in

the participant manual on p. 9.

Flipchart: Goals

e. Review with participants the Agenda for the day, giving the

flow of the program and indicating at what time the group will

break for lunch and breaks. This is a good time to also

introduce any “housekeeping” details regarding phone access,

restrooms, etc.

Module 1

????












Module 1

What do I/we want to learn about teams?

Instructor Notes


f. Guidelines for Working Together

(Propose the following ground rules, and ask the class to add

other ground rules based on their experiences within training

program. )

1. Listen to other’s points of view.

2. Be open to change/new ideas.

3. One person speak at a time.

4. Respect other’s opinions.

5. Keep our objectives in mind.

6. Attack the problem and not the people.

7.

8.

g. Personal Invitation from the Instructor

Issue an invitation similar to the following:

“Today we have an opportunity to work together. This program

will only be as good as your willingness to participate. Today I

invite you to be on my team: to get on the court and not just

be in the stands.”

????

Module 1



Guidelines for working together

1. Listen to the other’s point of view.

2. Be open to change/new ideas.

3. One person speak at a time.

4. Respect other’s opinions.

5. Keep our program objectives in mind.

6. Attack the problem and not the people.

7.

8.

Module 1

Instructor Notes


Module 2 Pet Peeves on Teams

Give participants the following instructions:

“Since most of us have had some experiences working on

teams, let’s start with talking about your ‘pet peeves’. Think of

any of the experiences from previous jobs to the present when

the work on the team did not go well. There is no need to

mention people or the specific project. Choose one other

person, and take the next five minutes discussing together

your ‘pet peeves in working on a team. Also, choose one

person to record the ideas. ’”

After the pairs have finished their discussions, create a list by

going around and asking each participant to share one idea

about a pet peeve.

When you have gone around the room once, ask the recorder

in each pair to report out one new idea from their discussion

(no repeats). Write the pet peeves on a flipchart.

Summary Indicate to participants that pairing is a quick way to get many

ideas generated in an efficient and effective manner, and they

may want to use it on their working teams.




????



Module 2

Pet peeves when working on teams

Think of any experiences from previous jobs to the present when you have been working on a team. Whatbehaviors or situations particularly irritate you?

1Pet peeves on teams

Instructor Notes


Module 3 Differentiating Team vs. Teamwork

“In our work experience we have participated or led a variety of

work groups, task forces, and project teams. It is important for

our work today to differentiate what we mean by ‘teams’ vs.

‘teamwork.’ These terms can cause confusion.”

Overhead 1: Team (read definition)

Emphasize that if you throw people together without a clear

goal and without authority they will have little likelihood of

success.

Overhead 2: Teamwork (read definition)

Emphasize that teams use teamwork, but there are other

groups and meetings that count on this kind of interaction

among the members to be successful. Relate these concepts to

anything you know about how teams have worked

successfully or struggled in the organization where this

training program is being presented.

Summary: “Now that we are clearer about the definition of teams and

teamwork, let’s look at the key elements of successful teams.”N

ext…









Module 3

Teamworkoverhead 2

A style of working together that values:

■ Listening to each other

■ Recognizing various interests/interdependencies

■ Building agreement

■ Providing support

■ Acknowledging accomplishments and contributions

Teamoverhead 1

A small group of people

■ Committed to a common purpose

■ With defined goals

This group is mutually accountable

■ For achieving the goals

■ And for how they work together

Differentiating teams and teamwork

Instructor Notes


Module 4 Task, Process, Relationship

“The better we understand the key elements in effective team

functioning, the more able we will be to contribute as a team

member or provide leadership for the team.”

Ask participants to turn to participant notes, pg. 25, “Previous

Team Experiences or Observations,” and take the next five

minutes to record what has worked well and contributed to

your successful experiences on teams, what hindered the

effectiveness on teams, and any impasses that totally disabled

the team.

After five minutes, ask the participants to set aside their ideas

for a moment, while you introduce them to a model for

working on teams.




ParticipantExercise



Previous team experiences or observations

Think back to teams or projects that you have worked on, and record the following:

What worked well and contributed to the team’s success?

What hindered the effectiveness of the team?

Were there any impasses that disabled the team?

2Module 4Key elements: Task, Process, Relationships

Instructor Notes


Module 4




Task

Process Relationships

Flipchart: Write the model for the three key elements for

successful teams on a flipchart.

Use a triangle with Task at the top, process at the lower left,

and relationships at the lower right. Make the point that if any

of these key elements are weak, the effectiveness of the team

is in jeopardy.

Provide a definition of each major element, and examples of

each.

Task: What the team does

■ What is the team supposed to accomplish in general?

(i.e., product, recommendation, policy, etc.)

■ What is the team trying to accomplish at this particular

meeting? (i.e., solve a problem, plan an event, identify policy

changes, etc.)

Process: How the team goes about its work

■ What methods is the team using to get the work done? (i.e.,

agenda, discussion, defined time limits, research and report,

brainstorming, consensus decision making, etc.)

Relationships: How the team members interact with each other

■ What needs to occur between people for this experience on

the team to be a satisfying one? (for example, people

introduced to each other, non-contributor invited to

participate, conflicts recognized and addressed, people

listen to each other)



Module 4

Task

Process Relationships

When are teams successful?

Effective teams pay attention to three key elements.

Task: What the team does■ What is the team supposed to accomplish in general? (ie, product, recom-

mendation, policy, etc.)■ What is the team trying to accomplish at this particular meeting? (solve a

problem, plan an event, identify policy changes, etc.)

Process: How the team goes about its work■ What methods is the team using to get the work done? (i.e., agenda,

discussion, defined time limits, research and report, brainstorming, con-sensus decision making, etc.)

Relationships: How the team members interact with each other■ What needs to occur between people for this experience on the team to be

a satisfying one? (i.e., people introduced to each other, non-contributorinvited to participate, conflicts recognized and addressed, people listen toeach other)

Instructor Notes


Module 4

????

Note that if at any point a team is not working well, this model

allows team members to look at the team and ask themselves:

■ are we clear about the task?

■ are the processes we are using effective to accomplish

the task?

■ are we paying attention to what is happening between

people?

“Now let’s look at your experience on teams.” Ask participants

to refer to the notes that they have just completed about their

experiences on teams, in order to categorize their descriptions

of successful team dynamics according to Task, Process, or

Relationship.

Ask for a few examples, and illustrate how to decide which

category is appropriate.

Ask participants to get in groups of five. Group members will

have fifteen minutes to share experiences of working on an

effective team or work group. The group decides for each idea

if it belongs under the key element of task, process, or

relationship.

All group members should record their categorizations on

page 29 under Task, Process, and Relationship. In addition, one

participant must be willing to report out for each group.

Nex

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Nex

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ParticipantExercise



Module 4

Elements of working on an effective team or group

Task

Process

Relationship

3

Instructor Notes


Module 4

After fifteen minutes, ask participants to shift their attention to

what was happening on teams where things were not working

well or something was hindering the teams effectiveness (Note

that they may even find some ideas in the pet peeves they

identified earlier). Ask participants to discuss what hindered

the group, and then decide what was needed to make the

team more effective. Give participants ten minutes to

categorize each idea under task, process, or relationship and

record their categorization in the worksheet for Participant

Exercise 4.

Reconvene the large group. Ask each group for two ideas (no

repeats)about what successful teams do to address task issues.

When finished, elicit ideas about process, then relationships.

Do not write them on a flipchart, but encourage participants to

take notes in the appropriate column if they hear ideas not

presented in their own group. Do not struggle with the

attendees about a particular category, but rather focus on how

important it is that they identified the appropriate issue.




ParticipantExercise

????



Module 4

Elements of working on an ineffective team or group

Task

Process

Relationship

4

Instructor Notes


Ask:

“Which of these key elements are the responsibility of the

leader ?”

“Which of these key elements are the responsibility of the

participants?”

*Challenge the assumption that most of these issues are the

responsibility of the leader and encourage that all team

members assume responsibility for the task, process and

maintaining relationships. Refer back to pet peeves if

appropriate. It is common for participants to believe that the

leader is responsible and to be angry when the leader does

not “fix” it. Highlight how team members can help the team to

address issues that will increase its success.

Ask participants to reflect for a moment on your involvement

in this group activity (they do not have to say anything out

loud).

”How much were you on the court?” (pause)

”How much were you in the stands?”(pause)

”What attracted you or kept you on the court”?(pause)

”If you were in the stands, what was needed to bring you on the

court?”(pause)

”What is one thing you would be willing to be more

accountable for at the next team meeting you attend?”

Conclude this Module by reading Overhead 3 (“Team Success

Depends Upon…”).

Module 4




????



Module 4

Team Success Depends Upon…overhead 3

■ Achieving Our Goal or Objectives

■ Effective Processes for Getting the Work Done

■ Relationships that build mutual respect and rapport

Each Team member is responsible for the success of each dimension.

Instructor Notes


Module 5 Setting Goals and DevelopingAction Plans

Introduce this Module with a statement similar to the

following:

“I would like to say a few things about goals. You mentioned

how important clear goals were when talking about the tasks

that get completed by the team. Here are some characteristics

of goals that are “S.M.A.R.T.” (that is, they help get the task

done).”

Overhead 4: Smart Goals

Review the “S.M.A.R.T.” acronym as explained on Overhead 4.

Give examples of SMART Goals:

■ By January 1 I will lose 10lbs, and walk a mile in less than 20

minutes (rather than I would like to get into shape).

■ By December 15 we will have a procedure developed for

conducting multimedia interviews with a specific industry

(rather than we need interview guidelines for working with

multimedia issues).






Module 5

S.M.A.R.T. Goalsoverhead 4

■ Specific

■ Measurable

■ Attainable

■ Relevant

■ Time-trackable

Setting goals and developing action plans

Instructor Notes


“To achieve the goals, the team needs to build an action plan.

And since often there are multiple goals you may need a plan

for each goal. It is important that all members of the team

contribute/comment on the action plan so that a realistic

timetable for work can be developed.”

Refer participants to Participant Handout 4, “Creating a Team

Focus,” on p. 37. Review the three main items on the handout.Asdf fklkjas ss a dfkj s fdfk askd fd jkl; thj a jklkjuu fkd. Asdf fklkjas ss a dfkj s fdfk askd fd jkl; thj a jk jklkjuu fkd, asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj.



ParticipantHandout

Module 5


Participant Handout

Creating a Team Focus

1. What is the team’s charter or mission?

2. What are the team’s goals?

I.

II.

III.

3. To achieve the goals, what specific action plans/steps need to be created or taken?

Goal IAction Plan

1.

2.

3.

4.

Goal IIAction Plan

1.

2.

3.

4.

4Module 5

Instructor Notes


Module 5

Refer participants to Participant Handout 5, “Action Plan

Worksheet,” on p. 39. The Worksheet is a useful way to record

who will be completing a task and when it will be completed.

Note that if obstacles and barriers are encountered, team

members should be encouraged to bring these issues back to

the team rather than struggling with them alone.




ParticipantHandout


Participant Handout

Action Plan Worksheet

An action plan is a prioritized checklist of what must be done to accomplish the stated goal.

Goal:

Actionstep/Task Who Assigned Completion Date Result

Module 5

5

Instructor Notes


Review Overheads 5 and 6. Examples of stakeholders are the

internal leadership team, EPA, governor’s office, citizens’ groups,

private industry councils, etc.

“If goals and an action plan are developed early on, they can be

presented to key stakeholders for approval or confirmation

that the team is heading the an appropriate direction.”

“It is easy for a team to have an entirely different concept from

management or its stakeholders of what needs to be done and

how to do it. Seeking buy-in before the team is too far along

reduces the possibility that the end points will be

unsatisfactory or meet debilitating resistance.”

Discuss how a team can identify all the stakeholders. First, a

review of everyone who may be significantly involved with the

work of the team and their roles can be useful. These people

are often not on the team, but will be interacting with team

members; some have decision making authority for the

agency.

Note that different team members may have different ideas

about who has authority within the team, which stakeholders

have decision making authority and which stakeholders have a

“comment only” involvement (Overhead 7). Second, it is

important for the team to clarify not only who the

stakeholders are, but if any of these stakeholders have decision

making authority or need to be kept informed. Frequently

there is confusion about the authority to make decisions. It is

best to bring these issues to the surface and get clarity while

the group is working, rather than risk a team seeing its work

undone at the end of the process because a key decision-

maker was not brought into the process early enough.

Module 5












Module 5

Stakeholdersoverhead 5

* Stakeholders are all those individual people or groups who may be

significantly impacted by the outcome of the group’s efforts.

Examples of Stakeholders:overhead 6

■ Internal leadership team

■ EPA

■ Governor’s office

■ Citizens’ groups

■ Private industry councils

Decision Making Authorityoverhead 7

■ Within the team

■ From Stakeholders

Get clarity early in the group’s work on levels of input and decision making.

Instructor Notes


Module 5

Optional: If there is time, ask participants: Have you had some experiences(positive or negative) that have led you to understand theimportance of including key stakeholders in the setting of goals orthe developing of action plans?

Conclusion: Just before lunch read the “Ralph and the Gophers” story aloudto the participants (ask them to turn to Participant Handout6). Ask participants to be prepared to interpret it for you. Thestory can be prefaced with a remark that some environmentalmeetings sound like the “Ralph” story. This humorous storyreinforces the importance of knowing the goals in order forthe strategies to make sense.

“Ralph’s team first let loose a pack of gophers. The planbackfired when a dog chased them away. They then threw aparty but the guests failed to bring their motor cycles.Furthermore, Ralph’s stereo system was not loud enough. Theteam spent the next day looking for a Peeping Tom in theYellow Pages. It was the installation of the blinking neon lightsacross the street that finally did the trick. And Ralph framed theads from the classified section where the team found the neonlight company. Ralph now has the framed ad hanging on hiswall.”

Ask participants:

Did you understand the words? Was the grammar accurate?

“Oh, I guess I left out one important point... Ralph was trying toget rid of his obnoxious neighbors.”

Reread the story. Ask participants what was missing (answer:the goal or objective). Note that the goal tells us why we aredoing what we are doing right now.

*When announcing lunch, remind participants that effectiveteams begin and end on time, and ask them to reconvenepromptly.

Lunch




ParticipantHandout

????

Nex

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Participant HandoutModule 5

“Ralph and the Gophers”

“Ralph’s team first let loose a pack of gophers. The plan backfired when a dogchased them away. They then threw a party but the guests failed to bring theirmotor cycles. Furthermore, Ralph’s stereo system was not loud enough. The teamspent the next day looking for a Peeping Tom in the Yellow Pages. It was the instal-lation of the blinking neon lights across the street that finally did the trick. AndRalph framed the ads from the classified section where the team found the neonlight company. Ralph now has the framed ad hanging on his wall.”

What is missing here?

6

Instructor Notes


Module 6 Focusing the Afternoon Session

Review what was covered in the morning: the importance of

understanding task-process-relationships in working on teams,

and the importance of developing goals and action plans with

the input of key stakeholders so the team members know

where they are and where they are going.

Ask participants to reflect for a moment on their involvement

in this morning’s group activities. Ask them:

■ How much were you on the court?

■ How much were you in the stands?

■ What attracted you or kept you on the court?

■ If you were in the stands, what was needed to bring you on

the court?

Outline for participants the three parts of the afternoon

portion of this training course:

■ An exercise to illustrate the value of team functioning when

dealing with complex tasks.

■ Examination of their role both as teacher and learner when

they bring their media expertise to the team.

■ Focus on a variety of decision making methods that can

help the team move its work forward.

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Module 6

Individual reflection on the morning’s group activities:■ How much was I on the court?■ How much was I in the stands?■ What attracted me or kept me on the court?■ If I was in the stands, what was needed to get me on the court?

Coming-up for the remainder of the day:■ An exercise to illustrate the value of team functioning when dealing with

complex tasks.■ An examination of one’s role as both a teacher and a learner when bring one’s

expertise to a team.■ A focus on a variety of decision-making methods that can help the team move

its work forward.

Focusing the afternoon session

Instructor Notes


Module 7 Communication Skills on Teams

Ask participants to think about team leaders and team

members who are most valuable on teams. In addition to

bringing expertise to the task, the most valuable team

members bring three process skills to the work. They know

how to:

(write on flipchart)

■ Listen

■ Speak Up

■ Build to Agreement

(Keep this flipchart visible during the team exercise that

follows.)

Explain each of these process skills:

■ Active listening means paraphrasing and clarifying, and

asking questions that explore for understanding rather than

criticize.

■ Speaking up means saying what is on one’s mind in a direct

way (rather than waiting and wishing the conversation

would go in a different direction).

■ Building to agreement means intentionally building links

and looking for similarities. Point out that for engineers, the

attention to detail frequently makes them look critically at

ideas and break them apart looking for ways that things will

not work. This talent makes them do their work well, but it

can make life on a team difficult if they do not also learn

how to build for agreement.




????



Module 7

Communication Skills on the Team

■ Listen

■ Speak up

■ Build agreement

Communication skills on teams

Instructor Notes


Module 8 A Team Exercise

Introduce the Mountain Adventure Survival Exercise on p. 49

in the following manner:

“I have a task that you are going to be asked to do individually

and then to work on as a team. You will have ten minutes to

work on the task individually and then I am then going to ask

you to join your team and work together for 20 minutes.”

Assign participants to teams with five or six members per

team. One method is to have each person count off 1,2,3,4, for

the number of teams you will need to accommodate everyone

in the class. All the 1’s become Team 1, all 2’s become Team 2,

etc. Designate at which corner of the room or in which

breakout room the teams will gather. Do not let the

participants go to their team location until you have reviewed

the instructions and they have completed their individual

tasks.

Read the instructions aloud for the whole group. Ask the

participants to complete the exercise individually without

discussing it with anyone else.

After ten minutes ask participants to stop, and instruct them to

join their teams and do the task as a group. Reinforce that the

goal stays the same — to choose those items they will carry

with them off the mountain. Remind them of the process skills

that make for good team communication, which are posted on

the flipchart (listen, speak up, and build for agreement.) Tell

them they will have twenty minutes to work together.

Give a two minute alert before the twenty minutes are up.

Because the group will be eager to know the correct answers,

read the correct list aloud, and indicate the rationale provided.




ParticipantExercise






Module 8

Mountain Adventure

You are members of a mountaineering expedition to the top of Mount McKinley in Alaska (20,320 feet).You are about halfway to the peak. A snow slide has injured two team members and a storm is moving in.

The group has decided to stay where it is.

One of you has volunteered to start down for help. You believe he/she can make some progress before thestorm hits. He/she will have to bivouac (spend the night on the mountain alone). The volunteer must travelquickly and therefore lightly.

He/she can carry 14 items. As a group, select the items he/she should take with him/her from the 37 items he/she is now carrying.

Assume that he/she will also be carrying all of the essential climbing gear, including ropes, slings, ice ax andhammer, climbing harness, rock pitons, etc.

He/she is wearing:Plastic climbing boots with padded innersGaiters (to keep snow out of boots)Fleece jacketFleece trousersFleece Balaclava hatWaterproof mittens with fleece linersThermal underwearSocks

Select 14 items from the following list:Shovel TarpWaterproof trousers Large polythene bag (big enough for a person toSki Poles get into)Compass SunglassesLight propane stove Bivouac Brush (for brushing snow off clothes andCooking pot sleeping bags)Swiss Army knife Hand flaresLarge tin mug Instant food packsSpoon SunscreenToilet paper Spare mittsMap GlovesDown sleeping bag with waterproof exterior CameraAltimeter FilmPad for sleeping bag MatchesTent WhistleWindproof jacket with hood Wineskin with wineFirst Aid Kit Chocolate barsPied d’elephant (half a sleeping Water bottle bag to cover lower limbs) Hot chocolate in packagesHeadlamp with lithium batteries Pencil and paper in polythene bag

A team exercise

Instructor Notes


Module 8

Mountain Adventure: The solution

Tell participants that experts recommended the following 14

items:

compass

map

instant food packs

headlamp with lithium batteries

sunglasses

sunscreen

down sleeping bag with waterproof exterior

water bottle

propane stove

large tin mug

Swiss army knife

matches

waterproof trousers

windproof jacket with hood

Tell participants that experts used the following decision

making criteria in selecting items in this type of

mountaineering situation:

■ keeping dry

■ keeping warm (maintaining internal body temperature)

■ knowing where you are

■ ensuring you are prepared for possible damaging sun or

snow glare

Note: wine should not be on the list because alcohol worsens

hypothermia



Module 8

Mountain Adventure Exercise Worksheet

The 14 items I select are: (individual exercise)

1. 2.

3. 4.

5. 6.

7. 8.

9. 10.

11. 12.

13. 14.

The 14 items we select are: (group exercise)

1. 2.

3. 4.

5. 6.

7. 8.

9. 10.

11. 12.

13. 14.

Instructor Notes


Ask participants: which team had all the correct items? How

many were off by one item? By two items? Etc. This will let you

know how much success each of the groups had.

Ask participants to turn to the discussion questions on page

53 of their manuals and to spend 10 minutes with their teams

discussing the questions.

Ask each team to share two learnings from its experience

working together. Remind participants that we can learn from

what did not work well as well as from what was done

effectively.

Record learnings on the flipchart. Reinforce and clarify any

content learned earlier. If teams got stuck in the task, ask the

large group what they might have recommended for the team

to do to get unstuck. Draw comparisons to how the same

dilemmas present themselves in everyday team work.

Note that the members of any team should ask themselves:

■ How am I contributing on this team?

■ What am I wishing would happen? Am I willing to act to

make the team aware of what I believe is needed?

Pose the following questions to participants(they do not need

to answer out loud):

How did you contribute to the team task in the Mountain

Adventure Exercise? What did you observe about yourself on

this team and how does it fit with what you know about how

you behave on other teams at work?

Break

????

Module 8






Questions for Discussing the Team Exercise

Do you feel your team was successful? Why?

How well did the team complete the task?

How well did the team attend to its process?

Listening to each other

Speaking up

Building for agreement

How did the team deal with its differences?

Who assumed the leadership role?

Did the leadership shift during your work together?

What other roles emerged on the team to deal with the task and the process?

Did these roles help or hinder the process?

How were the decisions made?

How did you know when you were finished?

If you worked on a similar team task, what would you do differently?

7

Instructor Notes


Module 9 Teaching and Learning on the Team

This Module focuses on the importance of becoming a peer

resource and an assertive learner on the multimedia team.

“When you come to work on a multimedia team, you will be

bringing your expertise and years of working experience in a

single media. You know the regulations, the alphabet soup,

how the laws have changed over time, etc. But others on the

team may not have your wealth of experience and possess a

background in a totally different media.

The challenge is for you to become a teacher in those areas in

which you have expertise, and for you to become an assertive

learner in those areas in which you need to build your

competence. Your team meetings will only be as successful as

your willingness to be a peer resource in your area of expertise.

It becomes your job to teach.”

Display and review Overhead 8.

Identify a work-related location (waste site, EPA location,

industrial polluter, etc.) at some distance from where you are

holding the training (a little complexity helps the exercise).

Ask the group: Is there anyone here who does not know how

to get to ?

Ask this person if he/she would be willing to volunteer to be

our learner for this exercise.

Ask the group: Who can provide directions for this person to ?

Ask both volunteers to come to the front of the room so

everyone can see and hear. Tell the two volunteers to “just go

ahead.” Provide no instructions. Allow the volunteers ten

minutes to do the exercise in whatever way they wish. If they

ask for guidance, respond, “do anything you think would be

useful.”




????



Module 9

The Peer Resource Relationshipoverhead 8

What Is It?

A relationship between a guide or mentor and a learner. The goal of the

relationship is for the mentor(with an area of expertise) to help the learner

learn new information or skills.

At any point in time we may be either the peer resource or the learner.

“Communicate with the other person that which you would want communicated

if your positions were reversed.” —Aaron Goldman

Teaching and learning on the team

Instructor Notes


Interrupt the process and say “Let’s stop here.” Thank the

volunteers and ask them to return to their seats.

Ask the large group:

■ What did the “teacher” do that helped the learning?

1. Record on a Flipchart: Tips for being a Peer Resource

Suggest that participants take notes in their workbooks as you

chart the responses. If a disagreement arises over a suggested

tip, note that we tend to blame teachers for inadequate

learning. However, the goal is also to become an assertive

learner so that our teachers give us all we need to easily grasp

the information. It is important to take responsibility for what

we need even if the teacher is not giving information to us in

the right way.




Module 9



Tips for peer resources: the teacher

1.

2.

3.

4.

5.

6.

Tips for the assertive learner

1.

2.

3.

4.

5.

6.

Module 9

Instructor Notes


2. Ask a second question:

What did the learner do to get his/her learning needs met?

What might he/she have done?

Record on a Flipchart: Tips for the Assertive Learner

Next, write the following on a new sheet of flipchart paper:

“Regardless of whether you are the learner or the peer

resource, you are 100% responsible for the learning.” (Aaron

Goldman)

Note that we each must be fully responsible for learning to

occur, instead of counting on a 50–50 sharing, because not

everyone may do the job equally well.

Reiterate that this exercise was a simple way to have

participants pay attention on the importance of two way

communication and the need to ask for feedback.

In summary, review Overhead 9, “Methods for Peer Resources

(concepts)”, and Overhead 10, “Methods for Peer Resources

(skills).”




Module 9

????









Module 9

Methods For Peer Resources — Conceptsoverhead 9

When teaching concepts/knowledge:

1. Introduce the concept WIIFM — What is in it for me to know this

information?

2. Assess current level of understanding

3. Explain the concept

4. Test the learner or ask for the learner to communicate their understanding

of the concept. Provide feedback and clarification to increase

understanding.

5. Summarize

Methods For Peer Resources — SkillsOverhead 10

When teaching a skill:

1. Introduce the skill WIIFM —What is in it for me to be able to do this?

2. Assess previous experience using the skill

3. Demonstrate the skill

4. The learner practices the skill

5. Provide feedback and coaching on mastering the skill

6. Summarize

Instructor Notes


Module 10 Decision-Making on the Team

Note for participants that the training has covered the

components of being on a team and teaching and learning,

and it is focusing finally on decision-making.”

Display Overhead 11, “Four Methods of Decision Making.”

Decribe each method and give an example.

Authoritative

■ The leader is usually the decision maker; however, an

authoritative team member can also become controlling

and insist that his or her recommendation be followed.

Example: “The conference will be held on the last weekend

of October. Be there!”

Consultative

■ Polls individuals and makes the decision using the

information collected.

■ This can occur either within or outside of the team meeting.

Example: “I have talked to each of the committee members

and heard recommendations to hold the conference on the

last two weekends in October. There was compelling

information that we would not be competing with other

event dates if we went with the last weekend in October.”




Nex

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Module 10

Four Methods of Decision Makingoverhead 11

■ Authoritative

— Decide and announce

— Discuss, decide and announce

■ Consultative

— Polls individuals and decides

— Polls the team and decides

■ Majority

— Team votes

■ Consensus

— Team decides on an option that all can support

Decision-making on the team

Instructor Notes


Majority

■ Team members vote and choose the option receiving more

than half of the votes.

Example: “We have three recommendations for our weekend

conference: the last weekend in October, and the first or

second weekend in November. Each of you may vote for the

weekend you prefer. We will total the votes and the weekend

with more than half will be our choice. If necessary we will

take the top two selections, and vote a second time.”

Consensus

■ The team finds an option that all can support, even if it is not

the first choice of some team members.

Example: “We need to come to agreement about the dates

and location of our conference. Let’s talk about the

possibilities and see if we can come to an agreement about

the date. It is important that we make our decision on those

factors that are critical to our conference success.”

Refer participants to page 63 in their Manuals for “Consensus

Guidelines.” Instruct participants to read guidelines.

Module 10

Nex

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ParticipantHandout



Consensus Guidelines

Seek to understand; Ask clarifying questions.

Express your point of view.

Try not to talk others out of their opinions.

Listen hard to opposing viewpoints.

Make sure everyone gets “air time.”

Consider any parameters on the decision that may be imposed by external forces.

Choose collaboration when you can; consider compromise when necessary.

Hold out if you don’t agree; try to modify a decision so that it is more acceptable toyou.

Don’t argue; agree to disagree.

Remember, you don’t have to be totally convinced a decision is right to go alongwith it.

Ask yourself: can I live with and support this decision?

8

Instructor Notes


Ask participants to think about the Mountain Adventure

exercise. What method(s) of decision making were used by

their team?

(Frequently the teams will indicate that they used some

authoritative decision making because someone in their group

is a mountain hiker.)

Emphasize:

■ There is no intrinsically right or wrong method.

■ The goal is to use the decision making method that is most

appropriate to the situation.

■ The challenge to the leader and the team is to be intentional

and explicit about how they will make decisions, and then to

have the flexibility to change the decision making method

when the circumstances warrant.

Display Overhead 12, “When Selecting a Decision Making

Method.”

Module 10






Module 10

When Selecting a Decision Making MethodOverhead 12

Factors to consider in selecting a decision making method include:

■ The need for “buy-in”

■ History of the group’s operating methods

■ Types of issues that are on the table

■ Time it takes to reach a decision

■ Importance to team development

Instructor Notes



Participant Handout

Advantages and disadvantages of each of the four methods ofdecision making

Advantages Disadvantages

Authoritative

focus limited ownershiptime efficient prevents other inputdecision is achieved allows definition of agenda by one person

resentment over carrying out someone else’s decision

Consultative

different viewpoints taken into account costly and time-consumingget outside perspective participants feel pressured

process can be abusedresentment by those not consulted

Majority/Voting

quick and cost-effective encourages discussion to deathdemocratic faster may not be betterculturally based majority is not always rightencourages discussion blurs responsibility and encourages “group think”

there are losers

Consensus

issues are truly resolved watered-down decisiontotal buy-in some ideas may never be heardimproves commitment takes more timenot intended to be power-based easier to misinterpret final consensus

9

Instructor Notes


Display Overhead 13, “Criteria For Decision Making: Criteria

Rating Chart.”

Explain that this is also an effective rating chart that can be

used by teams when making a decision.

It allows the team to make a decision using a defined set of

criteria. This chart can be useful when there are several

different proposals on the table, and a decision needs to be

made. The group first decides the criteria for making the

decision. If the criteria are not equal in value to the group, a

percentage value can be assigned to a specific criteria. The

total value of all criteria needs to equal 100%.

Optional: Demonstrate how to use the criteria rating sheet with

the example of buying a new vehicle (comparing a 4X4, a van, and

a station wagon). List those vehicles under consideration in the

side column. Across the top, put as many criteria as apply. The

criteria might include price under $25,000, seats 5 or more

passengers, gas mileage, hauls a boat, etc. But these criteria might

not be equal. The cost factor may be worth 55% and all other

criteria 15%. Or the ease of hauling the boat may be the

overriding factor. This type of chart allows one to make

comparisons as well as to assign a value to those comparisons.

(Do not include those criteria that are important and are met by

all the vehicles under consideration, such as air conditioning or

power windows).

Module 10






Module 10

Criteria Rating Chartoverhead 13

Decision Options Total 100%

Assign a percentage to each criteria. Criteria total 100%Rate each option against each criteria, assigning a value of the percentage.Total the score for each option

Criteria Rating Chart: Optional Exampleoverhead 13a

Criteria 1 Criteria 2 Criteria 3 Criteria 4Items underconsideration

Criteria 5

Instructor Notes


Module 11 Ending a Team and Program Conclusion

Display Overhead 14, “When Ending a Team or Team Project.”

Emphasize the importance of teams’ celebrating their

successes and recognizing the contributions of individual

members. Emphasize the importance of teams’ reflecting on

what contributed to their success and what hindered their

performance so that individuals can continue to learn how

teams function effectively.

Tell participants that, to reinforce what they have learned

today, they are going to do one more activity.

“I would like you to acknowledge to yourself one thing you

already do well that contributes to your success on a team.

And I would like you to identify one learning or skill you

gained from today’s program that you are willing to apply to

your work on teams.”

There are two suggestions for how to share this

acknowledgment.

Option 1. Go around the room and have each person report

the one learning or skill they will make a commitment to use

while working on teams.

Option 2. Choose a partner and for one minute each, share the

one learning or skill they will make a commitment to use while

working on teams. (This takes less time.)






Module 11

When Ending a Team or Team Project:overhead 12

■ Acknowledge individuals: recognize and celebrate accomplishments.

■ Document individual’s performance and contribution to team’s success for

inclusion in appraisal process (copy to employee and functional manager).

■ Summarize learnings with each other about what contributed or hindered

the team’s success.

Conclusion and summary

Instructor Notes


Module 11





Review/Closing










course offering.




+ ∆

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ParticipantWorkbookE V A L




Evaluation Form

Please complete all parts of this brief evaluation. Results will be used to improve this program. The goals ofthis training are: 1. to identify the key elements of successful teams, 2. to explore roles and responsibilities ofteam leaders and members, 3. to listen for understanding and to speak in ways that build agreement, 4. todevelop skill in providing peer resource assistance to team members, and 5. to identify appropriate decision-making methods for team use. Please rate the following elements of today’s workshop, both in terms of theirusefulness in reaching the instructional goal and their overall quality. Please provide written comments in thespace provided to explain your rating or to offer suggestions for improvement.

1. Program Introduction

Comments:

2. Pet Peeves on Teams

Comments:

3. Differentiating Teams vs Teamwork

Comments:

4. Task, Process, Relationships

Comments:

5. Setting Goals and Developing Action Plans

Comments:

6. Focusing the Afternoon Session

Comments:








Instructor Notes



Participant Handout

7. A Team Exercise

Comments:

8. A Team Exercise

Comments:

9. A Team Exercise

Comments:

10. A Team Exercise

Comments:

11. A Team Exercise

Comments:


Program IntroductionPet Peeves on TeamsDifferentiating Teams vs. TeamworkTask, Process, RelationshipsSetting Goals and Developing Action PlansFocusing the Afternoon SessionCommunication Skills on TeamsA Team ExerciseTeaching and Learning on the TeamDecision-Making on the TeamConclusion and Summary

Comments:








Instructor Notes



Participant Handout










DEP


Multimedia Teams II: Increasing theEffectiveness of Multimedia Teams



InnovationGathering






natural resources.

This integrated curriculum was designed under the sponsorship of an EPAEnvironmental Technology Initiative Grant to the Massachusetts Department ofEnvironmental Protection. The Toxics Use Reduction Institute, as contractor to the MADEP, coordinated the design and publication of curriculum materials in collaborationwith the MA DEP Bureau of Waste Prevention and the Northeast Waste ManagementOfficials Association.


*Enhanced Communication

*


Table of Contents Including Overheads



Module 3: Assessment of a Team’s Development .......................................................................................... 24

Tuckman’s Phases of Team Development ................................................................................................ 25

Tuckman’s Team Development Wheel ..................................................................................................... 27

Tuckman’s Team Development Grid ........................................................................................................ 31

Module 4: Teams as Problem Solvers ............................................................................................................. 34

Module 5: Generating Solutions ..................................................................................................................... 62

Module 6: Selecting a Solution ....................................................................................................................... 68

Module 7: Resolving Differences on the Team ............................................................................................... 70

Module 8: Negotiation Skills on the Team ..................................................................................................... 78

Preparation for Negotiation ..................................................................................................................... 79

Preparation for Negotiation ..................................................................................................................... 83

Module 9: Clinic of Team Issues ..................................................................................................................... 92

Module 10: Program Summary ...................................................................................................................... 94

Evaluation: ....................................................................................................................................................... 96

Table of Contents



Module 3: Assessment of a Team’s Development .......................................................................................... 24

Module 4: Teams as Problem Solvers ............................................................................................................. 34

Module 5: Generating Solutions ..................................................................................................................... 62

Module 6: Selecting a Solution ....................................................................................................................... 68

Module 7: Resolving Differences on the Team ............................................................................................... 70

Module 8:Negotiation Skills on the Team ...................................................................................................... 78

Module 9: Clinic of Team Issues ..................................................................................................................... 92

Module 10: Program Summary ...................................................................................................................... 94

Evaluation: ....................................................................................................................................................... 96

Instructor Notes

4 Instructor Notes Multimedia Teams II: Increasing the Effectiveness of Multimedia Teams

Icon legend

Trainer needs to



Nex

t…





ParticipantExercise




ParticipantHandout












FLIPCHART





OVERHEAD (no.)


PAUSE Video

Start Video


STOP Video




EXERCISE



Multimedia Teams II: Solving Problems and Resolving Conflicts 5

Overview

Instructional Goals

1. In their work, participants will use a step-by-step approach to resolve differ-ences and reduce conflict among team members.

2. Participants will help team members to apply team skills to pollution preven-tion efforts.

3. Participants will be better able to promote pollution prevention in team discus-sions.



1. Participants will be able to identify phases in the development of an effectiveteam and the appropriate actions that can help the team to increase its effective-ness at each phase.

2. Participants will be able to understand and apply a problem-solving method onthe team.

Instructor Notes

6 Instructor Notes Multimedia Teams II: Solving Problems and Resolving Conflicts

Target Audience This program is designed for those individuals who have been working on

teams and want to improve their ability to solve problems and resolve conflicts

that emerge on teams. It is designed to follow the course on Multimedia Teams I

which focuses on the basics of making teams work successfully. It is designed for

participants who have expertise in one environmental medium, and have been

or will be increasingly working with colleagues on teams with expertise in a

medium other than their own. Whenever possible the instructor should

reinforce the principles and value of pollution prevention.

Course length AM: 3.5 hours including (1 )15 minute break

PM: 2.5 hours including (1) 15 minute break

Number of participants 20

Room Set-Up A room large enough to accommodate a U-shaped table set-up with

participants sitting around the perimeter is ideal for discussion and participant

involvement. The breakouts into teams can occur at the four corners of the U,

using both sides of the tables. All teams need to be working in the same room

to maximize the effectiveness of this program design.

Instructor Note The materials in this instructor’s guide were developed to be used by

experienced trainers with excellent facilitation skills. The problem-solving and

negotiation content contains exercises that involve multiple small groups

working simultaneously on different issues.

Supply Materials NeededOverhead projector and screen2 flipcharts: one each to the left and right of the open space in the

U-shaped table set-upColored markersMasking tapeGreen Dots (Presaply color coding labels)Green Post-It notes (Size: 3x5)Yellow Post-It notes (Size: 3x3)Whistle or chime used to reconvene the class



Multimedia Teams II: Increasingthe Effectiveness of MultimediaTeams

Target Audience This program is designed for those individuals who have been working on

teams and want to improve their ability to solve problems and resolve conflicts

that emerge on teams. It is designed to follow the course on Multimedia Teams I

which focuses on the basics of making teams work successfully. It is designed for

participants who have expertise in one environmental medium, and have been

or will be increasingly working with colleagues on teams with expertise in a

medium other than their own. Whenever possible the instructor should

reinforce the principles and value of pollution prevention.

Instructor Notes


Place the following supplies in a plastic freezer bag for each team:

10 green dots cut in groupings of two

2 packets of 3x3 Post-It notes

packet of 3x5 green Post-It notes

One black and one color marker

Program Materials Needed

Overhead slides

Prepared Flipcharts

Prepared Flipcharts to display chart of the problem solving process on wall

Handout packets for each participant (20)

Case A: Role #1, Role # 2 (10 copies each)

Case B. Role #1, Role # 2 (10 copies each)

Participant evaluation forms (20)

Copies of Team Memory Jogger: A Pocket Guide for Team Members, publishedand distributed by Goal/QPC, 13 Branch Street, Methuen, MA 01844(1-800-643-4316).



Workshop Goals

■ Help participants identify phases in the development of an effective team andthe appropriate actions that can help the team to increase its effectiveness ateach phase.

■ Assist participants to understand and apply a problem-solving method on theteam.

■ Assist participants to use a step by step approach to resolving differences andreducing conflict among team members

■ Encourage and support participants to help team members to apply team skillsto pollution prevention efforts

Instructor Notes


Flipcharts The following flipcharts should be prepared prior to the training session. See the

course materials for the details for each flipchart.

A. Program Goals — see Instructor Notes, page 12

B. Agenda — see Participant Notes, page 13

C. Guidelines for Working Together — see Instructor Notes, page 16

D. Participant Introductions — see Instructor Notes, page 18

E. Participant Expectations — see Instructor Notes, page 18

F. Communication on Teams — see Instructor Notes, page 20

G. Problem Solving Process — see Instructor Notes, page 34

H. Problem Solving Process — see Instructor Notes, page 34[note: there is no Flipchart I]

J. Problem Solving Process — see Instructor Notes, page 34

K. Root Cause — see Instructor Notes, page 62

L. Brainstorming — see Instructor Notes, page 64

M. Methods for Evaluating Alternatives — see Instructor Notes, page 68



What It Is Like to Work in a Team

As the workplace makes the transition to team systems over the next decade,American workers will encounter significant changes in the work environment.Hiring, training, orientation, and other practices will be greatly altered. So will theday-to-day work experience. Many, if not most, of the rules enterprising Americanshave followed for success will fundamentally change. The skills and abilities Ameri-cans need to be successful in a team-oriented workplace are quite different fromthose required for success in the traditional American business. Here are some ofthe more significant differences…

—Joseph H. Boyett and Henry P. Conn Workplace 2000: The Revolution Reshaping American Business

On Teamwork

When geese fly in formation, they travel 70% faster than when they fly alone.

Geese share leadership. When the lead goose tires, He (or she) rotates back into the“V,” and another flies forward to become the leader

Geese keep company with the fallen. When a sick or weak goose drops out of theflight formation, at least one other goose joins to help and protect.

Being part of a team, we accomplish more, faster. Support, compassion and caring(honking from behind) inspire those on the front lines, helping them to keep pacein spite of pressure and fatigue. It is a reward, a challenge, and a privilege to be acontributing member of a team.

© Copyright 1988–1995, Enlightened Leadership International, Inc.

Instructor Notes


Workshop Goals

■ Participants will be able to identify phases in the development

of an effective team and the appropriate actions that can help

the team to increase its effectiveness at each phase.

■ Participants will be able to understand and apply a problem-

solving method on the team.

■ Participants will be able to use a step by step approach to

resolving differences and reducing conflict among team

members

■ Participants will be able to help team members to apply team

skills to pollution prevention efforts

Agenda


1 Program Introduction 30 min

2 Communication Skills 10 min

3 Assessment of a Team’s Development 30 min

4 Teams as Problem Solvers

Defining the Problem 70 min

Causes of the Problem 30 min

AM Summary 10 min

5 Generating Solutions 25 min

6 Selecting Solutions 10 min

7 Resolving Differences on the Team 35 min

8 Negotiating Skills on the Team

9 Clinic of Team Issues 15 min

10 Program Summary 10 min

Plus/Delta 10 min

11 Program Evaluation 10 min

Total 5 hours



Agenda

Module Format

1 Program Introduction

2 Communication Skills

3 Assessment of a Team’s Development

4 Teams as Problem Solvers

Defining the Problem

Causes of the Problem

AM Summary

5 Generating Solutions

6 Selecting Solutions

7 Resolving Differences on the Team

8 Negotiating Skills on the Team

9 Clinic of Team Issues

10 Program Summary

Plus/Delta

11 Program Evaluation

Instructor Notes


Module 1 Program Introduction

Welcome Welcome the group and share your enthusiasm about working

with the participants. Relate a personal experience of how your

own life has been increasingly impacted by your involvement

on teams in planning, delivering or evaluating training

programs. Emphasize that work on teams inevitably leads to

the need to solve problems collaboratively and to resolve

conflicts among the team members. Indicate that the primary

focus of Multimedia Teams II is problem solving and conflict

resolution.

a. Program goals

Flipchart A: Program Goals

Review the goals for the program on the flip chart. Remind

students that these goals are in their handout materials. Note

that the tools learned today also can be used in non-team

experiences as well. Alert students to be thinking of how

conflicts have emerged on their real-life teams so that in the

day’s exercises actual problems can be addressed.

b. Agenda for the Day

Flipchart B: Agenda

Review the general flow of the day and indicate where breaks

and lunch will take place. State at what time the program is

expected to end.

Communication on teams

Phases in Team Development

Break

Problem Solving Process (this will be finished in the early

afternoon)

Lunch (specify time)









Module 1

Multimedia Teams II: Solving Problems andResolving Conflicts

Program Goals

Program Introduction

Instructor Notes


Assessment of Conflict Style

Break

Resolving Differences through negotiations

Clinic of Team Issues (this is a time to deal with any team issues

addressed in either the Teams I or Teams II Modules of this

curriculum, and to use your expertise and that of participants

to address those concerns)

c. Guidelines

Flipchart C. Guidelines

Ask: “What guidelines do you want to set as the norm for how

we will work together today?”

Stress how important it is that team members explicitly define

the guidelines for how they will be working together. Write the

guidelines on the flipchart in numerical order.

Guidelines may include some of the following, but should be

solicited from the group:

■ Respect for each other’s point of view

■ Stay focused…keep on track (respect the time)

■ Take responsibility for your own learning

■ Speaking up in turn…watch that we do not

interrupt…watch for multiple conversations occurring at

the same time

■ Take one idea at a time

■ Listen to everyone’s ideas

■ Have fun



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Module 1



Module 1

Guidelines for the Workshop

Instructor Notes


d. Participant Introductions

Flip chart D (on left hand flipchart)

Name

Position

Where in the organization s/he works

Ask each person to state his or her name, position, place in the

organization, and one thing that s/he would like to learn about

working on teams.

Flip chart E. Expectations (on right hand flipchart)

“I would like to learn…”

Write each participant’s expectations on the flipchart. Note

any expectation that is not likely to be addressed during the

training. If appropriate, you may include any such expectation

in the Team Clinic module. Tape this flipchart on a wall.

????




Module 1






Module 1

Participant Introductions

Name

Position

Where in the organization you work

One thing I would like to learn about working on teams

Instructor Notes


Module 2 Communication Skills on Teams

Flip chart F

Listen

Speak Up

Build for Agreement

Remind participants that effective communication skills are

the cornerstone of effective team functioning. As team

members, they will want to work on being able to use all three

communication skills at the appropriate time. Review the

following information:

Listen

One way for a team member to let another team member

know that s/he is being heard is to actively paraphrase. (“What

I hear you saying is…“ “As I understand it you are saying…”)

Another way is to ask questions that explore for

understanding, rather than criticize or evaluate what has been

said (i.e., “Do you mean that if we delay the implementation of

this program we will lose 25% of the grant monies?”; “Do you

mean that we have no way currently to measure the release of

that chemical in the environment?”)

Speak up

It is important that each team member contribute his or her

ideas to the work of the team. To get the attention of the team,

use an introductory comment like: “I have an idea…I have

some concerns… I have experience in this area on another

project…”






Effective Communication on Teams

Listen

Each team member actively paraphrases to let another team member know thatthey are heard.

“What I hear you saying…”

“You believe it is important to…”

“You sound annoyed by the response you received to…”

“We see this differently. From your perspective you think…”

Speak up

Each team member contributes her or his ideas to the work of the team.

“Help me to understand how you came to this conclusion?”

“I have another idea about what is contributing to this problem.”

“I believe we will make a mistake if we do not speak with stakeholders about thisissue.”

Build for Agreement

Each team member seeks to build the relationships between common ideas.

“Let’s focus first on those areas where we agree on our approach to this issue.Then we can list the areas where we disagree.”

“Let’s break this issue down into some of its parts. Then we can see where weagree and where we disagree.”

Module 2Communication Skills

Instructor Notes


Build for Agreement

Team members should look for what different ideas or

recommendation have in common, not just what is different.

Note for participants that this can be difficult for an

engineering organization, which is accustomed to breaking

things down and finding differences. This analytic skill is

important to participants” work on teams, and they will

consciously need to look for ways to build on each other’s

ideas to reach agreement.

Summary: Ask participants to use these communication skills

during the training session as well on their work teams.

Indicate that during the training session, you will identify when

a participant uses effective communication skills to increase

the participant’s awareness of the importance of these skills.

Introduce the next concept. Read aloud the text on the

opposite Participant Notes page: “Team success depends

on…”

Achieving our goal or objectives

Effective processes for getting the work done

Relationships that build mutual respect and rapport

Module 2

????

Nex

t…



Team success depends on…





Module 2

Relationships

Goals

Processes

Instructor Notes


Module 3 Assessment of a Team’s Development

Introduce this module in the following way:

“When we are working on teams it can be useful to know that

teams have been observed to have phases of development.

Tuckman developed a model to illustrate those stages and

classifies them into four phases.”

Display Overhead 1, Tuckman’s Phases of Team Development.

