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2.1 Regulatory Requirements
Pollution and waste are serious issues for any chemical manufacturer. Normally the pollution and waste are a result of inefficient material use and operations, and wasteful practices. The problems they present can lead to increased health and safety concerns, result in high regulatory compliance costs, and hamper your company¹s ability to remain competitive in the marketplace. The practice of controlling pollution after it was created is an outdated measure that did little to reduce waste. Not only does pollution control equipment cost a lot of money, companies were further saddled with the mounting internal costs such as poor process efficiency, waste disposal, and regulatory affairs. Pollution Prevention ("P2") is a process that can help chemical companies overcome many of these costs by preventing the creation of pollution and waste at the source. P2 is a proven process that can help you improve on the practices and processes that cause pollution, as well as reduce or eliminate the costs associated with pollution control, waste disposal, and regulatory compliance. The competitive market and stringent environmental laws dictate that pollution and wasteful practices need to be minimized or eliminated. Pollution Prevention must be in the future for any chemical company planning to have a future.
2.1 Regulatory Requirements In Ohio, pollution prevention practices and plans may be established under media-specific regulations like EPCRA, RCRA, and NPDES, among others. Examples include waste minimization plans and storm water pollution prevention plans ("SWPPP"). For these regulated plans, pollution prevention practices are discussed in each of the pollution-media chapters of this self-help guide.
2.2 What is Pollution Prevention? Historically, chemical companies and regulators focused on pollutants and other wastes after they were already generated, thus relying on "end-of-pipe" controls or treatment (i.e. scrubbers, incinerators, treatment plants, etc.). Businesses now realize that efforts to reduce or eliminate waste before it is created (termed "Pollution Prevention") often result in positive environmental stewardship, reduced regulatory burden, and handsome cost savings. Protecting the environment and adding money to your bottom line are two powerful reasons for all chemical companies to incorporate Pollution Prevention in their everyday thinking. "Pollution Prevention is the use of various technical and non-technical means of source reduction and material recycling that limit waste and pollution creation." Pollution prevention has close ties to the quality movement. Just as quality management strives for "zero defects," pollution prevention targets "zero discharge" of pollutants. As shown in Figure 1-1, Pollution Prevention principles are in line with those of the PDCA cycle. The extent to which your operation will benefit from pollution prevention activities will depend on your control and knowledge of your own processes. Pollution prevention requires a neat, orderly, and efficient operation. Those businesses with operational discipline will likely succeed in changing materials and practices with minimum disruptions. P2 conserves raw materials through source reduction, material reuse or reclamation, responsible chemical management, and efficient energy and water use. Preventing waste from being created eliminates the need to recycle, treat, or dispose of wastes. Congress, via the 1990 Pollution Prevention Act, established a national hierarchy (ranking system) for evaluating various approaches to managing wastes. This ranking system established pollution prevention as the most desirable and beneficial approach to managing wastes. The complete hierarchy for managing wastes includes:
Your goal should be to rise on the hierarchy as you evaluate and implement different approaches to managing wastes. What Pollution Prevention Is Not: Pollution prevention, as explained in the preceding paragraphs, incorporates prevention and some types of recycling (reuse or reclamation). Pollution prevention does not include:
2.3 How Will Pollution Prevention Benefit Your Operation? Some chemical companies may choose to implement pollution prevention practices because it is the right thing to do for the environment and for their employees. All chemical companies should be interested in pollution prevention since it also provides an opportunity to reduce costs. Pollution prevention not only makes good environmental sense, it also makes good business sense. It is a "win-win" approach. What are some benefits offered by Pollution Prevention? · Economic - Reduced disposal and treatment costs; manpower and financial savings from reduced regulatory requirements (i.e. permitting, reporting, etc.); increased productivity through efficient operation of equipment; and lower raw material costs when reusing materials. · Environmental - Reduced emissions, releases, and disposal of wastes and hazardous chemicals; conservation of natural resources. · Human Health - Reduced employee exposures and safety risks from handling or working with wastes or hazardous chemicals. · Regulatory Compliance - Reduced permitting, reporting, and recordkeeping requirements. · Liability - Reduced liability associated with waste disposal, employee exposure, and regulatory enforcement. · Public Relations - Reduced publicity associated with chemical release reporting, emergencies, or accidents; offers "environmentally friendly" operations and products to customers. · Plant Operations - Reduced wasteful processes and practices that compromise an organization's productivity and product quality. The following "Pollution Prevention Hierarchy" provides an excellent visual representation of the benefits associated with each level of pollution prevention. Pollution Prevention Hierarchy:
