The first step in preparing a facility pollution prevention plan is to develop goals. These goals will identify specific reductions and accomplishments that you envision for the facility's pollution prevention program. Section 3-302(a) of Executive Order 12856 requires each Federal agency to develop "voluntary goals to reduce the agency's total releases of toxic chemicals for treatment and disposal from facilities covered by this order by 50 percent by December 31, 1999." Specifically, your facility pollution prevention plan should define how your facility will contribute to your agency's overall pollution prevention reduction goals (see Section 3-302(d) of Executive Order 12856). Some recommended goals might include the following:

Reductions in the release and use of toxic and extremely hazardous chemicals at your facility (see Executive Order 12856)

Reductions in the release and use of other pollutants as identified by your agency's pollution prevention strategy

Reductions in the unnecessary purchase of toxic and hazardous chemicals (see Executive Order 12873)

Affirmative procurement practices to ensure the purchase of recycled content materials as directed by EPA (see Executive Order 12873)

Increases in the volumes of materials captured for recycle

Reductions in the generation of solid wastes

Reduction in the consumption of materials, water, and power (see Executive Order 12902)

Reductions in the use and release of toxic chemicals to environmental justice areas where socioeconomic factors are of concern (see Executive Order 12898).

EPA is currently developing guidance on specific pollution prevention approaches that can be used by agencies and facilities in meeting their 50 percent reduction goals.

By setting goals, you will define the nature of the pollution prevention program and direct its initial efforts toward a quantifiable objective. As you develop the facility pollution prevention plan, you may identify new goals or modify original goals. Be sure to document and publicize any major changes to the program goals.

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The next step is obtaining a commitment from upper management. When management is committed to pollution prevention, the development (and implementation) of the program plan proceeds more smoothly. As with any new project, obtaining management support for pollution prevention involves providing managers with the information they need to make decisions. Managers should understand the reasons for developing a pollution prevention plan (e.g., the Executive Orders), and the elements of a pollution prevention program. Most important, the facility mangers should understand all of the potential benefits that they will reap in developing and implementing a pollution prevention program.

To obtain upper management commitment, you have to sell the concept. To do that, you have to convince managers that a pollution prevention facility plan will help the facility mission by:

Improving compliance with all applicable environmental requirements, regulations, and Executive Orders

Reducing operation costs with respect to waste management and the purchase of raw materials

Reducing the facility's chances of creating environmental contamination that may result in environmental liabilities and large-scale cleanup requirements

Improving the productivity of staff by providing a cleaner, healthier working environment through reduced use of toxic materials

Increasing efficiency through innovative pollution prevention techniques identified and implemented under the pollution prevention program.

Once upper management agrees to developing a facility plan, the facility director should sign a formal policy statement that expresses approval for the plan. In addition to the policy statement, upper management must provide the authority for the environmental staff to develop and implement the pollution prevention plan.

OBTAINING THE RIGHT KIND OF COMMITMENT!

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A pollution prevention program cannot succeed without the support of all facility staff. Therefore, the facility pollution prevention plan should be developed by facility staff who are led through the process by the environmental personnel responsible for the plan. EPA suggests a team approach in which various staff support the planning and implementation steps. Realize that various facility staff should participate in the planning process because they will ultimately be responsible for implementing pollution prevention options.

The same staff will not necessarily support the planning process throughout the effort. You will need assistance from staff who understand and operate different processes or missions at the facility. You will draw on different facility personnel when characterizing their operations and defining pollution prevention options that apply to them. You should also enlist staff who support the entire facility, including maintenance engineers, supply staff, and safety & occupational health professionals. These staff will be invaluable in defining facility-wide characteristics and pollution prevention opportunities.

To ensure that the right staff are available when needed, EPA suggests a TEAM BUILDING APPROACH that relies on education and flexibility so that facility staff can participate when needed. The following types of activities may support you in building a personnel pool that you can rely on throughout the development and implementation stages:

ISSUE THE POLICY STATEMENT

ENLIST MIDDLE MANAGEMENT SUPPORT

ESTABLISH AN OVERSIGHT GROUP

SELECT STAFF FOR BASELINING & OPPORTUNITY ASSESSMENT ACTIVITIES

PUBLICIZE THE PROGRAM

CREATE EMPLOYEE INCENTIVES

Successful Models

TIDEWATER INTERAGENCY PROGRAM

COAST GUARD

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Executive Order 12856 (Section 3-304) requires all Federal facilities to comply with the Toxic Release Inventory (TRI) reporting requirements under Section 313 of the Emergency Planning and Community Right-to-Know ACT (EPCRA). As explained in Section 2-207 of Executive Order 12856, these additional toxic pollutants may include "extremely hazardous materials" as defined in Section 329(3) of EPCRA, hazardous wastes as defined under the Resources Conservation and Recovery Act (RCRA) of 1976 (42 U.S.C. 6901-6986), or hazardous air pollutants under the Clean Air Act Amendments (42 U.S.C. 7403-7626), . For the purposes of establishing the baseline (under 3-302(c)), "other chemicals" are in addition to (not instead of) the Section 313 (TRI) chemicals. This means that facilities must not only determine which TRI chemicals they use and release at or above the thresholds established under EPCRA but also have to quantify the use and release of other "extremely hazardous chemicals" in developing their pollution prevention plans. Facilities may choose to highlight this TRI reporting and related reductions in the individual facility pollution prevention plans required by Section 30302(d) of the Executive Order.