Review Tuckman’s Stages.

Forming

Storming

Norming

Performing






Module 3

Tuckman’s Phases of Team Developmentoverhead 1

Forming

Storming

Norming

Performing

Assessment of a Team’s Development

Instructor Notes


Display Overhead 2, Tuckman’s Team Development Wheel.

Review the key words listed for each phase, as well as the

additional information presented on the following Instructor

Notes page.

Note for participants that this information is useful to have

because as we move from team to team it is easy for us to

compare one team experience with another. This gives us a

systematic way to understand in what ways they may be

different.

Emphasize that these are normal, predictable stages. It is not

possible to be a fully productive working team all the time.

Point out that the development of the team is not necessarily

linear. For example, a team can be very productive and then

return to a “storming” phase because the work on the team is

changing and the power and control of the group are being re-

negotiated.

Module 3






Module 3

Tuckman’s Team Development Wheeloverhead 2

Performance

Mature closenessResourcefulFlexibleOpenEffectiveClose and supportive

Forming

TestingPoliteImersonalWatchfulGuarded

Norming

Getting organized

Developing skillsEstablishing proceduresGiving feedbackConfronting issues

Storming

InfightingControlling conflictsConfronting peopleOpting outFeeling stuck

Phase Four Phase One

Phase Three Phase Two

Instructor Notes


Phase One: Forming

Here, the team members are trying to get a sense of each

other. Often they are overly pleasant. They are trying to figure

out how this team will function and what will be in it for them.

Phase Two: Storming

Team members struggle for power and control. “Camps” will

establish themselves. Some team members may decide to

leave because they are dissatisfied with what or how the team

is functioning. This is not an undesirable phase, although it can

be uncomfortable. It is a necessary phase so that teams can

move to a working, productive, and highly effective phase.

Phase Three: Norming

Team members come to agreement about how they will be

working together. There is new clarity about the goals for the

team and the role that each member will play. Members

become more honest about what they need and what they

will contribute to the team.

Phase Four: Performing

The team becomes productive and establishes an esprit de

corps. Team members are willing to work hard to accomplish

their goals and support each other in getting the work done,

and they become flexible in their roles. The team may do some

fun things together. Many teams never reach this stage, and it

would be unrealistic to think that all teams would become

high performing teams.

Module 3



Module 3

Instructor Notes


Refer participants to “Tuckman's Team Development Grid”

(Overhead 3) in their Participant Notes. Indicate that the

discussion will now turn to characteristics of team phases and

action steps to move the team forward.

Ask: Think of a team that you are currently working on or a

team you have worked on in the past at a specific moment in

time. What characterizes the behavior of the team members at

this point in time? Turn to pg. 33, and list the behaviors you see

and the phase you would consider the team to be in.

Note for participants that it can be useful to know strategies

that will help move the team toward a higher level of team

development. Ask the class to turn to pg. 33 in the workbook

and read through the recommendations for action steps to

move the team forward.”

After the class has had the opportunity to read through the

action steps, highlight one or two steps for each stage and

ask for questions.

Ask: “ Now go back to the team you were thinking about a few

minutes ago. Which of these strategies might have helped

move the work of the team forward at this point in time? “

Module 3

????

????






Module 3

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Instructor Notes


Ask participants to choose a partner and each take five

minutes to describe the team and the phase s/he believes the

team is in right now based on the characteristics that

distinguish the team. In addition, each partner should indicate

which of the strategies just reviewed s/he believes might be

useful for the team to consider or adopt at this time to improve

its functioning. Each person should ask his or her partner to

suggest additional ideas for strategies.

Call time after five minutes and remind everyone to give the

opportunity to their partner to speak if they have not already

done so.

After ten minutes, reconvene the whole group. Ask for two or

three examples.

Ask: “What phase did you believe your team is in? What

stratety did you or your partner believe might be helpful to

improve the team’s functioning?”

Emphasize the key learnings.

Break (15 min)

During the break, post the Problem-Solving Process

(Flipcharts G, H, J) on the wall.

????

Module 3






Assessing behaviors on my team

I see these behaviors on my team.

My team is currently functioning in Phase .

I can take the following actions to help improve my team’s functioning.

Module 3

Instructor Notes


Module 4 Teams as Problem Solvers

Lecturette: Problem Solving Process

Introduce this Module as follows:

“Teams are put together because there are complex issues toresolve. We give simple problems to individuals with themessage, ‘take care of it.’ However, tasks that are given to teamsoften have multiple layers that no one person can easilyresolve him/herself. It is the synergy of team problem-solvingcapability that leads to a solution greater than what any oneindividual can produce as a solution. These tasks given toteams may also be challenges to do things in a new way. Thismorning we are going to learn a problem-solving method thatis effective when working on teams.

This problem-solving method involves taking time to definethe problem and to determine the causes. Our hope in usingthis method is to increase the probability that our solutionswill be successful.

When we become aware of a problem or a problem is broughtto our attention, we proceed with the following steps.”

Display and review Flipchart G.

1. Defining the problem to be solvedSymptomsFacts

Display and review Flipchart H.

2. Determining the causes of the problemSelecting the root causeDisplay and review Flipchart I.

3. Generating solutions to the root causeDeveloping criteria for choosing a solutionChoosing the best solution based on the criteria

4. Developing and implementing an action plan.

5. Following up on the plan and checking on problem resolution.

(Note that the text of these flipcharts is reproduced in

Participant Notes on page 35.)












The Problem Solving Process involves

1. Defining the problem.■ Facts■ Symptoms

2. Determining the causes of the problem.■ Selecting the root cause

3. Generating solutions to the root cause.■ Developing criteria for choosing a solution■ Choosing the best solution based on the criteria

4. Developing and implementing an action plan.

5. Following-up on the plan and checking on problem resolution.

Module 4Teams as Problem Solvers

Instructor Notes


Lecturette

“The first step in the problem-solving process is to define the

problem. To get an accurate definition of the problem, we need

to identify the symptoms of the problem or present the facts

as we know them. Often when we do problem-solving we have

a tendency to make two mistakes.

1. First, we embed the solution in the problem. This is easy to do.

Most of us pride ourselves on being problem-solvers. We like

feeling competent and capable. So we prescribe in our

statement of the problem what we want done.

2. Second, we embed the cause in the problem without having

focused on symptoms and facts.”

To illustrate these mistakes, use your own examples from

everyday life, or use the example of "The Condo Leak", which is

in Participant Notes on page 39. Read this example aloud.

Module 4

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Module 4

Problem-Solving

When defining the problem■ state the facts■ list the symptoms

Avoid■ embedding the solution in the problem statement■ embedding the cause in the problem statement

Instructor Notes


Ask for a volunteer to create the problem statement and

record it on the flip chart along with all of the relevant facts.

“The maintenance staff wanted the facts. What are the facts?”

(Read the following information)

The owner’s vaulted ceiling began leaking at the highest point

and rivulets of water ran down the long ceiling dripping from

the highest point to the midpoint. The water came down the

ceiling approximately 12–14 ft. The remaining six feet of

slanted ceiling showed no evidence of water. The owner also

observed another rapid drip from a rafter in the basement

about one foot in from the outside wall. The basement drip

was below the area of the first floor ceiling drips but the carpet

was not wet. Four inches of water had collected in the pail in

the basement.

Based on the facts, the maintenance staff determined that the

leak in the basement was actually coming from the roof as

well. But they just could not see the water running into the

wall and down to the basement rafters. However, the leak in

the basement was directly below the water line on the first

floor.”

Thank the volunteer and ask him or her to take a seat.

Module 4



Module 4

The Condo Leak

“One winter when ice dams were particularly severe my condo developed a leak. Ilive in a modern unit that has a vaulted ceiling that is two stories high. This meansthat the ceiling has a long dramatic pitch. The water was running in rivlet fashiondown 3/4 of this ceiling and then dropping to the floor. I collected the water in pansin the living room so the carpet was not wet. However, I also had a leak in mybasement with water dropping from a rafter about 1 foot in from the outside wallbelow the area where the leak was occurring on the first floor. The floorboard wasnot wet. The pail in the basement collected about four inches of water.

I called the condo maintenance office and told them I needed to have my roofrepaired and my siding repaired due to leaks. I told them what solution I wanted.

This is what many of us do—tell others the solution we want. This is a commonerror.

The maintenance staff asked me to describe what I had seen, so they coulddecide on the cause and their own solution.”

Instructor Notes


Medical Example

Present a second example of problem description:

“Jane goes to the doctor and asks for medication for migraine

headaches. She asks Jane what makes her think that she is

having migraine headaches. The doctor wants to know what

symptoms Jane is having so that she can diagnose the

problem. Jane makes another common mistake in defining the

problem. She embeds the probable cause in the statement of

the problem.

Jane describes how sometimes after a meal, she gets a

headache and then get an upset stomach. The headache gets

so bad she has to rest quietly.

The doctor tells Jane she does not believe Jane is having

migraines. She believes Jane is having a food allergy. If you

were having migraines, these symptoms would appear after

exercise, but not after eating. Her recommendation was for

Jane to collect more data by keeping a journal to see what

foods Jane was eating when the headaches came on.”

With input from participants, create the problem statement on

the flipchart.

Module 4




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Module 4

Examples of Problem Statements

1. What are the facts in the condo leak example

2. What are the symptoms in the medical example?

Instructor Notes


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Ice Cream Shop

Present a second example of problem description:

“Now let’s take another example. I run an ice cream shop andnotice that I have a lot of chocolate ice cream in the store.

If I describe my problem as: (Write on a flipchart)

“…we are not selling enough chocolate ice cream”

…then I will look to sales for the answer. I may focus ondiscounting, promotions, etc. as my solution.

If I describe my problem as: (Write on a flipchart)

“…we are making too much chocolate ice cream”

…then I will look to slowing down production as the solutionto my problem.

However, If I say I have a problem and begin by stating thefacts as I know them, it sounds like this: (Write on flipchart)

Problem: Too much chocolate ice cream

■ I only want to carry a 10% inventory of any single flavor, andI am carrying a 30% inventory of chocolate ice cream.

■ The newspaper carried an article this week about chocolatenot being good for your health.

I now have a problem statement that contains facts. I maywant to gather further information, but I no longer haveembedded the solution in the problem statement.”

Ask: “From your experience on teams where have you beenpresented with a problem:

In which cases was the solution embedded in the problemstatement?

In which cases were the causes embedded in the problemstatement?”

Take examples from the class to illustrate defining the

problem.







Module 4

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Module 4

Ice Cream Shop Example

Problems:

Here, you have been presented with a problem. From your experience on teams,have you seen:

■ A solution embedded in the problem statement?

■ A cause embedded in the problem statement?

Instructor Notes


Indicate that the discussion will now turn to addressing

problems with which participants are dealing.

Direct students to page 45, and ask them to complete the

Problem-Solving Worksheet.

Ask participants to select a real problem that they are faced

with (big or small). It can be something that they are working

on or an issue facing their agency, as long as they choose

something that they are willing to talk about out loud. Ask

them to write the problem down under the heading, “I am

aware of this problem,” and then write down all the facts/

symptoms about this problem. Give participants five minutes

to complete this task.

Assign participants to teams (see next Instructor Notes page

for methodology). Designate the teams by number or name

and tell the participants the location in the room where each

team will be meeting. However, they must wait to go to these

locations until they have been given all the directions for the

next team task.

Module 4


Participant WorksheetModule 4

Problem-Solving

Take a real problem you are dealing with(big or small). It can be something you areworking on or an issue confronting your agency, but choose something you are willingto talk about. Write the problem down as you know it. Then, write all the facts orsymptoms about the problem. Lastly, write the problem as a statement of fact.

I am aware of this problem.

Describe the symptoms or facts of the problem:

■ What have you observed or heard that makes you believe there is a problem?

Write the problem as a statement of fact.

■ Eliminate any subjective interpretation of the facts.

■ Avoid embedding a probable cause in this statement.

■ Avoid embedding a possible solution in this statement.

Instructor Notes


Methodology for assigning teams

With a class of 20 participants, you will want to have four teams

with five members each. Teams can have more than five

members, but should not have less than five members. Use one

of the following methods to assign participants to a team:

a. If you know the participants, pre-assigned lists can be

developed.

b. If some participants are already working on a team together, it

is OK if they work on a real problem they are facing on the

team.

c. Teams can be formed by taking individuals with expertise in

different environmental media and putting them together.

d. Team members can be assigned randomly. The participants

can count off (1, 2, 3, 4, 1, 2, 3, 4, etc.) until all participants have a

number. All the ones form Team I, all the twos form Team II, etc.

Give each team the following tasks:

Task 1. Each team member will read in turn their statement of a

problem, and then describe the symptoms of the problem as s/

he has written them. As person reads the problem and

symptoms, other team members should not discuss or

respond.

Task 2. After each member has presented his or her problem, each

team chooses one of the problems to work on for the

remainder of the morning.

Suggestions for the instructor: Teams will need about 10

minutes to settle themselves, read the problem statements,

and choose a problem to work on. Give a 2 minute alert: “How

many teams have selected a problem statement to work on?”

You may give more time if the teams have not finished these

two tasks.

Module 4



Module 4

Team Problem Solving Task

Team Task 1. Each team member reads aloud the statement of the problem includ-ing the facts and symptoms of the problem. There is no discussion of the problem.

Team Task 2. After each team member has presented a problem, the team choosesone problem from within the team to work on as a team.

Instructor Notes


Once each team has decided on a problem that it will work on,

ask each team to reexamine the problem statement and the

symptoms. Give each team fifteen minutes for the following

tasks:

Task 3. As a team, ask whether there are additional facts or symptoms

that are important to understanding this problem.

Task 4. When you have all the facts and symptoms, write a problem

statement identifying the facts and symptoms. Do not

attribute causes or embed solutions.

Give each team ten minutes for the following task:

Task 5. Write the problem statement on flipchart paper and post it on

the wall. You will have 10 minutes.

After the teams have posted their problem statements, ask for

a spokesperson from each team to read the team's problem

statement. Give each team five minutes for feedback from

others in the class.

Ask the class:

Does the problem statement contain only facts and

symptoms?

Have solutions been embedded in the problem?

Have probable causes been embedded in the problem

statement?

What suggestions would you make to the team?

*Emphasize that the purpose of this feedback exercise is not to

look for errors, but to examine as a group the complexity of

problem-solving. Be sure that individuals offering feedback

explain their contributions sufficiently so that the team

members understand. Use any of the examples reviewed

earlier to reinforce core concepts.

Module 4

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Module 4

Team Problem Solving Task (cont’d)

Team Task 3. Examine the facts and symptoms of the problem your team hasagreed to work on.

Ask: Are there additional facts that are important to understanding this problem?

Are there additional symptoms that are important to understanding this problem?

Team Task 4. Write a problem statement including the appropriate facts and/orsymptoms.

Team Task 5. One team member will write the problem statement on the flipchartpaper and tape it on the wall for the class to read.

Wait for class discussion. Each team will read their problem statement aloud to theclass and ask for feedback from the class.

Team Task 6. The team makes modifications in their problem statement based onfeedback from the class.

The whole class will review each of the problem statements.

When reviewing problem statements presented by the teams, ask:

■ Does the problem statement contain only facts and symptoms?

■ Have solutions been embedded in the problem?

■ Have probable causes been embedded in the problem?

■ What other suggestions do you have for the teams?

Instructor Notes


Give each team five minutes for the following task:

Task 6. Make modifications to your problem statement based on

feedback from the class.

Summarize the Module with the following statement:

“If we do not state the problem accurately, we will not be able

to identify critical causes nor create the needed solution. Most

organizations pay too little attention to defining the problem.

Short term fixes are then introduced as if they were the

solution.

Caution to the Instructor: Some participants may raise the issue

that in a regulatory agency or political environment, they feel

compelled to respond to a problem as it has been given to

them. Consequently, they do not feel empowered to use the

methodology described above to redefine the problem. If this

issue arises, indicate that the day’s format only allows for a

small time (5–10 minutes) to discuss it. Acknowledge the

considerable tension that this dilemma may cause a team to

feel, and indicate that problem (re)definition in such a case will

require a team to make an important judgment call. Ask

participants to offer examples of successful strategies that they

have used to redefine the problem in a political environment.

Module 4



Module 4

Summary

If we do not state the problem accurately, we will not be able to identify criticalcauses nor create the needed solution. Most organizations pay too little attention todefining the problem. Short term fixes are then introduced as if they were thesolution.

Instructor Notes


Causes of the Problem

Lecturette

“We are now ready to examine what may be causing the

problem you have described.

On teams, we frequently begin a discussion of what we believe

may be causes of the problem. These conversations can be

fascinating and time-consuming. Verbal conversations are very

useful when people are new to a team and need to get to

know each other’s thoughts and values, as well as explore the

constraints and possibilities of a situation. I am going to

introduce you to a non-verbal method for examining causes

that can be used to focus the issue in a small amount of time. I

will be leading you through this step by step.” (You may want

to ring a bell or chime at the end of each step to gain the

group’s attention.)

Ask participants to rejoin their teams and, next to their

problem statement flipcharts, hang a blank sheet of flipchart

paper with their team number marked in the upper corner.

Read teams the instructions in Step One and give them ten

minutes.

Step One: “Each team has 3x3 packets of Post- It notes. All team members

are to work silently and independently to think of all the

possible causes for the problem. Write down each cause on a

separate Post-It note. When a person is finished, s/he should

post the Post-It notes randomly on the blank flipchart paper.”

Read aloud the instructions in Steps Two and Three together.

Tell participants that they have no time limit, and that each

group should sit down when it finishes the task.

Module 4






Module 4

Determine the Causes of the Problem

Each team posts a problem statement. Each team posts a blank sheet of flipchartpaper next to their problem statement.

Method

Step One: Take a 3 x 3 packet of post it notes. Think of all the possible causes forthe stated problem. Write down each cause on a separate post it note. Write onlyone cause cause on one note. When you are finished, post the notes randomly onthe blank flipshart paper designated for your team.

Instructor Notes


Step Two: “When your team is ready, silently go up to the flipchart and

read all the causes that have been posted. Without speaking to

each other, begin clustering those causes of the problem that

seem to go together. You may cluster the causes in whatever

way makes sense for you. Do not share with your teammates

your reasons for clustering the causes. If one Post- It keeps

being moved from one cluster to another, write the same

cause on another Post- It and place the duplicate Post- Its in

two clusters. It is fine if a cluster consists of one Post- It.”

Step Three: “Now take the 3x5 Post- It notes that have been distributed to

each team, and begin to create/define a category for the

clusters of causes as your team has grouped them. You may

speak to other members of your team during this task. When

you have finished, sit with your team and discuss what you

have discovered about the probable causes.”

When the teams have finished the task, get their attention and

review with them what they have done. (If one group takes a

long time, tell them they will have three minutes to finish the

task.)

“You have just identified all the causes of your team’s problem.

This process is an adaptation of the Cause and Effect/Fishbone

that is used in continuous process improvement.”

Ask participants to take a minute to share observations or

learnings about generating causes in this way. (If the class

needs prompting, ask: How was this process helpful in

identifying causes? How did this process hinder identifying

causes?)

Module 4

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Module 4

Determine the Causes of the Problem (cont’d)

Step Two: When the team is ready, silently go up and read all the causes that havebeen written. Without speaking to each other begin clustering those causes of theproblem that seem to go together. You may cluster the causes in whatever waymakes sense for you. Do not share your reasons for clustering the causes. If itappears that one cause keeps being moved form one cluster to another cluster, writethe same cause on another post-it, and let the same cause to be placed in twoclusters. It is OK if some causes are in a cluster of one.

Step Three: Take the 3 x 5 post-its that have been distributed to your team. Begin tocreate a category for each cluster of causes. You may speak to other members ofyour team during this task. A single post-it can have a label, or stand alone as it is.When finished, discuss with your team what you have discovered about probablecauses.

Instructor Notes


Reinforce the following if not identified by participants:

*Non-verbal processes can be valuable when you are working

with expansive parts of the process. They allow lots of data to

be generated in a short amount of time and in an organized

way. Conversations can then focus on the most important

issues rather than be diverted by scattershot ideas and

comments.

*All information generated in this way should be

understandable to the team. The team should take the time to

clarify what each member means by his/her contribution.

Give participants the final task, which is to decide upon the

root cause(s) of the problem identified.

Step Four: “Among the causes of your team problems are some root

causes that you believe would help solve the problem if they

were addressed. By addressing root problems, we make an

assumption that we will significantly eradicate or alleviate the

problem. This is different than relieving the symptom. If we

have a headache, we take aspirin or ibuprofen. However, if we

have a brain tumor, taking away the symptom will only mask

the problem. On a team, members will need to make decisions

about the root cause and how to address it. In most cases,

teams will need to create a plan to gather further information

to verify the root cause.

We will use a decision making process based on majority rule.

Module 4

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Module 4


Step Four: Deciding on the Root Cause.

The team identifies the root cause because if the root cause is addressed we assumethat we will eradicate the problem or make significant progress in reducing theproblem.

In most cases the team will need to gather further information to verify the rootcause, and a plan will be needed to be created to collect the information.

Instructor Notes


Each member of the team will receive two adhesive dots. You

are to place a dot next to the cause(s) you believe are the root

causes of the problem your team is addressing. Remember that

the root cause may be a single Post-It note rather than a

cluster of Post-It notes. We are going to vote on a root cause

because we need to narrow down our approach to the

problem, and we want our solution to address the root cause

of the problem.”

Module 4

Summary of AM Summarize the morning’s content. Note that we use a process

of expanding and focusing when we identify problems and

create solutions.

Review the steps in problem solving on the wall chart. Mark

the wall chart to indicate places in the problem solving process

where we expand our thinking and places in the process

where we focus our thinking.

1. Defining the problem to be solved

Symptoms

Facts

Writing a statement of facts and symptoms

2. Determining the causes of the problem (<Expand>)

Selecting the root cause (>Focus<)



Module 4


Task: Each member of the team will receive two dots. Place a dot next to the causesthat you believe are the root cause of the problem your team is addressing.

List the root causes of the problem identified by the majority vote of the membersof your team.

Instructor Notes


3. Generating solutions to the root cause (<Expand>)

Developing criteria for choosing a solution

Choosing the best solution based on the criteria (>Focus<)

4. Developing and implementing an action plan

5. Following up on the plan and checking on problem

resolution

Remind participants that it is especially important for team

members to alert each other when they are in an expanding

phase (i.e., “it’s important for us to consider all possible ideas

here”) or in a focusing phase (i.e., “we need to limit or select

what we can respond to”), so that members are contributing in

a way that helps the problem solving task move forward. Often

team members become invested in their own agenda and can

miss the cue that the team has shifted from expanding to

focusing, or vice versa.

Encourage participants to read, during lunch, the cluster

categories and problem cause on which other teams have

been working.

Lunch Break

Module 4



Module 4

Summary of AM

1. Defining the problem to be solved

Symptoms

Facts

Writing a statement of facts and symptoms

2. Determining the causes of the problem (<Expand>)

Selecting the root cause (>Focus<)

3. Generating solutions to the root cause (<Expand>)

Developing criteria for choosing a solution

Choosing the best solution based on the criteria (>Focus<)

4. Developing and implementing an action plan

5. Following up on the plan and checking on problem resolution

Instructor Notes


Module 5 Generating Solutions

When participants return from lunch, ask them to sit with their

teams.

Problem-Solving: Causes of the Problem

“The green dots on each of the charts of causes generated this

morning represent the clusters that each team believes to be

the root cause of its identified problem. In most circumstances,

the team would then need to answer the two questions you

see here.”

Display Flipchart K: Root Cause

For each Root Cause:

■ What information do you need to verify this cause?

■ How will you collect this information?

“We will not be taking the time to identify or collect this

information today. We are going to proceed as if the root

causes you have selected are the most appropriate on which

to focus to generate a solution to the problem.

Now you are ready to brainstorm solutions to the root cause.

We are going to do this using a method called “silent

brainstorming with round robin report out.” You will be

developing a solution for the root cause that received the most

votes from your team this morning.

Before we do this, I would like each of you to go back and have

the team member read his/her original statement of the

problem, as well as the problem statement as defined by the

team. It is important when we focus on solutions that we

reground ourselves in the original problem.

Then, read the root cause the team has selected.”






Module 5

Problem Solving

Causes of the Problem.

In the last exercise we worked on:

A. What may be the causes of the problem? (list all that apply, but do not describein detail).

B. Which causes do you want to investigate as “root causes” or the most probablecause of the problem?

The next step would be to ask:

For each “root cause”?■ What information do you need to verify this cause?■ How will you collect the information?

We will not be collecting this information today. We’ll proceed as if the root causesyou’ve selected (with dots) are the most appropriate to focus on for generatingsolutions.

Generating Solutions

Instructor Notes


After a few minutes, resume the directions:

“Now we are ready to brainstorm solutions. Rather than doing

this out loud, I would like each member of the team to create a

list of possible solutions for the root cause. Remember the

rules for brainstorming (whether you are talking to yourself or

to another member of the team).”

Display Flipchart L: Brainstorming — the Groundrules

■ hitchhike ideas (let one idea generate another)

■ no criticism (don’t dismiss your idea until you have had a

chance to share it with others)

■ think creatively

■ no judgments or evaluation

“You have five minutes to create your lists of possible solutions.

Then, in your group, have each team member give one idea at

a time. Do not repeat ideas that have already been mentioned.

Keep going around until all the ideas are shared (up to ten

minutes). Ask someone on your team to record the ideas on

the flipchart.”

Optional: If trying to save time, you can have participants write

on a sheet of paper instead of a flipchart. This is useful because

often the participants will generate ideas that they will want to

take with them to apply back on the job.

Give a two-minute alert and reconvene the group.

Module 5






Module 5

Problem solving

Methods for Generating Solutions

Silent Brainstorming with Round Robin Report Out

Rules for Brainstorming■ hitchhike ideas■ no criticism of ideas■ think creatively■ no judgments or evaluation of the idea

Tasks:

Silently brainstorm possible solutions for the root cause of your team’s problem.(Make a list of your possible solutions.)

Report Out

When each team member has finished generating solutions to the root causesilently, go around the team and ask each member to give one idea until all ideashave been presented.

Team members do not repeat ideas spoken aloud by another team member.

Instructor Notes


Ask: What advantages and disadvantages do you see in

generating ideas through “silent brainstorming with round

robin report out”?

Record the advantages on a flipchart. State the advantages

listed below if not mentioned by the participants:

■ gives quieter members an opportunity to contribute.

■ reduces the team member who may tend to dominate and

not realize that other team members have equally good or

the same ideas.

■ increases each team member’s sense of value.

■ provides motivation and appreciation.

Record the disadvantages on a flipchart. State the

disadvantages listed below if not mentioned by the

participants:

■ reduces the interaction among the team members (may not

be as useful in early stages of the team).

■ team leader may need to reinforce that only one idea may

be shared at a time.




Module 5

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Problem Solving

Methods for Generating Solutions

Advantages and Disadvantages of Silent Brainstorming with Round Robin Report

Advantages:

Disadvantages:

Module 5

Instructor Notes


Module 6 Selecting a Solution

Indicate that the discussion is now going to “focus,” after

“expanding,” in order to select a solution. Refer particpants to

page 69 of their Manuals for a list of appropriate methods for

evaluating alternative solutions.

Display Flipchart M: Methods for Evaluating Alternatives

■ Rank choices against each other.

This means comparing solutions, deciding which among

them is the best choice, second best, etc., and giving our

reasons.

■ Rate choices against a set of criteria.

This means that our solution must address certain criteria.

The criteria can be decided upon by the team, but

frequently include timeframe, cost, level of effort involved,

likelihood of stakeholder “buy-in,” etc.

■ Rate choices against a weighted set of criteria.

Same as above, except that after the team decides what the

criteria should be, it assigns values to the criteria.

“We are going to stop here for today. Your next step would be to

select a solution and then develop an action plan to

implement the solution. Remember that your materials from

the Teams I Module contain forms for developing an action

plan and assigning roles.

This completes the problem-solving process. It involves all the

steps we have done together. I hope you will introduce it to

your teams at work and use it.”

Refer to the wall chart and read the steps aloud.

Break






Module 6

Problem Solving

Methods for Evaluating Alternatives

■ Rank choices against each other

■ Rate choices based on a set of criteria

■ Rate choices against a weighted criteria

Selecting Solutions

Instructor Notes


Module 7 Resolving Differences on the Team

Introduce this Module in the following manner:

“When a group of people are working together it is common for

differences to arise. It is important that we understand how we

behave when we are ‘in conflict’ and to understand that others

may behave very differently than we do. First, we are going to

look at common behavior patterns that occur in conflict, and

give you an opportunity to assess your own behavioral style.

Then, we will discuss some negotiation strategies to help

reduce or resolve conflict.”

Flipchart

There are two dimensions that Thomas Kilman has identified

as being important to our behavior when we are in conflict.

One is how uncooperative or cooperative we become.

On the flipchart, draw a horizontal axis with the following two

words.

uncooperative cooperative

The other dimension is how unassertive or assertive we become

when we are in a situation of conflict.

On the flipchart, draw a vertical axis with the following two

words.

assertive

unassertive

Ask participants to redraw these two axes in their notes.






Module 7

Conflict Management Model

Self Assessment of Your Behavior in Conflict

Plot the point on the continuum that is most descriptive of you in a conflictsituation at work.

■ First, place an “X” on the horizontal axis to indicate how cooperative/uncoop-erative you are.

■ Second, place an “X” on the vertical axis to indicate how assertive/unassertiveyou are.

■ Then draw a straight, dotted, horizontal and vertical lines from each “X”, to findthe point where they intersect.

Resolving Differences on the Team

Assertive

UnassertiveUncooperative Cooperative

Instructor Notes


Module 7

Self Assessment of Your Behavior in Conflict

“We are now going to assess how each of us behaves when we

encounter a conflict in the workplace. Think about how you

behave when you and a colleague “bump heads” at work…”

“Do you become ‘super cooperative’ (hanging in their at all

costs, going to great lengths to try and make it all work out,

trying to appease the other so that you will both get along), or

are you “uncooperative” (digging your heels in, not responding

to the other party, taking an attitude of “prove me wrong,”

resisting, “if they are going to get me there they will have to

carry me there.”)

Place an X at the point on the continuum that is most

descriptive of you in conflict at work.

■ The other dimension is the unassertive — assertive dimension.

You are familiar with the concept of assertiveness. The

unassertive individual is more passive ( ie they tend to

withdraw in the face of conflict, avoid the other person, miss

the meeting so they do not have to engage); the assertive

person is clear, direct and focused on what they want and

need( ie, they state exactly what they are looking for and by

when; they state the conditions under which they are willing to

go forward, etc)

■ Place an X at that point on the continuum that is most

descriptive of you in conflict at work.

■ Draw a straight dotted line from each of the X’s until you find

the point at which they intersect. Mark that spot with an X.

Consider this location on the grid as a zone of behavior.

■ Instructor draws an oval to indicate the zones and writes the

appropriate zone label in the oval.



Avoids

Compete

Compromise

Collaborate

Accommodate

Assertive

UnassertiveUncooperative Cooperative

Module 7

Conflict Management Model

Instructor Notes





ParticipantHandout

Module 7

Zone 1 lower left area: Avoids

Usually will not engage

See things: I lose, you lose

Easily feel victimized

Zone 2 lower right area: Accommodates

Tend to go along to be cooperative

See things: I lose, you win to keep peace

Zone 3 middle of the grid: Compromise

Seeks solutions

See problem solving as give and take

Work to help others save face

See things: win-win if we both give something up

Zone 4 upper left area: Compete

I have a goal

I want what I want

Stops listening to other’s points of view

See things: I win, you lose

Zone 5 upper right area: Collaborate

Strong wishes and beliefs

Seeks to build coalitions up, down, and across the organization;

Sees things win-win if we can get creative about our needs

and interests

Turn to Handout pg. 75 and read more about what these styles

look like and when they are appropriate to use.



Conflict Management Styles and Uses

AvoidProblem is never really acknowledged because participants are reluctant to get involved; parties try to solve theproblem by denying its existence.

Appropriate To Use When:■ someone is better able to resolve the conflict;■ the obvious conflict masks the real problem;■ more important issues demand attention;■ the odds are against satisfying any of your concerns.

AccomodateParticipants try to smooth over the conflict by emphasizing positive/common elements that appeal to bothparties. Differences are played down.

Appropriate To Use When:■ preserving the relationship is very important;■ the issue is of greater importance to the other party;■ maintaining harmony is especially important;■ other party has greater power, status, etc.

CompromiseProblem is solved through exchanging concessions and “splitting the difference.” Participants strive for asolution where everyone wins something.

Appropriate To Use When:■ a temporary settlement is desired;■ time is short and a solution is necessary;■ both parties are powerful and committed to very different goals;■ the outcome is important, but not critical enough to warrant the time and energy of the other approaches.

1

Instructor Notes


Module 7

Now think about a situation that you are currently in or have

been in recently where there was a conflict with one of your

colleagues. Are you playing your traditional role? What role is

the other party in? Are these the best roles for resolving this

particular conflict?

Instructor takes Questions and Answers on this assessment

tool. Discussion.

The goal is to be able to develop the skill to use different styles

strategically for any given situation. The style that many find

the most challenging to act on is the Collaborator style.

Collaborators are excellent negotiators, and we are now going

to spend time looking at how to improve your negotiations

skills.

????



Conflict Management Styles and Uses (cont’d)

CompeteRelies on authority, position or power to force a solution, which results in a win/lose situation.

Appropriate To Use When:■ immediate action is necessary;■ an unpopular action is needed;■ you know you are right;■ dealing with people who take advantage of non-competitive approach.

CollaborateIssues are faced openly and parties look for creative solutions. Emphasis is on a solution that deals with theconcerns of all parties.

Appropriate To Use When:■ people are committed to solving the problem together;■ the issue is too important to solve by compromise;■ enough time is available to complete the problem-solving process;■ the goal is to integrate the needs of the participants who have very different perspectives.

1

Instructor Notes





Module 8 Negotiation Skills on the Team

When any of us approach a negotiation it is because two or

more people want different things or have different solutions

to a shared problem. Think of a vacation—I may want to go to

a beach resort and you want a metropolitan area with

museums, gourmet restaurants, etc. We easily become locked

into our position. If we are compromiser’s we may even be

willing to say, “I’ll go to the city this year, if you will go to the

beach resort next year.” If we are collaborators, we work

together to find a creative solution that meets both of our

needs. For example, locating beach resorts that are in

proximity to metropolitan areas.

Overhead 2: Negotiation: Position, interests, and options

Instructor: Review the key parts of preparing for negotiation

We begin with our separate positions, become clear about the

interest or need behind the position, generate options that

meet both interests, and identify an alternative of what you

intended to do if you cannot work this out.

Let’s take an example.

I am alone in a small study room in the local library. You enter

the room, and sit at the other end of the table. You go and

open the window. I want the window kept closed. If I am an

accomodator, I put on my sweater and put books on my papers

so the papers do not blow around. If I am competitive, I get up

and shut the window you have opened.



Module 8

Position

(Mine) (Theirs)

Interests or Needs

(Mine) (Theirs)

Options ( Be Creative)

1.

2.

3.

4.

What is the alternative if this cannot be resolved?

(Mine) (Theirs)

Preparation for Negotiationoverhead 2

Negotiating Skills on the Team

Instructor Notes


Module 8

Position (mine): I want the window closed

Position (theirs): I want the window opened.

Behind every position there are interests and needs.

Sometimes we need to get clear with ourselves what our need

or interest is; and we need to consider what the other person’s

need or interest might be.

Interest (mine): I get stiff necks easily and avoid sitting in a

direct draft. I do not want my papers blowing around and

getting mixed up.

Interest (theirs): I may guess at their interest to be that they like

fresh air. If I ask them what their need is I may find out that

they are hot blooded and get less sleepy if they work in cool

temperatures.

A collaborator begins a conversation by acknowledging that

we seem to want different things.” You want the window

closed; I want the window open.” POSITION

The collaborator then asks about the interest or need of the

other person and shares their own. Why is it important to you

that the window be open? The collaborator uses reflective

listening to acknowledge the need: “You tend to get sleepy if

you do not have fresh air and like cooler temperatures.” My

needs are different: “I dislike sitting in a direct draft because it

gives me a stiff neck. I also do not want to get these papers

mixed up which may happen if they get blown around.”



Module 8

Example Scenario for Negotiation:“Reading Room at the Local Library”

I am alone in a small study room in the local library. You enter the room and sit athe other end of the table. You go and open the window. I want the window keptclosed.

If I am an accommodater, I put on my sweater and put books on my papers so thepapers will not blow around. If I am competitive, I get up and shut the window.

Let’s prepare to negotiate more productively.

Instructor Notes


????

????

Module 8

Interests or Needs

Instructor note for the class that there is no difference about

the cool temperature. It is important to one party but not a

significant issue to the other party. We often assume that the

other person’s needs are the opposite of what we want. )

How about if we consider ways in which both of our needs/

interests could be met?

Ask the participants: What options are available to these two

library users? OPTIONS

Some responses may include: Open window from the top; Ask

the librarian to turn on the air conditioner; keep the door open

and open a window in the hall providing fresh air without a

draft.

The two library users decide which of the options will work for

them.

If no option is agreed upon, then it is important to know what

alternatives you have?

Alternatives

Ask: what alternatives are available to these library users?

You might decide to go to another place in the library to work.

You might explain your dilemma to the librarian and ask that

another place in the library be found for the person who

entered your room.

Now, let’s try it out.



Module 8

Position

(Mine) (Theirs)

Interests or Needs

(Mine) (Theirs)

Options (Be Creative)

1.

2.

3.

4.


(Mine) (Theirs)

Preparation for NegotiationExample Scenario for Negotiation: “Reading Room at the Local Library”

■ They could go to another place in the library.■ I could go to another place in the library towork.

■ I could explain my dilemma to the librarianand ask that another place be found for theperson who entered my room.

1. Open window from the top.

2. Ask librarian to turn on the air conditioner.

3. Keep a door open and open a window in the hall to provide fresh air without a draft.

(guess) They like fresh air.

(After asking them) They are hot-blooded and getless sleepy if they work in cool temperatures.

I get a stiff neck easily so I avoid sitting in adirect draft. I do not want my papers blowingaround and getting mixed up.

They want the window open.I want the window closed.

Instructor Notes


Module 8

Instructor: Decide ahead of time which one of the case studies

(A) or (B) (see Participant pp. 85, 87) would be appropriate for

your group (or write a new case study). Use only one case

study because your time is limited. Carefully monitor the time

as they do the following tasks to keep the group moving

quickly. Ask participants to count off 1,2,1,2, etc. Assign all the

ones, Role 1 of the case study and all the twos Role 2 of the

case study. Ask the participants to read the case study, and

individually answer the five questions as best they can. Give

them 5 minutes)

Now, find a partner; all ones find a two. Now each one-two set

join with another one-two set; making a group of four.

(20 minutes)

Step A. Each of the #1’s talk first about how they defined their position

and how they defined the other’s position.

(Take 1 minute each. Just give your statements. Do not discuss

as yet.)

Instructor call stop after 2 minutes. Give the next directions.

Step B. Each of the #2’s talk now about how they defined their

position and how they saw the other position.(Take 1 minutes

each.. Do not get into solutions.)

Instructor call stop after 2 minutes. Give the next directions.

Step C. #2’s talk about your interest and what you think the other’s

interest is. Take 2 minutes each. The listener’s use reflective

listening and seek to understand.)

Instructor call stop after 4 minutes.



Module 8

Case A

Role #1Role: Team Member carrying the heaviest part of the project

You have been working on a project team for the last four months. In the beginningeveryone pitched in and shared the workload. You and a fellow team membervolunteered to work on some materials that would assist the compliance efforts inthe regions. They are due in two weeks and over the last two weeks your fellowteam member has not done any more work on them. You are resentful of the loadyou are carrying, and are worried that s/he is backing off entirely. There is aboutanother 10 hours of work to be done to complete the task. You have a team meetingtomorrow.

You need to address the issue with your team member.

Take 5 minutes and respond to the following questions.What is your position? How will you find out their position?What is your interest? What do you imagine their interest might be?What options might be possible?

Role # 2Role: Team Member who has been backing off the project team

You have been working on a project team for the last four months. In the beginningeveryone pitched in and shared the workload. You and a fellow team membervolunteered to work on some materials that would assist the compliance efforts inthe regions. They are due in two weeks. Over the last month you have not done anywork on the project. You have avoided returning phone calls, and respond to E-mailwith a short note, “I am working on it.” In truth you have two other projects thatneed to be done for your boss, and home responsibilities that make it impossible tospend any extra time on the team project. You know your fellow team member isvery responsible and you can count on him/her to pick up the slack.

You wish your boss had never volunteered you for this team in the first place.You not sure how much work is left on the project because you have not checked inwith your team mate, but you suspect its about 10-20 hours. You have a teammeeting tomorrow and are unsure if you will attend. You would like to havesomeone else finish the work with you team partner.

You are hoping your partner will continue to say nothing. If he/she brings it up,you will tell them that you will get to it next week. You believe the project is valu-able, but it is no longer a priority for you at this time.

Take 5 minutes and respond to the following questions.What is your position? How will you find out their position?What is your interest? What do you imagine their interest might be?What options are available?

Instructor Notes


Module 8

????

Step D. #1’s talk about your interests and what you think the other’s

interest is. Take 2 minutes each to share your interests.

Now as a group discuss what you have observed about

positions and interests. Do not discuss options as yet.

Instructor calls stop after 4 minutes.

Step E. Now its time to generate some creative options that will meet

the needs of both parties. Take another 3 minutes and go

around the group and read one of the options you have

written. Keep going around until all the options have been

shared. If you think of additional options, share those with the

group as well. After all the options have been shared, the

group chooses the one or two that you feel will lead to the

best win-win solution.

Instructor asks each group to quickly report out the one or

two options that will work best. Caution the group to ask

themselves as they listen: are these solutions creative? Are

these solutions win-win?

As you have been having your conversations you been

following some of the steps in negotiation. This is the work of

William Ury in Getting Past No.



Module 8

Case B

Role #1Role: Team member preparing outreach materials

You are at team member preparing materials for outreach to an industry sector. Youlike this work as it allows you to use your expertise in developing graphics, usingnew computer programs, getting out of the office. Although you have only workedon something like this once before, you are excited to be part of this effort. Youagreed to work on the text and presentation materials for this project.

However, there is a new education group who came to your last team meeting.They are now say that they will develop the overall strategy, and select the appropri-ate way educate on this regulation. You see that as your job. You have some goodideas which they seemed to walk right past. You do not want this group taking overyour turf.

You need to address the issue with your team member.


Role #2Role: Education and Outreach Expert

You have taken a position in the new Education and Outreach unit in your organi-zation. You are an expert putting together interesting materials and using sophisti-cated computer programs to make them appear effective. You believe that DEPcould be much more effective if they concentrated more resources in this area.

You are consulting to a team that is preparing a major outreach effort. You knowexactly how they should proceed. There is a team member who has an interest inthis area, but not much experience. You are eager to show the team that the rightperson was picked to be in the education and outreach unit.


Instructor Notes


Module 8

Steps in Negotiation

Instructor reviews the steps on the participant handout

“Steps in Negotiation.”




ParticipantHandout



Steps in Negotiation

Adapted from William Ury, Getting Past No

Keep Yourself Grounded■ Monitor you self-talk■ Know your “hot buttons”■ Keep breathing■ Keep your interest in mind■ Gain time/distance/clarity

Use silenceAsk for time to think or considerNever make an important decision on the spot

Step to Their Side■ Use reflective listening■ Acknowledge the other’s point of view and stand up for your own…

“You are wanting me to… and I am wanting…”■ State where you agree and where you differ

“We agree that… and we differ about…”■ Use “yes, and” rather than “yes, but.”■ Make “I” statements rather than “You” statements

Explore the Options■ Ask: “Are there other ways we might be able to work this out?”■ Share your interest and invite them to share theirs

“What is important to me is…”“What is most important to you…?”

■ Begin to package: “I am willing to do this…, if you are willing to….”

Reframe When You Meet Resistance“To change the game, change the frame”

■ Treat the other person as a partner rather than an opponent“I think we can find a way together to work this out.”

■ Ask: “Why do you want that?” or “Why is that so important?”(Ask even when you assume you know the answer)

■ Say: “Help me to understand the problem you are trying to solve…”■ Ask “What would happen if…?”■ Ask: “How would you suggest I approach my supervisor with this?”■ Agree where there were problems in the past, and acknowledge that you too

want to avoid those kind of problems in the future

2

Instructor Notes


Module 8



Steps in Negotiation (cont’d)

Bridge the Gap Between Their Interests and Your Own■ Rather than pushing when you meet resistance, build a bridge.■ Help the other save face.■ Break your proposal down into smaller steps they can agree with.■ Consider an “if–then” approach

Reach Agreement■ Restate and summarize

“So we have agreed to….” (state the terms of the agreement specifically)■ Identify any unresolved areas■ Acknowledge your appreciation for any progress made■ If necessary, identify the next steps:

Who?Does What?With Whom?When?

Monitor the Agreement■ Establish a way to check that the agreement is working■ Establish a way that either party can call attention to problems that arise with the agreement

2

Instructor Notes


????

Module 9 Clinic of Team Issues

Ask the group to identify those issues that they are concerned

about when working on a team, and would like to take a few

minutes to discuss. Use the expertise within the group to

provide helpful assistance on these issues. This session can be

expanded if you have additional time.

Instructor: Common concerns raised at this point are:

■ how to get a team started

■ the relationship of the team and its outcomes/products to

management

■ getting agreement from management

■ how members of team get recognized for their

contributions

■ how to deal with team members who do not do their fair

share.



Module 9

Issues on Concerns with Working on TeamsIn your experience, what issues have you encountered when working on teams?

What do others here suggest might be helpful in addressing these concerns?

Clinic of Team Issues

Instructor Notes


Module 10 Program Summary

With all the new learning about teams, you will observe and

become more aware when things are not going well on the

team and know that there are strategies that can make a

difference. You can find reminders of the strategies in a

number of places.

1. The last page of the handout identifies some common

problems and the recommendations that will help.

2. You will find useful tips in the Team Memory Jogger available at

www.turi.org. A copy should be distributed to each participant.

Encourage them to keep this in their desk drawer or to carry it

in their briefcase for a quick read on the subway. There are

many tips they could use at team meeting tomorrow. Special

reference can be made to:

pg.31 Keys for a good start

pg. 15 Guidelines for interacting on a team

pg. 136 Checklist of common problems

3. You now have the resources of each person in this room who

shares the same understandings about the importance of

teams. Use each other. You do not have to be alone in figuring

out how to improve the functioning of the team.

Instructor: Thank participants for their involvement, questions




ParticipantHandout



Why Teams Don’t Work

Adapted from Harvey Robbins, Why Team Don’t Work

3Program Summary

Solution

Get hidden agendas on the table byasking what people personally wantfrom working on the team

Clarify the reason the team hasbeen formed; define its purpose andexpected outcomes; clarify how theteam’s goal is aligned with thecompany’s goals

Clarify with team members what isexpected of them; define roles andresponsibilities and provide writtencopy for all team members;check that manager expectationsare consistent with team roleexpectations

Choose the decision makingapproaches appropriate to eachdecision

Learn what team members expectand want form one another, whatthey prefer, how they differ, startvaluing and using differences

The leader must learn to serve theteam and keep its vision alive

Create system of free flow of usefulinformation to and from all teammembers

Symptom

People with private agendasworking at cross purposes

People don’t know what they’resupposed to do, or the task makesno sense

Team members are uncertainwhat their job is

Teams may be making the rightdecisions, but the wrong way

Team members do not get along

Leadership is tentative orinconsistent

Team members are groping inthe dark

Problem

Mismatched Needs

Confused Goals,Cluttered Objectives

Unresolved Roles

Poor Decision Making

Personality Conflicts

Poor Leadership

Insufficient Feedback andInformation

Instructor Notes
















course offering.




+ ∆







Multimedia Teams II: Increasing the Effectiveness of Multimedia Teams

Evaluation Form

Please complete all parts of this brief evaluation. Results will be used to improve this program. The goals ofthis training are: 1. identify phases in the development of an effective team and the appropriate actions thatcan help the team to increase its effectiveness at each phase; 2. understand and apply a problem-solvingmethod on the team; 3. use a step by step approach to resolving differences and reducing conflict among teammembers; and 4. help team members to apply team skills to pollution prevention efforts. Please rate thefollowing elements of today’s workshop, both in terms of their usefulness in reaching the instructional goaland their overall quality. Please provide written comments in the space provided to explain your rating or tooffer suggestions for improvement.

