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Minnesota Pollution Control Agency (MPCA)

Project XL Measurements Tables

PROJECT XL MEASUREMENTS TABLE (draft)
11/1/95
The following is a the start of a table which outlines the MPCA's proposed measurements for determining the success of pilot under the Project XL approach. To a large extent the criteria listed in the Project XL Federal Register Notice and the Minnesota proposal is used as the main measurement categories. Secondly two subcategories of measurements were identified to be:

1. MOU measurements - non-enforcement agreement between 3M, MPCA, and EPA. More of a short-term document. This is where measures agreed upon to determine the success of a given pilot are described. Once there is sufficient data on a pilot for the MPCA to determine what was successful and what lessons were learned, this document will likely be terminated.

2. Permit/Compliance measurements - enforceable compliance-related measurements. These are the long-term measurements needed to demonstrate the continued beyond compliance status of a facility.

CATEGORY 1 -SUPERIOR ENVIRONMENTAL PERFORMANCE (criteria to become a Project XL pilot)

CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
Current Baseline/3M a. Air
b. Hazardous waste
c. Water
d. Solid Waste
X
Upcoming Regulations/MPCA and EPA - what things would be required to maintain Project XL status a. Air
b. Hazardous waste
c. Water
d. Solid Waste
X
(reopen condition)
Beyond Compliance CAP/3M, MPCA and EPA a. Air
b. Hazardous waste
c. Water
d. Solid Waste
X
Regulatory Relief/3M, MPCA and EPA Report outlining regulatory relief provided for a specific pilot
X
Measures of Success Report/MPCA Annual report using the measurements to determine success/lessons learned to date. The MPCA will also use this document to determine when to terminate the MOU.
X

CATEGORY 2 -- ENVIRONMENTAL RESULTS MEASUREMENTS
Monitoring, Reporting and Evaluation/3M Compliance measurement (once per 24 hours?)
X
On-Site compliance records to the level to verify compliance w/CAP
X
Report exceptions to MPCA and community
X
Self? Third Party? Audit-annual? (audit of environmental management methods?, self audit as defined by the Environmental Improvement Act?)
X
Multi-Media P2 Report/3M Prior to recycling and control mass balance information (output x and y on pollution prevention graphic: SW, HW, water, stack & fugitive air; amount in products) - annual ? (NEW) - See attached drawing
?
?
Production output/unit of pollution (by chemical, for facility) - monthly ? (calculation using TRI)
?
?
After control mass balance information (output z on pollution prevention graphic: as submitted on FormR) - annual (TRI)
?
?

CATEGORY 3 -- COST SAVINGS, PAPERWORK REDUCTION, AND INNOVATION MEASUREMENTS
CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
Innovation/3M Report on changes/innovation in plant management as result of Project XL:
a. top management
b. plant management
c. employee
d. employee/management communication
e. accounting/environmental records
X
Market Capture/3M Market*:
a) time spent to market
b) how much product sold during that time period
c) estimated increase in market share
X
Administrative/3M, MPCA and EPA Project Development:
a) hours spent to develop the proposal from a designated starting point to implementation
b) baseline development (total of the number of hours for a regular permit application in each media??)
X
Project Implementation:
a) develop baseline hours (for b thru d below)
b) hours spent on modifications
c) hours spent on reporting
d) hours spent on recordkeeping
e) hour spent on compliance determination
f) where time was saved: benefits of hours spent on tasks that would not have been accomplished if not for the above hours saved
X

CATEGORY 4 - STAKEHOLDER SUPPORT MEASUREMENTS
CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
Increased Public Participation/3M, MPCA and EPA Local stakeholder group:
a. # of meetings
b. representation
c. survey community (before and after)
d. public complaints (before and after)
e. all are the different factions of the community represented?
X
Pilot Project Committee (PPC) third-party evaluation:
a. # of meetings
b. representation
c. lessons learned
X
Emissions summary for public
a. internet
b. local news
X
Evaluation of the relative effectiveness of the local stakeholder group vs a broader (PPC-type)based group
X

CATEGORY 5 - SHIFTING THE RISK BURDEN MEASUREMENTS
CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
Demographic analysis/3M Analyze population base of the area around the pilot site
X
Impact analysis of targeted groups/3M a. Impact on Community
b. Impact on workers
c. Impact on groups associated with product/waste life-cycle
d. Report on analysis
X

CATEGORY 6 - TRANSFERABILITY MEASUREMENTS
CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
Analysis of measurements to determine transferability/MPCA Review and evaluate information collected from categories 1 through 5 above to determine transferability
X
Evaluate potential candidate interest/MPCA a. Requests for information
b. Requests to become a Project XL pilot
X

CATEGORY 7 - TAKING CSI THE NEXT STEP MEASUREMENTS
CATEGORY TITLE/MEASURER
DESCRIPTION
MOU
PERMIT
CSI Impact Report/MPCA Develop a report of what the impact Project XL pilots had to take CSI the next step.
X


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