PREPARING A POLLUTION PREVENTION PLAN. by Larry K. Sibik Capsule Environmental Engineering, Inc. St. Paul, Minnesota

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1 Presented at the: American Instilute of Plant Engineers Conference Minneapolis, Minnesota September 30 - October I, 1991 PREPARING A POLLUTION PREVENTION PLAN by Larry K. Sibik Capsule Environmental Engineering, Inc. St. Paul, Minnesota Abstract Currently, 25 states have enacted some form of pollution prevention legislation. At least three additional states have proposed legislation. Many of these pollution prevention statutes require industrial and commercial sources of hazardous or toxic wastes and/or emissions to develop plans to reduce their generation. While each of these planning requirements varies in depth, the same general concept and approach has been incorporated into each: the reduction of hazardous and toxic wastes and/or emissions is best prevented at the source. Companies which are located in states without such legislation may also want to consider developing a pollution prevention plan. In addition to satisfying state guidelines, a wellprepared pollution prevention plan can provide a company with a blueprint to reduce its environmental exposure. In essence, a pollution prevention plan should become an integral part of a company's business plan. Introduction Starting in 1987, a new style of environmental legislation began to appear on the law books of state governments. Generically known as pollution prevention legislation, these new laws required that industry, government and the general public reduce, recycle, reuse and, as a last option, treat and dispose of the wastes generated by their activities. The scope of this legislation varied in that some states only addressed toxic or hazardous wastes while other states developed a more ambitious approach and covered the entire gamut of waste generation. In all, 23 states have enacted some form of pollution prevention legislation. Those states with pollution prevention laws include: Alaska, California, Delaware, Georgia, Illinois, Indiana, Kentucky, Louisiana, Maine, Massachusetts, Minnesota, Mississippi, New Jersey, New York, North Carolina, Ohio, Oregon, Rhode Island, South Carolina, Tennessee, Vermont, Washington and Wisconsin. At least three states (Florida, Iowa and Michigan) have proposed additional legislation.

2 The cornerstone of many of these states' pollution prevention laws is the requirement that individual manufacturing facilities prepare and implement a pollution prevention plan. In preparing such a plan, a company develops and investigates options for preventing the generation of wastes or the release of pollutants. The plan must address a facility's operations during a specified period of time, and it must be updated periodically. Common elements of a pollution prevention plan include the following: Policy statement Description of current waste- or emission-generating processes Description of current and past practices used to eliminate or reduce the generation of toxic pollutants Identification of pollution prevention options which are both economically and technically practical Pollution prevention objectives with numeric goals Rationale used to develop each goal Options which are not economically or technically feasible Of the 26 states listed above, pollution prevention planning is required in 18 of them. However, facilities located in states without pollution prevention laws may also want to consider developing a pollution prevention plan. For facilities in all states, however, a pollution prevention plan, integrated into a company's business plan, is an effective method of evaluating how facilities are dealing with environmental issues. Such a plan may work to lower potential liabilities, decrease negative publicity, improve manufacturing efficiencies and provide guidance in allocating financial and personnel resources. Policv State ment The policy statement must state the company's support for eliminating or reducing the generation of toxic pollutants to the environment. The policy statement should reflect the requirements of the state program as well as those of the company. One possible policy statement is presented below: "It is the policy of (company name here) to eliminate or reduce at the source of generation, recycle or reuse on site all materials which result in the generation or release of hazardous and/or toxic pollutants to the environment where such activities are judged to be both technically and economically feasible." -2-

3 The above policy statement reflects the goals and definitions of the state program while tempering the plan's activities to only those within the company's means. Description of the Generatine Processes The first step in developing any type of plan is to establish a baseline. In many cases the baseline to be used has already been established under the state guidelines: reported volumes from specified years of RCRA wastes generated, of SARA 313 emissions or of state-listed wastes generated or emitted. In such cases as above, determining the baseline is a matter of tracking down the appropriate paperwork (waste manifests and Form R reports, for example). Where no baseline criteria exist, the facility must establish them. The criteria selected should be measurable, should reflect the facility's activities and should include all the hazardous or toxic materials the facility uses. The description of the current processes should take the form of a black box diagram. A black box is an arbitrary boundary which can be drawn around a facility, a manufacturing process or an individual tank or machine. In selecting where a boundary is to be drawn, it is important that materials crossing the boundary can be identified and quantified in a mass balance equation. Materials which cross the boundary are broken down into inputs and outputs. Inputs include raw materials and fuel. Raw materials can be further broken down into those which form the final product and those which are "otherwise used." Examples of raw materials which fall into the "otherwise used category include cleaning solvents, etchants, coolants, oils and catalysts. Outputs include products, byproducts, wastes and emissions. If all materials crossing the boundary have been identified, then the mass balance equation will take the following form: Inputs = Outputs - Accumulation For most situations accumulation within the black box process is assumed to be nil. By using this black box approach, processes can be more easily defined. The process description would then include a description of the activities occurring within the black box, the inputs into the box and the outputs from the box. This type of methodology should be used on all the processes covered under the pollution prevention plan. Description of Current and Past Practices A description of current and past pollution prevention efforts is important for two reasons. First, such a description documents past activities in the event that conditions change or an idea resurfaces at some future date. This helps prevent work from being -3-