1. Program Introduction

Comments:

2. Communication Skills

Comments:

3. Assessment of a Team’s Development

Comments:

4. Teams as Problem Solvers

Comments:

5. Generating Solutions

Comments:

6. Selecting Solutions

Comments:








Review/Closing

Instructor Notes



Participant Handout

7. Resolving Differences on the Team

Comments:

8. Negotiating Skills on the Team

Comments:

9. Clinic of Team Issues

Comments:

10. Program Summary

Comments:


Program IntroductionCommunication SkillsAssessment of a Team’s DevelopmentTeams as Problem SolversGenerating SolutionsSelecting SolutionsResolving Differences on the TeamNegotiating Skills on the TeamClinic of Team IssuesProgram Summary

Comments:







Instructor Notes



Participant Handout










DEP


Pollution Prevention in the Job Function:Regulation and Policy Development




natural resources.

This integrated curriculum was designed under the sponsorship of an EPA EnviromentalTechnology Initiative Grant to the Massachusetts Department of Environmental Protection.The Toxics Use Reduction Institute, as contractor to the MA DEP, coordinated the designand publication of curriculum materials in collaboration with the MA DEP Bureau of WastePrevention and the Northeast Waste Management Officials Association.


InformationAccess





*P2 in the Job Function:

*



Module 1: Introduction/Review of Workshop Objectives ......................................................................... 10Workshop Goals ..................................................................................................................................... 11Pollution Prevention in Regulations and Policies ................................................................................ 11

Module 2: Definition of Pollution Prevention and Toxics Use Reduction ................................................ 12What is Pollution Prevention? ............................................................................................................... 13What Does Pollution Prevention Mean? ............................................................................................... 13Waste Prevention Hierarchy .................................................................................................................. 15Who Benefits from Pollution Prevention? ............................................................................................ 15How Does Pollution Prevention Benefit Businesses? ........................................................................... 17Implementing P2.................................................................................................................................... 17Why/How Should Government Agencies Implement P2? ................................................................... 19

Module 3: Process for Policy and Regulatory Development ...................................................................... 20What is an Effective Regulation/Policy Development Process? ........................................................... 21Model of a Regulation and Policy Development Process ..................................................................... 23Define the Problem ................................................................................................................................ 25Team Building ........................................................................................................................................ 25Scoping ................................................................................................................................................... 27Development of Solutions ..................................................................................................................... 27Internal Consensus Building ................................................................................................................. 29External Consensus Building ................................................................................................................. 31External Consensus Building ................................................................................................................. 33Promulgation ......................................................................................................................................... 35Promulgation ......................................................................................................................................... 35Implementation and Evaluation ........................................................................................................... 37Example One: Pollution Prevention Regulation for Auto Finishing Operations ............................... 39Example Two: Pollution Prevention PolicyNON Cover Letter .................................................................................................................................. 41

Module 4: Building Pollution Prevention into the Regulatory Process ..................................................... 44P2 Opportunities During Problem Definition ..................................................................................... 45Problem Definition Stage: Example ...................................................................................................... 47P2 Opportunities During Teambuilding .............................................................................................. 49Opportunities During Scoping ............................................................................................................. 49P2 Opportunities during Development of Solution ............................................................................ 51P2 Opportunities during Internal Consensus Building ....................................................................... 53P2 Opportunities during External Consensus Building ...................................................................... 53P2 Opportunities during Promulgation ............................................................................................... 55P2 Opportunities during Implementation and Evaluation ................................................................. 55

Module 5: Pollution Prevention Information Resources ............................................................................ 58Information Resources........................................................................................................................... 59

Module 6: Case Study Activity — Applying the Lessons from the Workshop .......................................... 61Working Case: Instructions ................................................................................................................... 61Working Case: Overview........................................................................................................................ 61Working Case: Overview........................................................................................................................ 63Working Case: Overview........................................................................................................................ 63Working Case: Overview........................................................................................................................ 65Working Case: Questions to Address .................................................................................................... 65

Module 7: Review/Closing ........................................................................................................................... 70Evaluation: .................................................................................................................................................... 71

Table of Contents

Module 1: Introduction/Review of Workshop Objectives ......................................................................... 11

Module 2: Definition of Pollution Prevention and Toxics Use Reduction ................................................ 13

Module 3: Process for Policy and Regulatory Development ...................................................................... 21

Module 4: Building Pollution Prevention into the Regulatory Process ..................................................... 45

Module 5: Pollution Prevention Information Resources ............................................................................ 59

Module 6: Case Study Activity — Applying the Lessons from the Workshop .......................................... 61

Module 7: Review/Closing ........................................................................................................................... 71

Evaluation: .................................................................................................................................................... 71

Instructor Notes

4 Instructor Notes Pollution Prevention in the Job Function: Regulation and Policy Development

Icon legend

Trainer needs to



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ParticipantExercise




ParticipantHandout












FLIPCHART





OVERHEAD (no.)


PAUSE Video

Start Video


STOP Video




EXERCISE



Pollution Prevention in the Job Function: Regulation and Policy Development 5

DRAFT VERSION:

NOT OFFICIAL COPY


Instructional Goals

1. Participants will gain an understanding of the current policy and regulatorydevelopment process in their state.

2. Participants will be more motivated to and more capable of promotingpollution prevention through policies, regulations, and programs.

3. Participants will become familiar with the available resources and tools they canuse to identify options for promoting P2 via regulations and policies.

4. Participants will be able to use these resources and tools to integrate pollutionprevention into regulations and policies.

Training Audience

The audience will include:

1. Policy and regulation writers who develop new or revised regulations andpolicies.

2. Representatives from operations staff who participate in policy and regulationdevelopment.

3. Division directors and deputy directors responsible for steering, reviewing, and/or signing off on new or revised regulations and policies.

4. Attorneys involved in developing policies and regulations.


1. Participants will be able to identify information and other resources available tohelp them integrate pollution prevention into regulations and policies.

2. Participants will be able to identify and incorporate pollution preventionoptions into the process of developing regulations and policies.

Pollution Prevention in the Job Function: Regulation and Policy Development



Instructional Goals

1. Participants will gain an understanding of the current policy and regulatorydevelopment process in their state.

2. Participants will be more motivated to and more capable of promotingpollution prevention through policies, regulations, and programs.

3. Participants will become familiar with the available resources and tools theycan use to identify options for promoting P2 via regulations and policies.

4. Participants will be able to use these resources and tools to integrate pollu-tion prevention into regulations and policies.


1. Participants will be able to identify information and other resources availableto help them integrate pollution prevention into regulations and policies.

2. Participants will be able to identify and incorporate pollution preventionoptions into the process of developing regulations and policies.

Pollution Prevention in the Job Function:Regulation and Policy Development

Instructor Notes


Agenda


1 Introduction/Review of Workshop Objectives 15 min

2 Definition of Pollution Prevention and TUR 30 min

3 Process for Policy & Regulatory Development 60 min

4 Pollution Prevention in the Regulatory Process 45–60 min

5 Pollution Prevention Information Resources 45–60 min

6 Case Study Activity 60–75 min

7 Review/Closing 15 min

Total 6–7 hours

Additional Instructor Notes

1. Overhead numbering system: Overheads are numbered sequentially andreferred to (by number) in both the “Instructor Notes” section and the“Participant Notes” section.

2. Space is provided in the student handbook for taking notes and following thediscussion.

3. The instructor should read through the training to identify areas that need to bemodified to suit his or her particular state. This training was designed inMassachusetts for its agencies. Other states may have to engage in a designprocess where management in the agency considers its expectations for howthe staff that is developing policies and regulations should incorporate P2 intotheir activities. Participants in the training need to receive a clear message aboutwhat management expects them to do differently in their jobs as a result ofhaving participated in the training.

Participant Notes


Agenda

Module

1 Introduction/Review of Workshop Objectives

2 Definition of Pollution Prevention and TUR

3 Process for Policy & Regulatory Development

4 Pollution Prevention in the Regulatory Process

5 Pollution Prevention Information Resources

6 Case Study Activity

7 Review/Closing

Instructor Notes


Module 1 Introduction/Review of WorkshopObjectives

Module One should be introduced by a senior manager in the

agency (e.g., a commissioner, secretary, or his or her deputy).

1. Display Overhead 1. The presenter of this section should

acknowledge the progress made by the agency so far in

building P2 into regulatory activity such as regulations,

enforcement, inspections, and permits. The leader should also

do the following:

■ address why this workshop focuses on regulations and

policies — regulations and policies set the foundation for

other agency staff work, and yet more should be done in

this area with regard to P2;

■ challenge the audience to go further in building P2 into

regulatory activities; and

■ lay out the expectations from senior staff regarding P2 in

regulations and policies — such as when P2 should be

incorporated, and how and when senior managers will look

for P2.

Optional: If time allows, the leader might cover reasons why P2 is

a good strategy; if not, this topic will be addressed in the next

section.

2. Overhead 2 summarizes the goals of this workshop. The

training is intended to provide inspiration, tools, and resources

for staff to build pollution prevention into regulations and

policies.

3. Introduce the presenter of the next section.









Module 1

Pollution Prevention in Regulations and Policiesoverhead 1

A Workshop for Regulatory Agency Staff

■ Why P2 for regulations and policy staff?

■ A challenge to go further in building P2 into regulatory activities

■ Expectations from senior staff

Workshop Goalsoverhead 2

■ Review the pollution prevention definition and the waste prevention

hierarchy.

■ Review basic policy and regulation development process.

■ Help participants identify pollution prevention opportunities during

regulation/policy development.

■ Familiarize participants with P2 resources.

Introduction/Review of Workshop Objectives

Instructor Notes


Module 2 Definition of Pollution Preventionand Toxics Use Reduction

This module is intended as both a refresher on what pollution

prevention is for those who are already familiar with the

concept and a brief introduction to pollution prevention for

the uninitiated.

1. Review the definition of pollution prevention shown on

Overhead 3 and Overhead 4. This is a broad definition

intended to help participants think about any and all pollution

prevention ideas.

Feel free to substitute the federal definition or your state’s

definition of pollution prevention.







Customize



What is Pollution Prevention?overhead 3

Pollution prevention is any activity which prevents pollution from being

created in the first place, versus pollution control, which deals with waste

after it has been generated.

■ Pollution Prevention is an umbrella term that covers:

— Toxics use reduction

— Reduction of waste oil, solid waste, etc.

— Water and energy conservation

What Does Pollution Prevention Mean?overhead 4

■ The following practices would be considered pollution prevention:

— equipment or technology modifications

— process modifications

— reformulations or redesign of products

— substitution of raw materials

— improvements in housekeeping, maintenance, training or

inventory control

Module 2Definition of Pollution Prevention and TUR

Instructor Notes


2. Overhead 5 presents the waste prevention hierarchy, which is

a tool for demonstrating the preferability of various means of

addressing pollution. As the hierarchy shows, pollution

prevention is the optimal method, where it is available,

because it prevents waste from being generated in the first

place. Make sure, however, that you acknowledge to

participants that all of the options for addressing

environmental pollution are useful and necessary at this time.

Module 2




3. In showing Overhead 6, describe how pollution prevention is a

win-win situation for business and government.

■ Business can be more environmentally friendly and improve

community relations as well as realize financial benefits.

■ Government agencies will be able to regulate better

because less pollution means less monitoring, permitting,

and enforcement.

■ The environment and public health benefit because of

reduced exposure to toxins.






Module 2

Waste Prevention Hierarchyoverhead 5

■ Pollution Prevention

■ Re-use/Recycling

■ Treatment

■ Disposal

Pollution Prevention

Re-use/Recycling

Treatment

Disposal

Who Benefits from Pollution Prevention?overhead 6

■ Business

■ Government Agencies

■ Environment and Public Health

Instructor Notes


4. Overhead 7 lists reasons why pollution prevention is an

effective strategy for businesses. Businesses that decrease their

toxic use, or that switch to less toxic material, can decrease

their costs of disposal, permitting, compliance, and other fees.

Module 2






asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj8 5. Overhead 8 shows ways that businesses can implement

pollution prevention.

■ Process-related techniques include input changes and

similar concepts.

■ Managerial techniques include incentives, attitude changes,

and total quality management.

■ Design techniques include designing for pollution

prevention in the process, designing products to be more

recyclable and reusable, incorporating less toxic elements in

production, and engineering better facility layout to achieve

P2.



Implementing P2overhead 8

■ Businesses implement P2 in three major ways:

— process-related techniques

— managerial-related techniques

— design-related techniques

How Does Pollution Prevention Benefit Businesses?overhead 7

■ For business, P2 can be a way to save money in terms of:

— Materials management

— Operating cost reductions

— Environmental risk avoidance

— Worker safety/reduced liability

Module 2

Instructor Notes


Review Overhead 9, which lists ways that government

agencies can implement pollution prevention strategies.

Module 2






Module 2

Why/How Should Government AgenciesImplement P2?

overhead 9

■ For regulatory agencies, P2 is a better way to protect the environment

■ P2 can be included in:

— Development of policies and regulations

— Permits, inspections and enforcement

— Technical assistance/outreach

— New protection strategies

Instructor Notes


Module 3 Process for Policy and RegulatoryDevelopment

This module is intended to walk participants through the

regulatory and policy development process. In the

Massachusetts DEP pilot, senior management took the

opportunity to lay out a number of specific elements of

regulatory/policy development that they wanted to

emphasize. This should be customized to suit individual states’

needs.

Ask participants what makes an effective regulatory process.

On a Flipchart, record their answers. Then, display Overhead

10 which lists some characteristics of an effective regulatory

process. Mention that during the regulatory process, an agency

should be looking for opportunities to leverage pollution

prevention, and that later in this workshop participants will

talk about ways to build P2 into the regulatory process.







Customize



What is an Effective Regulation/PolicyDevelopment Process?

overhead 10

■ Clarifies real problem(s)

■ Anticipates potential controversies and builds consensus problem solving

■ Engages the right people at the right time at the right level of detail

■ Minimizes delays and major reworks

■ Satisfies legal requirements

■ Identifies collateral support necessary for implementation

■ Supports implementation measures success

■ Fundamentally consistent across the department for type of product

Module 3Process for Policy and Regulatory Development

Instructor Notes


List the steps involved in a generic regulatory process.

Overhead 11 presents a model of a regulatory process that

was drawn up by Massachusetts DEP staff.

You may want to customize this model by adding or

subtracting steps, depending on how regulation is

promulgated in your state.




Module 3

Customize



Module 3

Model of a Regulation and Policy Development Processoverhead 11

6. Promulgation/Finalization

7. Implementation and Evaluation

1. Problem Definition

2. Team Building

3. Scoping

4. Development of Solution

5. a. Internal Consensus/Feedback on Draft Regulation/Policy

b. External Consensus/Feedback on Draft Regulation/Policy

Instructor Notes


2. Team-Building (Overhead 13): Getting the different internal

stakeholders engaged in leadership roles and draft

development can be important when it comes to

implementation of a regulation or policy. This is because more

investment in the drafting and developing phase translates to

more investment in the implementation phase. Team-building

across bureaus, offices, and regions means more than just

soliciting approval from different parts of the agency —

it means involving them in the process. (Note that Overhead

13 refers to administrative units within Massachusetts state

government; customize this overhead to make it appropriate

for your state.)

1. Defining the problem (Overhead 12): This is where the

regulatory/policy development process starts, and it is also

where the pollution prevention consciousness should take

hold. When defining the problem, staff should keep in mind

the waste prevention hierarchy and the preferred methods of

addressing waste. Considering the source of the problem

before jumping into control options can help agency staff

identify pollution prevention solutions to a problem.

Module 3







Customize



Module 3

Define the Problemoverhead 12

■ Pollution prevention & hierarchy

■ Source problem rather than a control problem

Team Buildingoverhead 13

■ BWP and cross bureau

■ Regional

■ EOEA staff

■ External stakeholders

Instructor Notes


4. Development of Solution: Once a variety of solutions are

identified, agency staff must select one option. The solution

should contain key signoffs, development milestones, and an

effectiveness evaluation plan (see Overhead 15). The

effectiveness evaluation plan should consider how the success

will be evaluated and by whom (i.e., stakeholders).

■ At this stage, the proposed solution should be circulated

within the agency for evaluation. Broader distribution to

outside stakeholders should also be considered.

3. Scoping: Overhead 14 lists key steps in developing the scope

of the regulation or policy.

■ Many policy development attempts can go awry because

the policy developers did not define the problem clearly or

correctly.

■ Involving the stakeholders can help define the problem and

identify solutions.

Module 3









Module 3

Scopingoverhead 14

What should be in the scope?

■ Problem definition

■ Solution options

■ Identification of goals (e.g., regulatory streamlining)

■ Team membership resource needs

■ Development milestones and key signoffs

■ Stakeholders/public impact and potential controversies

■ Program implementation plan

■ Effectiveness evaluation plan

Development of Solutionsoverhead 15

■ Key signoffs within agency



Instructor Notes


5. Internal Consensus Building (Overhead 16): The consensus

process is dependent upon whether the item being developed

is a regulation or policy. A regulation generally requires more

formal consensus building than a policy. The need for

consensus also depends on the potential “noise” factor, that is,

who is involved, how they are impacted, and how invested

parties are in the status quo that is being changed.

Internal partners to involve during consensus building include:

■ bureaus/programs/divisions

■ regional/field offices

■ staff attorneys

6. Optional: Ask participants whether/how the presence of pollution

prevention issues affects the potential “noise” factor.

Module 3






Module 3

Internal Consensus Buildingoverhead 16

■ Need to gauge potential “noise” factor

■ Involve internal partners

— bureaus/programs/divisions

— regional/field offices

— staff attorneys

■ “buy-in” from middle managers

Instructor Notes


7. External Consensus Building (Overhead 17): External

consensus building involves partners (e.g., EPA and other

agencies) and stakeholders (e.g., environmental, business and

community groups). Note: You will need to customize

Overhead 17 to reflect how your state works with its external

partners.

External partners may include EPA and other federal agencies.

They may also include other state agencies or offices. In

Massachusetts, for instance, external partners for a DEP

regulation would include the Executive Office of

Environmental Affairs and the Office of Administration and

Finance.

8. Optional: It may be necessary to obtain the approval, not just the

buy-in, of certain external partners. For example, in

Massachusetts, where this training was developed, the

Massachusetts Environmental Protection Act (MEPA) governs the

revision or development of environmental regulations. MEPA

currently requires the submittal of an Environmental Notification

Form (ENF) if a regulatory change will lessen the stringency of any

standard for environmental protection. You should research the

laws of your home state to see if they contain a MEPA-like statute.

If so, you might want to include an overhead here that describes

the role played by such a statute in the overall regulatory

development cycle. You should mention to participants that it is

important to consider whether pollution prevention-oriented

changes to a regulation will trigger an ENF submission or a similar

requirement.

Module 3




Customize



Module 3

External Consensus Buildingoverhead 17

A. External Partners

■ federal agencies: e.g., EPA

■ other state agencies

— EOEA

— Administration and Finance

— MEPA review

Instructor Notes


9. One way to build consensus on a regulation with external

stakeholders is through the Public Notice and Comment Cycle

(Overhead 18). The notice and comment cycle is iterative —

agency staff draft a regulation, receive comments, and redraft

as necessary based on the comments.

Note: You will need to customize Overhead 18 to reflect how

your state works with its external stakeholders.

■ Review the process for drafting a regulation within your

agency. Note that public notice and comment requirements

might not apply to the development of policies.

■ Public information sessions provide an opportunity for

agency staff to gauge stakeholders’ perceptions and

responses before agency management formally signs off on

a draft regulation. Drafters of regulation can also find out if

they need to clarify the issues further — i.e., whether the

regulation’s intended audience is interpreting its language

correctly.

■ Alternative Dispute Resolution (ADR) and Regulatory

Negotiation (RegNeg) are alternatives to the traditional

public notice and comment process. With ADR and RegNeg,

agency staff bring stakeholders together physically and

mediate a regulatory solution.

Module 3




Customize



Module 3


B. External Stakeholders

■ Public Notice and Comment

— public information sessions

— “interested party list”

— Environmental Justice outreach

■ Alternative processes

— Alternative Dispute Resolution (ADR)

— Regulatory Negotiation (RegNeg)

Instructor Notes


10. Promulgation (overhead 19): During promulgation, the

regulation is made available to the public. Promulgation

involves a variety of steps, including: assembly of supporting

documentation, and public notice.

■ Supporting documents may be necessary in order to make a

regulation or policy “official.” Overhead 20 lists the

supporting documentation that is required in

Massachusetts to promulgate an environmental regulation.

Customize this overhead to reflect your state’s

requirements.

11. Regulatory staff occasionally need non- traditional means to

reach their intended audiences. In Massachusetts, the

Environmental Monitor is a good alternative to newspapers

because it can provide an agency with the opportunity to

explain the proposed regulation or policy. Massachusetts also

has an “interested party list,” a consolidated list of people

interested in changes to certain regulations and policies.







Module 3

Customize



Promulgationoverhead 19

■ Need to make regulation or policy available and accessible

— publication in Environmental Monitor

— outreach to community through non-English speaking press

— trade associations

— Internet


■ Prepare supporting documentation (for rules and regulations)

— cost-benefit analysis (required under Executive Order 384)

— approval from Office of General Counsel

— cover memo on final draft approval must show how regulation affects:

• efficiency and streamlining

• pollution prevention

• resource implementation

• staff training and policy development

— Commissioner’s sign-off

— memo to EOEA requesting approval to promulgate

— Memo responding to public comments on draft regulation

Module 3

Instructor Notes


12. Implementation and evaluation (Overhead 21): If a regulatory

process builds in implementation from the beginning,

implementation will proceed more smoothly.

■ Evaluation works best if the people giving the feedback

have been a part of the team from the beginning. During

the evaluation stage, stakeholders should provide feedback

as to whether the goals set out by the original stakeholders

and drafters have been met by the regulation or policy.




Module 3

Indicate to participants that you are now going to present two

examples of an agency considering P2 opportunities during

the development of 1) a regulation and 2) a policy.

The examples given describe the experience of the

Massachusetts Department of Environmental Protection. You

may wish to customize by substituting examples and

participant handouts that summarize your state’s experiences.

Nex

t…

Customize



Implementation and Evaluationoverhead 21

■ Implementation issues should be addressed up-front during design phase

■ Implementation process should involve the stakeholders who will provide

evaluation feedback

Module 3

Instructor Notes


13. Overhead 22 presents an example of an agency considering

P2 opportunities during the development of a regulation. Refer

participants to Participant Handout 3 at the back of their

Manuals for a more complete description of this example.

In reviewing Overhead 22, address the following points:

■ The Massachusetts Department of Environmental

Protection (DEP) needed a method for limiting the release

of Volatile Organic Compounds (VOCs) from automotive

refinishing facilities. It wanted to limit the release of the

VOCs at the source rather than attempt to capture VOCs

already in the air.

■ DEP adopted a new regulation that went straight to the

source of the VOC emissions. The “end-of-pipe” controls

were replaced by various P2 strategies (see Overhead 22,

bullet point 2).

■ Successes: In this case, the Massachusetts DEP succeeded in

■ defining the problem being addressed as a P2 problem

rather than a pollution control problem, and

■ putting together a regulation development team that

included key outside stakeholders.

■ Lessons learned for the development of future regulations: DEP

is now working on making information on the regulation

easily accessible to the public and to industry by continuing

community outreach programs and assembling an

autobody regulatory compliance handbook.

Optional: Discuss with participants any suggestions for improving how the

Massachusetts DEP might consider P2 in developing another

regulation.

Module 3






Module 3

Example One: Pollution Prevention Regulation forAuto Finishing Operations

overhead 22

■ Problem: MA DEP wanted to reduce the amount of VOCs from the large

number of small auto shops

■ Solution: Prevent releases at all the sources in a small shop

• Product formulation — limit VOC in per unit volume

• Equipment design — high volume/low pressure sprayer

• Equipment maintenance — enclosed cleaning and waste recycling

• Equipment operations — keeping paint can closed

■ Lessons learned: Make the regulation accessible and available

• Initial outreach — to community and industry networks

• Input — invite stakeholders to help with the drafting

• Follow through — workbooks

See Participant Handout #3 in this Manual for a more complete description.

Instructor Notes


14. Overhead 23 presents an example of an agency considering

P2 opportunities during the development of a policy. Refer

participants to Participant Handout 4 at the back of their

Manuals for a more complete description of this example.

In reviewing Overhead 23, address the following points:

■ The Massachusetts Department of Environmental

Protection (DEP) wanted a way to leverage P2 in lower-level

enforcement actions by its Bureau of Waste Prevention

(BWP) via Notices of Non-Compliance (NONs). It already had

a mechanism for requiring P2 in the penalty phase of a

higher-level enforcement action, but most of the agency’s

enforcement actions are lower-level. To accomplish this

objective, the agency incorporated language into the

standard cover letter accompanying every NON, including:

— A statement that P2 is the preferred method for

returning to compliance, and

— A generic referral to the Massachusetts Office of

Technical Assistance (OTA), a non-regulatory state

agency that provides free and confidential P2 technical

assistance to companies.

■ During the first 6 months after finalization of this policy,

approximately 70% of all BWP NONs used the standard

cover letter. However, it has been difficult for DEP to

determine whether and to what extent companies have

taken P2 measures specifically as a result of the revised NON

cover letter language.




Module 3




ParticipantHandout

Nex

t…



Module 3

Example Two: Pollution Prevention PolicyNON Cover Letter

overhead 23

■ Problem: How to leverage P2 as the preferred means of compliance for lower

level enforcement actions

■ Solution: Policy that required the standard cover letter accompanying

Notices of Noncompliance (NONs)

• DEP policy statement — P2 is the preferred method of return to

compliance

• Assistance — referral to MA Office of Technical Assistance for on-site

P2-oriented engineering assistance

• Concrete suggestions — specific P2 recommendations with

compliance link

See Participant Handout #4 in this Manual for a more complete description.

Instructor Notes


■ Successes: In this case, the Massachusetts DEP succeeded in

■ defining the problem being addressed as a P2 problem

rather than a pollution control problem, and

■ increasing implementation by working P2 into an

already-established procedure (i.e., cover letters to

NONs).

■ Lessons learned for the development of future policies:

■ More on-going staff training and promotion of the

importance and value of P2 may be needed to increase

the effectiveness of a policy’s implementation.

■ DEP attorneys and field staff, as well as staff from the

OTA, should be more involved in the policy development

process.

Optional: Discuss with participants any suggestions for

improving how the Massachusetts DEP might consider P2 in

developing another policy.

Module 3

Participant Notes


Module 3

The Massachusetts DEP might improve how it considers pollution prevention in developing policies andregulations in the following ways:

Instructor Notes


Module 4 Building Pollution Preventioninto the Regulatory Process

This module discusses ways of building pollution prevention

into the different steps in the regulatory process, as outlined in

Module 3:


2. Team Building

3. Scoping


5. a. Internal Consensus/Feedback On Draft Regulation/Policy

b. External Consensus/Feedback On Draft Regulation/Policy



This module walks participants through the regulatory

development cycle again in order to engage participants in a

discussion about ways to build P2 into each step.

In this module, it is important to let the participants know

what their managers expect from them at each step in the

regulatory development process, in terms of P2. Use specific

real-life examples from your state to illustrate possibilities and

expectations.

Display Overhead 24. One way of encouraging P2 through a

draft regulation is to broadly define the underlying problem

(i.e., look at the “big picture” implications of a regulation). When

drafting any regulation, agency staff should give serious

thought as to how the regulation might improve the quality of

the environment.






Module 4

P2 Opportunities During Problem Definitionoverhead 24

■ Define underlying problems broadly (in terms of environmental impact)

■ Use “true” brainstorming, then narrow the focus

■ Include P2 goals as stated objectives

Pollution Prevention in the Regulatory Process

Instructor Notes


■ During the problem definition stage a common tendency is

to offer solutions immediately, before the problem is agreed

upon and understood. Reaching a clear and shared

definition of the problem at the outset can save time and

effort spent on reworking policies or regulations. The

instructor should explain to participants that “true”

brainstorming involves the generation of as many ideas as

possible, without evaluation or judgment. Engaging in “true”

brainstorming may increase the likelihood that P2 solutions

will be identified.

■ Example (Overhead 25): In Massachusetts, the DEP drafted a

regulation to streamline the hazardous waste (HW)

recycling permit process. The initial goal of this regulation

was to reduce the level of agency effort in reviewing certain

HW on-site recycling permits by streamlining the HW

permitting process (from a case-by-case review to a

presumptive approval). The staff developing this regulation

did not identify P2-oriented solutions because they did not

define the problem in terms of pollution prevention. By

contrast, other agency staff members whose job it was to

promote P2 via all of the agency’s activities took a broader

view and saw the underlying problem as the amount of

hazardous waste being released to the environment. In their

view, one goal of the regulation should be to reduce

facilities’ need for recycling permits by encouraging the

reduction of waste generated in the first place. These staff

members suggested requiring facilities to write P2 plans if

they wanted streamlined recycling permits. Unfortunately,

this suggestion was not incorporated into the final

regulation.

Module 4






Module 4

Problem Definition Stage: Exampleoverhead 25

■ Massachusetts DEP drafted a regulation to streamline the hazardous waste

(HW) recycling permit process

■ Staff had competing views of goals of regulation:

— encourage facilities to recycle rather than discard HW, versus

— reduce facilities’ need for recycling permits by encouraging the reduction

of waste generated in the first place

Instructor Notes


Display Overhead 26.

The scoping phase begins after agency staff has built

consensus on the problem identification, has analyzed some of

the underlying causes, and is beginning to look for solutions.

Overhead 27 lists some ways that are useful in identifying P2

solutions. The key questions that arise in the draft

development phase are: Which regulatory tools should be built

in to the regulation? Who should select these tools?

■ Numerous regulatory tools exist for integrating P2 into draft

policies or regulations.

■ Optional: Conduct a group exercise in which workshop

participants draw up a list of tools for promoting P2 via

regulations and policies. If they need help, get them started

with an example such as “Requiring P2 Planning.” Record these

tools on a flipchart. Afterwards, refer participants to the list of

regulatory tools in Handout 1, which is located towards the

end of the Manual, for a comparison with the list generated by

participants.

OR




Module 4

Nex

t…







ParticipantHandout






Opportunities During Scopingoverhead 27

■ Use brainstorming first, then narrow the focus

■ Use P2 resources available to identify P2 solutions

■ Consult with stakeholder groups; empower those being regulated

Module 4

P2 Opportunities During Teambuildingoverhead 26

■ Include “forward-thinking” agency staff who have had P2 training

and experience

■ Include staff from a P2 office/bureau, if one exists

■ Seek input from external stakeholders?

Instructor Notes


■ Refer participants to the list of regulatory tools in

Participant Handout 1, which is located on page 57 of the

Manual. Briefly review this list with participants.

■ The regulated community can be useful in helping agency

staff to identify and select solutions because it has technical

and empirical knowledge. Other pollution prevention

resources exist which can help agency staff identify which

regulatory tools to use for a particular policy or regulation

(see Module 5).

3. Display Overhead 28. Discuss with participants how the waste

prevention hierarchy shown in Module 3 can be a useful tool

for narrowing down and prioritizing the list of potential

solutions generated in the brainstorming stage. At the same

time, the instructor should remind participants that

management does not expect agency staff to eliminate good

ideas just because they do not fall under the category of

“pollution prevention”.

Ideally, P2 measures of success should be built in to the

regulation or policy during the solution development process.




Module 4



P2 Opportunities during Development of Solutionoverhead 28

■ Consider P2 as a selection criterion, and reductions in pollution as a success

measure

■ Use the waste prevention hierarchy to help prioritize possible solutions

Module 4

Instructor Notes



■ Feedback from pollution prevention groups and resources

will be helpful in making sure that agency staff have

explored all of the P2 angles available.

■ Outside stakeholders can help agency staff think through

the implementation issues. They will also be able to help

identify the barriers to implementation and whether or not

the regulation will work from a facility standpoint.

Module 6

4. Display Overhead 29.

■ Before agency management signs off on a draft regulation

or policy, it should ask agency staff how the regulation or

policy promotes pollution prevention. [Note: This review

procedure is required in Massachusetts.] If the regulation or

policy does not promote pollution prevention, agency

management should ask agency staff how it explored P2

opportunities and why P2-oriented solutions were rejected.

■ Agency staff should be required to indicate which P2

resources they have consulted. This type of accountability

gives agency staff the message that management values P2

and views it as an integral part of regulation drafting and

policymaking.







Module 4



P2 Opportunities during Internal Consensus Buildingoverhead 29

■ Consult with P2 office/bureau, if one exists, to ensure that P2 has been

adequately incorporated

■ Management should promote P2 by routinely asking the following

questions:

— Where is the P2?

— Were the P2 opportunities explored?

— Is there an implementation plan to support the P2 elements?

P2 Opportunities during External Consensus Buildingoverhead 30

■ Consult with external partners (EPA, other state agencies, P2 resources) to

ensure that P2 has been adequately incorporated

■ External stakeholders can provide a “reality check”

Module 4

Instructor Notes



■ Implementing pollution prevention requires staff training in

P2, staff and facility incentives to do P2, and P2-friendly

supporting procedures.

■ In order to evaluate a regulation’s effectiveness, agency staff

should ask the following questions:

■ How much pollution did the regulation prevent?

■ Did the benefits of preventing the pollution outweigh

the costs?

■ Was the regulation technically feasible? Enforceable?

■ An evaluation of the regulation will require the

quantification and gathering of the proper data.


■ Even after a draft regulation has been finalized,

opportunities exist to promote P2:

■ In the supporting documents that must be included in a

final regulation package, agency staff should indicate that a

P2 options analysis was done and should summarize the

results of such analysis.

■ The memorandum that agency staff must draft in response

to public comments should address the P2 impact and

implications of the new regulation.







Module 4



P2 Opportunities during Promulgationoverhead 31

■ Supporting documents should indicate that a P2 options analysis was done

■ Agency memo responding to public comments should address the P2

impace and implications of the new regulation

P2 Opportunities during Implementation andEvaluation

overhead 32

■ Ensure adequate staff training, incentives, supporting procedures,

infrastructure

■ Enlist assistance from outside P2 resources and stakeholders

■ Try to answer: How much pollution did the regulation prevent?

■ For evaluation, identify data to be quantified

Module 4

Instructor Notes


Module 4

Participant Handout


Tools for Integrating P2 into Regulations/Policies

1. Incentive-type tools■ fee waivers/fee differentials■ fee modification■ amnesty from enforcement■ exemption from requirements■ reporting modification/streamlining (e.g., unified reporting)■ permit modification/streamlining (e.g. whole facility/bubble permitting)■ penalty mitigation

2. Technical Assistance■ voluntary referrals to OTA, TURI, etc. (with or without incentives). This

can be a pre-requisite for benefits and/or as an example of good faith

3. Not requiring specific control technologies and encouraging P2 mecha-nisms

4. P2 planning requirements■ Voluntary (with or without incentives)■ Mandatory (required P2 planning, required hierarchy evaluation, imple-

mentation of options)■ enforcement

5. Specific P2 Techniques■ Voluntary (with or without incentives)■ Mandatory

6. Awards and Recognition■ the “good doobie” sticker

7. Whole facility/multi media approaches■ including the consideration of cross-media transfers

Implementation Mechanisms

1. Certification Requirements

2. Applications (permit applications)

3. Cover Letters (enforcement document cover letter)

4. Guidance

1Module 4

Instructor Notes


Module 5 Pollution Prevention InformationResources

The focus of the presentation on information resources should

be how these resources assist a regulatory agency staff person

when trying to promote P2 via regulations and policies.

1. Information Resources: Overhead 33 lists the information

resources that were covered in this training in Massachusetts.

You will want to identify resources, agencies, or associations

that provide technical information and policy assistance to the

regulating agency in the appropriate state. Ideally, you could

arrange for a representative of these resources to briefly speak

(5–10 min. each) about what assistance they can provide to the

regulatory agency. You might also want to research electronic

resources (i.e., on the internet), publications, and other

databases that will be useful for the regulatory agency when it

is developing pollution prevention in rules and regulations.




Customize



Information Resourcesoverhead 33

■ DEP TURA Unit

■ DEP’s Massachusetts Environmental Library

■ Toxics Use Reduction Institute (TURI)

■ Office of Technical Assistance

■ Northeast Waste Management Officials’ Association (NEWMOA)

Module 5Pollution Prevention Information Resources

Instructor Notes


Module 6 Case Study Activity — Applying theLessons from the Workshop

1. Small Group Case Study (refer participants to Participant

Handout #2 later in this module): This is a sample of a working

case and instructions that was used when this training was

developed in Massachusetts. You may want to develop a

similar working case based on a policy or regulation that is

currently being developed in your home state.

Using Overhead 34 through Overhead 39, give the

instructions as seen in overhead # 32, explain the case as

outlined in overhead #’s 33 through 36, and outline the

questions to address in the working case as detailed in

overhead # 37.

After groups have addressed all three questions, reconvene

the large group and have small group spokespersons report

out the results of their group’s discussions.






asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj34–39

Customize



Working Case: Instructionsoverhead 34

■ Break into small groups, select recorder and reporter

■ Understand the case

■ Brainstorm P2 opportunities (use tools list)

■ Brainstorm potential resources

■ Select recommended P2 option(s)

■ Report out

Working Case: Overviewoverhead 35

■ The Environmental Results Program replaces minor permits with

— Performance standards

— Compliance assistance

— Annual self-certification compliance

■ Goals of ERP

— Improve performance (including finding scofflaws)

— Smartest use of staff (permitting vs compliance/enforcement)

— Promote P2

Module 6Case Study Activity

Instructor Notes


Module 6




■ Industrial Wastewater (IW) is any wastewater other than sanitary.

■ IW Sewer Discharge System before ERP consisted of:

— DEP discharge permit

— DEP Pre-treatment Approval

— Local Discharge Permit and/or Standards


■ Legacy of Pre-ERP Sewer Discharge Program:

— Most dischargers are without DEP sewer discharge permits

— DEP sewer permits are often redundant with local sewer permits

Module 6

Instructor Notes


Module 6



Working Case: Questions to Addressoverhead 39

■ What options were brainstormed?

■ What information resources would you pursue?

■ What is your recommended option?


■ ERP approach for sewer dischargers

— certify compliance with all local and federal permits

— certify compliance with new statewide general standards/prohibitions

Module 6

Instructor Notes


Module 6

Participant Handout


Case Study Activity #1: P2 in ERP for Massachusetts SewerDischargers

ERP Background:

The Environmental Results Program (ERP) is a new regulatory approach for smalland mid-sized commercial and industrial facilities in Massachusetts. ERP replaces therequirement to obtain certain “minor” permits with:■ performance standards,■ easy to use compliance assistance materials,■ and an annual self-certification of compliance (signed by a senior company

official).

The goals of ERP include improving company environmental performance andcompliance, bringing scofflaws into the system, and shifting Massachusetts Depart-ment of Environmental Protection (DEP) staff time out of low value-added permit-ting into more beneficial areas such as increased compliance and enforcement. ERPhas already been implemented for the photoprocessing and dry-cleaning industrialsectors and ERP for commercial printers is nearing roll-out.

ERP for Sewer Dischargers:

The next ERP target is the current Massachusetts permitting requirements for dis-chargers of industrial wastewater to the sewer. Currently, any entity who dischargesany amount of industrial (i.e., non-sanitary) wastewater to the sewer must obtain astate industrial discharge permit from DEP. If the entity also pretreats that wastewaterprior to discharge it is expected to obtain a permit from DEP for its pretreatmentoperation (called a pretreatment plan approval). In addition to these state require-ments, there are also federal standards that apply to the most significant types ofdischarges. The local sewer authority (also called Publicly Owned Treatment Works, orPOTW) also has regulatory jurisdiction over these discharges. The POTW’s oftenrequire the most significant dischargers to obtain local discharge permits and mayhave sewer ordinances that lay out other performance standards for dischargers.

Of the 14,000 suspected industrial wastewater sewer dischargers in Massachusetts,fewer than 1,000 have obtained state sewer discharge permits and plan approvals.When state permits are issued they are often redundant with the locally issued permit.Under ERP, DEP will eliminate state sewer discharge permits and state pretreatmentplan aProval requirements. Under one scenario being considered for sewer discharg-ers, these permits will be replaced with a requirement that the discharger certifyannually to DEP that it is in compliance with all local and federal sewer rules andpermits. The discharger must also certify that is in compliance with some new generalstandards and prohibitions (such as a prohibition against disposing of hazardouswaste down the sewer).

2Module 6

Instructor Notes


Module 6

Participant Handout


2 cont’d

The Challenge — Incorporating P2 into ERP for Sewer Dischargers:

Pollution prevention is one of the major goals of ERP. The present permit system hasseen limited incorporation of P2 during the pretreatment plan approval and sewerdischarge permit process. The ERP Design Group has urged DEP to incorporate P2into ERP Sewer Discharges in order to reduce pollutant loading to the POTW’s andtheir receiving water bodies.

Using the skills you brought with you to today’s workshop as well as what you havelearned today (including the list of tools for integrating P2 into regulations andpolicies), your team should:

1. Brainstorm options for how to promote P2 via ERP for sewer dischargers.

2. Identify information resources you would pursue to help you with this task.

3. Select a recommended option for P2 in ERP sewer dischargers.

4. For your selected option, identify:■ What are the environmental benefits?■ What are the likely economic impacts on the sewer dischargers?■ What “noise” is likely?

Module 6

Instructor Notes
















+ ∆











Pollution Prevention In Job Function: Regulation and Policy Development

Evaluation Form

Please complete all parts of this brief evaluation. Results will be used to improve this program. The instruc-tional goals of this P2 in job function training are: 1) to review the process for developing policies and regula-tions, 2) to improve participant ability to identify and maximize opportunities to build pollution preventioninto the process for developing policies and regulations, and 3) to increase participant inclination to workpollution prevention into their policymaking and regulation drafting activities. Please rate the followingelements of today’s workshop, both in terms of their usefulness in reaching the instructional goal and theiroverall quality. Please provide written comments in the space provided to explain your rating or to offersuggestions for improvement.

1. Introductions/Review of Workshop ObjectivesComments:

2. Review of Definition of P2 & TURComments:

3. Process for Policy & Regulatory DevelopmentComments:

4. P2 in the Regulatory ProcessComments:

5. P2 Information ResourcesComments:

6. Case Study ActivityComments:

7. Review/ClosingComments:









Module 7: Review/Closing

Instructor Notes





Introductions/Review of Workshop ObjectivesDefinition of Pollution Prevention and Toxics Use ReductionProcess for Policy and Regulatory DevelopmentP2 in the Regulatory ProcessP2 Information ResourcesCase Study ActivityReview/Closing

Comments:






cont’d

Instructor Notes


Participant Handout


Case Study (Massachusetts): P2 in Automotive Refinishing Regulations

1. Problem

The Bureau of Waste Prevention (BWP) of the Massachusetts Department of Environmental Protection (DEP)needed a method for limiting the release of Volatile Organic Compounds (VOCs) from automotive refinishingfacilities. BWP wanted to limit the release of the VOCs at the source rather than attempt to capture VOCsalready in the air. Also, BWP lacked an efficient method of controlling the amount of VOCs present in thepaints/lacquers.

2. Prior Status

The DEP had limited authority over automotive refinishing facilities releases of VOCs. There were a few largefacilities with permits for VOC releases, but the vast majority of facilities were too small to require a permit. Atthe large facilities holding permits the regulatory method was end-of-pipe restrictions, typically met by carbonadsorption devices.

3. New Policy Solutions

The new regulation went straight to the source of the VOC emissions. The “end-of-pipe” controls were re-placed by emission control strategies requiring the following:

■ The use of High Volume Low Pressure (HVLP) spray equipment and electrostatic applicationequipment.

■ The cleaning of spray guns in an enclosed device that minimizes solvent evaporation, reuses thesolvent when possible and disposes properly of spent solvent.

■ Keeping any solvent containers that are not being used sealed at all times to eliminate spillage andevaporation.

■ Restriction on the amount of VOCs, per unit volume, in various coating products.

Along with these requirements the facilities are now required to train their employees on proper spray gun andspray gun cleaning practices. A “good neighbor” policy was also established which requires the facility toprevent emissions of particulates or odors which create a nuisance or condition of air pollution.

4. Lessons Learned

A. BWP Gains

The DEP is now able to regulate all facets of automotive refinishing down to the smallest facility. Throughemission limitations, per unit volume, the DEP can now regulate production of the paints and lacquers. TheDEP has also established the ability to check the compliance of the facilities through testing proceduresdescribed by the EPA. The requirements are typically met by most facilities inspected by the DEP since theinstallation of the new regulation.

The regulation aimed at reducing VOC emissions by 40%, but this is yet to be demonstrated by the DEP.

3

Instructor Notes


Participant Handout


B. Implementation Lessons■ The language used in the regulation must be universal so that the rules can be applied to all members

of the community regardless of facility size and practices.■ Small businesses must be able to understand the requirements, so keep the language simple.■ Make the information on the regulation easily accessible to the public and continue on-going commu-

nity outreach programs. The DEP is currently assembling an autobody regulatory compliance hand-book.

C. Process Lessons■ Input from stakeholders with working knowledge of the on-site problems must be brought into the

regulation’s development (e.g., DEP inspectors, the Massachusetts Office of Technical Assistance, andautobody shop owners/operators).

3 cont’d

Instructor Notes


Participant Handout


Case Study (Massachusetts): P2 Cover Letters for Notices ofNon-Compliance (NONs)

1. Problem:

For the Bureau of Waste Prevention (BWP) of the Massachusetts Department of Environmental Protection(DEP), Notices of Non-Compliance (NONs) are the first level of enforcement action for all but serious viola-tions. BWP wanted a simple method for using NONs issued to industrial and commercial facilities to leverageP2. However, BWP lacked the legal authority to require via NON the use of P2 to correct violations.

2. Prior Status:

All NONs were required to include a cover letter with standard language outlining when the violations werediscovered violations. The NON itself outlines the violation observed and the corrective actions requested.This cover letter made no reference to P2.

3. New Policy Solution:

The new policy mandated that all BWP NONs must use a standard cover letter. This standard cover letterincludes the following components:

■ Standard language promoting P2 as a preferred means of achieving compliance.■ Standard language encouraging the violator to voluntarily seek the P2 assistance of the Massachusetts

Office of Technical Assistance (OTA), the Massachusetts Toxics Use Reduction Institute (TURI), and/or DEP.

■ A “placeholder” paragraph in which BWP staff can suggest that the violator consider specific P2opportunities that were identified by the BWP.

■ A “placeholder” paragraph in which BWP staff can state possible connections between implementingthese P2 options and correcting the violations observed.

■ Copies to OTA.

After BWP adopted this policy, OTA began selectively contacting many of the facilities after OTA received itscarbon copy of the NON in order to offer its services.

4. Lessons Learned:

A. BWP Gains

During the first 6 months after finalization of this policy, approximately 70% of all BWP NONs used thestandard cover letter. (Many of the non-compliant NONs were likely to have been issued to non-industrial ornon-commercial facilities, such as landfills or asbestos abatement operations.) While tracking is inadequate,BWP enforcement (95% of which is NON-level) appeared to be the driving force behind an average of about23 site visits per year by OTA — 18% of OTA’s total annual site visits. OTA estimates that half of all facilitiesthey visit go on to implement P2, and that these facilities reduce their generation of toxics by a conservativeestimate of 37,000 pounds per year. (Note that the success rate of these NON-driven referrals dropped after thefirst year of implementation of the BWP policy.)

4

Instructor Notes


Participant Handout


B. Implementation Lessons■ Adding P2 onto an already-established procedure (e.g., cover letters to NONs) increases implementa-

tion.■ Offering standard language increases implementation.■ More on-going staff training and promotion of the importance and value of the P2 NON may be

needed to increase the use of the cover letter and the OTA referral effectiveness.■ Better feedback system on OTA site visit outcomes is needed.■ In drafting NONs, BWP staff rarely use the option of linking P2 to the violation remedy, and most do

not even identify specific P2 opportunities.■ DEP could consider offering an incentive to violators who implement P2 and/or utilize OTA’s services.■ DEP could follow up with violators to see if P2 was implemented (e.g., when it verifies that the facility

has complied with the enforcement action).