THE BASELINE DEVELOPMENT PROCESS

The chemical usage and release baseline required for TRI reporting is the first step in developing a facility baseline. These data are the minimum data needed for a hazardous material usage and release baseline. Such data, however will not be the only useful information for developing a facility pollution prevention plan that addresses all environmental issues and costs.

Developing an environmental baseline involves building a comprehensive picture of the materials usage patterns and environmental impacts associated with the facility. To develop a complete baseline, you will have to collect various information and assimilate it into a unified, multimedia description of your facility's environmental impacts. The baseline will define materials usage patterns and the environmental problems that arise from these usage patterns. To obtain this information, you will search and review data with the operations staff who are tasked to support this effort. Specifically, each waste generating operation should have one point of contact who can provide baseline statistics that represent that operation.

You can use the information gathered in several ways to describe the impacts created by on-site activities. In many cases, you may have to calculate or estimate the exact impacts by using a material balance calculation. The volumes of chemical releases are calculated by quantifying the amounts of materials used and the known amounts of waste generated. This method assumes that all material used will either be used in the product, become a waste, or be released into the environment. The MASS BALANCE is a simple way to account for all material that comes into the facility.

Pollution prevention can begin when materials enter the facility. Therefore, the baseline development process begins with the purchasing and supply departments. You and your pollution prevention team should determine who is responsible for purchasing and handling raw materials. Does one person order everything in a tightly controlled system, or can many people order materials for their sections' needs or their own needs? How does the supply system track, store, and distribute the new materials? Developing a baseline of purchasing information also involves quantifying the amounts and costs of the materials purchased and distributed, as well as identifying the locations and processes where they are being used.

With the materials purchasing, handling, and usage information collected, one-half of the puzzle is complete. The other half focuses on identifying waste generation and environmental releases from the facility. What products or services are being conducted at the facility that consume materials? What wastes and pollutants are being generated by the use of the materials, what processes are generating wastes and pollutants, and what are the volumes and characteristics of the wastes being generated? In addition, you should understand how wastes are managed following their generation, what problems are associated with the management or mismanagement of these wastes, and how they are disposed. You should also identify the costs associated with waste handling activities and whose budget pays for these costs.

At this point, the puzzle might appear finished, but the borders are still missing. The borders consist of the facility's natural resources and land use. You and your team should investigate how facility activities affect the external environment. What are the impacts of these activities on the natural resources and land, not only on the facility's property but beyond its borders? Stormwater runoff, groundwater contamination, and air emissions are examples of the environmental effects that might be characterized in your baseline.

Remember that the reason you are developing a baseline is to assess pollution prevention opportunities that might be taken to reduce environmental impacts, waste generation, and costs. When you begin to collect baseline data, you will observe operations and review data. As part of this process, you may identify pollution prevention opportunities. You should document these opportunities and incorporate them into your facility pollution prevention plan.

The baselining effort may require significant effort over a long period of time. The size of your facility, the number of waste generating processes, and environmental program staffing may make the baselining task a timely effort. Baselining should be a continuous process. You should develop an initial baseline within your time and staff constraints and build it over time. If you must gradually develop a baseline, start with the processes that you know create your most serious environmental problems and proceed from there. For example, you can use your TRI reporting data as your initial facility baseline. Over time, you can expand these data to include other chemicals and environmental impacts.

Baselining is a critical effort that should continue from this point forward. Baselining is the process of documenting environmental impacts, associating them with facility activities, and compiling records into an accessible information base. This TABLE identifies many types of information that might be useful in developing your facility environmental baseline.

KEYS TO SUCCESS IN DEVELOPING A BASELINE

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Under Section 3-302(d) of Executive Order 12856, you are required to identify pollution prevention activities and conduct opportunity assessments as part of your pollution prevention plan. Specifically, Section 3-302(d) states that "Federal agencies shall conduct assessments of their facilities as necessary to ensure development of such plans and of the facilities' pollution prevention program."