4 repeated unnecessarily and provides the groundwork for feasibility studies of similar work. Second, this documentation is useful to facilities which have adopted a proactive approach to pollution prevention. In the event that quotas for pollution prevention are imposed, this documentation may serve to lower the quota for a facility by demonstrating that the facility has already implemented a pollution prevention program. Investieation of Options Investigating the available options is very similar to a brainstorming session. Ideas should be solicited from as many sources as is practical for the size of the project. Judgment on the feasibility of each idea should be made only after considering all aspects. In developing options, several areas should be considered: raw material substitutions, product design, waste segregation, employee training, housekeeping, process modifications, on-site recycling and reuse. In addition to internal resources, a number of external resources are available to assist in developing options. Several of these resources are listed below: Feasibility Trade journals Professional organizations Vendors, both equipment and chemical Technical Assistance Programs (TAPS) Universities/colleges Consultants Both the technical and economic feasibility of the options presented in the previous section are addressed as a part of a pollution prevention plan. State pollution prevention planning requirements allow an option to be rejected on either technical or economic grounds. In considering the technical feasibility of an option, a number of details need to be addressed, including pollution prevention, quality, production rate, risk, and worker health and safety. In considering the economic feasibility, most companies have some method of evaluating a project s economics. Typical methods are return on investment (ROI), payback years, net savings or internal rate of return (IRR). DeveloDment of Goals Several state pollution prevention laws require that the facility set reduction or elimination goals. Where a facility is not in a position to set goals, they must state how they will proceed in developing these goals. Such goals should be related to the current -4-

5 toxic pollutants generated or released as either a percentage reduction or as a reduction in the total volume or weight. In considering these goals, it is important to remember that the amount of toxic pollutants generated is often closely related to production. Where possible, the plan's objectives should be tied to production to prevent under- or over-reporting of the progress made. It is also important to be realistic in developing these objectives and not set goals based solely on manufacturers' claims or best case conditions. Start-up problems and "the real world" have a habit of reducing the actual progress made; these should be taken into account in setting objectives. Any calculations, assumptions or rationale used in setting these objectives should be documented in the plan. Measurement of Promess As difficult as it is to measure the volume of generated toxic materials, measuring the amount of progress made is even more difficult. Variations in production can mask or swell any actual gains made in pollution prevention. While a number of measures of production exist, they were generally developed to gauge production for different reasons. Several of the measures which are generally available include: sales, units produced, square footage produced, raw materials used, number of employees and direct labor hours. Selecting a method of measuring production to include in a pollution prevention plan requires that the individual circumstances of the facility be taken into account. Each of the measures of production listed above contain inherent strengths and weaknesses. Sales figures are readily available; however, they vary with inflation, and changes in inventory also will affect the accuracy. Units produced, square footage produced and raw materials used are probably the best methods of relating production to wastes and emissions; however, for plants which produce a large variety of products, it can be difficult to produce accurate comparisons if the product mix changes. The number of employees or direct labor hours can help smooth out any variation in product mix, but is affected by changes in productivity or automation. Reports Most states which require pollution prevention planning also require progress reports or annual summaries. Of the various state pollution prevention planning requirements, this is the area with the greatest amount of variability among the states. Components of several of the most comprehensive progress reports are assembled below: Summary of each objective Summary of the progress made during the year, if any Methods used to achieve this progress An explanation of why the objectives were not achieved, if necessary -5-

6 Any explanation of why the objectives contained in the plan were not achieved should include a discussion of the barriers encountered. Such barriers could include technical, economic and regulatory hurdles. Future Considerations Mike Robertson, Director of the Minnesota Office of Waste Management, summed up the current Minnesota Pollution Prevention Act at a meeting of National Roundtable for Waste Reduction by referring to the act as a "put up or shut up" legislation. During the negotiations to develop this act, industry representatives kept repeating the claim that toxic releases can be best reduced if industry is allowed a free hand in implementing the methods it has developed internally. This act is the result of those claims. However, the concession of industry freedom to implement changes as it sees fit did not come without strings. In 1993, the Minnesota Office of Waste Management is to prepare a report to the legislature evaluating the need to require toxic pollutant use reports and reduction plans. If adopted, these toxic pollutant use reports and reduction plans would extend the current act from covering just the toxics released to all toxic materials used in a facility. This change from the regulatory agencies' command and control methods is definitely appreciated. This new thinking allows industry a chance to develop solutions which fit each individual company's structure and needs. However, the threat of returning to the old regulatory methods still looms over industry. It is for that reason that industry must make self-regulation and self-determination work. -6-

7 Biblioera &y Minnesota Gu ide to Pollution Prevention, Minnesota Office of Waste Management, March 1, State LePislation relating to Pollution Prevention, Compiled by Waste Reduction Institute for Training and Applications Research, Inc., April The Minnesota Pollution Prevention Act. Reauirements for Electroulaters and Surface Finishers, Larry K. Sib&, November 5,