C. Process Lessons■ More OTA involvement in the policy development process may have been warranted.■ DEP attorneys should have been involved in the policy development process.■ More field staff should have been involved in the policy development process.■ Building P2 into the already existing NON cover letter process was a good idea.

4 cont’d






DEP



InformationAccess






natural resources.

*



P2 in Regulatory Enforcement atCommercial and Industrial Facilities

*P2 in the Job Function




Module 1: Welcome ................................................................................................................................... 12

Pollution Prevention in Enforcement ................................................................................................ 13

Module 2: Introduction and Review of Workshop Objectives ................................................................ 14

Workshop Goals .................................................................................................................................. 15

Module 3: Definition of Pollution Prevention and Toxics Use Reduction ............................................. 16

What is Pollution Prevention? ............................................................................................................ 17

What Does Pollution Prevention Mean? ............................................................................................ 17

Waste Prevention Hierarchy ............................................................................................................... 19

Who Benefits from P2? ....................................................................................................................... 19

How Does P2 Benefit Business? ......................................................................................................... 21

How Does Business Implement P2? ................................................................................................... 21

Why/How Should Government Agencies Implement P2? ................................................................ 21

Module 4: Review of Pollution Prevention Opportunities in the Field .................................................. 22

P2 Tips: Schematic of Typical Industrial Operation ........................................................................ 23

Module 5: Review Regulatory EnforcementProcess; Brainstorm Opportunities for Pollution

Prevention Activities ........................................................................................................................... 26

Compliance Inspection & Enforcement Process ............................................................................... 27

Module 6: Using Pollution Prevention Information Resources .............................................................. 28

Module 7: Available Pollution Prevention Information Resources ......................................................... 33

P2 Information Resources .................................................................................................................. 33

Module 8: Review Case Study and Brainstorm P2 Options .................................................................... 34

Module 9: Discussion of Case Study P2 Options ..................................................................................... 48

Module 10: Brainstorm Compliance Enforcement and P2 Strategy for Case Study Facility ................ 58

Module 11: Discussion of Small Group Recommendations and Enforcement Resource Constraints . 64

Negotiation of P2 in Settlement ......................................................................................................... 67

Oversight and Implementation of P2 Settlement ............................................................................. 67

Trade-Offs in Value to Agency ............................................................................................................ 69

Module 12: Discussion of Proposed Method for Building an Internal Pollution Prevention

Enforcement Case Information Resource .......................................................................................... 70

Module 13: Wrap-up and Evaluation of the Training Module ............................................................... 76

Evaluation: ................................................................................................................................................. 77

Table of Contents

Module 1: Welcome ................................................................................................................................... 13

Module 2: Introduction and Review of Workshop Objectives ................................................................ 15

Module 3: Definition of Pollution Prevention and Toxics Use Reduction ............................................. 17

Module 4: Review of Pollution Prevention Opportunities in the Field .................................................. 23

Module 5: Review Regulatory EnforcementProcess; Brainstorm Opportunities for Pollution

Prevention Activities ........................................................................................................................... 27

Module 6 Using Pollution Prevention Information Resources ............................................................... 29

Module 7: Available Pollution Prevention Information Resources ......................................................... 33

Module 8: Review Case Study and Brainstorm P2 Options .................................................................... 35

Module 9: Discussion of Case Study P2 Options ..................................................................................... 49

Module 10: Brainstorm Compliance Enforcement and P2 Strategy for Case Study Facility ................ 59

Module 11: Discussion of Small Group Recommendations and Enforcement Resource Constraints . 65

Module 12: Discussion of Proposed Method for Building an Internal Pollution Prevention

Enforcement Case Information Resource .......................................................................................... 71

Module 13: Wrap-up and Evaluation of the Training Module ............................................................... 76

Evaluation: ................................................................................................................................................. 77

Instructor Notes

4 Instructor Notes P2 in Regulatory Enforcement at Commercial and Industrial Facilities

Icon legend

Trainer needs to



Nex

t…





ParticipantExercise




ParticipantHandout












FLIPCHART





OVERHEAD (no.)


PAUSE Video

Start Video


STOP Video




EXERCISE



P2 in Regulatory Enforcement at Commercial and Industrial Facilities 5

Instructor Notes


ETI Pollution Prevention in Regulatory Enforcement atCommercial and Industrial Facilities

Instructional Goals

1. Participants understand which types of activities are “pollution prevention”and which are not.

2. Participants understand the scope of their authority to require pollutionprevention outcomes in regulatory enforcement cases.

3. Participants are better able to identify enforcement situations where pollutionprevention outcomes are possible.

4. Participants are better able to use existing enforcement tools and policies toobtain pollution prevention outcomes.

5. Participants identify shortcomings in existing enforcement tools and policies,and in regulations, which prevent or hinder further instances of pollutionprevention outcomes.


■ Participants are regulatory personnel with experience in compliance inspec-tions and/or enforcement.

■ Participants have introductory knowledge of pollution prevention and toxicsuse reduction concepts, and are interested in more job-specific training.

■ Management has clearly articulated the expectations of regulatory personnelwith regard to pollution prevention.

■ Most participants previously will NOT have systematically applied pollutionprevention principles in their jobs.

■ Participants will have the capability to understand technical presentations, andto participate in technical discussions.

■ Participants will have regulatory expertise in at least one environmentalmedium (air, wastewater, hazardous waste, solid waste, toxics use reduction).

■ Participants will be a mix of staff and first-level managers.


Participant NotesETI Pollution Prevention in RegulatoryEnforcement at Commercial andIndustrial Facilities

Instructional Goals

1. Participants understand which types of activities are “pollution prevention”and which are not.

2. Participants understand the scope of their authority to require pollutionprevention outcomes in regulatory enforcement cases.

3. Participants are better able to identify enforcement situations where pollutionprevention outcomes are possible.

4. Participants are better able to use existing enforcement tools and policies toobtain pollution prevention outcomes.

5. Participants identify shortcomings in existing enforcement tools and policies,and in regulations, which prevent or hinder further instances of pollutionprevention outcomes.

Instructor Notes


Note: This training is designed for staff who both conduct inspections andundertake enforcement actions. In some states, these functions are performedby different staff. This training course should be modified as appropriate toaccurately reflect the job functions of the the training audience.

Instructor Tools

A key to successful training is involving attendees in the learning processthrough interactive techniques. One can never avoid the lecture methodentirely, however, especially when delivering detailed information. This moduleutilizes common tools for involving learners, and was designed and tested as aninteractive, informal, “workshop-style” day rather than only a formal series ofpresentations. Each module allows time for discussion among learners, andpresenters should make a point of facilitating as much discussion as time willallow.

Common tools for involving learners used in this training include:

Round the Room Discussion of Accomplishments

Each participant was asked to name a pollution prevention project on whichthey have already worked. This encourages learners to see that they are alreadyfamiliar with the topic and gives them confidence to contribute their expertisethroughout the remaining activities.

Brainstorming

In large groups (with a facilitator capturing comments on a flip chart), in smallgroups (with participants capturing comments on several flip charts or notepaper), or individually (with participants capturing thoughts on note paper),brainstorming is used extensively throughout the workshop. Brainstormingallows learners time to process information they have already received, andstimulates confidence, creativity, and interest in the topic.

Case Study

A case study was prepared and tested in this workshop module. You may wish toinvent your own case study, more specific and relevant to the needs of yourlearners, or modify the one included here.

Short, Active Lecture Modules

Formal lecture-style presentations are a necessary element of most trainingevents. Lecture modules are kept as short as possible, overhead materials arehanded out to learners in advance to facilitate note-taking, and interactivequestioning and discussion are actively facilitated.

Customize




1. Participants will be able to direct industrial/commercial facilities’ personnel,through specific and clarifying questions or through descriptive statements, toincreased awareness of and responsibility for undertaking pollution preventionsolutions to regulatory compliance problems.

2. Participants will increase the frequency with which they direct facilities’ per-sonnel to pollution prevention outcomes during compliance inspections.

3. Participants will increase the frequency with which they require pollutionprevention outcomes in regulatory enforcement.

4. Participants will identify and participate in removing roadblocks to pollutionprevention in enforcement tools, policies, and regulatory language.

Instructor Notes


Training Agenda


1. Welcome 15 min.

2. Introduction and Review of Workshop Objectives 45 min.

3. Definition of Pollution Prevention (P2) and 15 min.

Toxics Use Reduction

4. Review of P2 Opportunities in the Field 30 min.

5. Review Regulatory Enforcement Process 15 min.

and Brainstorm Opportunities for P2 Activities

6. Using P2 Information Resources 15 min.

7. Available P2 Information Resources 60 min.

8. Review Case Study and Brainstorm P2 Options 20 min.

9. Discussion of Case Study P2 Options 15 min.

10. Brainstorm Compliance Enforcement and 50 min.

P2 Strategy for Case Study Facility

11. Discussion of Small Group Recommendations and 50 min.

Enforcement Resource Constraints

12. Discussion of Proposed Method for Building an 25 min.

Internal P2 Enforcement Case Information Resource

13. Wrap Up: Summary and Evaluation 35 min.

TOTAL 6.25 hours


Participant Notes

Training Agenda

Module

1. Welcome

2. Introduction and Review of Workshop Objectives

3. Definition of Pollution Prevention (P2) and

Toxics Use Reduction

4. Review of P2 Opportunities in the Field

5. Review Regulatory Enforcement Process

and Brainstorm Opportunities for P2 Activities

6. Using P2 Information Resources

7. Available P2 Information Resources

8. Review Case Study and Brainstorm P2 Options

9. Discussion of Case Study P2 Options

10. Brainstorm Compliance Enforcement and

P2 Strategy for Case Study Facility

11. Discussion of Small Group Recommendations and

Enforcement Resource Constraints

12. Discussion of Proposed Method for Building an

Internal P2 Enforcement Case Information Resource

13. Wrap Up: Summary and Evaluation

Instructor Notes


Module 1 Welcome

Display Overhead 1 and have participants assemble and get

seated.

A senior-level manager in your agency should welcome

participants to the training. As an example, when this training

was pilot-tested at the Massachusetts Department of

Environmental Protection (MADEP), the Deputy Commissioner

for Operations and Program Planning delivered the welcome.

(In Massachusetts, the Deputy Commissioner for Operations

and Program Planning oversees both the central and Regional

activities for the agency’s three bureaus.) Having recently

returned from a sister-city trip to Sao Paulo, Brazil, with EPA-

New England (Region One) officials, he spoke movingly of the

poverty he had witnessed and the spectacular industrial

growth that had recently been initiated. The Deputy

Commissioner was particularly enthusiastic in reporting that

Brazilian officials were looking to American officials to advise

them on instituting pollution prevention regulations and

policies in order to avoid the sorts of environmental disasters

which befall industrialized countries. He conveyed to

participants the message that MADEP is now even more

committed to requiring pollution prevention outcomes in

regulatory enforcement cases.

The Assistant Commissioner for the MADEP Bureau of Waste

Prevention also added his welcome to participants. He spoke

passionately of his longstanding commitment to the

philosophy of pollution prevention, and he asked participants

to help identify, articulate, and remove barriers to achieving

pollution prevention outcomes in enforcement cases.






Pollution Prevention in Enforcementoverhead 1

An Environmental Technologies Initiative (ETI) Workshop for Regulatory

Compliance and Enforcement Staff

Module 1Welcome

Instructor Notes


Module 2 Introduction and Review ofWorkshop Objectives

Show Overhead 2 and briefly review the goals for the

workshop. Emphasize that this is a workshop, not just a training

session, because the participants are the enforcement process

experts who can best determine the P2 opportunities.

Acknowledge the progress made by the agency so far in

building P2 into regulatory activity such as regulations,

enforcement, inspections, and permits.

Go around the room and ask each participant to state their

name and which regional office they are from, and to identify

an enforcement case involving pollution prevention on which

they have worked.

Record brief information about each enforcement case (facility

name, violations, outcome) on a flip chart at the front of the

room. Post the flip chart with these P2 enforcement examples

on a wall to refer back to in Module 5.

Note: Module 5 will deal with how participants obtained the

specific P2 knowledge and information they needed to

complete these enforcement cases and what sources of P2

information they may have consulted. If this activity begins to

bring those data to the surface prematurely, ask participants to

hold their thoughts for a few minutes until that topic is

reached.









Module 2


■ Review P2 definition and the waste prevention hierarchy

■ Review the basic enforcement process

■ Help participants I.D. P2 opportunities in enforcement

■ Familiarize participants with P2 information resources

Introduction and Review of Workshop Objectives

Instructor Notes


Module 3 Definition of Pollution Preventionand Toxics Use Reduction

This module is intended as both a refresher on what pollution

prevention is for those who are already familiar with the

concept and a brief introduction to pollution prevention for

the uninitiated.

1. Review the definition of pollution prevention shown on

Overhead 3 and Overhead 4. This is a broad definition

intended to help participants think about any and all pollution

prevention ideas. Feel free to substitute the federal definition

or your state’s definition of pollution prevention.






asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj3–



Module 3


■ Pollution Prevention is any activity which prevents pollution from being

created in the first place, versus pollution control, which deals with waste

after it has been generated.

■ P2 is an umbrella term that covers:






— Equipment or technology modifications

— Process modifications

— Reformulations or redesign of products

— Substitution of raw materials

— Improvements in housekeeping, maintenance, training or inventory

control

Definition of Pollution Prevention (P2) and Toxics Use Reduction

Instructor Notes


Overhead 5 presents the waste prevention hierarchy, which is

a tool for demonstrating the preferability of various means of

addressing pollution. As the hierarchy shows, pollution

prevention is the optimal method, where it is available,

because it prevents waste from being generated in the first

place. Make sure, however, that you acknowledge to

participants that all of the options for addressing

environmental pollution are useful and necessary at this time.

In showing Overhead 6, describe how pollution prevention is a

win-win situation for business and government.

■ Business can be more environmentally friendly and improve

community relations as well as realize financial benefits that

were discussed earlier.

■ Government agencies will be able to regulate better

because less pollution means less monitoring, permitting,

and enforcement.

■ The environment and public health benefit because of

reduced exposure to toxins.







Module 3



Module 3




■ Treatment

■ Disposal


Re-use/Recycling

Treatment

Disposal

Who Benefits from P2?overhead 6

■ Business



Instructor Notes


Overhead 7 lists reasons why pollution prevention is an

effective strategy for businesses. Businesses that decrease their

toxic use, or that switch to less toxic material, can decrease

their costs of disposal, permitting, compliance, and other fees.

Module 2 Module 3

Overhead 8 shows ways that businesses can implement

pollution prevention.

■ Process-related techniques include input changes and

similar concepts.

■ Managerial techniques include incentives, attitude changes,

and total quality management.

■ Design techniques include designing for pollution

prevention in the process, designing products to be more

recyclable and reusable, incorporating recycled products in

production, and engineering better facility layout.

Review Overhead 9, which lists ways that government

agencies can implement pollution prevention strategies.












Module 3


overhead 9



—Development of regulations and policies

—Permits, inspections, and enforcement

—Technical assistance and outreach

—New protection strategies

How Does Business Implement P2?overhead 8

■ Business implements Pollution Prevention in 3 major ways:

— Process-related techniques

— Managerial-related techniques

— Design-related techniques

How Does P2 Benefit Business?overhead 7


—Materials management

—Operating cost reductions

—Environmental risk avoidance

—Worker safety/reduced liability

Instructor Notes


Module 4 Review of Pollution PreventionOpportunities in the Field

In this module, review with participants generic P2

opportunities in the field.

Overhead 10 presents a schematic of a typical industrial

operation. It is included in the workbook with some additional

text as a refresher for staff to use when examining possible P2

options at a facility. Acknowledge that this schematic is

probably familiar to participants from previous P2 training.

Briefly review with participants the text on the opposite page

that accompanies Overhead 10. Note that the questions

presented are questions to ask about P2 options when dealing

with a facility in an inspection and enforcement context. They

are meant to serve as a diagnostic tool, not as an exhaustive

analysis of a facility’s P2 opportunities.

Optional: Depending on participants’ experience and familiarity

with P2 in industrial operations, this Module could be interactive.

Instead of reviewing the text on the opposite page with

participants as outlined in the paragraph above, go through each

step of the schematic and have participants identify P2 options.

Record their suggestions on a flip chart.









Module 4

P2 Tips: Schematic of Typical Industrial Operationoverhead 10

Raw Materials

Storage

Production Operations

Maintenance Operations

By-Products

Emissions

Intermediate orFinished Product

Storage

Fugitive Emissions

Questions to ask about P2 options when dealing with afacility in an inspection and an enforcement context

The following are some questions to ask about P2 options when dealing with afacility in an inspection and enforcement context. These questions are not meant tohelp enforcement personnel conduct an exhaustive analysis of a facility’s P2 oppor-tunities. Instead, they are intended to serve as a diagnostic tool to assist enforce-ment personnel in determining the nature and extent of a facility’s examination ofits P2 options.

Raw Materials, Storage■ How comprehensive are supply purchase records?■ Are paints, oils, etc. standardized across process lines, i.e., does the facility

purchase and store a greater variety of materials than is necessary?

Examples of potential P2 opportunities:— improve inventory control to avoid overpurchasing, material spoilage, and

material obsolescence due to expired shelf life— centralize all material purchase records to facilitate easy tracking

Review of P2 Opportunities in the Field

Instructor Notes


Module 4

Optional: Review the specifics of the accompanying text in the

workbook, and facilitate active discussion or question-and-

answer on these materials.



Questions… (cont’d)

Production Operations■ Why is a facility using a particular toxic in a process line? Has the facility looked

at modifying the process line to reduce or eliminate the need for that toxic?■ How sophisticated are a facility’s process control systems? Are they automated?

High-performance?■ How familiar are the employees in one process line with the P2 opportunities/

challenges associated with upstream and downstream process lines?■ What is the source of a facility’s P2 information? Does it have any information

sources other than a trade association or solvent supplier?

Examples of potential P2 opportunities:— substitute vegetable-based fluids for oil-based cutting fluids, aqueous

cleaners for solvents, water-based paints for oil-based paints— install countercurrent rinsing systems, drip racks, dragout recovery tanks— install high performance nozzles, brushes, applicators

Maintenance Operations■ Is a facility’s approach to equipment maintenance reactive or proactive? How

frequently does the company tune up its equipment?■ Is there floor space available to accommodate process line modifications?

Examples of potential P2 opportunities:— tighten and repair all faucets, gaskets, and couplings to eliminate leaks— install lids on process tanks to reduce evaporation and spills

Fugitive Emissions, By-Products■ Can a facility eliminate any cleaning or rinsing steps from its process lines? Can

it use a less toxic cleaning agent or replace chemical cleaners with air blastsystems or thermal alternatives?

Examples of potential P2 opportunities:— schedule production to reduce equipment cleaning (e.g., sequence batch

mixes from light to dark to avoid intermediate cleaning steps)— replace solvent-based paint strippers with mechanical processes (e.g.,

abrasion or high velocity plastic bead guns)

Module 4

Instructor Notes


Module 5 Review Regulatory EnforcementProcess; Brainstorm Opportunities forPollution Prevention Activities

Show Overhead 11. (You may need to customize the

enforcement schematic beforehand in order to display a revised

Overhead 11 if your agency’s enforcement process is significantly

different.) Indicate that this is a schematic of a model

compliance inspection and enforcement process. Ask the

group to help review the schematic and modify it as necessary

to accurately reflect your agency’s work practices. Mark up the

overhead to show the group’s recommended changes.

Ask the group to indicate where and how pollution prevention

principles are currently considered during these work

practices. Record the P2 practices currently in use in the

agency on Overhead 10 using an asterisk (*) to separate these

thoughts from the schematic diagram changes suggested

above.

Ask the group to identify additional opportunities for working

pollution prevention into these work practices. Record these

additional suggestions of P2 practices in a different color on

the slide, or if the overhead is too crowded, on a flip chart.

Optional: After the workshop, you may wish to reproduce a

clarified version of the modified schematic plus all P2 suggestions

to distribute to participants as a reminder.




Customize



Module 5

Compliance Inspection & Enforcement Processoverhead 11

Inspection Targeting—determine which industries—determine which facilities

Perform Inspection—Note violations—Inspection Close-out Conference

Prepare Enforcement Case—specify violations—recommend enforcement action—recommend application of specific

policies (as necessary)

Prepare for Inspection—records, maps, file data—consult other Agency staff—Agency enforcement history

Request Additional Informationfrom Facility (if necessary) andDetermine Applicability of Regulations

Follow Agency Procedures forIssuing Enforcement ActionAgainst Facility

1.

3.

5.

2.

4.

6.

Review Regulatory Enforcement Process and Brainstorm Opportunities for P2 Activities

Instructor Notes


Module 6 Using Pollution PreventionInformation Resources

This Module discusses actual and potential ways that

regulatory staff can use P2 information resources in

enforcement actions.

Indicate that the discussion will now return to the around-the-

room activity from the Introduction. Refer to the flip charts

that participants generated describing existing enforcement

cases on which they had worked that used pollution

prevention. Ask the appropriate participants to identify the

sources of information and knowledge they used to explore

the P2 options and determine the P2 outcome. Record their

comments on a flip chart.

During this discussion, facilitate active thinking and

participation in the large group by asking questions such as:

■ Did anyone else here ever use that source of information?

Does everyone have access to (or a copy of ) that source?

■ Did you consider turning to the Internet, EPA, other state

agencies, or other non-governmental organizations for

more information? Why or why not?

■ Do you engage consultants or the facility’s personnel in

your thinking?

■ What else would have been helpful to you?

■ Did you run into any barriers within our agency in trying to

achieve a pollution prevention outcome in an enforcement

action? Has anyone else had that experience? (Try to elicit

the following examples of barriers: insufficient sharing of

information among agency staff, and staff perception that

P2 solutions in enforcement actions cannot be shared

internally due to confidentiality issues.)



Module 6

Using Pollution Prevention Information Resources: Notes

In my work on enforcement cases,

1. Do I consider turning to the Internet, EPA, other state agencies, or other non-governmental organizations for more P2 information? Why or why not?

2. Do I engage consultants or the facility’s personnel in my thinking?

3. What other P2 information would have been helpful to me?

Using P2 Information Resources

Instructor Notes


Module 6

Indicate to participants that the Worksheet provided on the

opposite page is for their note-taking benefit only (not for a

group Exercise).



Module 6

P2 Information Resources Worksheet

P2 resources used in our enforcement cases include:

Barriers to working P2 solutions into our enforcement actions include:

Instructor Notes


Module 7 Available Pollution PreventionInformation Resources

This module includes presentations by several internal and

external speakers, each of whom can offer services to the

agency’s compliance inspection and enforcement staff. The

services may include database access or searches, Internet

searches, written materials, professional expertise and advice,

or no-cost “consulting” on P2 opportunities at facilities typical

of those undergoing inspection or enforcement.

To make this Module successful, arrange for the participation

of one or more “P2 Information Service Providers.” Potential

speakers might include a P2 representative from the

appropriate EPA Regional office, a P2 expert from a nearby

office of a national or regional environmental organization, or

a P2 official from your agency or another state agency. Each

speaker should prepare and deliver a presentation of

approximately 15-20 minutes, preferably including slides or

handouts, that explains the following topics: the services

offered by his or her organization, any limitations on such

services, and the point of contact for such services.

Note: The agency that employs the workshop participants

should have specific agreements (preferably in place

beforehand) with each of the speakers’ organizations as to

what services will be offered to agency personnel, how the

delivery of services will be managed and monitored, and what

limits (if any) will be placed on these services.

Overhead 12 is a “placeholder” overhead which should be

replaced with an appropriate substitute such as an overhead

providing the names and phone numbers for the P2

Information Service Providers who are participating in this

Module.Customize






Module 7

P2 Information Resourcesoverhead 12

■ Internal resources include:

■ External resources include:

Available P2 Information Resources

Instructor Notes


Module 8 Review Case Study andBrainstorm P2 Options

Direct participants’ attention to their training workbook, and to

the presentation of the Case Study. Ask participants to read

the case study individually, and to individually write down as

many pollution prevention opportunities and options as

possible for this hypothetical case. Explain that group work

regarding this case study will be completed after lunch, after

the participants have had a little more time to think about the

case.

The key aspects of this case study are to provide a realistic yet

simple scenario with violations in several regulatory areas.

Taken together, the violations should constitute a serious case

requiring a moderate to severe penalty. The scenario should

allow for several P2 options to be completed by the firm, either

as compliance measures, or as supplemental projects in return

for some penalty mitigation. The case study should be for a

hypothetical firm in an industry with which the participants

are relatively familiar.

Note: This case study shows violations discovered in multiple

regulatory programs (air, hazardous waste, etc.) through a

multi-media inspection. If your organization conducts single-

medium inspections, you may need to customize this case

study so that it presents a single-medium inspection and

single-medium violations.

Customize



Module 8

Case Study Exercise

The following is a description of a fictitious Massachusetts company that is basedon several real wood products manufacturers in New England.

Company Background

Carver Company was founded in 1922 by William A. Carver III, son of a Bostonshipping magnate. Expelled from Harvard in 1918 for ungentlemanly conduct,William III left Boston in disgrace and moved to northern New England to seek hisfortune. After a few false starts, he purchased a small lumber business that suppliedrough-sawn wood to the Boston area market. To increase profit margins, Carversoon moved the company into more value-added products, such as fine-milledlumber, doors, and specialty moldings. In the pursuit of expansion, Carver pur-chased a small, local company that manufactured wooden bleacher seating. De-mand was increasing sharply for such seating, and Carver saw a natural synergybetween the two operations. Within five years, the seating business had become thelargest and most profitable part of the enterprise.

Growth and expansion into new product lines continued over the years as thecompany moved from wooden bleachers into many types of multiple seating forstadiums, arenas, classrooms and theaters. In 1972, Carver acquired another smalllocal manufacturer, Peterson Wood Furniture Company, which had long been agood customer of the Carver lumber mill. Peterson produced high quality officefurniture and had a good reputation, but the company had been driven to near-bankruptcy by inept management. In 1980, these companies were merged into asingle corporate structure with four divisions.

Like many in the business community, the Carver Company greeted the advent ofenvironmental regulations in the 1970’s with antagonism, and responded withminimal efforts aimed at achieving compliance as cheaply as possible and as late aspossible. Carver employed many local residents who were more worried about thestability of their jobs than the environmental performance of the company. Overthe past few years, however, there had been growing concern in the town about realand potential environmental problems caused by the lumber and manufacturingoperations. The lumber mill and the seating plant were next to the OskawaneshawRiver and reports of drums in old, inadequate containment areas, combined withother issues, prompted the formation of the CORN — Clean the OskawaneshawRiver Now. The group had only a few dozen members, but with a strong connec-tion to the local newspaper and other regional environmental groups, its influencewas much greater than its size. A recent edition of the Oskawaneshaw Gazette hadincluded a front page article featuring Carver’s environmental releases. This public-ity attracted the attention of the regional office of the Massachusetts Department ofEnvironmental Protection and they conducted a multi-media inspection of thefacility. This inspection focused on the company’s spray painting operations andVOC and RCRA compliance.

Review Case Study and Brainstorm P2 Options

Instructor Notes


Module 8



Finishing Operations

The Carver plants employed two basic types of finishing operations: manualapplication for the flat boards used in the bleacher seating and spray application forthe wood components of the other multiple seating and the furniture. Finishing ofthe arms, backs and seats of the non-bleacher seating was the highest volumefinishing operation of the company. Prior to finishing, lumber arrived from theCarver lumber mill and was stored in racks in a storage shed. The wood was movedfrom storage into the production area where it was cut to the correct length,shaped, drilled, sanded and stored in a large holding area on one side of the shopfloor prior to finishing.

All multiple seating was custom-made to order with different finishing specifica-tions requiring varied finishing times and quantities of materials. The woodencomponents of multiple seating were assembled onto metal frames prior to finish-ing and then carried into a large ventilated spraybooth. Figure 1 at the end of thiscase study (p. 47) presents a process flow diagram of the spray painting operation.Carver paints with traditional nitrocellulose coatings.

The spray paints and solvents used by Carver have high VOC content and containtoluene, xylenes, methyl isobutyl ketone (MIK), methyl ethyl ketone (MEK), andmethanol. While these chemicals are not classified as carcinogens, they have well-documented serious long-term health effects including neurological damage,developmental damage in offspring, damage to major organs, and other effects.Breathing these VOCs can also cause headaches, fatigue, and nausea.

Although the number and type of coats varied somewhat depending on the specifi-cations of the customer, typically three or four coats — stain, sealer, and one or twolacquer topcoat(s) — were applied with high volume, low pressure (HVLP) sprayguns. After each coat, the seating was carried to a flash-off area to dry, then to aprep area for sanding before being returned to the spray booth for the next coat.The spray gun parts, including lines and nozzles, were cleaned with a chlorinatedsolvent at the end of each shift and when lacquer pigments were changed. Thespraybooth had a strippable liner that was replaced as needed.

The coating materials were purchased in 55-gallon drums that were moved to theproduction area as needed and the contents transferred into the spray dispensers.Employees were responsible for cleaning the spray equipment after each shift or forcoating changeovers, and they obtained solvent from a 55-gallon drum stored nearthe work area. When a drum was used up, the person who emptied it contacted thestore room for a replacement. Used solvent was dumped into an open drum, whichwas sealed when full and sent to a centralized waste disposal holding area. Con-taminated rags and spraybooth liners were also drummed for disposal.

Module 8

Instructor Notes


Module 8

Individual Exercise

Have participants fill in answers on their own to the following

questions (which are repeated in the participant notes) in the

blank spaces provided on the opposite page:

1. What are the major wastes and pollutants generated at this

facility?

2. Please brainstorm P2 options for this coating operation.

3. How would these P2 options help this facility address the

violations described in the text (or other violations you noted)?

Allow 15–20 minutes for this individual exercise.



Module 8

Compliance Violations

The DEP inspection of the Carver wood coating facility initially identified thefollowing compliance violations:1. Hazardous Waste: Carver improperly managed the dried nitrocellulose residue

waste by not labeling the barrels properly, leaving them open, and storing themfor more than 90 days without a permit.

2. VOC Limitations: Carver violated the Massachusetts VOC regulations for woodcoating operations. Carver has the potential to emit more than 50 tons per year,but had not submitted an emissions control plan to DEP for approval. Addition-ally, some of the coatings Carver was applying exceed the Massachusetts VOClimits.

[Note that the MACT standard applicable to Carver’s wood finishing operationshas not yet taken effect.]

The Carver Company is not currently subject to Massachusetts Toxics Use Reduc-tion Act (TURA) planning and reporting requirements and therefore has neverprepared a Toxics Use Reduction (TUR) plan.

Individual Exercise

Answer the following questions in the blank spaces provided:

1. What are the major wastes and pollutants generated at this facility?

2. Please brainstorm P2 options for this coating operation.

3. How would these P2 options help this facility address the violations described inthe text (or other violations you noted)?

Instructor Notes


Module 8

Note to Trainer: Optional: The following “Pollution Prevention Options/

Opportunities” (opposite page) may be held in reserve in case the

participants have difficulty brainstorming P2 options. Or it may be

handed out with or following the case study, if desired.



Pollution Prevention Options/Opportunities

The following pollution prevention options or opportunities are available for woodfinishing operations:

A. High-Solids Coatings with HVLP spray guns

Carver could switch from sealer and lacquer coatings that average 26-percent solidsto coatings with 35 percent solids. To enable proper application of the material withHVLP guns, Carver would have to heat the coatings in-line and would need towork with its equipment supplier to modify the spray gun caps, nozzles and tips.The new coatings would contain approximately 40 percent fewer VOC’s and 80percent fewer HAP’s and would have costs and savings as listed below.

Coating materials: The higher-solids coatings are about double the cost of the lowsolids coatings on a per gallon basis but less material is used to achieve thesame finished thickness. Combined with the elimination of the second topcoat,total quantity of coating purchased by Carver would decline but the total cost isprojected to be about 10 percent more. The supplier expects the price differen-tial to decrease as more companies switched to higher solids coatings.

Production Labor: The higher solids coating would eliminate the need for a secondtopcoat in most cases and thus would reduce labor by about 4500 hours peryear on constant volume. The sealer coat, however, would be more difficult tosand, requiring orbital rather than block sanders, and an additional 1000 hoursof labor per year.

Cleaning solvent: Carver would consume 30 per cent more solvent due to the higherviscosity of the material.

Solvent disposal: one-half increase of solvent use -15%

Rag & spraybooth liner disposal: No significant change.

Electricity: Heating the coatings — additional $1000; increased air flow in the sealerflash-off area — additional $500

Heating oil: Increased air flow in the sealer flash-off area — $3000

Training: Extra production training in first 3-6 months of operations: $5000

Rework: Increased rework because there is less margin for error with a single,heavier topcoat: $15000 per year

Plant and Equipment: $30,000 to upgrade flash-off area and modify spray-gunequipment

Module 8

Instructor Notes


Module 8



B. Aqueous-Based Coatings

Another option would be for Carver to switch from nitrocellulose coatings toaqueous (water)-based coatings. While the potential environmental gains aresignificant, the financial benefits are less certain, and Carver is concerned aboutquality issues. Some customers have made it clear that they preferred the high glossof the conventional nitrocellulose lacquer. Nevertheless, use of the aqueous coatingswould reduce VOC’s and HAP’s more than 75% and would eliminate the need touse chlorinated solvents for cleanup. The water used for cleaning the spray equip-ment would require some type of treatment to allow its discharge under Carver’sexisting NPDES permit. The following cost items are estimated:

Coating materials: The aqueous-based coatings cost approximately 10 percent morethan what Carver is currently using, but the relative difference is expected todecrease.

Production Labor: No change — the same number of employees would be requiredto apply the aqueous-based formulations.

Cleaning Solvent: Chlorinated solvent use would be eliminated. Aqueous-basedcleaner @ 20% of cost.

Rag & spraybooth liner disposal: 20% of former cost.

Electricity: The ventilation requirements would be reduced by 25%

Heating Oil: Reduced by 25%

Training: Extra production training in first 3-6 months of operations: $5000;annual training costs cut in half

Water treatment: Initial costs: $75, 000 for lines and tankage. Chemicals: $2000 /yr.

Module 8

Instructor Notes


Module 8


Participant NotesModule 8

C. Ultra-Violet Coatings

Carver could install a state-of-the art ultra-violet coating system. Although suchsystems have been installed in the industry primarily to coat flat boards, such asthose used on the bleacher seating, new equipment has been introduced by onevendor to enable the use of ultra-violet coating on the more complex dimensions ofother multiple wood seating and furniture. The technology looks promising butdoes not yet have an extensive track record for the type of application Carver isconsidering. Moreover, an automated system would require a significant upfrontinvestment. It does, however, have the potential to generate major savings inmaterials and labor and also provide significant environmental advantages. Thecosts and savings are estimated to be the following:

Coating Materials: The U-V coatings cost more on a per gallon basis but consider-ably less would be used because the coatings have a higher percentage of solids.Moreover, over-spray is captured and recirculated into the spray equipment,eliminating waste. A reduction of about 30% in the cost of coating materials isprojected.

Production Labor: The automated system would enable the reassignment of at leasttwo employees to other operations.

Cleaning Solvent: UV coatings would reduce the amount of solvent required forclean-up by 90%.

Solvent disposal: Same reduction as solvent use — 90%

Rag & spraybooth liner disposal: Same reduction as solvent use — 90%

Electricity: The ventilation requirements would be reduced by 25%. UV lampswould costs about $5000 annually to operate.

Heating Oil: The ventilation requirements would reduce heating oil use by 25%.

Training: Extra training in first 3-6 months of operations: $10000. More productiontraining on an annual basis — $3000.

Plant and Equipment: $350,000 for equipment and $150,000 for installation, phasedstart-up and lost production during changeover.

Instructor Notes


Module 8


Participant NotesModule 8

Air Emissions— Leaks— Coating transfer to

smaller containers— Uncovered containers— Spills

Solid and/orHazardous Waste— Empty coating containers

Solid and/orHazardous Waste— Used rags— Used adsorbants

Air Emissions— Coating on furniture*— Overspray*— Used rags— Used adsorbants— Spills— Uncovered containers— Flushing guns and lines

with coating upon starup

Air Emissions— Leaks— Coating transfer to

smaller containers— Uncovered containers— Spills

Solid and/orHazardous Waste— Empty solvent containers

Solid and/orHazardous Waste— Used solvents— Disposable filters (if used)— Dried overspray/lacquer dust— Strippable spraybooth coating

Air Emissions— Gun/line cleaning— Metal filter cleaning (if used)— Uncovered containers— Spills— Application of strippable

spraybooth coating

Air Emissions— Coating on furniture

Furniture Piece

CoatingMaterials

Rags andAdsorbants

CleaningSolvent

StrippableSpraybooth

Coating

CoatingApplication

Cleaning**

Flashoff

Drying Oven

Sanding

* Quantity dependant onapplication equipment andother factors

** Frequency dependanton coating type andapplication equipment

Number of repetitions dependant on Number of Coating Operations

Spraybooth

Figure 1Waste Generation from Coating and Cleaning Operations

Wood Furniture: The Clean air Act Amendments of 1990 and Pollution Prevention Opportunities,NEWMOA and NESCAUM, September, 1997.

* Quantity dependent onapplication equipment andother factors

** Frequency dependent oncoating type and applicationequipment

Instructor Notes


Module 9 Discussion of Case Study P2 Options

In this Module, participants return to a large group to review

P2 options available for enforcement actions against the case

study facility. This review involves a discussion of relevant

enforcement policies and procedures. Because this course was

piloted with Massachusetts DEP enforcement staff, the text of

the Participant Notes for this Module summarizes a

Massachusetts-specific policy dealing with P2 and

enforcement.

You may wish to remove the MADEP material presented below

and in the Participant Notes for this Module and replace it

with material relevant to your agency’s P2 and enforcement

tools, policies and procedures. You may want to model your

presentation on the MADEP material presented in this Module.

Alternatively, you may discuss MADEP’s approach as a

hypothetical example. If so, use the Instructor Note text below

“as-is”.

Summary of Massachusetts example

The Massachusetts DEP (MADEP) is constrained by statute in

many enforcement situations to issuance of a Notice of

Noncompliance (NON). The NON, which is a form of first-level

“warning,” gives the violating facility an opportunity to correct

all noted violations within a reasonable time frame without

penalty. MADEP must issue an NON to a facility except in the

case of egregious or willful violations or a prior enforcement

history within a specified time limit.

Because the NON is a very straightforward document without

room for the negotiated language typical of a consent order,

and because the NON is used so extensively in first-offense

situations, MADEP devised a policy requiring a cover letter to

help promote P2 in these situations (see opposite page).

Customize



Standard Cover Letter for All Notices of NonCompliance

Massachusetts Department of Environmental Protection

Bureau of Waste Prevention

Policy #BWP-95-012

Signed by: Lee Dillard, Assistant Commissioner (Acting)

August 4, 1995

Policy Statement

Attached are two standard formats for cover letters for Notices of Noncompliance(NON) and Field Notices of Noncompliance (FNON) issued by the Bureau.Attachment 1 is the standard format for cover letters for Notices of Noncomplianceissued from the office after a facility inspection has occurred. Attachment 2, thecover letter for FNONs, should be used for the follow-up copies of FNONs distrib-uted from the office after an FNON has been issued at the facility.

The letters includes language to identify potential source reduction opportunities(paragraph seven [7]). This language will be used whenever enforcement action istaken against a facility where there may be ways of coming into compliancethrough the implementation of source reduction or toxics use reduction.

Background Statement

As the Bureau of Waste Prevention increases the emphasis on waste prevention incompliance, the need has arisen for NON language that encourages violators toconsider source reduction as a tool for coming into compliance. A draft version ofthis NON cover letter was presented in BWP FIRST training that has occurred todate and has been in use broadly for the last two years.

Additionally, a new enforcement tool, the Field NON (FNON) has been intro-duced. The FNON will be issued to the facility at the time of the inspection. A copyof the FNON will be sent via certified mail to the facility owner. An appropriatecover letter will serve to remind violators that source reduction should be consid-ered.

It will be necessary to include this document in FIRST training, and to make itavailable to all compliance and enforcement staff. The Compliance and Enforce-ment Team will evaluate the use of this document and recommend changes asnecessary to ensure that source reduction is considered whenever possible as a toolfor coming into and remaining in compliance.

Module 9Discussion of Case Study P2 Options

Instructor Notes


Ask participants to list some of the simple and more obvious

pollution prevention options, i.e., those which could be

incorporated into MADEP’s first-level enforcement response,

the NON. Record these suggestions on a flip chart.

Refer participants to the MADEP policy on P2 in cover letters

for NONs (in Participant Notes, starting on opposite page).

Remind them that it is MADEP policy to:

1. include a boilerplate paragraph on the benefits of P2 in a

cover letter attached to the NON;

2. suggest that the facility contact the Massachusetts Office of

Technical Assistance, a non-regulatory state agency

providing P2 assistance; and

3. copy the NON to the Massachusetts Office of Technical

Assistance for follow-up and tracking.




Module 9


Participant Notes

ATTACHMENT 1

CERTIFIED RE: BWP - (location)Noncompliance with M.G.L.Chaptersand 310 CMR

(Name of Entity) ° MAD #(Mailing Address of Entity) hazardous waste(City, Town, and Zip Code of Entity) classificationATTN:(Name of Individual) ° SR #

air qualityclassification

Enforcement Document No. ° NPDES or MA#wastewaterclassification

° DEP Facility ID #large quantity toxics user

° MA Sewer Connect#° AQ Stage II ID#

RE: NOTICE OF NONCOMPLIANCE

THIS IS AN IMPORTANT NOTICE. FAILURE TO TAKE ADEQUATE ACTION INRESPONSE TO THE NOTICE COULD RESULT IN SERIOUS LEGAL CONSEQUENCES.

Dear (Name of Individual)

Department personnel have observed that on (date)(activity) occurred atyour facility located on (street address) in (city), Massachusetts, in noncompliancewith one or more laws, regulations, orders, licenses, permits, or approvalsenforced by the Department. Specifically, Department personnel observed activitiesin noncompliance with applicable {Hazardous Waste Management, Air Quality,Industrial Wastewater, Solid Waste Management, and the Toxics Use Reduction Act}regulations.

Attached is a written description of (1) each activity referred to above,(2) the requirements violated, (3) the action the Department now wants you totake, and (4) the deadline for taking such action. An administrative penalty maybe assessed for every day from now on that you are in noncompliance with therequirements described in this Notice of Noncompliance. {Use the followinglanguage only if the NON includes failure to pay a Toxics Use Reduction Fee:Additionally, failure to pay toxics use fees could result in referral of thismatter to the Attorney General’s office and/or legal action taken by the AttorneyGeneral’s office on behalf of this Department.}

Notwithstanding this Notice of Noncompliance, the Department reservesthe right to exercise the full extent of its legal authority in order to obtainfull compliance with all applicable requirements, including, but not limitedto, criminal prosecution, civil action including court-imposed civil penalties,or administrative penalties assessed by the Department.

cont’d

Module 9

Instructor Notes


Module 9


Participant Notes

SOURCE REDUCTION OPPORTUNITIES

You may be able to reduce environmentally driven costs and possiblyreduce the regulatory requirements and fees applied to your firm if youeliminate or reduce the use of toxic materials or other inputs, or thegeneration of wastes, through decreased chemical use or increased processefficiency. As a result, you may save money and improve quality and productivity.

While inspecting your facility, Department personnel observedpotential source reduction opportunities associated with your

operation(s). Source reduction options you may want to evaluate for this(these) operation(s) include but are not limited to___________________________________________________. It is also possible thatimplementation of source reduction options may correct violations associatedwith your ___________________________ operation(s). Changes to your processcould alter the requirements, including notification (and/or permitting)requirements, imposed on you by any of the laws and regulations that theDepartment enforces.

Moreover, tracking annual usage of each toxic substance or other input,if you are not already doing so, may lead to identification of additionalsource reduction opportunities.

For further information on source reduction of toxic and other waste youmay contact:

° the Office of Technical Assistance (617-727-3260) for FREE, CONFIDENTIALtechnical assistance including on-site assessments, financial evaluations,the handbook “The Practical Guide to Toxics Use Reduction”, and other resources.

° the Toxics Use Reduction Institute (978-934-3275) for courses for certified“Toxics Use Reduction Planners”.

° DEP’s Toxics Use Reduction Implementation Team (617-292-5870) for guidancematerial on the Toxics Use Reduction Act requirements.

If you have any questions regarding this matter, please contact_____________________________ of this office at (###) ###-####.

Very truly yours,

DATE:___________________ _______________________

Regional EngineerBureau of Waste Prevention

enclosurecc: Christine Ayers, OE, DEP Boston

__________________, Board of Health__________________, Publicly Owned Treatment Works__________________, USEPA (If joint inspection)__________________, Regional Contact Person, OTA, EOEA, Boston

cont’d

Module 9

Instructor Notes


Module 9


Participant Notes

ATTACHMENT 2

CERTIFIED RE: BWP - (location)Noncompliance with M.G.L.Chaptersand 310 CMR

(Name of Entity) ° MAD #(Mailing Address of Entity) hazardous waste(City, Town, and Zip Code of Entity) classificationATTN:(Name of Individual) ° SR #

air qualityclassification

Enforcement Document No. ° NPDES or MA#wastewaterclassification

° DEP Facility ID #large quantity toxics user

° MA Sewer Connect#° AQ Stage II ID#

RE: FIELD NOTICE OF NONCOMPLIANCE

THIS IS AN IMPORTANT NOTICE. FAILURE TO TAKE ADEQUATE ACTION INRESPONSE TO THE NOTICE COULD RESULT IN SERIOUS LEGAL CONSEQUENCES.

Dear (Name of Individual)

Department personnel have observed that on (date)(activity) occurred atyour facility located on (street address) in (city), Massachusetts, innoncompliance with one or more laws, regulations, orders, licenses, permits,or approvals enforced by the Department. Specifically, Department personnelobserved activities in noncompliance with applicable {Hazardous Waste Management,Air Quality, Industrial Wastewater, Solid Waste Management, and the Toxics UseReduction Act} regulations.

A Field Notice of Noncompliance (FNON) including a written descriptionof (1) each activity referred to above, (2) the requirements violated, (3) theaction the Department now wants you to take, and (4) the deadline for takingsuch action was issued to (Mr./Ms. Name of Individual) of your facility at thetime of inspection. A copy of this Field Notice is attached. An administrativepenalty may be assessed for every day from now on that you are in noncompliancewith the requirements described in this Notice of Noncompliance.

Notwithstanding this Field Notice of Noncompliance, the Department reservesthe right to exercise the full extent of its legal authority in order to obtainfull compliance with all applicable requirements, including, but not limitedto, criminal prosecution, civil action including court-imposed civil penalties,or administrative penalties assessed by the Department.

cont’d

Module 9

Instructor Notes


Module 9


Participant Notes

SOURCE REDUCTION OPPORTUNITIES

You may be able to reduce environmentally driven costs and possiblyreduce the regulatory requirements and fees applied to your firm if youeliminate or reduce the use of toxic materials or other inputs, or thegeneration of wastes, through decreased chemical use or increased processefficiency. As a result, you may save money and improve quality and productivity.

While inspecting your facility, Department personnel observedpotential source reduction opportunities associated with your

operation(s). Source reduction options you may want to evaluate for this(these) operation(s) include but are not limited to___________________________________________________. It is also possible thatimplementation of source reduction options may correct violations associatedwith your ___________________________ operation(s). Changes to your processcould alter the requirements, including notification (and/or permitting)requirements, imposed on you by any of the laws and regulations that theDepartment enforces.

Moreover, tracking annual usage of each toxic substance or other input,if you are not already doing so, may lead to identification of additionalsource reduction opportunities.

For further information on source reduction of toxic and other waste youmay contact:

° the Office of Technical Assistance (617-727-3260) for FREE, CONFIDENTIALtechnical assistance including on-site assessments, financial evaluations,the handbook “The Practical Guide to Toxics Use Reduction”, and other resources.

° the Toxics Use Reduction Institute (978-934-3275) for courses for certified“Toxics Use Reduction Planners”.

° DEP’s Toxics Use Reduction Implementation Team (617-292-5870) for guidancematerial on the Toxics Use Reduction Act requirements.

If you have any questions regarding this matter, please contact_____________________________ of this office at (###) ###-####.