Using the baseline data, you can identify potential pollution prevention activities and opportunities. For example, the baseline may indicate that water usage is a critical issue for a facility. If water is a critical issue, what activities can be initiated to reduce usage, waste, and overall cost? For every issue documented under the baseline, the team should identify activities that will promote pollution prevention. In general, these activities will include the following:

Additional Analysis - The baseline may indicate that a process or environmental impact is not fully understood and that more complete information or data are needed. To fully characterize the problem, the staff will have to conduct analyses, analytical measurements, or studies. Upon completion of these analyses, the staff will assess pollution prevention opportunities.

Immediate Implementation - The baseline may provide applications of existing pollution prevention strategies, techniques, or technologies that can be implemented immediately to reduce environmental impacts. In such cases, the facility may seek to implement pollution prevention options immediately.

Pollution Prevention Opportunity Assessments - The baseline may also show that processes may be amenable to pollution prevention options. To define the best option, the staff should conduct a thorough pollution prevention opportunity assessment ( RECOMMENDED PROCEDURE DIAGRAM). Executive Order 12856 requires that all Federal facilities conduct opportunity assessments (as needed) to develop their facility pollution prevention plan. Several manuals (referenced in Section III) can be used to conduct pollution prevention opportunity assessments. For a general summary of the assessment process, see:

(1) POLLUTION PREVENTION OPPORTUNITY ASSESSMENTS,

(2) COMMON POLLUTION PREVENTION OPPORTUNITIES, and

(3) KEYS TO SUCCESS IN CONDUCTING OPPORTUNITY ASSESSMENTS.

Focus your initial effort on the pollution prevention activities that affect processes responsible for the environmental issues or impacts of greatest concern. Setting priorities requires weighing different objectives, such as toxic use reduction, cost reduction, or water use minimization. Each facility will have its own objectives depending on its overall pollution prevention goals and site-specific conditions (see Step 6).

Your facility pollution prevention plan should include a list of all of the pollution prevention activities and opportunities identified in this step. The facility pollution prevention plan will eventually act as a road map that ties together all of the additional analyses with the immediate implementation and opportunity assessment activities. As activities are completed or new ones identified through pollution prevention opportunity assessments, the list of prevention activities will change.

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By this time, you have a list that describes hundreds of pollution prevention activities. The next step is to develop priorities and rank the activities. That is, develop a list of action items that you and facility staff will undertake to integrate pollution prevention into your facility's activities. The order in which you choose to initiate pollution prevention activities and projects depends upon facility-specific considerations and environmental goals. These considerations will be used to rank all of the pollution prevention activities identified previously. The following considerations are commonly used to rank such activities:

Environmental Compliance - The project's impact on improving the facility's overall environmental compliance status. Section 3-302(b) of Executive Order 12856 places special emphasis on identifying and implementing pollution prevention projects that improve compliance.

Mission Impact - The project's potential impact on the facility's mission and the ability of the staff to accomplish their mission.

Environmental Benefits - The project's environmental benefits (e.g., air emission reduction, hazardous waste minimization).

Ease of Implementation - Complex changes that require additional staff effort may not be accepted as easily as simpler changes.

Cost Savings - the potential cost savings associated with project implementation. Pollution prevention techniques that result in improved efficiency and cost savings are usually accepted more readily than options that result in increased costs.

Other criteria that you may consider include the availability of disposal capacity, community concerns, environmental justice goals, worker safety and exposure, anticipation of future regulation, and resource consumption.

After you have identified ranking criteria, you should rank all pollution prevention activities identified on a numerical scale by assigning a value that reflects how the activity matches each criterion ( EXAMPLE). The highest ranking activity (i.e.; the opportunity with the highest total score) should be considered first for implementation. Often, one criterion is considered to be more important than the others. In such a case, a weighting factor can be used. Further information on ranking schemes is presented in the guidance documents listed in Section III.

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Once the pollution prevention team has developed a ranked list of pollution prevention activities, you should obtain upper management and senior staff support. This is an important opportunity for upper management to reaffirm its support for the pollution prevention program. To do this, you should convene a management review committee to review you facility pollution prevention plan. The management review committee should include representatives from all of the organizations that will be affected by the pollution prevention program.

During management review, the pollution prevention team should present the ranked list of activities for approval. You should explain the process used to develop the list and emphasize the potential benefits of the effort. Upper management must understand the relationship between the pollution prevention program activities and their impacts on the facility mission and existing environmental programs. The end product of this review should be a coherent, integrated pollution prevention program that supplements other facility programs (e.g., safety and occupational health, environmental compliance, training, and development).

By providing this information, you will allow upper management to make informed decisions from a program-wide perspective about prioritizing pollution prevention projects, developing an implementation schedule, and providing funding. If additional resources are needed for establishing the pollution prevention program (e.g., staff positions), they should be requested at this point.

You now have a management-approved pollution prevention plan for your facility. The next steps focus on getting your program stated. It is important to realize that the following steps may proceed simultaneously. In addition, you may find that the facility pollution prevention plan changes once you start learning more and conducting additional assessments. Be flexible and willing to modify the plan as you proceed.

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