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4. SOURCE REDUCTION EVALUATION ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- 4.1. SOURCE REDUCTION ALTERNATIVES The Act requires that source reduction evaluations be performed for all major waste streams. Where waste minimization measures seek to reduce the amount of hazardous waste after it has been generated,source reduction measures seek to prevent the generation of hazardous wastes. The Act requires that source reduction measures be evaluated in the following approaches: i Input Changes-such as raw material or feedstock changes to reduce,avoid or eliminate the hazardous materials that enter the production process (thereby avoiding the generation of hazardous wastes within the production process). i Operational Improvements-such as loss prevention,waste segregation,production scheduling, maintenance operations,and overall site management. i Production Process Changes-such as process changes,changes in production methods or techniques, equipment modifications,changes in process operating conditions (i.e.,temperature,pressure),process or plant automation,or the return of materials or their components for reuse within existing processes. i Product Reformulation-such as changes in design,composition or specification of final or intermediate products. > Administrative Steps-Administrative steps,such as inventory control and employee programs. Administrative steps include good operating practices that apply to the human aspect of conducting day-to- day operations at the facility. Appendix A identifies all source reduction alternatives considered under this Plan for each of the major waste streams within each of the above approaches. 4.2. EVALUATION CRITERIA As shown by Appendix A,for each source reduction measure that was developed,a determination was made with respect to its feasibility for implementation in accordance with the following factors or considerations: )I- Expected change in the amount of hazardous waste generated; 7 Technical feasibility; 7 Economic feasibility; 7 Effects on product quality; 7 Employee health and safety implications; >- Permits,variances,compliance schedules of applicable local,state and federal agencies; 7 Release,discharges or other environmental impacts. Each major waste stream was evaluated using above approaches and evaluation factors. Each evaluation factor above was graded with one of the following designations with respect to each source reduction measure where a positive impact was given a"P",a negative impact was given an"N"and a neutral or no impact was given an"0". In order for a proposed source reduction measure to be considered for implementation,it must not have been graded an"N"in any of the evaluation factors. For example,a proposed source reduction measure which increased wastes,were not technically possible,had negative impacts on employee safety or other adverse Dragon Products, LLC. I SB 14 Source Reduction Evaluation and Review Trinity Consultants 4-1