Very truly yours,

DATE:___________________ _______________________

Regional EngineerBureau of Waste Prevention

enclosurecc: Christine Ayers, OE, DEP Boston

__________________, Board of Health__________________, Publicly Owned Treatment Works__________________, USEPA (If joint inspection)__________________, Regional Contact Person, OTA, EOEA, Boston

Module 9

Instructor Notes


Module 10 Brainstorm Compliance Enforcementand P2 Strategy for Case Study Facility

This is the key learning module for the day. In this Module, the

participants practice “creative assertiveness” in formulating

pollution prevention requirements to address the

noncompliance observed at the facility. For many participants,

this will be an intellectual and emotional stretch, as the

standard responses to violations generally do not involve

pollution prevention solutions. There may be heated

discussions within and between small groups. The trainer will

have to use judgment in determining how to direct and

facilitate such discussions.

Included in the Participant Notes on the opposite page are

base penalty recommendations which MADEP uses to develop

an enforcement case. These base penalty numbers may be

mitigated downward or escalated upward by specific factors

according to MADEP policy criteria.

You may wish to remove the MADEP material in the Participant

Notes for this Module and, using this material as a model,

replace with penalty information that is specific to your

Agency.

Customize



Preliminary List of Violations and AssociatedRecommended Base Penalties

Violation Citation Base PenaltyPenalty Class

Haz Waste

Labelling 310 CMR 30.340(1)(b) $750.00 II

Open Barrels 310 CMR 30.340(1)(a)1.c. $750.00 IIref. 30.685(1)

>90 day storage 310 CMR 30.340(2) and $20,000.00 I30.801

VOCs

VOC emission limits 310 CMR 7.18(23)(b) and (e) $8,000.00 I

No emission control plan 310 CMR 7.18(23)(f) $750.00 II

Record keeping 310 CMR 7.18(23)(h) $750.00 IIsee 7.18(23)(g) and (i)

HAPs

No emiss. contr.plan appl. 310 CMR App.C.(3) b $5,000.00 I

Operating w/o a permit 310 CMR App.C.(3) d $5,000.00 I

Operating w/o a permit 310 CMR App.C.(3) f $5,000.00 I

Others?

Total Base Penalties $46,000.00

Module 10Brainstorm Compliance Enforcement and P2 Strategy for Case Study Facility

Instructor Notes


Ask (or assign) participants to form small groups to agree

upon a strategy for requiring the case study facility to return to

compliance with Agency regulations under a consent

agreement or a unilateral order.

Direct participants to the Participant Notes in this Module,

which contain some preliminary lists of violations and their

associated recommended base penalties. Refer participants to

the questions on the following Participant Notes pages for

determining the case strategy. Ask participants to capture their

recommendations in their workbooks or on note paper for

presentation to the large group in the next Module.

Along with any other available P2 “experts” or invested

managers in the room, circulate among the small groups to

monitor progress and facilitate as needed.

Note: The purpose of the participant questions in this Module differs

from the purpose of the participant questions in Module Eight

(the Case Study reading). Whereas the questions in Module

Eight were meant to initiate thinking about P2 and

enforcement options at the facility, the questions in this

Module are meant to direct participants to devise a

negotiation strategy for implementing an enforcement action

at the hypothetical firm. Unlike the earlier questions, which

were meant to “get the juices flowing”, these questions are

meant to assist participants in strategizing a final approach.

Module 10




ParticipantWorkbook



Questions for Small Group Discussion of “Carver” CaseEnforcement:

1. What penalty exposure (the maximum appropriate penalty) do you have tobegin with? (This is your bargaining chip.)

2. What is your goal for this facility in terms of return-to-compliance?What specific actions must the facility take?

3. What is your goal for this facility in terms of Pollution Prevention?What specific actions do you desire at this facility?

Module 10

Cont’d

Instructor Notes


Module 10



4. For each element below, what is your enforcement strategy:A. What is the “bottom line” you must walk away with?B. What is the best situation you would most prefer to walk away with?Note: you may include P2 actions within an enforcement order and/or in aSupplemental Environmental Project (SEP).

■ violations?A. must have:

B. would prefer:

■ base penalty amounts?A. must have:

B. would prefer:

■ assessed penalty option selected? (e.g., assessed, payment plan, mitigated,stipulated)A. must have:

B. would prefer:

■ SEP? (DEP can encourage and suggest to facility, but cannot direct)A. must have:

B. would prefer:

5. What are 3 key elements or oversight obstacles for an effective but low-DEP-resource Pollution Prevention enforcement project or SEP? Are there other waysto create an effective P2 project but further reduce DEP’s resource allocation?

Module 10

Instructor Notes


Module 11 Discussion of Small GroupRecommendations and EnforcementResource Constraints

Ask each small group to explain the enforcement case

strategy it selected. Referring back to Module Ten, each group

should explain its most-preferred outcome (the first

negotiating strategy offered to the facility) and its bottom-line

outcome (the least preferred outcome that will be acceptable

to the Agency). Briefly capture these recommendations on a

flip chart.

After each group has had an opportunity to report its

recommendations, facilitate a larger group discussion of

similarities and differences between the recommendations.

“Coax” the group toward the most complete P2

recommendations suggested, but acknowledge roadblocks

present in the Agency, which may include:

■ lack of staff P2 expertise and experience,

■ lack of Agency authority,

■ lack of Agency policies,

■ weak regulations,

■ weak support among senior managers or external Agency

watchdogs, or

■ a strong and organized industrial community.

Note: The large group discussion may raise issues regarding

conflicting or ambiguous Agency regulations, policies, or

authority. To foster a discussion that keeps within the time

frame for this Module, it may be helpful to capture such issues

on a separate flip chart and secure some volunteers to carry

the issues back to policy and rulemaking groups within the

Agency.

Indicate to participants that the Worksheet provided on the

opposite page is for their note-taking benefit only.









Enforcement Recommendations for the Case Study Facility:P2 Worksheet

The best enforcement strategy is:

The best P2 options include:

Module 11Discussion of Small Group Recommendations and Enforcement Resource Constraints

Instructor Notes


Acknowledge the staff members’ individual resource

limitations as a lead-in for presenting Overheads 13–15.

Display Overhead 13. Acknowledge that more thought and

activity to build pollution prevention outcomes into

enforcement actions will probably divert staff resources from

other activities they are currently engaged in. This demand on

Agency resources should be minimized to the greatest extent

possible. Some ways to do that include limiting the research

and review activities the Agency will undertake during the

settlement negotiation phase, and negotiating only a few

major milestones and timeframes.






asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj14 Display Overhead 14. Similarly, Agency oversight of the

facility’s implementation of a P2 project may require more or

less resource-demand. Possible ways to limit the demand on

Agency resources during the oversight enforcement period

include limiting the interim review and approvals, and tracking

only specific P2 milestones as measures of the facility’s

compliance with the enforcement action.

Module 11

Nex

t…



Less Resources

Company proposes P2 project.Agency negotiates timeframes and a few milestones.

Agency reviews info to help company develop P2 project proposal.Agency negotiates substance of project, time-frames and milestones.

More Resources

Agency completes research and thorough company review to develop P2 project proposal.Agency negotiates sub-stance, timeframes, and milestones.

Enforcement — P2 Resource Demand Continuum

Negotiation of P2 in Settlementoverhead 13

Less Resources

P2 milestones tracked by Agency simply as compliance milestones of the settlement during the enforcement period.

Agency reviews and approves defining aspects of the project as well as milestones during the enforcement period.

More Resources

Agency reviews and approves operational aspects (e.g., evaluation of alternatives), defining aspects, and milestones during the enforcement period.


Oversight and Implementation of P2 Settlementoverhead 14

Module 11

Instructor Notes




asdf uriwq th fhtoiu as chio wk oiu asd I wauun fakc ndar os dba a nac state rhe fjk ti apoiu djk ak weruioiaj15 Display Overhead 15. Finally, exerting staff resources to

achieve more P2 outcomes in enforcement actions results in

various value trade-offs for the Agency. Low resource

expenditure (that is, undertaking only a few P2 cases or

limiting activities to simplistic projects) can result in

completing more cases and obtaining higher penalty dollars,

and will maintain a staff focus on regulatory and enforcement

basics. However, higher resource expenditure (that is, more —

or more complex — P2 cases) can result in increased staff

knowledge of P2 options and industrial processes, increased

data from facilities, increased assurance that P2 will be

considered and implemented by more facilities, long-term

benefits to the economy through industrial cost-savings, and

short- and long-term benefits to the environment through

removing or reducing a future area of noncompliance,

weighed against any increased demand on the Agency

resources.

Module 11



Low P2 ResourceExpenditure Increases:

(+) No. of cases that Agency can complete(+) Possible total penalty dollars assessed

(if penalties mitigated for P2 outcomes)

(+) Focus on regulatory and enforcement basics

High P2 ResourceExpenditure Increases:

(–) Demand on Agency staff resources(+) Staff knowledge and involvement in

P2 options and industrial processes(+) P2 and other data from facilities(+) Assurances of P2 consideration by

more facilities(+) Possible cost-savings by industry for

implementing P2 return-to-compliance (long-term benefit to economy)

(+) Future noncompliance possibly avoided


Trade-Offs in Value to Agencyoverhead 15

Module 11

Instructor Notes


Module 12 Discussion of Proposed Methodfor Building an Internal PollutionPrevention Enforcement CaseInformation Resource

The data collection model presented in the Participant Notes

of this Module describes a proposal still under development at

the Massachusetts DEP.

If a similar data collection process is ongoing at your Agency,

you may wish to remove the MADEP material presented in this

Module and replace it with material relevant to your

Agency’s model. Alternatively, you may discuss MADEP’s

proposed approach as a hypothetical example. If so, use the

Instructor Notes and Participant Notes of this Module “as-is.”

Note: This module is most useful if senior managers at the Agency

have already: (1) committed resources to developing a P2-in-

Enforcement information resource, and (2) reviewed and

approved the proposed data elements and collection

procedures. If these commitments and approvals have not

occurred, you should facilitate the discussion as a

“recommendations gathering” session, rather than a “final

polishing” review. Next, lead the large group through the

following discussion.

Acknowledge that building pollution prevention projects into

enforcement cases occurs much more frequently at some

Agencies than others, and suggest that building an

information resource within this Agency will be beneficial in

tracking the extent to which P2 is being incorporated into

enforcement activities, and can also serve as a valuable

resource to Agency staff looking for ideas and suggestions for

future cases.

Customize



MADEP/BWP ENFORCEMENT-P2PROJECT DATA COLLECTION PROCEDURE: PROPOSAL

1. Periodically (frequency to be determined), the Bureau’s Planning and EvaluationDivision (PED) Pollution Prevention Branch (P2 Branch) will obtain a listing fromthe MADEP Facility Master File (FMF) of all higher level enforcement cases(enforcement action more severe than a Notice of Noncompliance or NON) forsome prior period. These cases include Administrative Consent Orders (ACOs),Administrative Consent Orders with Penalty (ACOPs), Unilateral AdministrativeOrders (UAOs), and Penalty Assessment Notices (PANs).

For example, the P2 Branch will obtain a quarterly listing of all higher level en-forcement cases from the quarter ending 3 months prior.

2. The P2 Branch will review copies of each higher level enforcement documentfrom the MADEP Office of Enforcement (OE) files in Boston for pollution preven-tion activities included within the enforcement action or in any SupplementalEnvironmental Project (SEP) document referenced in the enforcement action. Ifpollution prevention activities are included, a copy of the enforcement documentand SEP document (if applicable) will be obtained for the Enforcement-P2 ProjectData files.

3. Using the FMF pre-inspection report and the enforcement document(s) ob-tained from OE for each facility, the P2 Branch will complete the MADEP/BWPEnforcement-P2 Project Data Collection Form to the greatest extent possible.

4. To obtain the remaining information on the MADEP/BWP Enforcement-P2Project Data Collection Form, the P2 Branch will telephone the BWP RegionalOffice or Boston inspector who prepared the enforcement action and obtain theremaining information, if possible.

5. The inspector who prepared the enforcement action will try to provide allremaining information where reasonably possible.

RECOMMENDATION: Require the facility to complete the MADEP/BWP En-forcement-P2 Project Data Collection Form as an action within the enforcementagreement.

6. The P2 Branch will maintain the data and records collected so as to provideinformation to future inspectors contemplating similar P2 projects or enforcementfor similar violations, and to provide aggregated data for MADEP senior managersin presentations and in evaluating progress in encouraging pollution prevention inthe regulated community.

RECOMMENDATION: The P2 Branch should establish an electronic database tocapture information on the MADEP/BWP Enforcement-P2 Project Data CollectionForm to allow for ease in aggregating data and in searching for particular projectinformation. This database may be a stand-alone system to be made available to allMADEP offices through a central server, or may be a subportion of the FacilityMaster File (FMF).

Module 12Discussion of Proposed Method for Building an Internal P2 Enforcement Case Information Resource

Instructor Notes


Also, acknowledge that expanding an existing data system, or

developing a new data system to house the data, is a difficult

task and may require the input and cooperation of two or

more divisions within the Agency.

Finally, explain that other Agencies may make the contents of

their P2-in-Enforcement data systems available. For example,

EPA-New England (Region 1) has shared its data with the New

England states and with non-governmental organizations in

the Northeast. Likewise, non-governmental organizations may

collect information from one or more states and may make it

available to Agencies if requested.

Direct the participants’ attention to their workbooks. A list of

data elements useful to collect, and a proposed procedure for

collecting and maintaining the data, are contained in the

workbooks. Facilitate two separate and consecutive

discussions:

1. Are the listed data elements

— useful?

— complete?

— essential?

2. Is the proposed procedure workable as a trial policy?

Module 12



Module 12

MADEP/BWP Enforcement-P2 Project Data Form: Proposal

Attach copy of enforcement document, SEP (if applicable), and FMF pre-inspectionreport to this form.

I. Facility InformationFacility Name:(***)Address:(***)Inspector:(***)Enforcement No:(***) (includes code for enforcement type:ACO, ACOP, UAO,PAN)Industrial DescriptionSIC CodeType Of Violations: reg citation & brief description (^^^)

II. P2 Project InformationSEP Type(s): if a SEP, choose one or more as applicable1. Public Health2. Pollution Prevention3. Pollution Reduction4. Environmental Restoration & Protection5. Assessments and Audits6. Environmental Compliance Promotion7. Emergency Planning & Preparedness

Project Description:(^^^)Associated Media (AIR, IWW, LAND, HW, SW, OTHER) (^^^)Associated Statute — which programs does the project affect? — AQ, HW, SW,IWW, TURA, Other)

III. Penalty InformationDate Of Order:(***)Proposed (Initial) Penalty Amount: (may be in SEP document)SEP Credit Amount: (may be in SEP document)Final Penalty Amount Assessed:(***) (equals proposed penalty minus SEPcredit amount)Penalty Due Date:(***)

Instructor Notes


Module 12



Module 12

MADEP/BWP Enforcement-P2 Project Data Form: Proposal(cont’d)

IV. SEP Cost/Credit Information (may be in SEP document)Present Value After Tax Project Cost

(Initial & Annual Operations/Maintenance)(may be >> credit amount):

Net Present Value of Investment to Facility (may be positive or negative):Period Of Calculation (usually in number of years):Payback Period of SEP to Facility (if any):

V. Environmental Benefit Of P2 ProjectPollutant:Projected Quantity: Unit Of Measure:Projected Percent Reduction:Medium: (air, wastewater, land, HW, SW, other)Pollutant:Projected Quantity: Unit Of Measure:Projected Percent Reduction:Medium: (air, wastewater, land, HW, SW, other)

Other Comments:

(***) Data already collected in MADEP Facility Master File database (FMF)

(^^^) Data already present in MADEP enforcement document and/or SEPdocument

Boldface: Data to be obtained from inspector (inspector may require facility toprovide)

Instructor Notes
















course offering.




+ ∆




ParticipantExercise

Participant EvaluationRegulatory Enforcement at Commercial and Industrial Facilities


Pollution Prevention (P2) In Job Function Training: P2 in Enforcement

Evaluation Form

Please complete all parts of this brief evaluation. Results will be used to improve this program. The instruc-tional goals of this P2 in job function training are: 1) to review the enforcement process, 2) to improve partici-pant ability to identify and maximize opportunities to build pollution prevention into the enforcementprocess, and 3) to increase participant inclination to work pollution prevention into inspection and enforce-ment activities. Please rate the following elements of today’s workshop, both in terms of their usefulness inreaching the instructional goal and their overall quality. Please provide written comments in the space pro-vided to explain your rating or to offer suggestions for improvement.

1. Introductions/Review of Workshop Objectives

Comments:

2. Definition of P2 & TUR

Comments:

3. Review of P2 Opportunities in the Field

Comments:

4. Review Regulatory Enforcement Process andBrainstorm P2 Opportunities

Comments:

5. Using P2 Information Resources

Comments:







Instructor Notes




6. Available P2 Information Resources

Comments:

7. Review Case Study

Comments:

8. Discussion of Case Study P2 Options

Comments:

9. Brainstorm Compliance Enforcement and P2 Strategy forCase Study Facility

Comments:

10. Discussion of Small Group Recommendations andEnforcement Resource Constraints

Comments:

11. Building a “P2 in Enforcement” Information ResourceWithin the Agency

Comments:

12. Summary and Wrap-up

Comments:









Instructor Notes





Introductions/ObjectivesReview of Definition of P2 & TURReview of P2 Opportunities in the FieldReview Regulatory Enforcement ProcessUsing P2 Information ResourcesAvailable P2 Information ResourcesReview Case StudyDiscussion of Case Study P2 OptionsBrainstorm Strategy for Case Study FacilityDiscussion of RecommendationsBuilding a “P2 in Enforcement” Info. ResourceSummary and Wrap-up

Comments:











DEP



InformationAccess






natural resources.



Surface Coatings*Industrial Process Sector:


*


2 Instructor Notes Surface Coatings

Table of Contents with List of OverheadsModule 1: Introductions/Expectations ............................................................................................................................................................................. 10Module 2: Coating Process Introduction ......................................................................................................................................................................... 16

The Coating Process ................................................................................................................................................................................................... 17Process Steps ................................................................................................................................................................................................................ 17Preparation & Application Methods ......................................................................................................................................................................... 17Preparation & Application Methods ......................................................................................................................................................................... 19Curing & Process Support .......................................................................................................................................................................................... 19Two-Stage Primer Topcoat System ............................................................................................................................................................................ 21Pretreatment Processes ............................................................................................................................................................................................... 21Process Input-Output Analysis .................................................................................................................................................................................. 23Coating Process Regulation ........................................................................................................................................................................................ 25

Module 3: Surface Preparation and Pretreatment ........................................................................................................................................................... 26Adhesion, Phosphating and Rinsing ......................................................................................................................................................................... 29Adhesion ...................................................................................................................................................................................................................... 29Adhesion — Corrosion .............................................................................................................................................................................................. 31Adhesion — Contaminants ....................................................................................................................................................................................... 31P2-Options .................................................................................................................................................................................................................. 33Phosphating ................................................................................................................................................................................................................. 35Phosphating ................................................................................................................................................................................................................. 35Cleaning and Rinsing .................................................................................................................................................................................................. 37Pretreatment Processes ............................................................................................................................................................................................... 37Counter Current Rinsing ........................................................................................................................................................................................... 39Sealing after Phosphating ........................................................................................................................................................................................... 39Wash Primer ................................................................................................................................................................................................................ 41

Module 4: Spray Coating Pollution Prevention ............................................................................................................................................................... 42Conventional Spray ..................................................................................................................................................................................................... 49Spray Bounce-back ..................................................................................................................................................................................................... 49HVLP Spray ................................................................................................................................................................................................................. 51Airless Spray ................................................................................................................................................................................................................ 51Air-Assisted Airless ..................................................................................................................................................................................................... 53Electrostatic Spray ....................................................................................................................................................................................................... 53Electrostatic Spray ....................................................................................................................................................................................................... 55Expected Transfer Efficiency ...................................................................................................................................................................................... 55Transfer Efficiency ...................................................................................................................................................................................................... 57Transfer Efficiency ...................................................................................................................................................................................................... 57Transfer Efficiency ...................................................................................................................................................................................................... 59Financial Implications ................................................................................................................................................................................................ 59

Module 5: Liquid Coating Pollution Prevention ............................................................................................................................................................. 60Coating Composition Basics ...................................................................................................................................................................................... 61Resin Types .................................................................................................................................................................................................................. 61Pigments ...................................................................................................................................................................................................................... 63Coating Terms ............................................................................................................................................................................................................. 63Typical Coatings .......................................................................................................................................................................................................... 65Water-Borne vs High Solids Solvent Borne Coatings .............................................................................................................................................. 65Air/Force Dry Versus Bake ......................................................................................................................................................................................... 67Water & Solvent Borne Coatings ............................................................................................................................................................................... 67Comparing Systems .................................................................................................................................................................................................... 69

Module 6: Viscosity and Pollution Prevention ................................................................................................................................................................. 70Viscosity Control ......................................................................................................................................................................................................... 73Solvent Reduction & Viscosity ................................................................................................................................................................................... 73Solvents & Viscosity .................................................................................................................................................................................................... 75Viscosity and Temperature ......................................................................................................................................................................................... 75

Module 7: Regulatory Integration Activity ....................................................................................................................................................................... 76Module 8: Review Activity ................................................................................................................................................................................................. 88Module 9 Alternative Coating ........................................................................................................................................................................................... 90

Electrostatic Powder Coating ..................................................................................................................................................................................... 93Electrostatic Spray Gun .............................................................................................................................................................................................. 93Powder Fluidized Bed .................................................................................................................................................................................................. 95Supercritical CO

2......................................................................................................................................................................................................... 95

Supercritical CO2

......................................................................................................................................................................................................... 97Radiation Cured Coatings ........................................................................................................................................................................................... 97Ultraviolet Curing System ........................................................................................................................................................................................... 99Radiation-Cured Coatings .......................................................................................................................................................................................... 99

Module 10: Gun and Line Cleaning, Paint Stripping .................................................................................................................................................... 100Minimizing Gun & Line Cleaning ........................................................................................................................................................................... 101Minimizing Gun & Line Cleaning ........................................................................................................................................................................... 101Paint Stripping .......................................................................................................................................................................................................... 103

Module 11: Resource Review ........................................................................................................................................................................................... 118Module 12: Site Visit ......................................................................................................................................................................................................... 122Module 13: Closing and Evaluation ................................................................................................................................................................................ 126

Surface Coatings 3

Table of Contents

Module 1: Introductions/Expectations ..................................................................................................... 11

Module 2: Coating Process Introduction .................................................................................................. 17

Module 3: Surface Preparation and Pretreatment .................................................................................... 27

Module 4: Spray Coating Pollution Prevention ........................................................................................ 43

Module 5: Liquid Coating Pollution Prevention ...................................................................................... 61

Module 6: Viscosity and Pollution Prevention ......................................................................................... 71

Module 7: Regulatory Integration Activity ............................................................................................... 77

Module 8: Review Activity ......................................................................................................................... 88

Module 9 Alternative Coating ................................................................................................................... 91

Module 10: Gun and Line Cleaning, Paint Stripping ............................................................................. 101

Module 11: Resource Review ................................................................................................................... 119

Module 12: Site Visit ................................................................................................................................. 123

Module 13: Closing and Evaluation ........................................................................................................ 127

Instructor Notes



Icon legend

PAUSE Video

Start Video


STOP Video


EXERCISE

Nex

t…

Trainer needs to











OVERHEAD (no.)





FLIPCHART





ParticipantExercise




ParticipantHandout

HANDOUT or EXERCISE



Surface Coatings 5

Instructor Notes


Instructor Tools

A key to successful training is to involve attendees in the learning processthrough the use of interactive techniques. However, one can never getcompletely away from lecture — especially when delivering detailed technicalinformation. This training utilizes four tools to engage participants in thelearning process and increase retention of technical information presented vialecturettes and written materials. Each of these tools is discussed below.

Summarizing to Reinforce Learning

Summarizing content immediately following a lecturette can dramaticallyincrease retention and reinforce key concepts. In this training, we use asummarizing tool called the “10–2.” When using the “10–2,” the trainer lecturesfor approximately 10 minutes, and then instructs the participants to pair off for 2minutes to review the material. During the two minute review, participantspair off with each other to discuss a question that the trainer provides. It is VERYimportant that the trainer give the participants a good question — one thatstimulates an interesting discussion and serves as a review of the key conceptsjust presented. Participants should take turns answering the question for oneminute each. Following the two-minute discussion, the training continues. The“10–2” is used in Modules 3, 8, and 9 in this course.

Around the Clock Learning Partners.

In order to get participants into pairs, we use a tool called “Around the ClockLearning Partners.” At the onset of the training (during Module 1 in this training)participants make written appointments on a “clock” with other participants.

Activators

This training also makes use of Activators. Activators are brief activitiesscheduled prior to a reading or lecturette. The purpose of an activator is to helpparticipants learn new information by developing their interest and building ontheir current knowledge. Three specific activators are outlined in this trainingare:

1. “Things I Know, Think I Know, Want/Need to Know,” a small groupbrainstorming tool used in Module 3;

2. “Word Splash,” a large group brainstorming tool used in Module 4; and

3. “Carousel Brainstorming,” designed to get small groups to examine anumber of questions and build on one another’s ideas. This tool is used inModule 6.


Surface Coatings 7

Surface Coatings

Instructional Goals

1. Participants will be able to identify and describe metal surface coating options.

2. Participants will be better able to identify opportunities for facilities to imple-ment alternative metal surface coating technologies

3. Participants will be more inclined to work metal surface coating technologiesinto their interactions with facility personnel (i.e., during permitting review,compliance inspections, and enforcement actions).


1. Participants will be able to ask specific and clarifying questions during aninspection, permit review, or enforcement action. These questions will helpmake the facility aware of opportunities to implement alternative metal surfacecoating technologies.

2. Participants should increase the frequency with which they bring alternativemetal surface coating options to industry’s attention.

3. Participants will be able to describe basic metal surface coating processes andP2 options.

Surface Coatings

Instructor Notes


Overhead Numbering System

Overheads are numbered in sequential order. Overhead I–1 stands for Instructornotes, overhead number one.

Written Resources

Several written reports and publications were used to prepare this training.Most of these documents are available at no or low cost to public agencies. Thefirst two documents on the list below were found to be especially helpful inpreparing the training and should be referenced by the trainer. Trainers maywant to consider making these publications available to participants at thetraining by ordering them in advance.

1. Pollution Prevention in the Paints and Coatings Industry. EPA/625/R-96/003

2. Pollution Prevention in Paints and Coatings Processes — A Manual forPollution Prevention Technical Assistance Providers. NEWMOA. Boston, MA1997

3. EPA Guide to Cleaner Technologies: Organic Coating Replacements. EPA/625/R-94/006

4. Pollution Prevention Tips. NC Pollution Prevention Program. 1993

5. Maine Paints and Coatings Technology Conference Resource Guide. 1995

6. Protective Coatings. Clive H. Hare. Technology Publishing Co. Pittsburgh, PA1994

Additional Instructor Notes

Get Spray Guns

The trainer should try to get spray guns to display during the training. Spray gunmanufacturers and distributors may have sample spray guns, non-spec guns, orunreparable guns that the trainer can borrow for this purpose.

Table Arrangement

Participants should sit at tables in groups of five orsix. Circular tables work well for these groups.Rectangular tables should be arranged in a chevronshape with the speaker at the front.

6' x 3'

X

X XX

XX

X

XXX

XX

X

X XX

XX

X

XXX

XX

X

X XX

XX

X

XXX

XX


Surface Coatings 9

Written Resources

Several written reports and publications were used to prepare this training. Most ofthese documents are available at no or low cost to public agencies.

1. Pollution Prevention in the Paints and Coatings Industry. EPA/625/R-96/003

2. Pollution Prevention in Paints and Coatings Processes — A Manual for Pollu-tion Prevention Technical Assistance Providers. NEWMOA. Boston, MA 1997

3. EPA Guide to Cleaner Technologies: Organic Coating Replacements. EPA/625/R-94/006

4. Pollution Prevention Tips. NC Pollution Prevention Program. 1993

5. Maine Paints and Coatings Technology Conference Resource Guide. 1995

6. Protective Coatings. Clive H. Hare. Technology Publishing Co. Pittsburgh, PA1994

To order copies of these materials, contact Janet Clark at www.turi.org.

Instructor Notes


Module 1 Introductions/Expectations

1. INTRODUCTION: The trainer begins by introducing himself/

herself and discussing the purpose of the training and its

content (in general terms).

2. Flipchart: The trainer next asks participants to state their

names, affiliations, what reactions they have gotten when

recommending P2 in their regulatory roles (in general and

specifically in paint and coating operations), and what they

hope to learn during the course. As participants are discussing

their experiences, the trainer should take notes on a flipchart.

3. AGENDA: The trainer should review the agenda on overhead 1

and refer to the flipchart notes. The trainer should highlight

the areas the training will cover while referring to the topics

listed on the flipchart. The trainer can review the wealth of

experience in the room and point out that participants can

expect to benefit from the knowledge of their colleagues.

Nex

t…





Surface Coatings 11

Module 1

Agenda

Day 1

Module 1 Introductions/Expectations

Module 2 Coating Process Introduction

Module 3 Surface Preparation and Pretreatment

Module 4 Spray Coating Pollution Prevention

Module 5 Liquid Coating Pollution Prevention

Module 6 Viscosity & Pollution Prevention

Module 7 Regulatory Integration Activity

Module 8 Review Activity

Module 9 Alternative Coating

Module 10 Gun and Line Cleaning, Paint Stripping

Module 11 Resource Review

Module 12 Site visit

Module 13 Closing and Evaluation

Introductions/Expectations

Instructor Notes


Training Agenda

Day 1 Approximate Time

Module 1 Introductions/Expectations 20 minutes

Module 2 Coating Process Introduction 50 minutes

Module 3 Surface Preparation and Pretreatment 40 minutes

Module 4 Spray Coating Pollution Prevention 75 minutes

Module 5 Liquid Coating Pollution Prevention 45 minutes

Module 6 Viscosity & Pollution Prevention 30 minutes

Module 7 Regulatory Integration Activity 90 minutes

Plus Delta on Day 1 10 minutes

Total 6 hours

Day 2

Module 8 Review Activity 15 minutes

Module 9 Alternative Coatings 40 minutes

Module 10 Gun Cleaning & Paint Stripping 40 minutes

Module 11 Resource Review 20 minutes

Module 12 Site Visit Preparation 15 minutes

Site Visit 2.5 hours

Site Visit Debriefing 20 minutes

Evaluation 15 minutes

Total 5 hours

Module 1


Surface Coatings 13

Agenda

Day 2


Module 9 Alternative Coatings

Module 10 Gun Cleaning & Paint Stripping


Module 12 Site Visit Preparation

Site Visit

Site Visit Debriefing

Evaluation

Module 1

Instructor Notes


4. Small group exercise: The trainer refers to the learning clock

on the opposite page and asks participants to make

appointments on their clock. Participants are instructed to

make an appointment with 12 different people — one for each

hour of the clock. Participants should be sure they both record

the appointment on the clocks. Make an appointment only if

there is an open slot at that hour on both of your clocks.

Around the Clock Learning Partners

In order to get participants into pairs, we use a tool called

“Around the Clock Learning Partners.” At the onset of the

training (during Module 1 in this training) participants make

written appointments on a “clock” with other participants until

all twelve hours on the clock are scheduled. The trainer

instructs participants to schedule a different person for each

hour, and reminds participants that they should both record

the appointment on their clocks. At various points in the

training — typically following a lecturette of approximately

ten minutes — the trainer directs the participants to “stand up

and find their one o’clock partner.” (After the next 10-minute

lecturette they get together with their two o’clock partner, and

so on.) The trainer gives a specific question for the participants

to discuss with their partner during the two-minute period.

Following the two-minute discussion, the participants return

to their seats.

Module 1


Surface Coatings 15

Around the Clock Learning Partners

Make an appointment with 12 different people — one for each hour on the clock. Besure you both record the appointments at the same time on your clock. Only makethe appointments if there is an open slot at that hour on both of your clocks.

12

6

9 3

210

8 4

111

7 5

12:00

11:00 1:00

10:00 2:00

9:00 3:00

8:00 4:00

7:00 5:00

6:00

Module 1

Instructor Notes


Module 2 Coating Process Introduction

Section 1 Overview of Coating Processes

The trainer should explain that he/she is going to review the

myriad of different coatings, application methods, and curing

processes.

1. LARGE GROUP DISCUSSION: Display Overhead 1 and discuss

the simplified coating process flow diagram and review the

steps in the diagram. Ask participants the following questions:

1. What kinds of substrates are coated?

(Answers include metal, wood, plastic, paper, and fabric.)

2. What are the chief types of coatings used to coat metal

surfaces?

(Typical answers will include conventional, high solids, water

borne, powder, UV-curable, two-part or plural coatings, etc.)

2. LARGE GROUP DISCUSSION: Display Overhead 2 and ask

participants to list application methods, curing systems, and

coating systems in a large group interactive format.

Ask the following questions and record responses on a

flipchart.

1. How are metal surfaces prepared for coating? The trainer

may want to group the responses on the flipchart into

several categories (Overhead I–1 (p. 19) lists possible

responses)

1. phosphating (including iron and zinc phosphating)

2. chemical cleaning/surface preparation:

a. solvents (e.g., semi-aqueous and chlorinated organic

solvents),

b. aqueous cleaners with and without mechanical action

such as ultra sonics

c. acidic cleaners












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Surface Coatings 17

The Coating Processoverhead 1

Surface prep. Application & Curing

Process support

Un-coatedproduct Coated product

• cleaning• stripping

• equip. cleaning• maintenance• inv. control

Process Stepsoverhead 2

Surface Pretreatment

Application Methods

Curing Methods

Process Support

Module 2

Preparation & Application Methodsoverhead I-1

Preparation Application

Coating Process Introduction

Instructor Notes


3. Non-chemical cleaning/surface preparation:

a. oxidizing, abrasion, tumbling, de-burring, sanding, CO2

blasting, steel shot, baking soda, corn starch, and

plastic media

2 What are different types of coating application methods?

(Overhead I–1 (p. 19) lists possible responses)

1. Spray, electrostatic, rolling, dipping, printing, powder

coating, curtain coating

3 What are different types of curing methods? (Overhead I–2

lists possible responses)

1. heat, air dry, UV, and chemical curing

4 What ancillary operations come into play? (process support)

(Overhead I–2 lists possible responses)

1. Cleaning: spray guns, lines, over-spray areas, spills, storage

areas

2. Misc.: inventory management, hydraulic oil waste, rags,

equipment maintenance

Optional: this discussion can be run as a small group discussion

followed by a report back from each group. However, small group

activities generally require more time than large group

discussions.

Module 2


Surface Coatings 19

Module 2



■ phosphatizing ■ spray

■ caustic cleaning ■ powder

■ acid cleaning ■ roll

■ thermal cleaning ■ flow

■ deburring ■ curtain

■ electrostatic

Curing & Process Supportoverhead I-2

Curing Methods Process Support

■ air dry ■ gun cleaning

■ baking oven ■ line cleaning

■ radiation (UV/IR) ■ maintenance

■ vapor-injection

■ two-component

Instructor Notes


3. LARGE GROUP DISCUSSION: Upon completing the discussion,

the trainer should review the process flow diagrams in

Overheads 3 and 4.

Overhead 3 covers priming and coating as a two stage

process. In this process, the incoming raw material is cleaned.

The cleaning removes contaminants that could undermine the

integrity of later processes (i.e., welding, painting, etc.). The

material is then primed, assembled, re-primed (if and where

necessary), and finally topcoated. In this process, the priming

and topcoating take place in two separate stages. Priming and

topcoating as a single stage process is possible when products

require little or no assembly before shipping. In a single stage

process, the painting operation is not interrupted for assembly

between priming and topcoating.

Overhead 4 reviews surface preparation processes, specifically

phosphating and conversion coating. Iron phosphating is

usually a three step process. Enhanced corrosion protection is

provided by a five step process, especially when using zinc

phosphate. Pieces can either be immersed or sprayed

depending on their size. For aluminum applications, chromate

oxide formulations are used to apply conversion coatings,

although non-chromate formulations can be used.

Module 2








Surface Coatings 21

Module 2

Two-Stage Primer Topcoat Systemoverhead 3

Welding and Fabrication

steam cleaning incoming rawmaterial

dry-off ovenmetal pretreatment priming spraybooth

curing oven

curing ovencuring ovenprepping area

vapor degreasing

assembly area

Pretreatment Processesoverhead 4

C. Schematic of typical conversion coating process for aluminum work pieces.

A. Schematic of three-stage iron phosphating process.

B. Schematic of five-stage iron or zinc phosphating process.

degrease (hot)

1

water rinse(ambient)

2

deoxide(120°F)

3


4

chromate ornonchromat

conversion coating

5


6

seal rinse(ambient)

7

degrease (hot)

1


2

iron or zincphosphate (hot)

3


4

seal rinse(ambient)

5

degrease/ironphosphate (hot)

1


2

seal rinse(ambient)

3

Instructor Notes


Section 2 Coating Processes Input-Output Process

1. SMALL GROUP EXERCISE: The trainer should display

Overhead 5 and explain that participants are to work in small

groups preparing a coatings input-output analysis. The trainer

should instruct participants to do three things in their small

groups:

1. choose a particular process for coating metal, although they

can choose other processes such as continuous roll coating

of paper

2. perform an input-output analysis on the process, and

3. list the various regulations (federal and state) that impact

coating processes.

The trainer should write the following directions on a flipchart:

1. Purpose: To identify the inputs, outputs, and losses in the

process. Identify the regulations that affect the coating

process.

2. Definitions:

1. Input — any raw materials that go into the process (e.g.,

sheet metal, solvents, paints, energy, etc.)

2. Output — The end products of the process.

3. Losses — any waste material, by-products, or other

emissions.

3. Directions:

1. study the process flow diagram,

2. list inputs on the diagram (see Overhead 6),

3. list outputs on the diagram, and

4. list the losses on the diagram.

Module 2








Surface Coatings 23

Module 2

Process Input-Output Analysisoverhead 5

Process Inputs Process Outputs Process Losses

SurfacePreparation

Application andCuring

ProcessSupport

Input-Output Analysis

1. Purpose: To identify the inputs, outputs, and losses in the process. Identify theregulations that affect the coating process.

2. Definitions:■ Input — any raw materials that go into the process (e.g., sheet metal, solvents,

paints, energy, etc.)■ Output — The end products of the process.■ Losses — any waste material, by-products, or other emissions.

3. Directions:■ Study the process flow diagram,■ List inputs on the diagram (see Overhead 6),■ List outputs on the diagram, and■ List the losses on the diagram.

Instructor Notes


5. after the input-output analysis, list all applicable fed/state

regulations, and

6. discuss which regulations have the greatest potential

impact on P2 in the process you have chosen

The trainer should proceed around the room and check the

small groups to see whether the groups are discussing the

assigned topic and that all group members are getting a

chance to speak, etc.

When the groups have completed the input-output analysis

and listed the main federal and state regulations, the trainer

should reconvene the training and ask participants to debrief

their small group discussions.

■ The debriefing should first discuss the input-output process —

the trainer may fill in Overhead 5 with an overhead marker or

record responses on a flipchart.

■ The trainer may choose to display Overhead 6 and fill it in with

an overhead marker or record responses on a flipchart. The

trainer should mention that regulations play a large role in a

firm’s decision to make pollution prevention changes and that

these issues will be explored in greater detail in subsequent

parts of the training.

Module 2



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Surface Coatings 25

Module 2

Coating Process Regulationoverhead 6

■ CAA

■ OSHA

■ RCRA

■ CWA

■ Other

Instructor Notes


Module 3 Surface Preparation and Pretreatment

1. ACTIVATOR ACTIVITY

As a large group, participants should list what “They Know,

Think they Know, and Need or Want to Know” (see below for

more information about this activator) about the following

questions and record answers on a flipchart:

■ What affects coating adhesion?

■ How do coatings protect against corrosion?

■ What is phosphating and how does it work?

■ What are the typical P2 options in the cleaning and rinsing

operations that occur prior to coating?

During the brainstorming phase, emphasis should be placed

on getting lots of ideas rather than debating or discussing the

ideas as they are generated. Debate, clarification, and

discussion of ideas should occur once the brainstorming phase

is over. Following the activity, the trainer can review the

questions and present the brainstorming ideas, or proceed to

the following lecturettes followed by a large group review of

the material.

Instructor Tool: Under this first activator, “Things I Know, Think I Know, Want/

Need to Know”, participants brainstorm in small groups for five

minutes on all the things they know, think they know, and want or

need to know about the topic they will be studying. A paper with

three headings — “know,” “think I know,” and “want/need to know”

— should be prepared to record the responses. The responses can

be presented to the larger audience in one of two formats. Each

group can prepare its responses on a piece of flipchart paper and

present the results to the larger group. Alternatively, the groups

can prepare their answers on regular paper and the trainer, in a

large group format, can solicit the results from each group and

write them on a flipchart at the front of the room.








Surface Coatings 27

Module 3

Group Activity

I know:

I think I know:

I want/need to know:

Instructor Notes


2. LECTURETTE: Overheads 7 through 11

Explain and discuss surface preparation and adhesion using

Overheads 7 through 11 in Module Three. A brief summary of

surface preparation follows. (For more detailed information,

see the Surface Preparation section of the resource package.)

Overhead 7 is an overview overhead to introduce the module.

The trainer should mention that good coating adhesion

reduces rework and recoating requirements therefore

reducing chemical use and waste generation. Good adhesion

depends upon proper cleaning of the substrate and

phosphatizing of metal substrates. Proper cleaning promotes

coating-substrate adhesion and removes grease, scale, and

welding byproducts. Phosphating provides cathodic

protection against corrosion and a surface for the coating to

adhere to.

Overhead 8 reviews the major threats to adhesion —

corrosion on metal substrates and mold releases on plastic

substrates. The Right-First-Time concept should be

emphasized as well. Under this concept, firms can avoid many

costs while reducing waste generation.







Module 3


Surface Coatings 29

Adhesion, Phosphating and Rinsingoverhead 7

Adhesion

■ prevents corrosion and coating failure

Cleaning

■ promotes coating-substrate adhesion

■ removes oil, grease, scale, welding byproducts, etc.

Phosphating

■ cathodic protection against corrosion

■ surface for coating to adhere to

Adhesionoverhead 8

Adhesion Threats

■ metal: corrosion

■ plastics: mold releases (waxes & silicon)

Right-First-Time

■ avoidable costs: labor, materials, energy, time

■ reduce waste: strippers, coating, energy, etc.

rustmoistureoxygen

Module 3Surface Preparation and Pretreatment

Instructor Notes


Overhead 9 reviews the actual process of corrosion in greater

detail. The trainer should emphasize that corrosion occurs in

an electrolyte and is a reaction between iron ions and hydroxyl

groups (formed from the breakdown of water). Corrosion can

be prevented through the use of moisture and oxygen barriers,

good adhesion, and sacrificial or cathodic protection. For a

more detailed review of the corrosion process on metal

substrates, see “Chapter 3: Adhesion as a Critical Factor” in

Pollution Prevention in the Paints and Coatings Industry. EPA/

625/R-96/003 pp. 16–22.

Overhead 10 reviews the types of contaminants that reduce

adhesion. For metal substrates there are three main types of

contaminants: oil and grease, scale, and welding byproducts.

Oil and grease prevent wetting of the metal substrate by the

coating since the surface tension of the coating is greater than

the surface tension of oil and grease. As a result, the cohesive

forces of the coating tend to dominate over adhesive forces to

the substrate. The result is poor wetting (and poor adhesion).

Scale, which is a metal oxide, is a byproduct of metal forming

operations (i.e., forging or heat treating). The flaky film can act

as a cathode and therefore accelerate corrosion and cause

coating failure. Scale also may contain electrolytes, such as

acids or bases, that speed corrosion. Welding byproducts, such

as slag, also contain corrosive substances . Spatter, another

welding byproduct, tends to have an irregular profile that

protrudes through the coating. Lastly, the welding seam is

typically alkaline. Alkaline conditions accelerate corrosion (and

therefore coating failure).







Module 3


Surface Coatings 31

Module 3

Adhesion — Corrosionoverhead 9

Electrochemical Process

■ in electrolyte, iron dissolves (anodes) to form iron ions (Fe+)

■ electrons from iron react w/ H2O and O2 to form OH- (cathodes)

■ reaction between Fe3+ and OH- forms Rust (Fe2O3)

■ corrosion rate = f (difference in oxidation potential) e.g. Cu & Fe

Corrosion Prevention

■ C2 and moisture barriers

■ superior adhesion to restrict anode-

cathode flow

■ sacrificial or cathodic protection

anodearea

cathodearea

iron ions rust

Adhesion — Contaminantsoverhead 10

1. Oil & Grease

■ prevent wetting if surface tension of coating is > oil or grease

2. Scale (oxides)

■ flaky film, can act as a cathode, contains electrolytes (acid, base, etc.)

3. Welding Byproducts

■ slag: contain corrosive substances

■ spatters: irregular profile, may protrude

■ seam: alkaline

slag weld spatter

Instructor Notes


Overhead 11: A number of good business practices and P2

options can reduce the premature coating failure caused by

corrosion. They include proper material storage, such as low

humidity environments protected from rain. Protective

coatings (oils) may be applied to the metal substrates to

reduce corrosion. Such oils, typically applied by the metal stock

manufacturer, should be compatible with no-clean or aqueous

cleaning systems. Just-in-time delivery also reduces the chance

of corrosion in storage and offers many other benefits to the

facility.

SUMMARIZING Lecture on these overheads for approximately ten minutes

with 2 minutes after Overhead 11 for the summarizing exercise

“Around the Clock Learning Partners.” Ask the paired

partners to discuss the following question:

■ What affects adhesion and what can be done (in a P2 sense)

to prevent rejects (coating failure due to poor adhesion)?????




Module 3


Surface Coatings 33

Module 3

P2-Optionsoverhead 11

1. Material Storage

■ indoor storage prevents corrosion

2. Protective Coating

■ rolling oils, corrosion preventatives

■ compatible with simple cleaning steps

3. Just-in-Time Delivery

■ reduce chance of corrosion in storage

■ many other benefits

Instructor Notes


Overhead 13: Zinc phosphating offers better corrosion

protection than iron phosphating but has higher raw material

cost. Zinc phosphate produces a thicker film and the zinc offers

better sacrificial cathodic protection to the substrate when

compared to iron phosphate. Both processes must be pH and

temperature controlled to deliver sufficient film thickness.

3. LECTURETTE: Overheads 12 through 18

Explain and discuss phosphating and rinsing while referring to

Overheads 5 through 11. A brief summary of each overhead

follows. (For more information on phosphating and rinsing see

the Surface Preparation section of the resource package.)

Overhead 12: Phosphating increases coating adhesion by

reducing the likelihood of electrolytic corrosion or rust.

Phosphating provides a barrier to water and oxygen and also

helps restrict anode-cathode flow. There are two basic types of

phosphating solutions: zinc phosphate and iron phosphate.

While phosphating enhances corrosion protection, it reduces

cycle time (in terms of an extra step to the process) and

increases labor and chemical costs.







Module 3


Surface Coatings 35

Module 3

Phosphatingoverhead 12

Types: Purpose:■ iron phosphate “increase coating adhesion by■ zinc phosphate reducing electrolytic corrosion■ wash primers reaction”

Enhances Performance:barrier to oxygen & moisturedielectric film (insulator)rough surface for gripping

Tradeoffsa. adds costs — extra step, labor & chemicalsb. applicable to high value added partsc. not used on plastics


iron zinc comments

conc: 3 – 5% 3 – 5% range important

temp: 120 – 140; 90°F 120 – 140; 90°F deposition = f(temp)

pH (spray): 3 – 6 1.8 – 2.4 precipitation = f(pH)

pH (imm): 3–6 3.0

iron phosphate25-80 mg/ft2

zinc phosphate100-1,000 mg/ft2

■ immersion deposition■ spray deposition

Instructor Notes


Overhead 15: This overhead depicts typical phosphating

systems. The trainer should briefly review each schematic and

the function of each step in the process.

Overhead 14: One can reduce or eliminate the need to clean

metal parts by coating substrates with materials such as water-

soluble or phosphate-based anti-corrosion agents. Part design

often affects what chemicals must be used to clean metal parts

— for example small, tight geometry’s may require solvent

degreasing. Designing out these tight geometry’s often makes

aqueous cleaning an option. Cleaning the substrate prior to

phosphating is also important so that the phosphating bath

can leave a sufficiently thick deposit. Rinsing in all steps of the

coating process is critical to good coating adhesion and

reducing metal pH to minimize potential corrosion.