2.4 Pollution Prevention Problem Solving A Practical Approach to Preventing Pollution A structured problem-solving process is the most effective method for finding the right pollution prevention opportunities for your environmental management issues. A problem-solving process will ensure you effectively identify, analyze, and implement the best solution to your environmental problem. This process can help save you time, resources, and money. Many companies have used problem-solving processes to improve quality and productivity. The problem-solving methodology adheres closely to that of the PDCA cycle, as shown in Figure 1-1. More companies are now using these same problem-solving processes to prevent losses (wastes) from occurring from their operations. Explore the pollution prevention success stories of chemical companies in Ohio that have implemented pollution prevention practices. Your chemical company can also enjoy these benefits if you implement a sound pollution prevention process. Most models used for problem-solving processes include elements such as problem identification, data collection and analysis, generating potential solutions, evaluating and selecting solutions, implementing solutions, and measuring results. These same models can be adapted and used for pollution prevention. Problem-solving processes for pollution prevention can be improved through the use of tools such as process mapping, materials accounting, and cause/effect analyses. The Pollution Prevention Problem-Solving Process is shown below, and it can be used (or adapted) to help your chemical company identify, evaluate, and implement pollution prevention opportunities. This process is neither complicated nor does it require a great deal of technical skill to use. With a little practice through hands-on use by an employee-led team, your company can gain the skill and ability to effectively identify pollution prevention opportunities for any situation. Pollution Prevention Problem Solving Process
Step 1 Select and Study an Operation for Losses The first step is to select and begin studying an operation (or process) for improvement. Any chemical facility operation where there are losses occurring could be a good candidate for pollution prevention. Consider these common pollution prevention areas for chemical operations:
An important outcome from Step 1 is a complete understanding of the process. To improve a process, you must first completely understand it. A useful tool for developing an understanding of a process is "process mapping." Process mapping identifies individual steps to the process, including important "inputs" and "outputs." The material flow diagrams used in process mapping will lead to a better understanding of a process, including where key "losses" may be occurring. An example of a process map for a batch chemical operation is shown below.
Batch Chemical Operation Process Map Example
Refer to Worksheet 1 - "Process Map Template" in to map your key chemical processes.
Step 2 Identify Key Losses Step 2 focuses on identifying and collecting data relating to the losses, which includes assigning volume and cost data to inputs and outputs. This is referred to as "materials accounting." The process map developed in Step 1 can be used as a template to easily display the materials accounting information. Completing this step will show you the volume of "losses" that are occurring from your operation, and more importantly, how much these losses are costing your company. This helps identify the economic and environmental impact of losses from your chemical operations. Worksheet 2, the "Materials Accounting Template," can help you display this information for further analysis. Once this template is completed for any process, you will want to prioritize the waste streams to determine which should be investigated first. To do this, utilize the "Waste Stream Priority Rating" worksheet (Worksheet 3). Based on the Priority Ranks you develop, you can now select one or more key waste streams to further investigate for pollution prevention opportunities.
Step 3 Analyze Key Losses After you select a waste stream for investigation, the next step is to fully analyze the factors that are contributing to the losses. This is often referred to as a "root cause analysis." In this step, defining all the causes for the losses will help you decide on and prepare the right pollution prevention options to reduce or eliminate those losses. An effective tool used for root cause analysis is a cause and effect diagram, or "fishbone diagram." The effect, or loss, is the "head of the fish." Causes branch out from the backbone that is attached to the head of the diagram. Four main cause categories (main branches) are most often used for the diagram: personnel, materials, methods, and machinery. By asking the question "why is this occurring?" several times, you begin to fill in the diagram. This simple analysis will help you identify important factors contributing to the loss that is occurring. An example of a simple cause and effect analysis is shown below.
Worksheet 4 is a "Root Cause Analysis" template that you can use to help analyze key losses from your chemical operations. After completing this root cause analysis for your process of concern, it may become apparent which factors are the leading causes of the loss. Often times, additional data gathering and analysis may be needed to better identify the key factors.