Module 3


Surface Coatings 37

Module 3

Cleaning and Rinsingoverhead 14

Reducing/eliminating the need to clean

■ compatible protective oils and coatings

■ redesigning parts

Cleaning prior to phosphating key

■ alkaline type, easily rinsed

Rinsing

■ reduce pH of metal prior to phosphatizing

■ minimize alkaline salts & grime contaminating phosphating bath

■ excess phosphates that effect primer





degrease (hot)

1


2

deoxide(120°F)

3


4


conversion coating

5


6

seal rinse(ambient)

7

degrease (hot)

1


2


3


4

seal rinse(ambient)

5


1


2

seal rinse(ambient)

3

Instructor Notes


Overhead 17: Facilities often immerse or spray sealers onto

metal substrates following phosphating operations. The sealers

act to harden the phosphate coating. Such sealers may be

chromate based or non-chromate based. The non-chromate

sealers are newer products and, from an environmental

standpoint, are more desirable than chromate sealers.

Overhead 16: This overhead reviews counter current rinsing.

Counter current rinsing can dramatically reduce water use

without sacrificing product cleanliness. The figure shows that

for a dilution ratio of 100:1, a three stage counter current rinse

reduces water use by ~95% . In this example, the dilution ratio

refers to a hypothetical case where 100 parts water are needed

to sufficiently dilute 1 part of solution (be it cleaner or

phosphating solution). With a one stage rinse system, one

would need 99 parts water to dilute the 1 part solution. A two

state system requires 9.5 parts water. A three part system

requires only 4.3 parts water. Counter current rinsing reduces

water use because the water is used several times in a single

rinsing operation.







Module 3


Surface Coatings 39

Module 3

Sealing after Phosphatingoverhead 17

Hardens the deposited phosphate coating

Chromate based (contains Cr 3+ and Cr6+)

■ fills phosphate voids

■ chemical reaction with base metal

■ rinsing and treatment often required

Non-chromate based (polymer sealer)

■ form a protective layer over exposed areas (no reaction)

■ post sealer rinse not required

Counter Current Rinsingoverhead 16

Counter current rates for parts with a 1 gal/min drag-in:

dilution ratio stage 1 stage 2 stage 3

100:1 99 9.5 4.3

degrease (hot)

1

CCR(ambient)

2


3

CCR(ambient)

4

di rinse(ambient)

5

process flow

counter current rinse flow

Instructor Notes


Overhead 18: An alternative to phosphating metal substrates

to increase adhesion is to apply wash primers. These wash

primers may be solvent-based solutions with 6.5 grams VOC

per liter of coating, or they may be water-borne with less than

3.5 grams VOC per liter of coating.

SUMMARIZING After Overhead 18, use 2 minutes with “Around the Clock

Learning Partners.” Ask the paired partners to discuss one of

the following questions:

■ What role does phosphating play in adhesion?

■ What are typical P2 approaches to the cleaning, rinsing, and

phosphating steps in a painting process?

????




Module 3


Surface Coatings 41

Module 3

Wash Primeroverhead 18

Alternative to phosphates

VOC’s 6.5g/l

■ ethyl alcohol or IPA

■ phosphoric acid

■ zinc chromate

■ water, pigments, resin

water-borne < 3.5 g/l

Instructor Notes


Module 4 Spray Coating Pollution Prevention

1. Introduction

The trainer should mention that the next part of the training

will concern spray coating application. To introduce the topic,

the class will view a spray painting video.

2. Video

Show Section 2 of the video “Wood Furniture Finishing” by

Graco. Section 2, which is titled “Fluid Handling and Finishing

Equipment,” will introduce the topic of spray coating. We chose

this video because it contains excellent demonstrations of

spray techniques and transfer efficiency. It also shows a typical

spray painting production environment. Although the video is

not specific to metal finishing, many of the techniques are the

same, and wood furniture finishing is frequently encountered

by regulatory personnel.


Surface Coatings 43

Video: “Wood Furniture Finishing” by Grace

Section 2

Air Spray Airless Spray Air Assisted Airless Spray

The three most common configurations for spraycoating systems.

A woman applying a surface coating using an airless spray configuration.

Module 4Spray Coating Pollution Prevention

Instructor Notes





Instructor Tool: The second activator used in this training is known as a “Word-

Splash.” A “Word-Splash” is a collection of key terms or

concepts selected from a reading or lecture that is about to be

presented. Selected terms are displayed at angles around the

main topic that is centered in large bold font in the middle of

the page. Participants are asked to brainstorm for two to five

minutes on how the terms relate to the main topic. Once the

ideas are generated, participants turn to the printed material

to check the accuracy of their statements and revise where

necessary.

On a flipchart, the trainer should write down the key terms

and phrases as they are mentioned and defined in the video.

These terms include:

transfer efficiency overspray tip size

fluid pressure air pressure heaters

atomization spray pattern bounceback

spray technique air lead/air lag electrostatic spray

Module 4


Surface Coatings 45

Close-up view of a spray application onto a cabinet.

A technician applies a surface coating to tables.

Module 4

Instructor Notes


The following three types of spray equipment mentioned in

the video should also be written down on the flipchart.

Electrostatic spray coating (a fourth type of spray coating

equipment) will probably come up later in discussion and

should be added to the list at that time.

conventional (airspray)

airless

air-assisted airless

(electrostatic)




Following the video, the trainer should review the definitions

of these terms or phrases with regard to their effect on

preventing pollution.

Module 4


Surface Coatings 47

Table being coated with an air assisted spray gun.

A technician applies a surface coating to furniture.

Module 4

Instructor Notes


Overhead 20: This overhead depicts how high air pressure in

conventional spray guns causes exploding and blasting at the

surface where the coating is applied. These effects cause

turbulence in the air and result in significant overspray and

coating migration in addition to bounceback from the

substrate.

3. Lecturette: Overheads 19 through 26

The trainer quickly reviews Overheads 19 through 26. (Training

notes: For more information on these overheads, see the article

“How Are Coatings Applied” by Carl Izzo in the resource

package.)

Overhead 19: This overhead reviews conventional spray guns.

Such guns use compressed air to atomize the coating at air

pressure ranges of 40 to 70 psi. Conventional spray systems

have many advantages including high production rates and

excellent atomization. However, such systems have extensive

overspray, high emission rates, and high booth clean-up costs.







Module 4


Surface Coatings 49

Module 4

Conventional Sprayoverhead 19

Compressed air atomized paint

Pressures range from 40 to 70 psi

Advantages

■ high production rates

■ excellent atomization — high quality finish

Disadvantages

■ extensive overspray

■ booth clean-up cost

■ filter clean-up cost

■ high VOC and HAP emissions

Spray Bounce-backoverhead 20

Exploding and blasting effects cause turbulence resulting in: overspray,

migration, bounceback

HVLPLVHP

Instructor Notes


Overhead 21: HVLP (high volume low pressure) spray guns are

designed to minimize the overspray, migration, and

bounceback effects that plague conventional systems. HVLP

guns spray well into recessed cavities, have lower VOC

emissions and paint waste, and are portable and easy to clean.

However, HVLP system cannot be used in every application

since they do not atomize coatings as well as conventional

systems. HVLP guns also spray at lower rates making their

application in high volume production operations difficult.

Overhead 22: Airless spray guns use high fluid pressure (500 to

6,500 psi) to atomize the coating (as opposed to using air

pressure to aid atomization). Airless spray has many

advantages including high rates of coating flow and high

transfer efficiency. However, airless spray offers relatively poor

atomization and increased hazard of skin injection as a result

of high fluid pressure.







Module 4


Surface Coatings 51

Module 4

HVLP Sprayoverhead 21

Compressed air atomizes paint @ 10 psi

Advantantages Disadvantages

■ sprays well in recesses/cavities ■ atomization unsufficient for

■ reduced paint waste fine finishes

■ lower booth clean-up costs ■ lower production rates

■ lower filter replacement costs

■ lower overspray, VOC, and HAPs

Airless Sprayoverhead 22

■ high fluid pressure (500 to 6,500 psi)

■ no pressurized air flow


■ high rates of paint flow ■ relatively poor atomization

■ relatively high transfer efficiency ■ expensive nozzles

■ gun handling versatility ■ reduced fan pattern control

■ can apply highly viscous fluids ■ tendency for tip plugging

■ skin injection danger

■ increased operating training

required

■ increased maintenance required

Instructor Notes


Overhead 24: In electrostatic spray, the atomized coating

droplets are charged at the gun tip. These charged particles are

attracted to the electrically grounded substrate coating.

Because of the electrostatic charge on the coating droplets,

transfer efficiency is relatively high. However, electrostatic

systems have high equipment and maintenance costs. In

addition, parts must be conductive in order to electrostatically

coat them.

Overhead 23: Air-assisted airless systems use a combination of

fluid pressure and compressed air to atomize the coating.

These systems offer very good atomization, excellent fluid

delivery and fan pattern control, and have high transfer

efficiency. However, such systems are capital intensive and

increase hazards due to skin injection as a result of high fluid

pressure.







Module 4


Surface Coatings 53

Module 4

Air-Assisted Airlessoverhead 23

■ ~150 to 800 psi of fluid pressure

■ 5 to 30 psi of compressed air


■ good atomization ■ capital cost

■ varied fluid delivery ■ skin injection danger

■ low bounceback ■ increased operating training

■ increased maintenance

Electrostatic Sprayoverhead 24

■ atomized paint droplets charged at gun tip

■ part electrically neutral


■ uniform film thickness ■ guns tend to be bulky

■ good wrap around and delicate

■ good edge cover ■ extra cleanliness essential

■ high transfer efficiency ■ faraday cage effect

■ safety/fire hazard

■ parts must be conductive

■ high equipment and

maintenance costs

Instructor Notes


Overhead 26 illustrates transfer efficiency ranges of different

coating systems. Note that actual transfer efficiency depends

not only on the type of system, but also on proper spray

technique and proper maintenance of the spray system.

SUMMARIZING Participants should pair up with “Around the Clock Learning

Partners” and discuss one of the following questions:

■ What are the physical operating differences between HVLP,

airless, air-assisted airless and electrostatic guns?

■ What are the advantages/disadvantages of HVLP versus

electrostatic air-assisted airless?

Overhead 25 illustrates the wrap around effect of electrostatic

spray.







Module 4


Surface Coatings 55

Module 4


Expected Transfer Efficiencyoverhead 26

Application Type vs Expected Transfer Efficiency (%)

30 40 50 60 70 80 90 100

Electrostatic, rotary

atomizer

Electrostatic, airless

Electrostatic, air atomized

HVLP

Air-assisted Airless

Conventional

Instructor Notes


4. Small Group Activity Using Overhead 27

Perform a “Word-Splash” on phrases relating to transfer

efficiency. (For more information on “Word-Splash” see

Instructor Tools section.)

■ In small groups, participants should discuss how the phrases

given relate to transfer efficiency — the topic of the article.

■ Participants then read sections 9.1.1 and 9.5.1 (on pages 74

and 81–83) of “Chapter 9: Transfer Efficiency as It Affects Air,

Water and Hazardous Waste Pollution” in Pollution Prevention

in the Paints and Coatings Industry. EPA/625/R-96/003

p. 16–22.

■ After reading, the small groups should discuss how the

article helps them to better understand the relationship

between the phrases and transfer efficiency.

■ The trainer then asks if there are any questions.


Lecture on these three overheads.

Overhead 28 explains how coating thickness affects transfer

efficiency. For example, in Part A of this overhead the coating

appears to be acceptable. However because the specified

coating thickness is half of what is delivered, the extra paint

delivered would represent a waste of fifty percent of the paint.

Transfer efficiency would then be only fifty percent.

In Part B, the donut shaped pattern means there is extra paint

being sprayed around the edges. In building the coating to the

specified thickness, about 25 percent of the paint is wasted in

the donut shaped pattern. In an even shaped fan pattern,

building the coating to the specified thickness would not







Module 4


Surface Coatings 57

Module 4

Transfer Efficiencyoverhead 27

leading edge50% overlap dry film

thickness

lagging edge

fluid flow rate

air pressurehook spacing

office size

spray angleemits VOC in

coating

fan width

distance to target

Transfer Efficiency


A. thickness of applied film

■ 1 mil film specified; 2 mil film delivered

■ transfer efficiency = 50%

B. spray pattern

■ fan-shaped pattern versus donut~

■ if 1 mil thickness specified ~ donut

wastes 25% of paint

C. electrostatic faraday effect

■ edges attract extra paint

■ limits paint in recessed areas therefore

— over painting non recessed area

— manual touch-up

Instructor Notes


require excess paint to be sprayed, since the coating would be

delivered evenly until it reached the specification.

In Part C, the Faraday Cage Effect is illustrated. The faraday

cages occur in electrostatic spraying. The charges tend to build

on corners and edges of pieces thereby attracting more paint.

Paint is also prevented from flowing past these areas into

recesses that need to be coated. Because these areas tend not

to be covered, manual touch up may be necessary. Extra paint

that builds on the edges also will lower transfer efficiency.

Overhead 29: This chart shows transfer efficiency as a function

of VOC emissions. The chart indicates that coatings that are

lower in solvents (which are emitted as VOC’s) tend to have

higher transfer efficiency. This is because more solids are

sprayed onto the part with a smaller percentage of the paint

(i.e., solvents) being wasted. In comparison, a conventional

coating that is high in solvent content, would have low transfer

efficiency as most of the coating is evaporated as VOC

emissions.

Overhead 30 shows the financial savings realized as a result of

an improvement in transfer efficiency. In this example, all

factors remain the same except transfer efficiency. (see

Appendix C of the EPA manual “Pollution Prevention in the

Paint and Coatings Industry” September, 1996) Improvements

in transfer efficiency of 15% are achievable and contribute

considerably to pollution prevention.

Hand out sections 9.1.1 and 9.5.1 (on pages 74 and 81–83) of

“Chapter 9: Transfer Efficiency as It Affects Air, Water and

Hazardous Waste Pollution” in Pollution Prevention in the Paints

and Coatings Industry. EPA/625/R-96/003.










ParticipantHandout

Module 4


Surface Coatings 59

Module 4


90.080.070.060.050.040.030.020.010.0

0.0200 40 60 80 100

VC

O E

mis

sion

s

(lb.

/1,0

00ft

2 coa

ted)

Transfer Efficiency

Financial Implicationsoverhead 30

Annual Savings by Improving TE from 30% – 45%

Costs w/ Costs w/ Savings Due toTE = 30% TE = 45% TE Improvement

Cost of waste $29,649 $15,530 $14,119filters + labor

Cost of wasted $73,101 $38,291 $34,810paint

Total cost of $102,750 $53,821 $48,929waste

Instructor Notes


Overhead 32 covers the first component—resins. Resins fall

into three types:

■ Lacquers (e.g., vinyls, acrylics, and chlorinated rubber) are

long chain polymers. These polymers entangle as the

material is applied and dries to form protective coating.

■ Dispersions (e.g., latex, vinyls, and acrylics) are polymers that

are encapsulated in micelles which chemically react and

dissipate upon coating application leaving behind an

interlaced protective coating.

■ Chemically curing (e.g., epoxies and urethanes) coatings

consist of short chain polymers that chemically combine

with the help of the addition of a catalyst. Such coatings

generally have superior physical and chemical properties

but are more expensive and difficult to apply.

Module 5 Liquid Coating Pollution Prevention


Present Overheads 1–6 in the 10–2 format.

Overhead 31 covers the four main components of a coating

which will be reviewed.Asdf fklkjas ss a dfkj s fdfk askd fd jkl; thj a jk jklkjuu fkd







Surface Coatings 61

Module 5

Coating Composition Basicsoverhead 31

Four main components

■ resins (also polymer or binder)

■ solvents

■ pigments

■ additives

Resin Typesoverhead 32

Lacquers

■ high molecular weight

■ long chains attract & entangle

■ highly viscous solution

■ e.g. vinyls, acrylics, & chlorinated rubber

Dispersions (also emulsions or oxidizing coatings)

■ high molecular weight in discrete micelles

■ combine when solvent (water) evaporates

■ low viscosity

■ e.g. latex; resins include vinyls & acrylics

Chemically Curing

■ low molecular weight polymers

■ produce large MW chains upon curing

■ e.g. epoxies and urethanes

Liquid Coating Pollution Prevention

Instructor Notes


Overhead 33: This overhead explains the third component of

coatings — pigments. A hiding pigment is one that provides

color and opacity to the coating. An extender pigment

provides neither color nor opacity but can control gloss, add

strength, or lower permeability. Extender pigments are usually

low cost and are used to adjust pigment for solvent volume.

Overhead 34: This is a list of common coating terms. For more

information on their meaning see the glossary in the resource

package. This overhead will be used for the summarizing

exercise in this module.

SUMMARIZING Participants should pair up with “Around the Clock Learning

Partners” and discuss define the coating terms in Overhead 34.

Following the summarizing activity, the trainer should ask if

there are terms whose definitions need further clarification or

definition.







Module 5


Surface Coatings 63

Module 5

Pigmentsoverhead 33

Hiding Pigment

■ e.g. TiO2, red iron oxide, chromium oxide

■ add color and opacity to the coating

■ other functions: corrosion and blistering resistance, fire retardancy, and UV

protection to improve weathering

Extender Pigments

■ e.g. talc, clay, barium sulfate

■ provide neither color nor opacity

■ may control gloss, add mech. strength, or lower permeability

■ low cost material — used to adjust pigment to solvent volume

Coating Termsoverhead 34

■ plasticizer

■ catalyst (drier)

■ wetting agents

■ dispersants

■ biocides

■ freeze-thaw stabilizers

■ coalescents (film forming aids)

■ flow and leveling agents

■ resin (vehicle, polymer, binder)

Instructor Notes


2. Small Group Exercise: In small groups of five or six,participants should fill out Overhead 36.

The overhead should be filled out from the viewpoint of a

company that is planning to make the switch from

conventional coatings to either water borne or high solids

coating. The trainer should instruct participants to discuss

which coating (water borne or high solids) has a relative

advantage over the other coating. The purpose of this exercise

is for the participants to understand the advantages and

disadvantages of the different coatings in the context of a

production process/pollution prevention decision that many

metal coating facilities must contend with. The trainer should

lead a facilitated discussion between the groups so that the

groups can arrive at the appropriate answers. Trainers should

refer to information on the advantages and disadvantages for

the two coating types in Tables 10–4 and 10–5 on pages 91–93

of the EPA Pollution Prevention in the Paints and Coatings

Industry. EPA/625/R-96/003.

Overhead 35 shows how solvent content varies by coating

type.







Module 5


Surface Coatings 65

Module 5

Typical Coatingsoverhead 35

100%90%80%70%60%50%40%30%20%10%

0%

legend

legend

legend

Water-borneEnamels

Water-borneSpray Coatings

Electro-Deposition

PowderCoatings

High Solids

Water-Borne vs High Solids Solvent Borne Coatingsoverhead 36

Aspect Water-borne High Solids Coatings

VOC Emissions

Drying Factors

Film Thickness

Safety Profile

Dip Coating

Appearance Defects

Application Flexibility

Surface Preparation

Viscosity Management

Electrostatic Application

Direction of Lower Solvent ContentSolid

Solvent

Water

Instructor Notes


4. Lecturette: Overheads 38 and 39 cover high solids andwater borne coatings. The differences between these twosystems are illustrated.

Overhead 38 Summarizes some of the main attributes of high

solids and water borne coatings. High solids coatings (which

are typically 50–70% solids by weight), result in lower VOC

emissions per gallon of solids applied. High solids coatings are

similar to low solids coatings in application, curing, and

performance — although they do tend to be higher in

viscosity. Water borne coatings typically have lower VOC

content than solvent coatings. However, water borne coatings

are by no means “solvent free” and my contain as much as 30%

solvent by volume.

3. After completing the Overhead 36 exercise, participantsshould be asked to perform the same type of analysis onOverhead 37.

The overhead should be filled out from the viewpoint of a

company has chosen its coating (i.e., water borne) and now

must decide they type of curing system to put in place (air

force/dry or bake). The trainer should instruct participants to

discuss which curing method (air force/dry or bake) has a

relative advantage over the other. The purpose of this exercise

is for participants to understand the advantages and

disadvantages of different curing methods in the context of a

production process/pollution prevention decision that many

metal coating facilities must contend with. Trainers should

refer to information on the advantages and disadvantages of

the air/force dry versus bake in Table 10–6 on pages 93 of the

EPA Pollution Prevention in the Paints and Coatings Industry. EPA/

625/R-96/003.







Module 5


Surface Coatings 67

Module 5

Air/Force Dry Versus Bakeoverhead 37

Aspect Air/Force Dry Bake

Substrate Versatility

RACT Regulations

Heating Requirements

Physical/Chemical Properties

Appearance Defects

Curing Times

Clean-up Requirements

Water & Solvent Borne Coatingsoverhead 38

High Solids Solvent Borne Coatings

■ lower MW polymers w/ additives to enhance x-linking

■ contain 2.3 to 3.5 lb VOC per gal

■ 50-70% solids

■ similar to low solids coatings in application, curing, and performance

■ higher viscosity

Water Borne Coatings

■ VOC content ~ 3.5 lb/gal less water

■ Contain organic co-solvent (2 to 30%) to dissolve the resin

Instructor Notes


Overhead 39 illustrates how coating solids and transfer

efficiency affect solvent emissions in a coating operation. The

example assumes that a “widget” requires a gallon of solids to

be sufficiently coated. Note that as percent solids in the

coating and transfer efficiency increase, the paint required to

cover the coating and solvent emissions decrease.




Instructor Tool: The third activator used in this training is known as “Carousel

Brainstorming.” “Carousel Brainstorming” is an innovative tool used to

help participants brainstorm what they already know about a topic

they are going to learn more about. “Carousel Brainstorming” will be

used next to explore “cutting,” or changing viscosity in coatings. (See

next small group activity.)

The directions for “Carousel Brainstorming” are as follows:

1. The trainer attaches paper to the walls around the room — one piece

of paper for each group. The trainer writes a question or topic on each

piece of paper.

2. Each group starts with a different colored marker and stands in front

of one of the questions.

3. Each group chooses a recorder to write their responses.

4. Quickly brainstorm responses to the posted question or topic

5. When the trainer gives the signal after 2 minutes, move one sheet to

your right. Brainstorm quickly and add to the material brainstormed

by the previous group (2 minutes).

6. At the signal, move to your right and repeat the process.

7. Continue until each group has brainstormed responses to all the

questions.

8. Optional last step: Each group ends up at the chart where they began

with a few minutes to:

■ look it over and see what developed after they left it;

■ group the ideas into categories, eliminating repeated ideas.

Module 5


Surface Coatings 69

Module 5

Comparing Systemsoverhead 39

Assume: 1 gal of solids required to cover widget

Coating Transfer Paint SolventSolids (%) Efficiency (%) Required Emissions

(gal) (gal)

100 30 3.33 0

50 30 6.66 3.33

50 70 2.85 1.43

75 70 1.9 0.95


Instructor NotesModule 6 Viscosity and Pollution Prevention

1. Small Group Exercise

Have participants brainstorm the following questions using

the “Carousel Brainstorming” technique described on the

previous page.

■ What effect does cutting (changing coating viscosity) have

on coating properties? (Too low a viscosity can make the

film insufficient to hide substrate, increase transparency,

increase runs and sags, and increase the likelihood of

premature corrosion.)

■ Why do firms cut coatings (change coating viscosity) prior

to application? (Firms cut coatings to save money by

decreasing paint use, improve atomization and ease of

application, decrease drying time, or impart certain

characteristics to the coating)

■ What materials do firms use to cut (change coating

viscosity) their coatings? (solvents—toluene, xylene,

acetone, MEK, MIBK, water) Do all materials effect viscosity

similarly? (No, they can effect viscosity differently because of

their different surface tensions, etc.)

■ How can a firm control viscosity without excessive cutting?

(Viscosity can also be controlled by applying heat, using a

diluent, adding air, stirring continuously, decreasing time

paint spends on the shelf, using a catalyst, etc.)

Surface Coatings 71

Participant ExerciseModule 6

What effect does cutting(changing coating viscosity)have on coating properties?

Why do firms cut coatings(change coating viscosity)prior to application?

What materials do firmsuse to cut (change coatingviscosity) their coatings?

How can a firm controlviscosity without excessivecutting?

Viscosity & Pollution Prevention

Instructor Notes



After the carousel brainstorming session, review and discuss

Overheads 40–43.

Overhead 40 reviews why controlling viscosity is important.

Reasons include controlling film thickness and hiding, runs and

sags, and coating atomization. The overhead also reviews how

viscosity is controlled. Firms measure viscosity using tools such

as a Zahn cup or viscometer. Viscosity is controlled by adding

solvents to the coating and controlling the temperature of the

coating and the spray booth.

Module 6

Overhead 41 shows a graph of viscosity vs. solvent reduction.

When using the same solvent to cut two different coatings, the

results can be very different. Adding solvent to Coating A

achieves a small reduction in viscosity. Adding the same

amount of solvent to Coating B achieves a much greater

viscosity reduction. If a paint sprayer used the same amount of

solvent for Coating B that s/he usually used for Coating A,

Coating B would be much too thin to use.








Surface Coatings 73

Module 6

Viscosity Controloverhead 40

Why Control Viscosity?

■ proper film thickness to control hiding

■ runs and sags

■ atomization/quality

How Do You Control Viscosity?

■ measure (Zahn cup, viscometer)

■ maintain constant booth and coating temperature

■ specify acceptable viscosity range

Solvent Reduction & Viscosityoverhead 41

Solvent reductions can affect different coatings differently.

Vis

cosi

ty

Reduction

Coating A

Coating B

Preferred Application Viscosity

Instructor Notes


Overhead 43 illustrates the effectiveness of temperature in

controlling viscosity. Increasing the temperature can achieve

the desired application viscosity. Using temperature increases

can help decrease the use of solvents in reducing viscosity. The

use of in-line heaters to reduce viscosity, lower VOC emissions,

and improve coating atomization is a pollution prevention

option for many spray painting operations.

Overhead 42 illustrates how different solvents can affect the

same coating differently. Using the proper solvent for a given

coating can help to reduce VOC emissions because it will take

less solvent to achieve the proper application viscosity.

However, some coatings do require the use of diluents to

achieve certain properties that are desirable in the coating.







Module 6


Surface Coatings 75

Module 6

Viscosity and Temperatureoverhead 43

Viscosity varies with temperature.

Vis

cosi

ty

Temperature

Application Viscosity

Coating A

Coating B

Initial Viscosity

Solvents & Viscosityoverhead 42

Vis

cosi

ty

Reduction

Diluent #1

Diluent #2

True Solvent

Instructor Notes


Module 7 Regulatory Integration Activity

1. Small Group Exercise: Handout: “Young Engineering”

The trainer will introduce attendees to the activity which

centers around a fictitious company called Young Engineering.

Detailed information on coatings and VOC emissions is

supplied to participants. In small groups of five or six

participants, review company data and determine how the

firm would be regulated. Participants will then discuss

methods for requiring/encouraging the facility to implement

P2. Following the small group exercises, participants will report

back to the entire group on their findings.

The next two Instructor pages provide solutions to the case

study.

■ Participants will break into small groups of 5–6 people.

■ Together, groups will review company data and determine

how the company would be regulated.

■ Participants will then discuss methods for requiring/

encouraging the facility to implement P2.

■ Following small group exercise, participants will report fact

findings to entire group.

Following , you’ll find a 5-page participant handout for the

case study.

Conclude the Activity with groups reporting their findings.

This concludes Day I of the training. Review the day with a brief

discussion of what worked, what could have been improved in

this training day.

Preview the next day’s agenda. Adjourn.




ParticipantHandout


Surface Coatings 77

Case Study

Young Engineering

The following five pages present a case study centered around a fictitious companynamed Young Engineering providing detailed information on coatings and VOCemissions.

Participants will break into small groups of 5–6 people.

■ Together, groups will review company data and determine how the companywould be regulated.

■ Participants will then discuss methods for requiring/encourging the facility toimplement P2.

■ Following the small group exercise, participants will report fact findings toentire group.

Module 7Regulatory Integration Activity


Instructor NotesInstructor Guide to Young Engineering

This section contains:

1. A completed input-output chart

Cleaning

solvent, rags, energy, wire brushsolvent emissions, rags,spent brushesSolvent hand-wipe,

wire brush cleaning

Surface Preparation (steel shelving only)

phosphate soln, energybatch dumps ofphosphate solutionDegrease/Iron Phosphate

(Hot)

water (5 gpm)phosphate solution,waterWater Rinse

(Ambient)

phosphate solution, chromate chromateSeal rinse(Ambient)

energy, air waste heatForce HotAir Dry

Coating Operation

coating (VOCs, HAPs, etc.)coating (VOCs, HAPs, etc.)reject parts

Primer Coating


Top Coat

Cleaning

methylene chloridemethylene chloride,striped paint

Paint Stripping Operation

xylenewaste xylene, xylene air emissionsGun, Line, and Booth

Cleaning

Module 7

Surface Coatings 79

Participant Handout

Case Study: Young Engineering

Introduction

Two weeks ago inspectors performed an inspection at Young Engineering located inSalem, Massachusetts. A file review on the company turned up air permits and a TitleV restriction on operations to keep the firm below a 50 ton major source threshold(known as an RES or Restricted Emissions Status). Upon their arrival, inspectorsfound the facility lacking in key record keeping information. During the inspection,inspectors took numerous notes and requested that the facility send plant operatingand coatings data to aid the Department in determining the standards and regulationsthe company must comply with.

Company Description

Young Engineering, fabricates and coats dumpsters, trash compactors, and othermiscellaneous metal components. The company was founded in 1981 when it pur-chased the operations of a sheet metal fabricator that had been fabricating and coatingmetal parts at the Salem location since 1973. Young Engineering employs 14 full timeemployees. Its standard industrial classification (SIC) code is 3490. Young Engineeringoperates its facility nine hours per day, five days per week, 51 weeks per year (totalhours per year = 2,295 hrs).

Process Description

Young Engineering manufactures and coats heavy gauge steel shelving, dumpsters, andtrash compactors. Its operations include:■ metal cutting, forming, and welding operations■ degreasing and cleaning■ wire-brush rust, scale, and grime removal■ cutting and forming operation■ coating (priming and top coating) in two large spray booths (openings are 18’x50’

and 12’x20’)■ paint stripping

The company uses three different process flows to make its products:

1. new dumpsters and compactors are fabricated from heavy gauge steel and coated(products are not phosphated);

2. old dumpsters and compactors are stripped and recoated (there is no fabricationstep and parts are not phosphated); and

3. heavy gauge steel shelves are fabricated, phosphated, and coated.

Module 7


Instructor Notes

2. A completed VOC Emissions Calculations table

Completed VOC Emission Calculations

MSDS Coating Used VOC type % VOC Coating Density lbs VOC/gal VOC VOC(gal) (lb/gal) solids applied (tons – actual) (tons – potential)

1 2,624 toluene, xylene 44.08% 7.99 7.94 4.6 17.6

2 2,421 toluene, xylene 58.85% 7.97 6.6 5.7 21.7

3 1,093 toluene, xylene 63.62% 8.34 6.9 2.9 11.1

4 652 toluene, xylene 55.96% 8.77 5.4 1.6 6.1

5 674 toluene, xylene 55.84% 9.2 4 1.7 6.6

6 1,829 toluene, xylene 56.84% 8.49 5.3 4.4 16.8

7 654 toluene, xylene 57.62% 8.3 8.5 1.6 6.0

8 275 toluene, xylene 48.25% 8.73 7 0.6 2.2

9 64 toluene, xylene 55.65% 8.47 5.3 0.2 0.6

10 1,277 toluene, xylene 57.20% 9.26 8.5 3.4 12.9

Cleaner 1,200 toluene, xylene, MEK 100.00% 7 na 4.2 16.0

Totals 30.8 117.6

3. A listing of possible P2 options

1. storing stuff inside, not outside2. better surface preparation:

■ how about media blasting?■ phosphoric wiping of welds■ phosphate the dumpsters and compactors? — need drying capability

3. better set up for phosphating process to go to zero discharge4. why not HVLP or at least air-assisted airless?5. what types of filters — we don’t have that data yet6. operator training7. water-borne coatings8. better viscosity control9. humidity control???10. gun cleaner or better procedures11. high solids coatings

4. A listing of possible ways regulatory staff could promote P2 at

Young Engineering

There are numerous methods for promoting P2 including regulatoryinspections and enforcement procedures.

Module 7

Surface Coatings 81

Participant Handout

Case Study: Young Engineering (cont’d)

Sheet metal steel is delivered and stored inside. Fabricated dumpsters and compactorswhich are to be recoated are delivered to Young Engineering and stored outside. Priorto coating, dumpsters and compactors are cleaned using a combination of wirebrushes, solvent rags, and hand rotary wire brushes. Product that is being recoatedrequires more effort than newly fabricated dumpsters and compactors. Surfacepreparation for steel shelving involves a three stage iron phosphating process on aconveyorized line that includes cleaning/phosphatizing, rinsing, sealing, and dryingsteps. Wastewater from the phosphating line is piped to an evaporator. Waste from theevaporator passes TCLP and is landfilled.

Dumpsters, compactors, and steel shelving are coated in one of the company’s twospray booths. Dumpsters and compactors are transported using a fork lift or dolly andsuspended using a hoist. Parts are then primer-coated using solvent borne coatingsapplied with airless spray guns. After the primer cures (~24 hours), the parts receive asolvent borne top coat using the same airless spray application equipment. Both theprimer and top coats air-dry without the aid of hot forced air or baking ovens.

Inspection Results

During a review of the process, the inspector noticed the following:■ there were no daily logs to tract coatings use or VOC emissions;■ there was no gun cleaning equipment observed, the inspector suspected the firm

simply sprayed xylene through the guns to clean them;■ there seemed to lots of rework for dumpsters and compactors that were coated

improperly, problems included orange peel and solvent popping;■ the company has no wastewater discharge;■ the company had proper air permits for their operation; and■ the company has a hazardous waste program that seems to be operating properly.

The facility manager also noted that its customers were complaining about corrosionproblems (especially near the welds but other places too) with the dumpsters andcompactors and that the company’s customers were complaining about quality andthe price of the units. The manager stated he was having a hard time keeping the pricecompetitive and that any DEP-forced changes that increase cost might put the com-pany out of business.

The company has no water discharge. Its NOx, SOx, CO, and PM-10 emissions haveall averaged under 1 ton per year for the last six years. Young’s RES places a 49 tonannual (12-month rolling) and 6.9 ton monthly cap on VOC emissions from thefacility. HAP emissions are limited to 24 tons per rolling 12-month period. In the RES,Young has restricted its use to only 3 HAPs (toluene, xylene, and MEK). However,emissions of any individual HAP is limited to 9.5 tons per rolling 12-month period.

Module 7



Surface Coatings 83

Participant Handout


VOC & HAP Data

To determine VOC emission rates, Young Engineering prepared a table listing eachcoating used at the facility, the amount used, and other relevant coating informationfrom the material safety data sheets (MSDS) (see Table 1 on following page). The tablecan be used to calculate actual and potential VOC emissions. To calculate VOC actualand potential emissions, the formulas below were used1.

Actual VOC (tons) = coating used (gal) * %VOC * coating density (lb/gal) *1/2000 (lb/ton)

Potential VOC (tons) = Actual VOC (tons) * 8,760 (hrs) ( 2,295 (hrs)

Your Tasks

1. Complete Process Analysis:■ Review the process flow diagram on the following page and fill in the portions

of the input-out analysis that are incomplete.

2. Regulatory Analysis:■ Complete the calculations in Table 1 and determine whether the facility must

comply with Reasonable Available Control Technology Standards. If so, is thecompany in compliance?

■ Determine what other, if any, environmental regulations Young Engineering islikely to have to comply with. What additional information do you need tomake this determination?

3. Pollution Prevention AnalysisYoung Engineering has many potential pollution prevention options available tothem. Use the following procedure to brainstorm possible options:

■ for each part of the process, identify material use and losses;■ in your group, brain storm possible ways to substitute materials, minimize

use, and prevent waste generation (please note that it is unlikely that YoungEngineering can use powder coatings for dumpsters and compactors give theirlow value);

■ prioritize the options your group came up with; and■ discuss how you in your role as a regulatory staff could promote P2 at Young

Engineering.

1 Actual operating hours = 9 hrs/day * 5 days/wk * 51 wks/yr = 2,296 hrs

Potential operating hours = 24 hrs/kay * 7 days/wk * 52 wks/yr = 8,760 hrs

Module 7



Surface Coatings 85

Participant Handout

MSDS Coating Used VOC type % VOC Coating Density lbs VOC/gal VOC VOC(gal) (lb/gal) solids applied (tons – actual) (tons – potential)

1 2,624 toluene, xylene 44.08% 7.99 7.94 4.6 17.6

2 2,421 toluene, xylene 58.85% 7.97

3 1,093 toluene, xylene 63.62% 8.34 6.9 2.9 11.1

4 652 toluene, xylene 55.96% 8.77 5.4 1.6 6.1

5 674 toluene, xylene 55.84% 9.2 4 1.7 6.6

6 1,829 toluene, xylene 56.84% 8.49 5.3 4.4 16.8

7 654 toluene, xylene 57.62% 8.3 8.5 1.6 6.0

8 275 toluene, xylene 48.25% 8.73

9 64 toluene, xylene 55.65% 8.47 5.3 0.2 0.6

10 1,277 toluene, xylene 57.20% 9.26 8.5 3.4 12.9

Cleaner 1,200 toluene, xylene, MEK 100.00% 7 na 4.2 16.0

Totals


Table 1: VOC Emission Calculations

Module 7



Surface Coatings 87

Participant Handout

Cleaning

solvent, rags, energy, wire brushsolvent emissions, rags,spent brushesSolvent hand-wipe,

wire brush cleaning

Surface Preparation (steel shelving only)

phosphate solution, energybatch dumps ofphosphate solutionDegrease/Iron Phosphate

(Hot)

water (5 gpm)phosphate solution,waterWater Rinse

(Ambient)

phosphate soln, chromate Seal rinse(Ambient)

energy, air Force HotAir Dry

Coating Operation


Primer Coating

coating (VOCs, HAPs, etc.)Top Coat

Cleaning

methylene chloridePaint Stripping Operation

xylene Gun, Line, and BoothCleaning


Module 7

Instructor Notes



Day 2 Training

1. Lecturette

Take ten minutes to briefly review what the topics of

discussion from the previous day.

2. Summarizing

During the two minute session, participants should go to their

around the clock partner and discuss two things they learned

yesterday, and two things they are unsure of. They should try to

gain more understanding of these topics with their partner.


Surface Coatings 89

Day Two

Surface Coating Training

This second part of Pollution Prevention in Surface Coating Training will begin

with a review of the first part.

1. What are two things I learned in the first day of training.

2. What are two things I am still unsure of?

Instructor Notes


Module 9 Alternative Coatings

1. Video: A 10 minute video, “Powder Coating — Technologyof the Future … Here Today,” will introduce participants tothis technology and the topic of alternative coatings.

2. Optional Small Group Exercise

In small groups of five or six, the participants should fill out the

table comparing liquid coatings to powder coatings using the

information about powder coatings from the video.


Surface Coatings 91

Powder vs. Liquid Coatings

Aspect Liquid Powder

Color Tinting, Changes Matching

Possible Substrates

VOCs and Haz Waste

Operator Training

Coating Performance

(thickness, durability, etc.)

Surface Preparation

Operating Cost

Floor Space

Curing Temperature

Module 9: Alternative Coatings

Instructor Notes


3. Lecturette

Overheads 44 through 51

Present Overheads 2–11 in a brief lecture.

Overhead 44: In electrostatic powder coating operations, the

substrate is unheated but must be electrically conductive. To

charge the powder, the operator uses a gun that contains a

high-voltage electrode. Upon pulling the gun trigger, the high

electrical potential around the electrode ionizes the

surrounding air, causing a corona. As powder particles leave

the gun and pass though the charged air, the electrostatic

charges transfer to the powder particles, which then become

attracted to the grounded part. The powder is then cured in a

convection oven at a temperature of 325F – 400F. The

electrostatic attraction between powder and substrate can be

mitigated by two factors: the faraday cage effect and air ions

entrapped in the coating.

Overhead 45: Tribocharged powder application guns have

plastic sheath on the inside that, due to friction, charges

powder particles as they exit the gun. When the particles leave

the gun, they seek the grounded substrate via electrical

attraction. The powder is then cured in a convection oven at a

temperature of 325F–400F.







Module 9


Surface Coatings 93

Module 9

Electrostatic Powder Coatingoverhead 44

Unheated substrate

Substrate or primer coat electrically conductive

High-voltage, low current (~100 kV)

Powder wraps on part — follows electric field lines

However:

■ Faraday Cage effect yields uneven powder coating

■ air ions can can become trapped

ground

Electrostatic Spray Gunoverhead 45

Tribocharging:

■ friction between powder and spray gun — electrostatic powder

■ substantially smaller electric field — reduced Faraday effect

■ smoother finish, thicker films possible, better coverage of intricate parts

charging electrode

part to be coated

powdersupply

high voltagesupply powder wrap around

Instructor Notes


Overhead 46 A fluidized bed coating system utilizes a tank

with a membrane at the bottom through which air is forced.

The air acts to suspend the powder in the tank in a cloud. The

preheated part (usually around 400F) is immersed into the

fluidized bed. Powder particles melt and stick upon contact

with the substrate. The powder is then cured in a convection

oven at a temperature of 325F–400F.

Overhead 47: A Super-critical CO2 system is designed to use

liquefied carbon dioxide as a solvent for coatings. The system

mixes the CO2 and a high solids coating in the spray gun,

producing excellent atomization. System advantages include

fewer VOC emissions (reductions of 50 to 80 percent) and

increased transfer efficiency, and less worker exposure. The

system however has high capital expense and requires training

of workers on spray techniques and system maintenance.







Module 9


Surface Coatings 95

Module 9

Powder Fluidized Bedoverhead 46

Fluid-like powder

Workpiece preheated to ~ 500F; powder melts upon contact

Used mainly for thermoplastic coatings (10–30 mils)

Electrostatic bed common also but limited to 2-D parts

air permeable membrane

part to be coated

fluidized powder

Supercritical CO2

overhead 47

Supercritical CO2 fluid replaces organic solvents

CO2 gas heated > 88F and compressed to ~1,100 psi

CO2 compatible with many resins, painting facilities and procedures

CoatingMaterial

CO2

part to be coatedmixing valve

spray gun

Instructor Notes


Overhead 48: Super-critical CO2 system advantages include

fewer VOC emissions (reductions of 50 to 80 percent),

increased transfer efficiency, and less worker exposure. The

system however has high capital expense and requires training

of workers on spray techniques and system maintenance.

Overhead 49: Radiation cured coatings cure when they are

exposed to specific wavelengths of ultraviolet (UV) or electron

beam (EB) radiation. Their VOC emissions are very low,

approaching zero for some formulations. Since UV radiation is

low energy, the polymers of UV curable coatings contain

special photo-initiators to promote polymer cross-linking. EB

coatings differ from UV coatings in that EB delivers high

energy — therefore polymers can cross-link without the need

for photo-initiators. UV cured coatings are used in the paints

and coatings industry more often than EB coatings (which

tend to be used in applications such as the manufacture of

printing inks).







Module 9


Surface Coatings 97

Module 9

Supercritical CO2

overhead 48

CO2 replaces solvents used to spray-apply coatings


■ reduced VOC and HAP emissions ■ limited experience

■ thick coatings ■ royalty costs

■ reduced toxicity and odor ■ bulky gun and supply tubing

■ reduced hazardous waste ■ lower fluid delivery rates

■ high transfer efficiency

■ easy clean-up

Radiation Cured Coatingsoverhead 49

Coating sprayed on the object

Object subject to UV or EB radiation

Curing takes place almost instantaneously

Instructor Notes


Overhead 51: There are numerous environmental (VOC and

energy) advantages of UV curable coatings over conventional

coatings. Safety is a major concern with the coatings since the

vapors from the coating application process can be hazardous.

Overhead 50: UV cured coatings are typically spray applied on

flat substrates. Parts then pass within a few inches of a UV

radiation source (typically mercury arc lamp). This explains why

the substrate must have a very simple geometry — such as a

flat or uniformly round shape. Most UV coatings are clean in

nature and are applied as over varnishes on beverage cans,

lipstick containers, etc. Adding color pigments to the

formulation retards curing and extends curing time.







Module 9


Surface Coatings 99

Module 9

Ultraviolet Curing Systemoverhead 50

UV Radiation Source

Air Ventilation

UV Curing Paints Wood Panels onConveyor Belt

ConveyorMotion

Radiation-Cured Coatingsoverhead 51


■ virtually no VOC or HAP emissions ■ limited to flat or cylindrical

■ good stain and abrasion resistance materials

■ reduced toxicity and odor ■ polymers can cause skin

■ low temp, small ovens required irritation

■ reduced fire hazard ■ high raw material costs

■ increased production rates ■ no FDA approval for food

■ low energy costs (24x acrylic resin) products

■ limited use in high-build

applications

■ shrinkage and adhesion problems

Instructor Notes


Module 10 Gun and Line Cleaning, Paint Stripping


Review and discuss the overheads on gun cleaning.

Overhead 52: HVLP guns can be cleaned using the following

procedure. First, turn down the fluid pressure but leave the

valve open. Next, set the gun air pressure at ~40 psi. Then cover

the gun orifice with a cloth. Pull the trigger. The air will push

the fluid back into the reservoir. Finally, flush the line with a

small amount of solvent into a grounded drum. Note: This

procedure should not be used on airless or air assisted airless

guns.

Overhead 53: Other methods to minimize waste and solvent in

gun cleaning operations include the use of enclosed gun

cleaning systems and the use of disposable plastic covers over

guns to keep coatings from curing while the gun is not in use

(i.e., during shift breaks or overnight). Proper scheduling can

also prevent P2. Such scheduling includes running light colors

at the start of a shift, followed by darker colors (less cleaning is

required when running a darker color after a lighter color than

vice versa). Other scheduling methods include making the

end-of-day clean-up coincide with the end of a job and

scheduling jobs with similar colors consecutively.








Surface Coatings 101

Module 10

Minimizing Gun & Line Cleaningoverhead 52

HVLP Guns (not airless or air assisted airless)

■ turn down fluid pressure but leave valve open

■ set gun air pressure ~40 psi

■ cover orifice with cloth & pull trigger

■ air pushes fluid back into reservoir

■ flush line with small amount of solvent into grounded drum

Airless & Air-assisted Airless

■ close air compressor valve

■ remove fluid orifice carefully

■ flush air & fluid lines with solvent into grounded drum


Enclosed gun cleaners

Disposable plastic covers

Scheduling

■ light to dark colors

■ end-of-day clean-up coincide w/ end of job

■ jobs with similar colors

Gun and Line Cleaning, Paint Stripping

Instructor Notes


2. Small Group Activity: Paint Striping

The trainer should start this activity by displaying Overhead 54

and explaining that there are a host of new paint stripping

technologies that have come on the market in the last few

years. The new technologies are environmentally preferable to

traditional solvent stripping. These methods include:

■ Impaction Methods (plastic media, wheat starch, and water

blasting)

■ Thermal Methods (burn-off and molten salt bath)

■ Abrasion Methods (baking soda blasting)

■ Cryogenic Methods (CO2 pellets and liquid N

2 blasting)

The trainer should briefly review these technologies in

preparation for the small group activity. Following the review,

the trainer should write up on a flipchart the following terms:

■ steel/rack hooks

■ dumpsters

■ automotive paint for refinishing

■ plastic components

The trainer should explain that the groups will be given a brief

article that reviews the various “cleaner” paint stripping

technologies. The group should assign different persons to

read sections of the hand out (i.e., one person for each of the

four types of technologies). After reading the article, the group

should discuss which “cleaner” stripping technologies would

be suited to the substrates listed on the flipchart. For the sake

of clarity, the trainer may want to write these directions on

another sheet of flipchart paper so that participants can

review the directions and make sure they understand them.

Module 10









Module 10

Paint Strippingoverhead 54

Impaction Methods Thermal Methods

■ Plastic media blasting ■ Burn-off

■ Wheat starch blasting ■ Molten salt bath stripping

■ High & medium pressure washing

Abrasion Methods Cryogenic Methods

■ Baking soda blasting ■ CO2 pellet blasting

■ Liquid N2 blasting

Instructor Notes


Next, the trainer should distribute Section 14.4 “Cleaner”

Technologies: Alternatives to Conventional Methods in

Pollution Prevention in the Paints and Coatings Industry. EPA/

625/R-96/003 pp. 142–146.

After the groups have read reviewed the article, the trainer

should ask the group: “Which technologies would appear to

work best on the different substrates?”

The chart below can be use as a guide for the instructor. The

instructor should encourage a larger group discussion:

“What are the relative benefits of the various technologies and

their application in a variety of paint stripping and substrate

cleaning operations?”

Substrate Technology

steel/rack hooks thermal, cryogenic, and

impaction

dumpsters impaction methods

automotive paint impaction and abrasion

for refinishing

methods

plastic components impaction methods

Participant Notes 1. Handout Section 14.4 “Cleaner” Technologies: Alternatives to

Conventional Methods in Pollution Prevention in the Paints and

Coatings Industry. EPA/625/R-96/003 pp. 142–146.




ParticipantHandout

????

????

Module 10



14.4 “Cleaner” Technologies: Alternatives toConventional Methods

This section briefly describes a selection of alternativepaint stripping approaches and lists their respectiveadvantages and potential drawbacks. Approaches arepresented according to their mechanism of action. Itis unlikely that any one of these approaches will offera broadly applicable means of stripping coatings inindustrial processes. Nonetheless, facility operatorsshould consider such cleaner technologies whendeveloping a strategy for minimizing pollutiongeneration. A number of newer approaches notcovered in this document also show promise forreducing process-related pollution in paint strippingoperations. Certain of these emerging technologies inparticular are promising and thus bear watching,including laser heating, flashlamp heating, and icecrystal blasting. (For information on these methods,see Refs. 1 and 2.)

14.4.1 Impaction Methods

14.4.1.1 Plastic Media Blasting

Plastic media blasting (PMB) is an impaction methodthat is capable of removing a coating without damag-ing the substrate of a delicate workpiece. The ap-proach involves projecting plastic media at aworkpiece’s surface either pneumatically with a hose-and-nozzle system (usually in manual operations) orcentrifugally from rotating wheels (in automatedoperations within a cabinet). After the coating hasbeen removed, the workpiece is vacuumed or sub-jected to high-pressure air to remove residual plasticdust. Because PMB is a completely dry process thatrelies on a nontoxic media to remove coatings, nowastewater or VOCs are generated.

In most applications, the plastic media are collectedand cleaned, using an air cyclone or vibrating screens,and then reused several times before being discarded.

Depending on the particular coating being removed,however, debris cleaned from the media may containhazardous metals or unreacted resins that requirespecial handling. In general, spent media are notrecyclable or biodegradable, although research isbeing conducted on beneficial approaches to manag-ing spent media.

The PMB approach has been widely used in both themilitary and commercial sectors. While PMB issufficiently sensitive to selectively remove individualcoating layers, with larger and harder media thisapproach also can be used to remove such resistantfinishes as polyurethane and epoxy coatings. ThePMB method is applicable for metal substrates as wellas plastic surfaces. PMB is used in the aerospaceindustry to remove coatings without damagingsensitive underlying substrates (e.g., the aluminumskins of aircraft).

Key advantages of the PMB approach include:

■ Minimizes pollution generation. Avoids generationof wastewater and VOCs.

■ Recyclability. If the correct plastic media isselected, they can be recycled up to 30 times.

■ High throughput. Can be effective at a highercoating removal rate than is possible using somesolvents.

■ Broad applicability. For example, it can be used onsteel, aluminum, plastic, fiberglass, glass, printedcircuit boards, and aluminum clad materials.

■ Sensitivity Avoids. Damaging substrates oraltering the dimensions of critical components;can remove individual coatings.

■ Limited masking required. Less than for otherconventional stripping processes, such as chemi-cal stripping or sand blasting.

“Cleaner” Technologies: Alternatives to Conventional Methods

from Pollution Prevention in the Paints and Coatings Industry. EPA/625/R-96/003. pp. 142–146.




Participant Handout

Principal limitations of the PMB approach include:

■ Conventional sand or grit blasting can be faster.

■ Less effective than other methods for cleaningprocess equipment with a heavy buildup ofcoatings.

■ Less effective than other methods for removingrust and corrosion from metals.

■ Larger and harder media can damage plastic andcomposite substrates.

■ Contaminants remaining in the recycled mediacan damage substrates.

■ Capital and startup costs can be higher than forconventional abrasive blasting.

14.4.1.2 Wheat Starch Blasting

Wheat starch blasting is an impaction method thatinvolves use of generally the same techniques andprocess equipment as PMB. The principal distinctionbetween these two methods is the blast media: Wheatstarch is even more gentle than plastic. Additionally,because wheat starch is 100 percent carbohydrate, thespent media is biodegradable. Using aerobic wastemanagement processes, the media can be digestedinto a liquid that can then be separated from thecoating debris. Also, wheat starch is a renewableagricultural resource that, for certain applications,can be used effectively in place of petroleum-basedmedia.

Although wheat starch is relatively soft, it can berecycled several times before the particles become toosmall to be effective. As the media breaks down, dust-like particles must be stripped from coarser particlesin the recycling process.

Wheat starch blasting is of interest primarily for itsgentle stripping action. Thus, application and testingof this method have been focused on sensitive sub-strates, such as thin aluminum (e.g., in the aircraftindustry) and fiberglass and certain plastics (e.g., inthe automotive industry).

Key advantages of the wheat starch blasting approachinclude:

■ Sensitivity. Avoids damaging substrates; recom-mended particularly for substrates such asaluminum, soft alloys, anodized surfaces, andcomposites.

■ Selectivity. Individual coatings can be removed(e.g., only the topcoat).

■ Minimizes pollution generation. Avoids generationof VOCs and excess wastewater.

■ Recyclability. If the correct plastic media isselected, they can be recycled up to 30 times.

■ Moderate throughput. Can be effective at amoderate coating removal rate.

■ Low-cost, biodegradable media. Wheat starch is aninexpensive, renewable resource; spent media canbe biodegraded from sludge.

Principal limitations of the wheat starch blastingapproach include:

■ Stripping action can be slow, depending oncoating hardness.

■ Media are sensitive to moisture and can requirethe addition of an air drying system in humidenvironments.

■ Removal of the media dust and paint chipsrequires a somewhat extensive media recoverysystem.

■ Dust generation can present an explosion poten-tial unless precautions are taken.

■ May not be appropriate for workpieces that areassemblies because media particles can becomeentrapped.

■ Less effective than other methods for cleaningprocess equipment because of the heavy buildupof coatings.

“Cleaner” Technologies cont’d

Module 10




Participant Handout

■ Less effective than other methods for removingrust and corrosion from metals.

■ Contaminants remaining in the recycled mediacan damage substrates.

14.4.1.3 High- and Medium-Pressure Water Blasting

Water blasting is a well-established impactionmethod for high-throughput surface cleaning that hasemerging applications for coating removal processes.This blasting approach involves subjecting workpiecesto jets of water delivered at sufficient pressure fromrotating nozzles to strip surface material without thebenefit of an abrasive media. For high-pressureblasting operations, water is pumped at a rate rangingfrom 15,000 to 30,000 psi. Medium-pressure blastingis performed with water jets operating in the range of3,000 to 15,000 psi.

This blasting approach generally avoids the genera-tion of VOCs and other air quality issues associatedwith some wet blasting media. For some operations,however, workpieces first undergo a presoak withalcohol or a similar inorganic solvent. Water used inblasting operations can be recycled after if has beenprocessed to remove debris.

In the automotive industry, medium-pressure waterblasting is used for stripping overspray coatings frompart support hooks used in water wall spray paintbooths. Also, a German airline has used this approachwith presoaking to strip aged coatings from planes.High-pressure water blasting is being developed bythe U.S. Air Force for paint stripping operations onlarge aircraft. (Ultra high-pressure water blasting-from 30,000 to 50,000 psi-reportedly has been usedselectively to remove resistant coatings in the auto-motive, aircraft, ship building, and nuclear industries[2J].)

Key advantages of the water blasting approachinclude:

■ High throughput. Can yield a high rate of coatingremoval.

■ Minimizes pollution generation. Avoids generationof VOCs, dust, and spent media; wastewater canbe treated in a conventional treatment system.

■ Recyclability. Water can be recycled after filteringout debris.

■ Low cost. Medium-pressure operations can havelow capital and operating costs.

■ Broad size applicability. No workpiece size restric-tions unless blasting cabinets are used; theprocess can be used indoors or outdoors and inmobile operations.

Principal limitations of the water blasting approachinclude:

■ Capital costs can be high if sophisticated systemsare used (i.e., high-pressure systems wouldtypically involve the use of robots).

■ High volumes of water are necessary.

■ A filtration system is required to recycle blastingwater.

■ Pressurized water jets can present a hazard toworkers.

14.4.2 Abrasion Method

14.4.2.1 Sodium Bicarbonate Wet Blasting

Sodium bicarbonate wet blasting is an abrasionmethod that is similar in many respects to wheatstarch blasting. The principal distinction is that theespecially fine media used for this method (bakingsoda) scours the surface, rather than breaking up thecoating by impaction. As with wheat starch blasting,this method is sufficiently gentle to remove coatingswithout damaging the substrate.

The media is delivered to the workpiece from a nozzlegenerally at low pressure with a wet blast system (i.e.,in water at from 20 to 70 psi, although the system candeliver the media at up to 500 psi). As with other wetblasting approaches, the use of water avoids possible

Module 10





Participant Handout

damage to the substrate from heat buildup and helpscontrol dust generated by shattering of the media.Typically, a water rinse step follows the blasting step.Although the media cannot be recycled, they can bedissolved, leaving the coating debris to be filtered outfor disposal.

Coatings can be removed by this method usingmodified sandblasting equipment. If the process isoperated indoors, an exhaust ventilation system witha cyclone separator and intake piping must be addedto control blast media overspray.

Sodium bicarbonate wet blasting has been used toremove both friable and elastomer organic coatingson sensitive workpieces, such as thin metal parts andmachinery. This method is effective on both metal,plastics, and wood.

Key advantages of the sodium bicarbonate wetblasting approach include:

■ Sensitivity. Avoids damaging substrates; recom-mended particularly for thin metals (e.g., alumi-num, anodized aircraft skins), plastics andcomposites, and wood; in particular, heat sensi-tive substrates can be stripped because the blastwater keeps the surface cool.

■ Selectivity. Individual coatings can be removed(e.g., only the topcoat).


■ Process efficiency. Because the media are notrecycled, the workpiece does not need to becleaned prior to blasting.

■ Moderate throughput. Can be effective at amoderate coating removal rate.

■ Low-cost media. Sodium bicarbonate is inexpen-sive; spent media can be dissolved from sludge.

Principal limitations of the sodium bicarbonate wetblasting approach include:

■ The media cannot be recycled.

■ Operator safety measures and equipment must beincluded in the process (e.g., an exhaust ventila-tion system).

■ Uninhibited sodium bicarbonate and waterresidue can corrode substrate.

■ May not be appropriate for areas where water isin short supply.

14.4.3 Thermal Methods

14.4.3.1 Burnoff

Burnoff is a thermal method that involves a combina-tion of volatilization, pyrolysis, and oxidation. Thismethod of paint stripping is both fast and especiallyeffective for resistant or accumulated coatings.Coating burnoff can be achieved using one of threemethods, each of which requires subjectingworkpieces to extremely high temperatures.

In direct burnoff, workpieces are passed through anoven in which high-temperature flue gas (1 ,000˚ to1,200˚F) ignites the coating. Workpieces then mightbe subjected to an afterburner step before undergoinga step for removing inorganic residues. Anotherburnoff approach involves direct heating in anabrasive fluidized bed, where the coating is thermallydegraded through pyrolysis and partial oxidation at atemperature of 900˚ to 950˚F. This approach requiresthe use of an after-burner to oxidize the intermediateorganic products. The third approach relies onpyrolysis to volatilize the coating. The organic fumesgenerated by this process are treated in an after-burner, which converts hydrocarbons to carbondioxide and water. Workpieces must then undergo astep for removal of inorganic residues. In the burnoffcoating removal process, afterburners are generallycapable of minimizing the generation of VOCs.

Other than monitoring, operation of a burnoffcoating removal line involves mechanical or manualloading of workpieces. Systems are typically auto-mated, however.

Module 10





Participant Handout

Burnoff is widely used to strip thick overspraybuildup from a variety of process equipment used inpaints and coatings operations. Burnoff technologymay be useful for removing coatings from workpiecesin certain operations, but limitations apply. Forexample, metals with a melting point below 900Fgenerally are not appropriate for this approach.

Key advantages of the burnoff approach include:

■ Performance. Effective for rapid removal of heavy,resistant coating deposits.


■ Applicable for a wide range of part sizes. Applicableto all shapes; limitations relate only to the size ofthe burnoff unit.

Principal limitations of the burnoff approach include:

■ Temperatures are too high for parts made ofplastics, composites, or metals with relatively lowmelting points (e.g., zinc-bearing materials).

■ Coatings that contain chlorinated compoundscan emit hydrochloric acid; when part surfacescool, hydrochloric acid together with atmo-spheric moisture can cause severe corrosion.

■ Products of incomplete combustion containingheavy metals or other compounds may begenerated, requiring disposal as a hazardouswaste.

■ Resulting gases can present risk of fire.

■ Abatement equipment (e.g., scrubbers or filters)may be required for offgas treatment.

14.4.3.2 Molten Salt Bath Stripping

Molten salt bath stripping is a process that, likeburnoff, is currently used primarily for fast removalof heavy coating deposits from process equipmentused in paints and coatings operations. The moltensalt process involves immersing parts (either inbaskets or suspended from hooks) into a heated bath

(from 5500 to 900˚F) containing inorganic salts (e.g.,sodium carbonate). The salt functions as a heattransfer medium, subjecting immersed parts touniformly high temperatures that result in chemicaloxidation of the coating. Carbon and hydrogen in thecoating are oxidized to carbon dioxide and water. Theexothermic reaction that occurs in the molten saltbath minimizes the loss of heat that might otherwiseresult from the immersion of cool parts. In general,metals from the coating pigments are retained in themolten salt bath, entering the offgas only in smallamounts.

After the reaction has ceased, parts are removed fromthe bath and allowed to cool. A thin coating of saltwill have formed on part surfaces and must beremoved.

This is accomplished by rinsing the parts in a tapwater bath at ambient temperature.

Along with sludge containing primarily metal salts,the process generates offgases and wastewater fromthe rinsing step. Thus, operators must make provi-sions for sludge disposal and include offgas abate-ment equipment and wastewater treatment in theirprocess line.

Molten salt bath stripping is used primarily forsupports and fixtures used in coating applicationlines. The approach is relatively fast (bath dwell timesrange from seconds to minutes) and particularlyeffective on heavy, resistant coatings. It can be used toremove a variety of organic coatings, including nylon,polyester, and epoxies.

Key advantages of the burnoff approach include:

■ Performance. Effective for rapid removal of heavy,resistant coating deposits.

■ Pollution prevention. No VOCs (or odors) aregenerated.

■ Applicable for a wide range of part sizes. Applicableto all shapes; limitations relate only to the size ofthe bath.

Module 10





Participant Handout

■ Not time-critical. If the metal substrate canwithstand immersion in the molten bath, thesubstrate will not be harmed by overexposure(e.g., applies to most steels and to aluminum).

■ Long bath life. Sludge must be removed, but thebath itself does not need to be dumped andreplenished.

■ Minimal treatment required for waste rinse water.After making minor pH adjustments with amineral acid, rinse water can be discharged;alternatively, because of its high pH, the watercan be used beneficially to neutralize wastewaterfrom other acidic operations (e.g., from an acidpickling or phosphating process).

Principal limitations of the molten salt bath approachinclude:

■ Generated sludge must be disposed of and rinsewastewater treated.

■ Abatement equipment (e.g., scrubbers or filters)is required for offgas treatment.

■ Temperatures are too high for parts made ofplastics, composites, or metals with relatively lowmelting points (e.g., some die-cast alloys).

■ Not appropriate for parts with sealed tubingbecause internal pressure buildup can cause tubeor weld failures and pose a threat of explosion.

■ Operator safety measures and equipment must beincluded in the process (e.g., a fume hood mustbe installed to remove smoke generated by theprocess).

14.4.4 Cryogenic Methods

14.4.4.1 Carbon Dioxide Pellet Blasting

Carbon dioxide (C02) pellet blasting is a cryogenicmethod capable of removing coatings from specifiedareas of a workpiece while minimizing the amount ofresidue left on the piece’s surface. The approachinvolves projecting dry ice pellets at a workpiece’s

surface (at from 75 to 1,000 ft/sec) from a nozzle. (Acentrifugal projection system is in. development.)

The equipment for this technology includes a systemfor converting refrigerated liquid C02 into thepelletized blasting media. The media remove coatingsby a combination of impact, embrittlement, thermalcontraction, and gas expansion. After the pellets strikethe workpiece surface, they revert to a gaseous state,both enhancing coating removal and avoidingsignificant residue buildup. After blasting, workpiecesare subjected to jets of air to remove coating frag-ments.

Because the approach can strip coatings selectively(i.e., specific areas of a workpiece as well as individualcoating layers), it has broad application for industriesprocessing sophisticated parts and components.Applications include the aerospace, automotive,electronics, and food processing industries. Forexample, this method can be used on surfaces nearmoving parts and on sensitive electronic pieces.

Key advantages of the C02 pellet cryogenic blastingapproach include:

■ Selectivity/sensitivity. Can be used on specificareas of a workpiece and to remove individualcoatings.

■ Process efficiency. Minimizes residue on workpiecesurfaces. Also, the need for masking is eithereliminated or reduced to a minimum.

■ Pollution prevention. Generates only smallamounts of solid waste; also avoids handling ofspent media and wastewater.

■ Broad applicability. Can be used on a variety ofsubstrates (e.g., steel, aluminum, printed circuitboards, fiberglass, plastics).

■ Minimized hazards. Uses a nonflammable,nonconductive blast media.

Principal limitations of the C02 pellet cryogenicblasting approach include:

Module 10





Participant Handout

■ Media cannot be recycled.

■ Process equipment is relatively expensive.

■ Throughput can be slow for workpieces withresistant coatings.

■ Condensation can occur on the workpiecesurface.

■ Safety equipment must be included in the process(e.g., a ventilation system for C02 gas).

14.4.4.2 Liquid Nitrogen Blasting

Liquid nitrogen cryogenic blasting is a variation ofthe PMB method that involves chilling the workpieceto embrittle the coating before subjecting it toimpaction with a plastic media. The piece is sprayedwith liquid nitrogen as it rotates on a spindle within acabinet, and then is blasted with the impactionmedia, which are projected into the cabinet by throwwheels.

After chilling the coating (to about -320˚F), the liquidnitrogen warms to ambient temperatures and evapo-rates into a gaseous form. This harmless gas can bevented to the atmosphere, leaving the media to becollected, separated from coating debris, and recycled.

The liquid nitrogen cryogenic blasting approach isused primarily to remove coating buildup fromcertain types of process equipment used in paints andcoatings operations (e.g., paint hangers, coating racks,floor gratings). Operations in the automotive andappliance industries have used this method withsuccess.

Key advantages of the liquid nitrogen cryogenicblasting approach include:

■ Minimizes pollution generation. Avoids generationof wastewater and VOCs; because the process isdry, no water is used.

■ Recyclability. If the correct plastic media isselected, they can be recycled numerous times.

■ High throughput. Can be effective at a relativelyhigh coating removal rate.

■ Low operating costs. Compressed air and electric-ity requirements are low.

Principal limitations of the liquid nitrogen cryogenicblasting approach include:

■ Capital and startup costs can be high.

■ Not appropriate for thin coatings and less effec-tive on epoxies and urethanes.

■ The stripping cabinet restricts the size of partsthat can be processed.

14.5 References

1. U.S. Environmental Protection Agency. 1993.Guide to Cleaner Technologies: Organic coatingRemoval. EPA/625/R-93/015. Cf-fice of Researchand Development, Cincinnati, OH (November).

2. U.S. Environmental Protection Agency. 1991.Reducing Risk in Paint Stripping: Proceeding ofan International Conference. Wash ington, DC,February 12–13. NTIS PB91-224-303. Office ofToxic Substances, Washington, DC.

Module 10


Instructor Notes



1. Lecturette

The trainer will briefly review the indexed reference section

that accompanies the training package. The reference section

contains case studies, articles and a glossary of key coating

terms. It is important for participants to quickly review the list

of articles as well as the index. By becoming familiar with the

reference section during the training, participants are more

likely to turn to it when searching for coatings related P2

information. Special reference should be made to the

government and non-profit research publications on P2 in

coatings located on page 6 of the reference section. The trainer

should recommend that participants obtain these documents

as they are typically free for government employees.

The trainer should also briefly review the internet as a

pollution prevention research tool. The handout on general

pollution prevention and coating bookmarks should be

handed out at this time. The trainer can also refer interested

participants to the ETI Internet Training, which is part of the

curriculum that includes this training.

Handouts: 1. Pollution Prevention Bookmarks

2. For a bibliography of paint and coating reports and

publications, contact Janet Clark at www.turi.org.



Pollution Prevention Bookmarks

Federal/International Government SitesEnvirosense — EPA’s Flagship P2 Site http://es.inel.gov

UNEP-IETC Homepage — UN’s Cleaner Production Site http://www.unep.or.jp/

EPA’s Pollution Prevention Homepage http://www.epa.gov/opptintr/p2home/

Manufacturing Extension Partnership Source http://www.mep.nist.gov/

Pacific Northwest Pollution

Prevention Resource Center http://pprc.org./pprc/index.html

Industrial Clean Production and

Environmental Management http://www.epic.net/CTEM/

EPIC Home Page — Department of Energy P2 Site http://146.138.5.107/EPIC.htm

University Sites

Univ. Michigan National P2 Center

for Higher Education http://www.umich.edu/~nppcpub/index.html

Technology, Business and Environment at MIT http://web.mit.edu/ctpid/www/tbe/

UC Berkeley CGDM Home Page http://euler.berkeley.edu/green/cgdm.html

UCLA CCT Home Page http://cct.seas.ucla.edu/

U.S. EPA Oil Spill Program http://www.epa.gov.oilspill/index.htm

Paper Coating SitesTAPPI http://www.tappi. org

Pulp & Paper Catalog Homepage http://www.pulp-paper.com

AET Home Page: Paper industry environmental consortium http://aet.org

PulpandPaper.Net Jumplist http://www.pulpandpaper.net/ppn.acgi$jumplist

Textile Coating Links

School of Textile & Fiber Engineering http://www.gatech.edu/textile/tfehome.html

NCSU College of Textiles Homepage http://www.tx.ncsu.edu

Textile Web http://www.textileweb.com

National Textile Center Home Page http://ntc.tx.ncsu.edu

Process/Sector-specific SitesPaint Coatings Net — Main Menu http://www.paintcoatings.net/pcnmain.htm

National Metal Finishing Resource Center Home Page http://www.nmfrc.org/

SAGE — Solvents Alternative Guide http://clean.rti.org/

CAGE — Coatings Alternative Guide http://clean.rti.org/cage

finishing.com http://www.intac.com/~finish/

Printers’ National Environmental

Assistance Center http://www.inhs.uiuc.edu/pneac/pneac.html

Wood Furniture and Fixtures Industry

Sector Notebook http://www.csa.com/routenet/epan/wdfurnsn.html

Powder Coating Net http://www.powdercoat.com

Printers’ National Environmental Assistance Center http://www.pneac.org

Module 11Resource Review

Instructor Notes


Module 11



State Government SitesIllinois Waste Management and

Research Center http://www.wmrc.uiuc.edu

Great Lakes Regional P2 Roundtable http://www.glrppr.uiuc.edu/wrmc/great1/index.html

Waste Reduction Resource Center

Home Page http://wrrc.p2pays.org

P2GEMS Home Page http://www.uml.edu/TURI/

Technical Assistance Resources for P2 http://www.epa.ohio.gov/opp/tarp/tarp.html

California Air Resources Board

Information System http://www.arb.ca.gov/homepage.htm

MA Toxics Use Reduction Institute http://turi.org

Search EnginesNorthernlight http://www.northernlight.com

Altavista http://www.digital.altavista.com

Excite http://www.excite.com

Yahoo http://www.yahoo.com

Module 11


Instructor NotesModule 12 Site Visit

1. Selecting a site visit candidate

When selecting a site visit candidate, the trainer should

consider whether the visit should focus on a company that has

made investments in pollution prevention technologies and

practices or on a company that has not made such

investments. Firms that have made P2 investments offer

participants an opportunity to observe new technology and

efficient work practices. Firms that have not made such

changes offer participants an opportunity to practice their

observation and communication skills (by observing P2

opportunities and communicating them to facility personnel).

2. Site Visit Preparation:

To prepare participants for the site visit, the trainer should

introduce the site visit by presenting the following:

■ the firm’s products, main processes, and experience with

pollution prevention;

■ any process flow diagrams or input-output analysis available

from the facility

■ what participants will be observing during the plant tour;

and

■ how to communicate P2 options observed during the tour

with facility staff.

3. Site Visit



Industry Process/Sector Training for Environmental Regulators

Surface Coating Site Visit Questionnaire

The goal of the site visit is to provide familiarity with and understanding of the operations of the typicalsurface coating shop.

Before Site Visit1. What do I expect to see at the surface coating

shop? (describe, e.g., employees, equipment, level ofknowledge re: agency, attitude, other)

After Site Visit1. What was different than what I expected?

2. Were any questions left unanswered?2. What questions will I want to get answers toduring the site visit? (list)

3. What compliance issues do I think I am mostlikely to encounter?

3. What compliance issues did I encounter?

Site Visit

Instructor Notes


4. Large Group Discussion: Site Visit Debriefing

The trainer should facilitate a large group discussion following

the site visit. The discussion should be tailored to the specific

visit, the production processes observed, and the interaction

with facility personnel. For example, the trainer could lead a

large group discussion to evaluate

■ whether and how participants identified P2 opportunities at

the facility;

■ success or frustration participants had when

communicating P2 opportunities to facility representatives;

and

■ any other observations.

Participant Notes: Any literature that the facility might distribute including

company literature, process flow diagrams, and/or input/

output analyses.

Module 12



Module 12

Site Visit Debriefing:

4. What was the most important thing I learned at today’s site visit?

Suggestions or comments which could improve future site visits:


Instructor NotesModule 13 Closing and Evaluation


















+ ∆


Participant Handout

Surface Coatings

Evaluation Form

Please complete all parts of this brief evaluation. Results will be used to improve this program. The goals ofthis process sector training are: to provide an industry specific overview (including history, processes andpollution prevention opportunities); and to develop familiarity with and understanding of the operations of atypical shop. Please rate the following elements of today’s workshop, both in terms of their usefulness inreaching the instructional goal and their overall quality. Please provide written comments in the space pro-vided to explain your rating or to offer suggestions for improvement.

1. Introductions/Expectations

Comments:

2. Coating Process Introduction

Comments:

3. Surface Preparation and Pretreatment

Comments:

4. Spray Coating Pollution Prevention

Comments:

5. Liquid Coating Pollution Prevention

Comments:







Day 1

Closing and Evaluation


Instructor Notes


Participant Handout

6. Viscosity and Pollution Prevention

Comments:

7. Regulatory Integration Activity

Comments:

Day 2

8. Review Activity

Comments:

9. Alternative Coatings

Comments:

10. Gun Cleaning and Paint Stripping

Comments:

11. Resource Review

Comments:









Instructor Notes


Participant Handout

12. Site Visit Preparation

Site Visit

Site Visit Debriefing

Evaluation

Comments:


Day 1

Introductions/ExpectationsCoating Process IntroductionSurface Preparation and PretreatmentSpray Coating Pollution PreventionLiquid Coating Pollution PreventionViscosity and Pollution PreventionRegulatory Integration Activity

Day 2

Review ActivityAlternative CoatingsGun Cleaning and Paint StrippingResource ReviewSite Visit Preparation…Site Visit…Site Visit Debriefing…Evaluation

Comments:








Instructor Notes


Participant Handout

14. What was the most significant thing that you learned in this two-day training?

15. In what way(s) do you expect to apply what you have learned in your work?








DEP


Electroplating and Surface Coating Finishing Sector Training

Overhead #

Module 11 Welcome ................................................2

2 Agenda ...................................................3

Module 23 Straight Talk on Metal Finishing ......... 4

4 Why Are Things Plated? ....................... 5

5 Surface Finishing Processes ................. 6

6 Five Basic Processes ..............................7

7 Two types of shops ...............................8

8 Characteristics of Captive Shops ......... 9

9 Characteristics of Job Shops ..............10

10 Work Handling Methods ...................11

11 Three General Steps in Plating .......... 12

Module 312 Flow Chart ..........................................13

13 Flow Chart ..........................................14

Module 414 Pollution Prevention Opportunities .15

15 P2 Opportunities in SolventDegreasing ..........................................16

16 Cause and Effect Diagram forDragout ...............................................17

17 Reducing Dragout ..............................18

18 Rinsing Over Plating Tank ................. 19

19 Common Rinsing Configurations ..... 20

20 Drip Boards ........................................21

21 Reactive Rinsing .................................22

22 Dragout Prevention ............................23

23 More on Drag Out Amounts ..............24

24 Estimation of Drag Out .....................25

25 Solvent Replacement ..........................26

26 Pollution Prevention Opportunitiesin Processing .......................................27

27 Pollution Prevention Opportunitiesin Processing .......................................28

28 Some Pollution PreventionOpportunities .....................................29

29 Hi-Tech Methods for MaterialRecovery ..............................................30

30 Diffusion Dialysis ...............................31

31 Vacuum Evaporators for ChemicalRecovery ..............................................32

32 Reverse Osmosis Nickel RecoveryApplication .........................................33

33 Ion Exchange .......................................34

Module 634 Metal Finishing Resources ................. 35

35 Web Sites .............................................36

36 List servers ..........................................37

Electroplating and Surface Finishing Sector Training Module 1 2

Welcomeoverhead 1

By the end of the day, we hope you will be able to:

■ Gain a better understanding of the plating process

■ Identify pollution prevention opportunities in plating facilities

■ Develop skills to work with a facility to encourage the use of P2 as a tool for

compliance

■ Integrate P2 into your current job

Module 1


Agendaoverhead 2

■ Introduction

■ Straight talk on metal finishing

■ Video: Facility tour

■ Pollution prevention opportunities

■ Identify the waste

■ Resources for metal finishing

■ Incorpoating P2 into your job

■ Review/Closing


Straight Talk on Metal Finishingoverhead 3

Overview

In this session, we are going to cover background information on the metal

plating industry.

Information included in this module:

■ Types of shops

■ Characteristics of the shops

■ Overview of the Plating Process

Module 2


Why Are Things Plated?overhead 4

■ Aesthetics

■ Economics

■ Lubricity

■ Conductivity

■ Corrosion Protection

■ Plating on non-conductors


Surface Finishing Processesoverhead 5

PolishingBuffingGrinding

EtchingElectroetching

PVDCVD

SurfaceFinishes

OrganicTechnologies

LiquidCoatings

PowderCoatings

Anodizing Chromating Phosphating AqueousProcesses

PhysicalProcesses

MetalDeposition

RemovalTechnologies

ConversionTechnologies

AqueousProcesses

ElectroplatingElectrolessPlating

DryProcesses


Five Basic Processesoverhead 6

■ Plating

■ Polishing/Bright Dipping

■ Passivating

■ Anodizing

■ Chromating


Two types of shopsoverhead 7

■ Captive shops

■ Job Shops


Characteristics of Captive Shopsoverhead 8

■ Usually greater resources to invest in P2

■ Expertise in finishing operations varies widely

■ Greater ability to influence how parts are engineered


Characteristics of Job Shopsoverhead 9

■ Vary greatly in technical expertise

■ Process controls inconsistently used or understood

■ Process knowledge is usually gleaned from vendors


Work Handling Methodsoverhead 10

■ Rack

■ Barrel


Three General Steps in Platingoverhead 11

Pre-cleaning Process

Plating

Post-Process



1. Pre-cleanAlkaline cleaner

1a. Rinse

2. Acid PicklingHydrochloric Acid Pickle

2a. Rinse

3. PlatingElectroless Nickel

3a. Rinse

4. Stain Free DryingWater Shedding Liquid

5. DegreasingVapor Degreasing

NaOH

Water

HCI

Water

NiSO4Organic Acids

Water

StoddardSolvent

Trichlorethylene

NaOH, Oils, Dirt

Spent Rinsewater,Dragout

HCI, Metal

Spent Rinsewater

NiSO4Organic Acids

Spent Rinsewater

TrichlorethyleneStoddard SolventsOils, Greases, etc.

Barrel electroless Nickel Line

Module 3



Copper/Nickel Plating Over Aluminum

Sodium Tetraborate Sodium TetraborateDirt

1. Pre-cleanSoak Clean

Sodium Hydroxide NaOH, Al2. Surface PrepCaustic Etch

Water Spent Rinsewater2a. RinseSame as 1a

Sulfuric, Nitric,Hydroflouric Acids H2SO4/HNO3/HF/Al3. Surface Prep

Desmut

Zinc CyanideSodium Hydroxide ZnCn, NaOH4. Conversion Coating

Zincate



6. PlatingNickel Sulfamate Plate

Potassium Copper CyanideCopper Cynide

Potassium CyanidePotassium Hydroxide

KCuCn, CuCn, KCn, KOH5. PlatingCopper Cyanide Strike







Pollution Prevention Opportunitiesoverhead 14

In this section we will cover information on P2 techniques and technologies for

plating. These include

■ P2 Opportunities in Solvent Degreasing

■ P2 Opportunities in Processing

■ Hi-Tech methods for P2

Module 4


P2 Opportunities in Solvent Degreasingoverhead 15

■ Improve degreaser efficiency

— keep degreaser covered

— spray wand tip below vapor level

— remove parts slowly

■ Use highest possible amount of freeboard

■ Use refrigeration coils


Board Angle

Board Overlap Drainage Time

Dragout TankTemperature

Evaporation Rate Drainage Boards

Rack Design Removal Rate

Concentration Tank Spacing

Parts Orientation Worker Practices

Process BathConditions

Process LineLayout

DragoutLoss

Cause and Effect Diagram for Dragoutoverhead 16


Reducing Dragoutoverhead 17

During Workpiece Removal

■ Increase drip times

■ Rinse over the plating tank

■ Run rinses back to the plating tank

■ Use dragout tanks

■ Use drip boards

■ Use reactive rinsing


Rinsing Over Plating Tankoverhead 18

Evaporation

DIWater

DIWater

Step 1: Plating Process Step 3: Immersion Rinse


Evaporation

Step 2: Recovery/Spray Rinse Step 4: DI Water Spray



Common Rinsing Configurationsoverhead 19

Work Flow

Drag Out

PlatingBath

Rinse

FreshWater

To Treatment

Rinse Type: Single OverflowWater Use Rate: HighApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out

PlatingBath

Rinse

To Treatment

Rinse

FreshWater

To Treatment

Rinse Type: Two Stage ParallelWater Use Rate: ModerateApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out Drag Out

PlatingBath

Rinse

To Treatment To Treatment

To Treatment

Rinse

FreshWater

Rinse Type: Two Stage CounterflowWater Use Rate: LowApplications: All Process BathsRecovery Rate: None

Work Flow

Drag Out Drag OutDi Water

PlatingBath

Drag OutTank

Rinse

Drag Out

Rinse

FreshWater

Rinse Type: Single Stage Recovert/Two Stage Counterflow RinseWater Use Rate: LowApplications: Most Heated Baths, Especially PlatingRecovery Rate: Low (70–90F), Moderate (90–120F), High (120F+)

Work Flow

Drag Out & Return Drag Out

Di Water

PlatingBath

Drag OutTank

Drag In

Drag InTank

Rinse

Drag Out

Rinse

FreshWater

Rinse Type: Drag In Drag Out Recovery/Two Stage Counterflow RinseWater Use Rate: LowApplications: Most Process Baths, Especially Ambient to Low Temp. Plating SolutionsRecovery Rate: Low (70–90F), Moderate (90–120F), or Higher (120F+)


Drip Boardsoverhead 20

Plating Bath

Type of Drip Board

Drip Board Rating

Rating

Type of Drip Board

Type of Drip Board

Type of Drip Board

Type of Drip Board

Plating Bath

Rinse Tank

DragOut

DragIn

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Plating Bath

Part


Reactive Rinsingoverhead 21

AlkalineCleaner

AlkalineCleaner

Rinse

To Wastewater Treatment Plant

Fresh Water

Fresh WaterTo Wastewater Treatment Plant

NickelPlate

Rinse

AcidPickle

AcidPickle

Rinse

Nickel Plating Line

RinseRinse


Dragout Preventionoverhead 22

During the Process Step

■ Use lowest possible concentration of chemicals

■ Operate baths at highest possible temperatures

■ Remove racks slowly and smoothly

■ Rack properly


More on Drag Out Amountsoverhead 23

gal dragout/1,000 sq.ft. processed

Solution Type Flat Contoured

Brass 0.95 3.3

Cadmium 1.00 3.1*Chromium (33 oz) 1.18 3.0*Chromium (53 oz) 4.53 11.9Copper Cyanide 0.91 3.2Watts Nickel 1.00 3.8Silver 1.20 3.2Stannate Tin 0.83 1.6Acid Zinc 1.30 3.5Cyanide Zinc 1.20 3.8

* <2x increase in chemical concentration results in 4x increase in dragout. This isdue to viscosity.


Estimation of Drag Outoverhead 24

Nature of Work Drainage Drag-out Rate (gal/1,000 ft2)

■ Vertical


— Poorly Drained 2.0


■ Horizontal



■ Cup Shapes




Solvent Replacementoverhead 25


■ Solvency

■ Solvent Purity

■ Fast Acting

■ Low Surface Tension

■ Inert to Substrate



Chemistry

■ Alkalinity

■ Wetting Agents

■ Detergents

■ Metal Attack Inhibitors




■ Heat

■ Agitation


Some Pollution Prevention Opportunitiesoverhead 28

■ Ultrasonic Agitation

■ Low Acid De-smut in Aluminum Cleaning




Hi-Tech Methods for Material Recoveryoverhead 29

■ Diffusion Dialysis

■ Evaporation

■ Reverse Osmosis/Electrodialysis

■ Ion Exchange


Diffusion Dialysisoverhead 30

FilterWater Filter PumpAcidWater

Acid Module

Stack

Metal Contaminants

to Treatment or Recovery

Recovered Acid

Recycled to Bath

AcidBath


Vacuum Evaporators for Chemical Recoveryoverhead 31

75° F RecoveryRinse

Condensate Return28 gph

City Water

Process Tank(60 sq.ft. ofsurface area)

RecoveryRinse

OverflowRinse

30 gph

2 gph

To Treatment

Vacuum Evaporator

SolutionPurification

Concentrated Solution (2 ghp) to Process Tank

E <1 gph D.O. = 1 gph

DI Water<1 gph

S

C

Open Rinse System


Heated Process

Tank

To Waste Treatment 10 gph

City Water4 gph

Ni Plate27 g/l Ni

CarbonFilter

3,000 mg/l Ni 333 mg/l Ni 37 mg/l Ni

Rinse Rinse Rinse

Evaporation4 gph

Drag-out 1 gph Drag-out Drag-out

Reject (concentrate)5 gph (5.9 g/l)

Reverse Osmosis Unit

City Water 5 gph

Permeate95 gph

(32 mg/l Ni)Note: drag-in is assumed to equal drag-out (1 gph)

Feed Stream100 gph

Reverse Osmosis Nickel Recovery Applicationoverhead 32


Ion Exchangeoverhead 33

Heated Chrome

TankRecovery

RinseRecovery

Rinse

Evaporation DI WaterDrag-out/Drag-out Recovery

FeedTank

ProductTank

Water for Dilution

Evaporator(if Required toConcentrate

Processed Bath)

Filte

r

Acid Acid

Catio

n

IX Regeneration

Duplex CationColumns

Regenerant toWaste Treatment

or Off-site Disposal

Catio

n

BathReturn Ion Exchange Feed


Metal Finishing Resourcesoverhead 34

■ People■ Hard Copies■ Computer Resources

— Listserves— Websites

Module 6


Web Sitesoverhead 35

■ National Metal Finishing Resource Center http:/www.nmfrc.org

■ Enviro$en$e http:/es.inel.gov

■ ESF http:/www.finishing.com

■ FSA http:/www.metal-finishing.com

■ products Finishing http:/www.gardner.com


List serversoverhead 36

■ P2 Tech-subscribe [email protected]

■ P2 Reg-subscribe [email protected]

■ NBEN Talk-subscribe [email protected]

■ National Metal Finishing Resource Center-subscribe http:/www.nmfrc.org

Garment Cleaning Training

Overhead #

Module 22 Dry Cleaning Definition ......................2

3 Dry Cleaning Industry Profile .............3

4 Breakdown of Dry CleaningShop Expenses ......................................4

5 Garment Cleaning ProcessFlow Chart ............................................5

6 Solvents Used [1993 U.S. Data] ........... 6

7 Perchloroethylene .................................7

8 Types of Dry Cleaning Machines:Dry-to-dry vs. Transfer Machines .......8

9 Process Flow of Typical DryCleaning System ................................... 9

10 Vapor Control: Carbon Adsorption .. 10

11 Vapor Control: RefrigeratedCondenser ...........................................11

12 Water/PCE Separator .........................12

13 Distillation System ............................. 13

14 Cartridge Filter (exploded view) .......14

15 Spin Disc Filter ................................... 15

16 Powder Filter .......................................16

17 Process Flow of Typical DryCleaning System ................................. 17

18 PCE Emissions from Dry CleaningShops ...................................................18

Module 319 Acute Exposure ...................................19

20 Chronic Exposure ...............................20

21 Environmental Effects Associatedwith Exposure to PCE ........................21

22 Pathways of Exposure to PCE ............22

23 Pathways of Exposure to PCE ............23

Module 424 Six Ways to Accomplish Pollution

Prevention ...........................................24

25 Product Reformulation ...................... 25

26 Production Unit Redesign/Modification .......................................26

27 Production Unit Modernization .......27

28 Improved Operation andMaintenance .......................................28

29 Input Substitution ..............................29

30 Alternative Garment CleaningTechnologies .......................................30

31 Ultrasonic Cleaning ............................31

32 Garment Care Test Equipment .......... 32

33 Ozonation ...........................................33

34 Liquid CO2 .................................................... 34

35 Wet Cleaning .......................................35

36 Process Flow Diagram forWet Cleaning .......................................36

37 Multi-Process Wet Cleaning ...............37

38 Machine Wet Cleaning ....................... 38

39 Diagram of a Wet Cleaning Machine 39

40 Potential Barriers to Wet Cleaning .... 40

41 Why Do Garment Cleaners ChooseWet Cleaning? .....................................41

42 Cost Comparison of Dry Cleaningand Multiprocess Wet Cleaning ......... 42

Garment Cleaning Training Module 2 2

Dry Cleaning DefinitionOverhead 2

“The cleaning of fabrics in an essentially nonaqueous solvent, by means of:

■ one or more washes in solvent,

■ extraction of excess solvent by spinning,

■ and drying by tumbling in an airstream.”

(310 Code of MA Regs. § 7.01)

Module 2


Dry Cleaning Industry Profileoverhead 3

■ SIC: 7216

■ highly competitive

■ dominated by small, family-owned businesses

■ 28% of U.S. shops have annual revenues of less than $28,000 (1991 data)

■ Massachusetts shops (1992 data):

— 4,189 employees

— $137 million in revenues

■ zero or negative growth predicted for industry


Breakdown of Dry Cleaning Shop Expensesoverhead 4

Cost Category, % of Total Annual Expensesabor

Labor40–50%

Rent and Real Estate Taxes11–13.5%

Utilities9.5–11.5%

Supplies9.25–11.25%

New Equipment7–9%

Compliance w/Gov’t Regs2.25–4.25%


Garment Cleaning Process Flow Chartoverhead 5


Pretreat clothes

Clean clothes

Dry clothes

Press clothes

Assemble clothes


Pretreat clothes

Clean clothes

Dry clothes

Press clothes

Assemble clothes


Solvents Used [1993 U.S. Data]overhead 6

Perchloroethylene (PCE, perc) 92%

Petroleum Solvents 6%

CFC’s/HCFC’s/Trichloroethane <2%

Perchloroethylene (PCE, perc)92%

Petroleum Solvents6%

CFC’s/HCFC’s/Trichloroethane<2%


Perchloroethyleneoverhead 7

Cl Cl

C = C

Cl Cl

Characteristics:

■ sweet, chloroform-like odor

■ nonflammable under normal conditions

■ low boiling point

■ easily dissolves oils and greases

■ denser than water (sinks)


Types of Dry Cleaning Machines:Dry-to-dry vs. Transfer Machines

overhead 8


��

yyyyyyyyyyyyyyyy

condensercarbon

adsorber

muckcooker(still)

stillbottoms

lintfilter

filter

separator

steamchargedsolvent

puresolvent

washer/dryer

water



Solvent vaporWastes



��

yyyyyyyyyyyy

��

yyyyyyyyyyyy

Vapor-ladenair “In”

Condenser

Waste water

Solvent tostorage

Waterseparators

Blower

PneumaticDampers

Solvent vaporstrapped inCarbon Bath

Air “Out” Steam

Vapor Control: Carbon Adsorptionoverhead 10


Vapor Control: Refrigerated Condenseroverhead 11

��

Water Exhaust Airstream(Transfer Machines Only)

Dryer ExhaustAirstream

RefrigeratedCondensing Coils

Vented toAtmosphere

Condensate toSeparator


Vapor-ladenair in

Vent

Solvent and water from Condenser

AirWaste WaterOut

Water

Perc

Solvent toStorage Tank

Water/PCE Separatoroverhead 12


DistilledPerc

Perchloroethylene

Sparge Steam

Steam

Condenser

OutIn

Perc Vapor

Distillation Systemoverhead 13


Cartridge Filter (exploded view)overhead 14

PaperElement

Center Post

End Cap

End Cap

Carbon

Meshed Wrap

OuterShield

CenterCylinder


��

��

��

��

��Disk Filters

(shaded area)

Venting toButton Trap

Solvent In

Solvent Out

Into FilterValve

Still DrainValve

Still

Spin Disc Filteroverhead 15


1. Precoat 2. Filtration(through accumulatedprecoat)

3. “Bump off”filter cake



FilteredSolvent Filter waste

to muck cooker

UsedPerc

UsedPerc

Powder Filteroverhead 16



��

yyyyyyyyyyyyyyyy


muckcooker(still)

stillbottoms

disposal

lintfilter

filter

separator

steamchargedsolvent

puresolvent

washer/dryer

water



Solvent vaporWastes


PCE Emissions from Dry Cleaning Shopsoverhead 18

■ 148.5 million pounds of PCE were released to the environment by U.S. dry

cleaners in1994

■ approximately 2/3 of dry cleaning shops’ PCE emissions are to the air

(through process and fugitive loss)

■ a controlled machine might annually release:

— 2200-4300 lbs. of PCE to air

— .07-1.9 lbs. of PCE in wastewater

— 140 gallons of still bottoms, 50 filters


Module 3

Acute Exposureoverhead 19

Observed effects of acute exposure (high dose, short duration) include:

■ irritation to skin, eyes, nose, and throat

■ superficial burns

■ depression of the central nervous system, slurred speech, impaired motor

functions, loss of consciousness

■ death


Chronic Exposureoverhead 20

Possible effects of chronic exposure (low dose, long duration) include:

■ impaired neurobehavioral function: headaches, dizziness, sleepiness

(reversible)

■ non-carcinogenic liver and kidney damage

■ reproductive disorders (decreased sperm count, increased incidence of

spontaneous abortions)

■ cancer — bladder, cervical, esophagal (possibly liver cancer and leukemia)


Environmental Effects Associated withExposure to PCE

overhead 21

BIOTA:

■ bladder, kidney, and liver cancers leukemias reported in rodents

■ toxic to phytoplankton populations

■ sub-acute and chronic effects in fish

■ bioaccumulation in marine organisms

AIR/WATER:

■ atmospheric half-life of 96 days

■ up to 26% of groundwater and 38% of surface water in U.S. exhibits PCE

contamination



INHALATION:

■ working in dry cleaning shop

— current OSHA standard = 100 ppm

— proposed standard = 25 ppm

■ living in a household with a dry cleaning worker

■ visiting a dry cleaning shop

■ bringing home freshly dry cleaned clothes (offgassing)

■ residing above or adjacent to a dry cleaning shop



INGESTION:

■ drinking PCE contaminated water

— EPA Maximum Contaminant Level standard for PCE in drinking water

is 5 micrograms/L

— measurements in Cape Cod groundwater are 16 times the MCL

■ eating PCE-contaminated food (especially dairy products and

other fatty foods)


Module 4

Six Ways to Accomplish Pollution Preventionoverhead 24

■ Product Reformulation

■ Production Unit Redesign/Modification

■ Production Unit Modernization

■ Improved Operation and Maintenance

■ Input Substitution

■ Alternative Technologies


Product Reformulationoverhead 25

■ In garment cleaning, the product is _______________

■ Ways of reformulating the product include ___________


Production Unit Redesign/Modificationoverhead 26

Examples of garment cleaning production unit redesign/modification include:

■ hardpiping a PCE still to a carbon adsorber to increase the solvent

extraction rate

■ draining filters more thoroughly before disposal

(over a weekend is recommended)

■ draining filters in a closed casing

■ using multiple emission control devices in sequence

(e.g., carbon adsorber after a refrigerated condenser, a carbon filter

after a spin disc filter)


Production Unit Modernizationoverhead 27

Examples of production unit modernization include:

■ adding or upgrading emission control devices

— installing a spin disc filter system

— installing a more efficient PCE still

■ using drip-free, airtight couplers to refill machines with solvent and therefore

minimize PCE vaporation


Improved Operation and Maintenanceoverhead 28

Perform regular maintenance:■ Change filters regularly■ Replace gaskets regularly (aeration & deodorizer valves, button trap,

cleaning machine door)■ Clean button traps, lint screens, fan blades, condensor coils■ Desorb carbon adsorbers promptly■ Check refrigerated condenser temperaturesPerform regular inspections:■ Check for leaks at gaskets, hose couplings and connections, pumps,

air relief valves, storage containers, air vents■ Check air and exhaust vents for drips■ Check level gauge on solvent tanksCorrectly size loadsMinimize time that machine door, button trap are openProvide proper training for employees


Input Substitutionoverhead 29

■ no “drop-in” substitutes currently available

■ Rynex

■ alternative solvents require alternative technology


Alternative Garment Cleaning Technologiesoverhead 30

■ ultrasonic

■ ozonation

■ liquid CO2

■ wet cleaning


Ultrasonic Cleaningoverhead 31

■ High frequency sound waves agitate garments in a liquid medium

■ Microscopic bubbles in the liquid medium implode, producing shock waves

that dislodge stain molecules from fabric

■ Mechanical action does not involve large-scale fabric movement that increases

the wear and tear on garments


Garment Care Test Equipmentoverhead 32

32" 48"

48"

32"

Ultrasonic Generator

RinseWater

RinseTank

WashTank

Transducers

FillWater

FineFilter

Heater

Pump90 GPM, 30 PSI

SustainerDrain


Ozonationoverhead 33

■ An onsite electrical generator produces ozone gas.