Step 4 Generate P2 Options In Step 3, you analyzed key losses and identified the most important factors leading to those losses. In Step 4, you will generate specific source reduction and recycling options to reduce or eliminate those losses. Possible source reduction options would include those relating to improved operating practices (i.e. inventory control, employee training, better procedures, improved housekeeping, preventative maintenance, etc.), material substitutions, process changes and/or equipment modifications, and product changes. Methods used to generate options may include a simple "brainstorming session" with employees. Benchmarking with other chemical companies, customers, suppliers and using outside vendors or technical assistance providers may also prove beneficial. The "Option Generation" and "Option Description" worksheets (Worksheets 5 and 6) will help you list and select P2 options for further evaluation.
Step 5 Evaluate P2 Options At this point, you need to analyze the feasibility of the pollution prevention options to determine which options are best for your situation. In some cases, you may decide to proceed directly to implementation for those options that are of little or no cost, easily implemented (i.e. no technical risk), and clearly have an environmental impact. For other options, however, you may decide that economic, technical, and environmental analyses are required to make an informed decision. The "Economic Analysis ‚ Payback Period" and "Economic Analysis ‚ Net Present Value" worksheets (Worksheets 7 and 8) can be used to help you determine the costs, savings, and payback for the pollution prevention options. Options with favorable payback periods (i.e. less than 2 years) could be good candidates for implementation. Options that have a positive net present value should also be looked upon favorably for implementation. Often loans, grants, tax exemptions, and other financial incentives are available to make some options more economically attractive. For example, the State of Ohio has the Pollution Prevention Loan Program that provides low interest loans for P2 equipment for qualified companies. "Technical Analysis" (Worksheet 9), can be used to explore several possible technical situations to determine if the P2 options will "technically" fit your operations. This will be important for the options that include process changes and/or new equipment. The last thing you want to do is implement a P2 option that sends a negative "ripple effect" throughout your operation, such as creating a bottleneck or negatively impacting otherwise efficient operations. The "Environmental Analysis" (Worksheet 10) can help you score which P2 options provide the highest environmental benefit. Those scoring the highest could be selected and prioritized for implementation. As you will see, the Environmental Analysis addresses the criteria used earlier in Step 2 in the Waste Stream Summary Worksheet.
Step 6 Implement P2 Options and Measure Results Based on the feasibility analysis performed in Step 5, the best P2 options based on your specific application can be selected for implementation. Consider establishing an implementation plan that includes a project schedule to identify tasks and timelines for better managing the implementation of your pollution prevention options. Your plan may also need to consider obtaining capital for financing the implementation of your options. An important element of P2 option implementation should include a process for gathering appropriate data to help monitor your option. You should also be prepared for any contingencies, and include necessary revisions or updates to your implementation plan. To determine if your option is effective and is achieving the desired results, evaluation of the option is needed after implementation. You should look at data collected from implementation and compare it to the information you collected when you began the pollution prevention process. For example, you can consider re-evaluating those key factors that were previously determined to be contributing to losses to see if they have been effectively addressed. You should also look for improvement by comparing waste volumes or toxicity levels to those of your benchmark (i.e. Worksheet 2, "Materials Accounting Summary"). Further, it is imperative that you actively search for any new problems that may have occurred after implementation. Consider publicizing the results internally and externally to encourage and promote on-going P2 activities. You should also consider measuring the economic (i.e. annual savings) and environmental (i.e. annual pounds of pollution prevented) benefits from the implementation of your P2 options. Information from this step can be used for continuously improving your on-going pollution prevention problem-solving efforts. For more information, including additional resources on pollution prevention problem solving, refer to the Sources of Additional Information section at the end of this Chapter.
2.5 Pollution Prevention Facility Planning Many chemical companies have benefited from implementing a facility-wide pollution prevention program. The American Chemistry Council Responsible Care® program has developed many outstanding resources to help the chemical industry develop and implement facility-wide pollution prevention programs. Other resources, including those from the Office of Pollution Prevention at Ohio EPA, are also available to help chemical companies with their pollution prevention efforts. A facility-wide pollution prevention program involves developing and implementing a continuous strategy to reduce all forms of waste generated by facility operations. What are the key elements of an effective pollution prevention program? While there are several important characteristics of successful pollution prevention programs, the elements listed below are often recognized as the key elements common to successful pollution prevention programs. Key Elements of a Successful P2 Program:
If you are interested in implementing a Pollution Prevention program, just getting started with one, or looking to improve your company¹s existing program, consider learning more about these elements from the resources listed below. Sources of Additional Information
Publications and References
Updated: 11/01/01
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