■ Wash water is ozonated (injected with ozone gas), thus solubilizing

garment soils.

■ Filters remove soils from the wash water which is recycled, reozonated,

and reused.

■ Garments remain on hangers throughout the cleaning process to avoid

dimensional change.


Liquid CO2

overhead 34

■ A proprietary garment cleaning technology using liquid CO2 as the cleaning

solvent may become commercially viable in 1998.

■ CO2 is non-flammable, non-corrosive, less toxic than PCE, inexpensive ($.50/

lb.), and readily available.

■ Liquid CO2 is converted to gas after the garment cleaning cycle. 90% of the

CO2 can be recaptured for reuse

■ Disadvantage: Garment cleaning with CO2 requires high pressure (700 lbs per

square inch) comparable to that of CO2 in soda fountains in restaurants


Wet Cleaningoverhead 35

■ Wet cleaning is the professional cleaning of garments in an aqueous solvent.

■ It is distinct from laundering and hand-washing.


Process Flow Diagram for Wet Cleaningoverhead 36

Water, Soil& Additives

Washer/Extractor

MachineDry

HangDry

FiltrationSystem

RecycledWater Tank

Heated Air

• Inspect• Sort• Pretreat

Stains

Water, SoapsConditionersSoftenersSizings

DirtyClothes

Clean, WetClothes

Clean, DryClothes

Finishing &Assembly

SpentFilters

Water

DirtyWater


Multi-Process Wet Cleaningoverhead 37

■ Labor-intensive

■ Relies heavily on manual laundering techniques such as scrubbing and gentle

hand-washing


Machine Wet Cleaningoverhead 38

■ Uses a computerized washing machine designed to minimize agitation

■ The dryer controls heat and moisture precisely through sensors


Diagram of a Wet Cleaning Machineoverhead 39

Dirt

Conventional Washer• Strong agitation• Linited controls• Low capital investment

Wet Clean Machine• Gentle agitation• Microprocessor controls• High capital investment

Daewoo• Microprocessor controls• Low capital investment• Air bubbles create gentle agitation• Bubbles help remove soil

Air Bubbles

Air Bubbles

Vibrations ofClothes

Clothes


Potential Barriers to Wet Cleaningoverhead 40

■ Lack of expertise with techniques

■ Skepticism about cleaning performance

■ Fear of customer disapproval and loss of market share

■ Increased labor and water costs

■ Garment care labels marked “Dry Clean Only”

■ Disbelief regarding risks associated with PCE


Why Do Garment Cleaners Choose Wet Cleaning?overhead 41

■ Cost Savings

■ Regulatory Relief

■ Occupational safety

■ Added garment cleaning capacity

■ Market niche


Cost Comparison of Dry Cleaning andMultiprocess Wet Cleaning

overhead 42

Dry Clean ($) Wet Clean ($)

Annual Operating Costs 43,920 43,880

Annual Labor Costs 5,000 15,500

Capital Recovery 6,140 90

Haz Waste Disposal 1,390 0

Solvent 370 0

Filters 630 0

Permit Fee 80 0

NOTE: These cost data are for shops that do 100% wet cleaning.

EPA, 1993 (Based On 1992 Data)


Overhead #

Module 31 Team ......................................................2

2 Teamwork ..............................................3

Module 43 Team Success Depends Upon… .......... 4

Module 54 S.M.A.R.T. Goals ................................... 5

5 Stakeholders ..........................................6

6 Examples of Stakeholders: ...................7

7 Decision Making Authority ................. 8

Module 98 The Peer Resource Relationship .......... 9

9 Methods For Peer Resources —Concepts .............................................. 10

19 Methods For Peer Resources —Skills .................................................... 11

Module 1011 Four Methods of Decision Making .... 12

12 When Selecting a Decision MakingMethod ................................................13

13 Criteria Rating Chart ......................... 14

Module 1114 When Ending a Team or

Team Project: ...................................... 15

Multimedia Teams I: Making Teams Work Module 3 2

Module 3

Teamoverhead 1

A small group of people

■ Committed to a common purpose

■ With defined goals

This group is mutually accountable

■ For achieving the goals

■ And for how they work together


Teamworkoverhead 2

A style of working together that values:

■ Listening to each other

■ Recognizing various interests/interdependencies

■ Building agreement

■ Providing support

■ Acknowledging accomplishments and contributions


Module 4

Team Success Depends Upon…overhead 3






Module 5

S.M.A.R.T. Goalsoverhead 4

■ Specific

■ Measurable

■ Attainable

■ Relevant

■ Time-trackable


Stakeholdersoverhead 5

* Stakeholders are all those individual people or groups who may be significantly

impacted by the outcome of the group’s efforts.


Examples of Stakeholders:overhead 6

■ Internal leadership team

■ EPA

■ Governor’s office

■ Citizens’ groups

■ Private industry councils


Decision Making Authorityoverhead 7

■ Within the team

■ From Stakeholders

Get clarity early in the group’s work on levels of input and decision making.


Module 9

The Peer Resource Relationshipoverhead 8

What Is It?

A relationship between a guide or mentor and a learner. The goal of the

relationship is for the mentor(with an area of expertise) to help the learner

learn new information or skills.

At any point in time we may be either the peer resource or the learner.

“Communicate with the other person that which you would want communicated if

your positions were reversed.” —Aaron Goldman


Methods For Peer Resources — Conceptsoverhead 9

When teaching concepts/knowledge:

1. Introduce the concept WIIFM — What is in it for me to know this

information?

2. Assess current level of understanding

3. Explain the concept

4. Test the learner or ask for the learner to communicate their understanding

of the concept. Provide feedback and clarification to increase

understanding.

5. Summarize


Methods For Peer Resources — SkillsOverhead 10

When teaching a skill:

1. Introduce the skill WIIFM —What is in it for me to be able to do this?

2. Assess previous experience using the skill

3. Demonstrate the skill

4. The learner practices the skill

5. Provide feedback and coaching on mastering the skill

6. Summarize


Module 10

Four Methods of Decision Makingoverhead 11

■ Authoritative

— Decide and announce

— Discuss, decide and announce

■ Consultative

— Polls individuals and decides

— Polls the team and decides

■ Majority

— Team votes

■ Consensus

— Team decides on an option that all can support


When Selecting a Decision Making MethodOverhead 12

Factors to consider in selecting a decision making method include:

■ The need for “buy-in”

■ History of the group’s operating methods

■ Types of issues that are on the table

■ Time it takes to reach a decision

■ Importance to team development


Criteria Rating Chartoverhead 13

Decision Options Total 100%

Assign a percentage to each criteria. Criteria total 100%Rate each option against each criteria, assigning a value of the percentage.Total the score for each option


Module 11

When Ending a Team or Team Project:overhead 14

■ Acknowledge individuals: recognize and celebrate accomplishments.

■ Document individual’s performance and contribution to team’s success for

inclusion in appraisal process (copy to employee and functional manager).

■ Summarize learnings with each other about what contributed or hindered

the team’s success.

Multimedia Teams II: Increasing the Effectiveness of Multimedia Teams

Overhead #

Module 31 Tuckman’s Phases of Team

Development......................................... 2

2 Tuckman’s Team DevelopmentWheel ....................................................3

3 Tuckman’s Team Development Grid ...4

Module 84 Preparation for Negotiation ................5

Preparation for Negotiation ................6

Multimedia Teams II: Increasing the Effectiveness of Multimedia Teams Module 3 2

Module 3

Tuckman’s Phases of Team Developmentoverhead 1

Forming

Storming

Norming

Performing


Tuckman’s Team Development Wheeloverhead 2

Performance

Mature closenessResourcefulFlexibleOpenEffective

Forming

TestingPoliteImersonalWatchful

Norming

Getting organized

Developing skillsEstablishing proce-dures

Storming

InfightingControlling con-flictsConfronting people

Phase Four Phase One

Phase Three Phase Two


Stage

Characteristics

Action Steps to Movethe Team Forward

Stage I

Forming

Introduction and courtesyInformation SharingStereotypingHigh need for group approvalLow need for group identityNo conflict“Why we’re here” decisionsBeginning structureNeed to feel purpose is impor-

tantNo hidden agendas evident

Write mission statement/purpose

Set goalsAssess capabilities of leader

and memberEstablish rolesDevelop ground rulesIdentify resources and toolsClarify …expectationsTake risksDo “get acquainted” activities

Stage II

Storming

Competition beginsMarketing of territoryCliques form and changePositions are rationalizedSome members are quietSome members are

aggressiveLittle team spiritChanging direction & priori-

ties

Facilitate winsCreate positive environmentListenTake extra time to

work togetherRequest and accept feedbackHonor commitmentsMake connections with all

team membersClarify boundaries of func-

tional manager and team

Stage III:

Norming

Roles established informal &formal rules established

Steady cliques are evidentTeam identity establishedProgress toward goal is shownCreativity emergesNew member entry is difficultMembers avoid rocking the

boatLimited disagreement:“Group Think” a dangerGroup hierarchy established

Keep up team winsShare leadershipUse goals to drive discussion-

makingDelegate freelyDefine higher goalsCarefully select new membersReinforce “synergy”Self evaluatePraise each otherMaintain traditionsCoach and integrate new

members

Stage IV:

High Performing

Requires unanimous support tobe here

High moraleIntense loyaltyAll group members acceptedAgreement to disagreeNew members cause regression

to previous stageCliques are absentSuperb goal achievement

When Ending a team orTeam Project:

Acknowledge individuals,

recognize accomplish-

ments, celebrate successes,

and document perfor-

mance.

Tuckman’s Team Development Gridoverhead 3


Position

(Mine) (Theirs)

Interests or Needs

(Mine) (Theirs)

Options ( Be Creative)

1.

2.

3.

4.


(Mine) (Theirs)

Module 8

Preparation for Negotiationoverhead 4


Position

(Mine) (Theirs)

Interests or Needs

(Mine) (Theirs)

Options (Be Creative)

1.

2.

3.


(Mine) (Theirs)

Preparation for NegotiationExample Scenario for Negotiation: “Reading Room at the Local Library”

I want the window closed. They want the window open.

(guess) They like fresh air.

(After asking them) They are hot-blooded and getless sleepy if they work in cool temperatures.

■ They could go to another place in the library.

I get a stiff neck easily so I avoid sitting in a directdraft. I do not want my papers blowing aroundand getting mixed up.

■ I could go to another place in the library towork.

■ I could explain my dilemma to the librarianand ask that another place be found for theperson who entered my room.

1. Open window from the top.

2. Ask librarian to turn on the air conditioner.

3. Keep a door open and open a window in the hall to provide fresh air without a draft.

Pollution Prevention in the Job Function: Regulation and Policy Development

Overhead #

Module 11 Pollution Prevention in Regulations

and Policies ...........................................2

2 Workshop Goals ................................... 3

Module 23 What is Pollution Prevention? .............4

4 What Does Pollution PreventionMean? ....................................................5

5 Waste Prevention Hierarchy ................6

6 Who Benefits from PollutionPrevention? ...........................................7

7 How Does Pollution PreventionBenefit Businesses? ...............................8

8 Implementing P2 ..................................9

9 Why/How Should GovernmentAgenciesImplement P2? ....................................10

Module 310 What is an Effective Regulation/Policy

Development Process? ........................11

11 Model of a Regulation and PolicyDevelopment Process .........................12

12 Define the Problem ............................ 13

13 Team Building .....................................14

14 Scoping ................................................15

15 Development of Solutions ................. 16

16 Internal Consensus Building .............17

(Module 3)

17 External Consensus Building .............18

18 External Consensus Building .............19

19 Promulgation ......................................20

20 Promulgation ......................................21

21 Implementation and Evaluation ........ 22

22 Example One: Pollution PreventionRegulation for Auto FinishingOperations ..........................................23

23 Example Two: Pollution Prevention PolicyNON Cover Letter ..............................24

Module 424 P2 Opportunities During Problem

Definition ............................................25

25 Problem Definition Stage: Example .. 26

26 P2 Opportunities DuringTeambuilding ......................................27

27 Opportunities During Scoping .......... 28

28 P2 Opportunities during Developmentof Solution ..........................................29

29 P2 Opportunities during InternalConsensus Building ............................ 30

30 P2 Opportunities during ExternalConsensus Building ............................ 31

31 P2 Opportunities duringPromulgation ......................................32

32 P2 Opportunities duringImplementation and Evaluation ........ 33

Module 533 Information Resources ....................... 34

Module 634 Working Case: Instructions ............... 35

35 Working Case: Overview .................... 36




39 Working Case: Questions toAddress ................................................40

Pollution Prevention in the Job Function: Regulation and Policy Development Module 1 2

Module 1

Pollution Prevention in Regulations and Policiesoverhead 1

A Workshop for Regulatory Agency Staff

■ Why P2 for regulations and policy staff?

■ A challenge to go further in building P2 into regulatory activities

■ Expectations from senior staff



■ Review the pollution prevention definition and the waste prevention hierarchy.

■ Review basic policy and regulation development process.

■ Help participants identify pollution prevention opportunities during

regulation/policy development.

■ Familiarize participants with P2 resources.



Pollution prevention is any activity which prevents pollution from being created

in the first place, versus pollution control, which deals with waste after it has

been generated.

■ Pollution Prevention is an umbrella term that covers:




Module 2




— equipment or technology modifications

— process modifications

— reformulations or redesign of products

— substitution of raw materials

— improvements in housekeeping, maintenance, training or

inventory control





■ Treatment

■ Disposal


Re-use/Recycling

Treatment

Disposal


Who Benefits from Pollution Prevention?overhead 6

■ Business




How Does Pollution Prevention Benefit Businesses?overhead 7







Implementing P2overhead 8

■ Businesses implement P2 in three major ways:

— process-related techniques

— managerial-related techniques

— design-related techniques


Why/How Should Government Agencies Implement P2?overhead 9



— Development of policies and regulations

— Permits, inspections and enforcement

— Technical assistance/outreach



What is an Effective Regulation/PolicyDevelopment Process?

overhead 10

■ Clarifies real problem(s)

■ Anticipates potential controversies and builds consensus problem solving

■ Engages the right people at the right time at the right level of detail

■ Minimizes delays and major reworks

■ Satisfies legal requirements

■ Identifies collateral support necessary for implementation

■ Supports implementation measures success

■ Fundamentally consistent across the department for type of product

Module 3


Model of a Regulation and Policy Development Processoverhead 11




2. Team Building

3. Scoping


5. a. Internal Consensus/Feedback on Draft Regulation/Policy

b. External Consensus/Feedback on Draft Regulation/Policy


Define the Problemoverhead 12

■ Pollution prevention & hierarchy

■ Source problem rather than a control problem


Team Buildingoverhead 13

■ BWP and cross bureau

■ Regional

■ EOEA staff

■ External stakeholders


Scopingoverhead 14

What should be in the scope?

■ Problem definition

■ Solution options

■ Identification of goals (e.g., regulatory streamlining)

■ Team membership resource needs

■ Development milestones and key signoffs

■ Stakeholders/public impact and potential controversies




Development of Solutionsoverhead 15

■ Key signoffs within agency




Internal Consensus Buildingoverhead 16

■ Need to gauge potential “noise” factor

■ Involve internal partners

— bureaus/programs/divisions

— regional/field offices

— staff attorneys

■ “buy-in” from middle managers



A. External Partners

■ federal agencies: e.g., EPA

■ other state agencies

— EOEA

— Administration and Finance

— MEPA review



B. External Stakeholders

■ Public Notice and Comment

— public information sessions

— “interested party list”

— Environmental Justice outreach

■ Alternative processes

— Alternative Dispute Resolution (ADR)

— Regulatory Negotiation (RegNeg)



■ Need to make regulation or policy available and accessible

— publication in Environmental Monitor

— outreach to community through non-English speaking press

— trade associations

— Internet



■ Prepare supporting documentation (for rules and regulations)

— cost-benefit analysis (required under Executive Order 384)

— approval from Office of General Counsel

— cover memo on final draft approval must show how regulation affects:

• efficiency and streamlining

• pollution prevention

• resource implementation

• staff training and policy development

— Commissioner’s sign-off

— memo to EOEA requesting approval to promulgate

— Memo responding to public comments on draft regulation


Implementation and Evaluationoverhead 21

■ Implementation issues should be addressed up-front during design phase

■ Implementation process should involve the stakeholders who will provide

evaluation feedback


Example One: Pollution Prevention Regulation forAuto Finishing Operations

overhead 22

■ Problem: MA DEP wanted to reduce the amount of VOCs from the large

number of small auto shops

■ Solution: Prevent releases at all the sources in a small shop

• Product formulation — limit VOC in per unit volume

• Equipment design — high volume/low pressure sprayer

• Equipment maintenance — enclosed cleaning and waste recycling

• Equipment operations — keeping paint can closed

■ Lessons learned: Make the regulation accessible and available

• Initial outreach — to community and industry networks

• Input — invite stakeholders to help with the drafting

• Follow through — workbooks


Example Two: Pollution Prevention PolicyNON Cover Letter

overhead 23

■ Problem: How to leverage P2 as the preferred means of compliance for lower

level enforcement actions

■ Solution: Policy that required the standard cover letter accompanying Notices

of Noncompliance (NONs)

• DEP policy statement — P2 is the preferred method of return to

compliance

• Assistance — referral to MA Office of Technical Assistance for on-site

P2-oriented engineering assistance

• Concrete suggestions — specific P2 recommendations with

compliance link


Module 4

P2 Opportunities During Problem Definitionoverhead 24

■ Define underlying problems broadly (in terms of environmental impact)

■ Use “true” brainstorming, then narrow the focus

■ Include P2 goals as stated objectives


Problem Definition Stage: Exampleoverhead 25

■ Massachusetts DEP drafted a regulation to streamline the hazardous waste

(HW) recycling permit process

■ Staff had competing views of goals of regulation:

— encourage facilities to recycle rather than discard HW, versus

— reduce facilities’ need for recycling permits by encouraging the reduction

of waste generated in the first place


P2 Opportunities During Teambuildingoverhead 26

■ Include “forward-thinking” agency staff who have had P2 training

and experience

■ Include staff from a P2 office/bureau, if one exists

■ Seek input from external stakeholders?


Opportunities During Scopingoverhead 27

■ Use brainstorming first, then narrow the focus

■ Use P2 resources available to identify P2 solutions

■ Consult with stakeholder groups; empower those being regulated


P2 Opportunities during Development of Solutionoverhead 28

■ Consider P2 as a selection criterion, and reductions in pollution as a success

measure

■ Use the waste prevention hierarchy to help prioritize possible solutions


P2 Opportunities during Internal Consensus Buildingoverhead 29

■ Consult with P2 office/bureau, if one exists, to ensure that P2 has been

adequately incorporated

■ Management should promote P2 by routinely asking the following questions:

— Where is the P2?

— Were the P2 opportunities explored?

— Is there an implementation plan to support the P2 elements?


P2 Opportunities during External Consensus Buildingoverhead 30

■ Consult with external partners (EPA, other state agencies, P2 resources) to

ensure that P2 has been adequately incorporated

■ External stakeholders can provide a “reality check”


P2 Opportunities during Promulgationoverhead 31

■ Supporting documents should indicate that a P2 options analysis was done

■ Agency memo responding to public comments should address the P2

impace and implications of the new regulation


P2 Opportunities during Implementation and Evaluationoverhead 32

■ Ensure adequate staff training, incentives, supporting procedures,

infrastructure

■ Enlist assistance from outside P2 resources and stakeholders

■ Try to answer: How much pollution did the regulation prevent?

■ For evaluation, identify data to be quantified


Information Resourcesoverhead 33

■ DEP TURA Unit

■ DEP’s Massachusetts Environmental Library

■ Toxics Use Reduction Institute (TURI)

■ Office of Technical Assistance

■ Northeast Waste Management Officials’ Association (NEWMOA)

Module 5


Working Case: Instructionsoverhead 34

■ Break into small groups, select recorder and reporter

■ Understand the case

■ Brainstorm P2 opportunities (use tools list)

■ Brainstorm potential resources

■ Select recommended P2 option(s)

■ Report out

Module 6



■ The Environmental Results Program replaces minor permits with

— Performance standards

— Compliance assistance

— Annual self-certification compliance

■ Goals of ERP

— Improve performance (including finding scofflaws)

— Smartest use of staff (permitting vs compliance/enforcement)

— Promote P2



■ Industrial Wastewater (IW) is any wastewater other than sanitary.

■ IW Sewer Discharge System before ERP consisted of:

— DEP discharge permit

— DEP Pre-treatment Approval

— Local Discharge Permit and/or Standards



■ Legacy of Pre-ERP Sewer Discharge Program:

— Most dischargers are without DEP sewer discharge permits

— DEP sewer permits are often redundant with local sewer permits



■ ERP approach for sewer dischargers

— certify compliance with all local and federal permits

— certify compliance with new statewide general standards/prohibitions


Working Case: Questions to Addressoverhead 39

■ What options were brainstormed?

■ What information resources would you pursue?

■ What is your recommended option?

P2 in Regulatory Enforcement at Commercial and Industrial Facilities

Overhead #

Module 11 Pollution Prevention in Enforcement .2

Module 22 Workshop Goals ................................... 3

Module 33 What is Pollution Prevention? .............4

4 What Does Pollution PreventionMean? ....................................................5

5 Waste Prevention Hierarchy ................6

6 Who Benefits from P2? .........................7

7 How Does P2 Benefit Business? ........... 8

8 How Does Business Implement P2? .... 9

9 Why/How Should GovernmentAgencies Implement P2? .................... 10

Module 410 P2 Tips: Schematic of Typical

Industrial Operation ..........................11

Module 511 Compliance Inspection & Enforcement

Process .................................................12

Module 712 P2 Information Resources ................. 13

Module 1113 Negotiation of P2 in Settlement ........14

14 Oversight and Implementation ofP2 Settlement ......................................15

15 Trade-Offs in Value to Agency ...........16

P2 in Regulatory Enforcement at Commercial and Industrial Facilities Module 1 2

Pollution Prevention in Enforcementoverhead 1

An Environmental Technologies Initiative (ETI) Workshop for Regulatory

Compliance and Enforcement Staff

Module 1


Module 2


■ Review P2 definition and the waste prevention hierarchy

■ Review the basic enforcement process

■ Help participants I.D. P2 opportunities in enforcement

■ Familiarize participants with P2 information resources


Module 3


■ Pollution Prevention is any activity which prevents pollution from being

created in the first place, versus pollution control, which deals with waste after

it has been generated.

■ P2 is an umbrella term that covers:







— Equipment or technology modifications

— Process modifications

— Reformulations or redesign of products

— Substitution of raw materials

— Improvements in housekeeping, maintenance, training or inventory

control





■ Treatment

■ Disposal


Re-use/Recycling

Treatment

Disposal


Who Benefits from P2?overhead 6

■ Business




How Does P2 Benefit Business?overhead 7







How Does Business Implement P2?overhead 8

■ Business implements Pollution Prevention in 3 major ways:

— Process-related techniques

— Managerial-related techniques

— Design-related techniques



overhead 9



— Development of regulations and policies

— Permits, inspections, and enforcement

— Technical assistance and outreach



Module 4

P2 Tips: Schematic of Typical Industrial Operationoverhead 10

Raw Materials

Storage

Production Operations

Maintenance Operations

By-Products

Emissions

Intermediate orFinished Product

Storage

Fugitive Emissions


Module 5

Compliance Inspection & Enforcement Processoverhead 11

Inspection Targeting—determine which industries—determine which facilities

Perform Inspection—Note violations—Inspection Close-out Conference

Prepare Enforcement Case—specify violations—recommend enforcement action—recommend application of specific

policies (as necessary)

Prepare for Inspection—records, maps, file data—consult other Agency staff—Agency enforcement history

Request Additional Informationfrom Facility (if necessary) andDetermine Applicability of Regulations

Follow Agency Procedures forIssuing Enforcement ActionAgainst Facility

1.

3.

5.

2.

4.

6.


Module 7

P2 Information Resourcesoverhead 12

■ Internal resources include:

■ External resources include:


Less Resources

Company proposes P2 project.Agency negotiates timeframes and a few milestones.

Agency reviews info to help company develop P2 project proposal.Agency negotiates substance of project, time-frames and milestones.

More Resources

Agency completes research and thorough company review to develop P2 project proposal.Agency negotiates sub-stance, timeframes, and milestones.


Negotiation of P2 in Settlementoverhead 13

Module 11


Less Resources

P2 milestones tracked by Agency simply as compliance milestones of the settlement during the enforcement period.

Agency reviews and approves defining aspects of the project as well as milestones during the enforcement period.

More Resources

Agency reviews and approves operational aspects (e.g., evaluation of alternatives), defining aspects, and milestones during the enforcement period.


Oversight and Implementation of P2 Settlementoverhead 14


Low P2 ResourceExpenditure Increases:

(+) No. of cases that Agency can complete(+) Possible total penalty dollars assessed

(if penalties mitigated for P2 outcomes)

(+) Focus on regulatory and enforcement basics

High P2 ResourceExpenditure Increases:

(–) Demand on Agency staff resources(+) Staff knowledge and involvement in

P2 options and industrial processes(+) P2 and other data from facilities(+) Assurances of P2 consideration by

more facilities(+) Possible cost-savings by industry for

implementing P2 return-to-compliance (long-term benefit to economy)

(+) Future noncompliance possibly avoided


Trade-Offs in Value to Agencyoverhead 15

Surface Coatings

Overhead #

Module 21 The Coating Process ............................. 2

2 Process Steps ......................................... 3

I-1 Preparation & Application Methods ...4

Preparation & Application Methods ...5

I-2 Curing & Process Support ...................6

3 Two-Stage Primer Topcoat System ......7

4 Pretreatment Processes ........................8

5 Process Input-Output Analysis ............9

6 Coating Process Regulation ............... 10

Module 37 Adhesion, Phosphating and Rinsing .11

8 Adhesion ............................................. 12

9 Adhesion — Corrosion ...................... 13

10 Adhesion — Contaminants ............... 14

11 P2-Options ..........................................15

12 Phosphating ........................................ 16

13 Phosphating ........................................ 17

14 Cleaning and Rinsing .........................18

15 Pretreatment Processes ...................... 19

16 Counter Current Rinsing ...................20

17 Sealing after Phosphating ..................21

18 Wash Primer ....................................... 22

Module 640 Viscosity Control ................................44

41 Solvent Reduction & Viscosity ........... 45

42 Solvents & Viscosity ........................... 46

43 Viscosity and Temperature ................ 47

Module 944 Electrostatic Powder Coating .............48

45 Electrostatic Spray Gun ...................... 49

46 Powder Fluidized Bed .........................50

47 Supercritical CO2 ....................................... 51


49 Radiation Cured Coatings ................. 53

50 Ultraviolet Curing System ................. 54

51 Radiation-Cured Coatings ................. 55

Module 1052 Minimizing Gun & Line Cleaning ..... 56

53 Minimizing Gun & Line Cleaning ..... 57

54 Paint Stripping ....................................58

Module 419 Conventional Spray ............................23

20 Spray Bounce-back .............................24

21 HVLP Spray ........................................25

22 Airless Spray .......................................26

23 Air-Assisted Airless .............................27

24 Electrostatic Spray ..............................28


26 Expected Transfer Efficiency ..............30

27 Transfer Efficiency ..............................31



30 Financial Implications ....................... 34

Module 531 Coating Composition Basics ..............35

32 Resin Types .........................................36

33 Pigments .............................................37

34 Coating Terms ....................................38

35 Typical Coatings .................................39

36 Water-Borne vs High Solids SolventBorne Coatings ................................... 40

37 Air/Force Dry Versus Bake ................. 41

38 Water & Solvent Borne Coatings .......42

39 Comparing Systems ............................43

Surface Coatings

Overhead #

Module 21 The Coating Process ............................. 2

2 Process Steps ......................................... 3

I-1 Preparation & Application Methods ...4

Preparation & Application Methods ...5

I-2 Curing & Process Support ...................6

3 Two-Stage Primer Topcoat System ......7

4 Pretreatment Processes ........................8

5 Process Input-Output Analysis ............9

6 Coating Process Regulation ............... 10

Module 37 Adhesion, Phosphating and Rinsing .11

8 Adhesion ............................................. 12

9 Adhesion — Corrosion ...................... 13

10 Adhesion — Contaminants ............... 14

11 P2-Options ..........................................15

12 Phosphating ........................................ 16

13 Phosphating ........................................ 17

14 Cleaning and Rinsing .........................18

15 Pretreatment Processes ...................... 19

16 Counter Current Rinsing ...................20

17 Sealing after Phosphating ..................21

18 Wash Primer ....................................... 22

Module 640 Viscosity Control ................................44

41 Solvent Reduction & Viscosity ........... 45

42 Solvents & Viscosity ........................... 46

43 Viscosity and Temperature ................ 47

Module 944 Electrostatic Powder Coating .............48

45 Electrostatic Spray Gun ...................... 49

46 Powder Fluidized Bed .........................50



49 Radiation Cured Coatings ................. 53

50 Ultraviolet Curing System ................. 54

51 Radiation-Cured Coatings ................. 55

Module 1052 Minimizing Gun & Line Cleaning ..... 56

53 Minimizing Gun & Line Cleaning ..... 57

54 Paint Stripping ....................................58

Module 419 Conventional Spray ............................23

20 Spray Bounce-back .............................24

21 HVLP Spray ........................................25

22 Airless Spray .......................................26

23 Air-Assisted Airless .............................27



26 Expected Transfer Efficiency ..............30




30 Financial Implications ....................... 34

Module 531 Coating Composition Basics ..............35

32 Resin Types .........................................36

33 Pigments .............................................37

34 Coating Terms ....................................38

35 Typical Coatings .................................39

36 Water-Borne vs High Solids SolventBorne Coatings ................................... 40

37 Air/Force Dry Versus Bake ................. 41

38 Water & Solvent Borne Coatings .......42

39 Comparing Systems ............................43

Surface Coatings Module 2 2

The Coating Processoverhead 1

Surface prep. Application & Curing

Process support

Un-coatedproduct Coated product

• cleaning• stripping

• equip. cleaning• maintenance• inv. control


Process Stepsoverhead 2

Surface Pretreatment

Application Methods

Curing Methods

Process Support







■ phosphatizing ■ spray

■ caustic cleaning ■ powder

■ acid cleaning ■ roll

■ thermal cleaning ■ flow

■ deburring ■ curtain

■ electrostatic


Curing & Process Supportoverhead I-2

Curing Methods Process Support

■ air dry ■ gun cleaning

■ baking oven ■ line cleaning

■ radiation (UV/IR) ■ maintenance

■ vapor-injection

■ two-component


Two-Stage Primer Topcoat Systemoverhead 3

Welding and Fabrication

steam cleaning incoming rawmaterial

dry-off ovenmetal pretreatment priming spraybooth

curing oven

curing ovencuring ovenprepping area

vapor degreasing

assembly area






degrease (hot)

1


2

deoxide(120°F)

3


4


conversion coating

5


6

seal rinse(ambient)

7

degrease (hot)

1


2


3


4

seal rinse(ambient)

5


1


2

seal rinse(ambient)

3


Process Input-Output Analysisoverhead 5

Process Inputs Process Outputs Process Losses

SurfacePreparation

Application andCuring

ProcessSupport


Coating Process Regulationoverhead 6

■ CAA

■ OSHA

■ RCRA

■ CWA

■ Other


Adhesion, Phosphating and Rinsingoverhead 7

Adhesion

■ prevents corrosion and coating failure

Cleaning

■ promotes coating-substrate adhesion

■ removes oil, grease, scale, welding byproducts, etc.

Phosphating

■ cathodic protection against corrosion

■ surface for coating to adhere to

Module 3


Adhesionoverhead 8

Adhesion Threats

■ metal: corrosion

■ plastics: mold releases (waxes & silicon)

Right-First-Time

■ avoidable costs: labor, materials, energy, time

■ reduce waste: strippers, coating, energy, etc.

rust

moistureoxygen


Adhesion — Corrosionoverhead 9

Electrochemical Process

■ in electrolyte, iron dissolves (anodes) to form iron ions (Fe+)

■ electrons from iron react w/ H2O and O2 to form OH- (cathodes)

■ reaction between Fe3+ and OH- forms Rust (Fe2O3)

■ corrosion rate = f (difference in oxidation potential) e.g. Cu & Fe

Corrosion Prevention

■ C2 and moisture barriers

■ superior adhesion to restrict anode-

cathode flow

■ sacrificial or cathodic protectionanodearea

cathodearea

iron ions rust


Adhesion — Contaminantsoverhead 10

1. Oil & Grease

■ prevent wetting if surface tension of coating is > oil or grease

2. Scale (oxides)

■ flaky film, can act as a cathode, contains electrolytes (acid, base, etc.)

3. Welding Byproducts

■ slag: contain corrosive substances

■ spatters: irregular profile, may protrude

■ seam: alkaline

slag weld spatter


P2-Optionsoverhead 11

1. Material Storage

■ indoor storage prevents corrosion

2. Protective Coating

■ rolling oils, corrosion preventatives

■ compatible with simple cleaning steps

3. Just-in-Time Delivery

■ reduce chance of corrosion in storage

■ many other benefits



Types: Purpose:■ iron phosphate “increase coating adhesion by■ zinc phosphate reducing electrolytic corrosion■ wash primers reaction”

Enhances Performance:barrier to oxygen & moisturedielectric film (insulator)rough surface for gripping

Tradeoffsa. adds costs — extra step, labor & chemicalsb. applicable to high value added partsc. not used on plastics



iron zinc comments

conc: 3 – 5% 3 – 5% range important

temp: 120 – 140; 90°F 120 – 140; 90°F deposition = f(temp)

pH (spray): 3 – 6 1.8 – 2.4 precipitation = f(pH)

pH (imm): 3–6 3.0

iron phosphate25-80 mg/ft2

zinc phosphate100-1,000 mg/ft2

■ immersion deposition■ spray deposition


Cleaning and Rinsingoverhead 14

Reducing/eliminating the need to clean

■ compatible protective oils and coatings

■ redesigning parts

Cleaning prior to phosphating key

■ alkaline type, easily rinsed

Rinsing

■ reduce pH of metal prior to phosphatizing

■ minimize alkaline salts & grime contaminating phosphating bath

■ excess phosphates that effect primer






degrease (hot)

1


2

deoxide(120°F)

3


4


conversion coating

5


6

seal rinse(ambient)

7

degrease (hot)

1


2


3


4

seal rinse(ambient)

5


1


2

seal rinse(ambient)

3


Counter Current Rinsingoverhead 16

Counter current rates for parts with a 1 gal/min drag-in:

dilution ratio stage 1 stage 2 stage 3

degrease (hot)

1

CCR(ambient)

2


3

CCR(ambient)

4

di rinse(ambient)

5

process flow

counter current rinse flow


Sealing after Phosphatingoverhead 17

Hardens the deposited phosphate coating

Chromate based (contains Cr 3+ and Cr6+)

■ fills phosphate voids

■ chemical reaction with base metal

■ rinsing and treatment often required

Non-chromate based (polymer sealer)

■ form a protective layer over exposed areas (no reaction)

■ post sealer rinse not required


Wash Primeroverhead 18

Alternative to phosphates

VOC’s 6.5g/l

■ ethyl alcohol or IPA

■ phosphoric acid

■ zinc chromate

■ water, pigments, resin

water-borne < 3.5 g/l


Conventional Sprayoverhead 19

Compressed air atomized paint

Pressures range from 40 to 70 psi

Advantages

■ high production rates

■ excellent atomization — high quality finish

Disadvantages

■ extensive overspray

■ booth clean-up cost

■ filter clean-up cost

■ high VOC and HAP emissions

Module 4


Spray Bounce-backoverhead 20

Exploding and blasting effects cause turbulence resulting in: overspray,

migration, bounceback

HVLPLVHP


HVLP Sprayoverhead 21

Compressed air atomizes paint @ 10 psi

Advantantages Disadvantages

■ sprays well in recesses/cavities ■ atomization unsufficient for

■ reduced paint waste fine finishes

■ lower booth clean-up costs ■ lower production rates

■ lower filter replacement costs

■ lower overspray, VOC, and HAPs


Airless Sprayoverhead 22

■ high fluid pressure (500 to 6,500 psi)

■ no pressurized air flow


■ high rates of paint flow ■ relatively poor atomization

■ relatively high transfer efficiency ■ expensive nozzles

■ gun handling versatility ■ reduced fan pattern control

■ can apply highly viscous fluids ■ tendency for tip plugging

■ skin injection danger

■ increased operating training

required

■ increased maintenance required


Air-Assisted Airlessoverhead 23

■ ~150 to 800 psi of fluid pressure

■ 5 to 30 psi of compressed air


■ good atomization ■ capital cost

■ varied fluid delivery ■ skin injection danger

■ low bounceback ■ increased operating training

■ increased maintenance



■ atomized paint droplets charged at gun tip

■ part electrically neutral


■ uniform film thickness ■ guns tend to be bulky

■ good wrap around and delicate

■ good edge cover ■ extra cleanliness essential

■ high transfer efficiency ■ faraday cage effect

■ safety/fire hazard

■ parts must be conductive

■ high equipment and

maintenance costs




30 40 50 60 70 80 90 100

Expected Transfer Efficiencyoverhead 26

Electrostatic, rotary

atomizer

Electrostatic, airless

Electrostatic, air atomized

HVLP

Air-assisted Airless

Conventional



leading edge50% overlap dry film

thickness

lagging edge

fluid flow rate

air pressure

hook spacing

office size

spray angleemits VOC in

coating

fan width

distance to target

Transfer Efficiency



A. thickness of applied film

■ 1 mil film specified; 2 mil film delivered

■ transfer efficiency = 50%

B. spray pattern

■ fan-shaped pattern versus donut~

■ if 1 mil thickness specified ~ donut

wastes 25% of paint

C. electrostatic faraday effect

■ edges attract extra paint

■ limits paint in recessed areas therefore

— over painting non recessed area

— manual touch-up



90.080.070.060.050.040.030.020.010.0

0.0200 40 60 80 100

VC

O E

mis

sion

s

(lb.

/1,0

00ft

2 coa

ted)

Transfer Efficiency


Financial Implicationsoverhead 30

Annual Savings by Improving TE from 30% – 45%

Costs w/ Costs w/ Savings Due toTE = 30% TE = 45% TE Improvement

Cost of waste $29,649 $15,530 $14,119filters + labor

Cost of wasted $73,101 $38,291 $34,810paint

Total cost of $102,750 $53,821 $48,929waste


Module 5

Coating Composition Basicsoverhead 31

Four main components

■ resins (also polymer or binder)

■ solvents

■ pigments

■ additives


Resin Typesoverhead 32

Lacquers■ high molecular weight■ long chains attract & entangle■ highly viscous solution■ e.g. vinyls, acrylics, & chlorinated rubber

Dispersions (also emulsions or oxidizing coatings)■ high molecular weight in discrete micelles■ combine when solvent (water) evaporates■ low viscosity■ e.g. latex; resins include vinyls & acrylics

Chemically Curing■ low molecular weight polymers■ produce large MW chains upon curing

■ e.g. epoxies and urethanes


Pigmentsoverhead 33

Hiding Pigment

■ e.g. TiO2, red iron oxide, chromium oxide

■ add color and opacity to the coating

■ other functions: corrosion and blistering resistance, fire retardancy, and UV

protection to improve weathering

Extender Pigments

■ e.g. talc, clay, barium sulfate

■ provide neither color nor opacity

■ may control gloss, add mech. strength, or lower permeability

■ low cost material — used to adjust pigment to solvent volume


Coating Termsoverhead 34

■ plasticizer

■ catalyst (drier)

■ wetting agents

■ dispersants

■ biocides

■ freeze-thaw stabilizers

■ coalescents (film forming aids)

■ flow and leveling agents

■ resin (vehicle, polymer, binder)


Typical Coatingsoverhead 35

100%90%80%70%60%50%40%30%20%10%

0%

legend

legend

legend

Water-borneEnamels

Water-borneSpray Coatings

Electro-Deposition

PowderCoatings

High Solids


Water-Borne vs High Solids Solvent Borne Coatingsoverhead 36

Aspect Water-borne High Solids Coatings

VOC Emissions

Drying Factors

Film Thickness

Safety Profile

Dip Coating

Appearance Defects

Application Flexibility

Surface Preparation

Viscosity Management

Electrostatic Application


Air/Force Dry Versus Bakeoverhead 37

Aspect Air/Force Dry Bake

Substrate Versatility

RACT Regulations

Heating Requirements

Physical/Chemical Properties

Appearance Defects

Curing Times

Clean-up Requirements


Water & Solvent Borne Coatingsoverhead 38

High Solids Solvent Borne Coatings

■ lower MW polymers w/ additives to enhance x-linking

■ contain 2.3 to 3.5 lb VOC per gal

■ 50-70% solids

■ similar to low solids coatings in application, curing, and performance

■ higher viscosity

Water Borne Coatings

■ VOC content ~ 3.5 lb/gal less water

■ Contain organic co-solvent (2 to 30%) to dissolve the resin


Comparing Systemsoverhead 39

Assume: 1 gal of solids required to cover widget

Coating Transfer Paint SolventSolids (%) Efficiency (%) Required Emissions

(gal) (gal)

100 30 3.33 0

50 30 6.66 3.33

50 70 2.85 1.43

75 70 1.9 0.95


Module 6

Viscosity Controloverhead 40

Why Control Viscosity?

■ proper film thickness to control hiding

■ runs and sags

■ atomization/quality

How Do You Control Viscosity?

■ measure (Zahn cup, viscometer)

■ maintain constant booth and coating temperature

■ specify acceptable viscosity range


Solvent Reduction & Viscosityoverhead 41

Solvent reductions can affect different coatings differently.V

isco

sity

Reduction

Coating A

Coating B

Preferred Application Viscosity


Solvents & Viscosityoverhead 42

Vis

cosi

ty

Reduction

Diluent #1

Diluent #2

True Solvent


Viscosity and Temperatureoverhead 43

Viscosity varies with temperature.V

isco

sity

Temperature

Application Viscosity

Coating A

Coating B

Initial Viscosity


Module 9

Electrostatic Powder Coatingoverhead 44

Unheated substrate

Substrate or primer coat electrically conductive

High-voltage, low current (~100 kV)

Powder wraps on part — follows electric field lines

However:

■ Faraday Cage effect yields uneven powder coating

■ air ions can can become trapped


ground

Electrostatic Spray Gunoverhead 45

Tribocharging:

■ friction between powder and spray gun — electrostatic powder

■ substantially smaller electric field — reduced Faraday effect

■ smoother finish, thicker films possible, better coverage of intricate parts

charging electrode

part to be coated

powder

high voltagepowder wrap around


Powder Fluidized Bedoverhead 46

Fluid-like powder

Workpiece preheated to ~ 500F; powder melts upon contact

Used mainly for thermoplastic coatings (10–30 mils)

Electrostatic bed common also but limited to 2-D parts

air permeable membrane

part to be coated

fluidized powder


Supercritical CO2

overhead 47

Supercritical CO2 fluid replaces organic solvents

CO2 gas heated > 88F and compressed to ~1,100 psi

CO2 compatible with many resins, painting facilities and procedures

part to be coatedmixing valve

spray gunCoatingMaterial

CO2


Supercritical CO2

overhead 48

CO2 replaces solvents used to spray-apply coatings


■ reduced VOC and HAP emissions ■ limited experience

■ thick coatings ■ royalty costs

■ reduced toxicity and odor ■ bulky gun and supply tubing

■ reduced hazardous waste ■ lower fluid delivery rates

■ high transfer efficiency

■ easy clean-up


Radiation Cured Coatingsoverhead 49

Coating sprayed on the object

Object subject to UV or EB radiation

Curing takes place almost instantaneously


Ultraviolet Curing Systemoverhead 50

UV Radiation Source

Air Ventilation

UV Curing Paints Wood Panels onConveyor Belt

ConveyorMotion


Radiation-Cured Coatingsoverhead 51


■ virtually no VOC or HAP emissions ■ limited to flat or cylindrical

■ good stain and abrasion resistance materials

■ reduced toxicity and odor ■ polymers can cause skin

■ low temp, small ovens required irritation

■ reduced fire hazard ■ high raw material costs

■ increased production rates ■ no FDA approval for food

■ low energy costs (24x acrylic resin) products

■ limited use in high-build

applications

■ shrinkage and adhesion problems


Module 10


HVLP Guns (not airless or air assisted airless)

■ turn down fluid pressure but leave valve open

■ set gun air pressure ~40 psi

■ cover orifice with cloth & pull trigger

■ air pushes fluid back into reservoir

■ flush line with small amount of solvent into grounded drum

Airless & Air-assisted Airless

■ close air compressor valve

■ remove fluid orifice carefully

■ flush air & fluid lines with solvent into grounded drum



Enclosed gun cleaners

Disposable plastic covers

Scheduling

■ light to dark colors

■ end-of-day clean-up coincide w/ end of job

■ jobs with similar colors


Paint Strippingoverhead 54

Impaction Methods Thermal Methods

■ Plastic media blasting ■ Burn-off

■ Wheat starch blasting ■ Molten salt bath stripping

■ High & medium pressure washing

Abrasion Methods Cryogenic Methods

■ Baking soda blasting ■ CO2 pellet blasting

■ Liquid N2 blasting