POLLUTION PREVENTION TOTAL ENVIRONMENTAL MANAGEMENT AN APPROACH TO /y/dbf ENVIRONMENTAL REGULATIONS SEPTEMBER 22, 1992 GARRICK.T.

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1 . *,, /y/dbf TOTAL ENVRONMENTAL MANAGEMENT AN APPROACH TO POLLUTON PREVENTON CONFERENCE FOR SOUTHERN STATES ON HAZARDOUS WASTE MNMZATON, POLLUTON PREVENTON AND ENVRONMENTAL REGULATONS BLOX, MSSSSPP SEPTEMBER 22, 1992 GARRCK.T. SOLOVEY, P.E.

2 't TOTAL ENVRONMENTAL MANAGEMENT AN APPROACH TO POLLUTON PREVENTON Garrick J. Solovey, P.E. Malcolm Pirnie, nc. NTRODUCTON Pollution prevention is emerging as a top priority on environmental agendas throughout the county. Both federal and state initiatives have been launched to focus on reduction or prevention of pollution through cost-effective changes in production, operation, and use of raw materials. The federal Pollution Prevention Act of 1990 (Section 6601), Omnibus Budget Reconciliation Act of 1990, PL , November 5, 1990) declares as a national policy that "pollution should be prevented or reduced at the source whenever feasible". Accordingly, USEPA has proposed rules under 40 CFR Part 342 requiring that waste reduction reporting and goals be added to the current Toxic Chemical Release nventory (TR) reporting requirements of SARA Title Federal Register (September 25, 1991). Additionally, other related environmental legislation such as the Clean Air Amendments, RCRA NPDES Permitting, etc., focus upon pollution prevention and source reduction as a means to achieve compliance. The interaction and impact of these regulations requires industry to view compliance from a "total environmental management" perspective. DSCUSSON Hazardous waste regulations and policies have existed in the United States for over a decade. Federal regulations alone now number 10,000 pages, and the plethora of state, local, and regional regulations is still growing, with no end in sight. We are a nation that demands much from its industrial machine, and we now demand that our industries meet our needs without any environmental impact -a tremendous challenge. Solutions to today's environmental problems require a comprehensive approach to source reduction, treatment, recovery, and disposal. Waste minimization, operational assessments, multi-media treatment scenarios, and health and safety concerns will all play a large part in an overall waste management system. The decade of the 90's wiu see a continued shift from technology to risks, as a basis for hazardous waste compliance as well as remediation. Simply moving hazardous wastes from one disposal site to another is no longer acceptable. The challenge will be to implement permanent solutions that provide the maximum degree of safety to our environment. The regulatory framework echoes this concept. New and proposed regulations are becoming more integrated and multi-media, putting emphasis on source reduction and recycling. Historically, when ongoing production processes have resulted in noncompliance, plant management has turned to end-of-pipe solutions. Such remedies, however, usually do not address source reduction and tend to become significantly expensive over time. As changes to production

3 requirements are instituted, a facility s ability to remain competitive and in continuous compliance may be drastically affected, calling for additional capital investment. For many years, the costs of environmental concerns were not significant components of productivity and operating costs (as were labor, materials and rework). Today, however, environmentally driven costs ranging from waste disposal to the present value of future Superfund liabilities must also be considered by plant and corporate management. An approach to accomplishing this is found in several of the techniques and methods typically used to analyze manufacturing operations for productivity and quality improvement. These methodologies include functional systems analysis, statistical sampling programs, design of experiments (DOE), traditional alternatives analysis and structured decision making techniques. t is important to recognize that solutions to environmental compliance issues do not necessarily involve only equipment, systems and facility modifications. There are other non-capital intensive solutions that can offer dramatic improvement potential when applied in appropriate combinations. For instance, they might include: 1. Procedural changes in the way materials are purchased, processed, inspected or shipped. 2. Substitution of materials which are more environmentally acceptable. 3. mproved material handling schemes which control spills or reflect an improved process. 4. mproved infomation system between various plant functions and the shop floor. 5. Process control changes which reduce variability and achieve consistency and predictability. 6. Optimized work flow through process sequence changes. APPROACH The Total Environmental Management Approach lends itself to a multi-phase program. These phases (Figure 1) typically consist of Phase - Baseline Characterization defines the production process and ascertains the current regulatory situation. This effort reviews and evaluates environmental and production data, flow charts, layouts, throughput, cost data, etc. Phase 1 - Alternative Development evaluates various alternative production, modernization and environmental compliance options. Recommended alternatives based on structured decision making techniques, associated risks and costs are presented and the selection of the preferred alternative is made. Phase Design and Operational Planning consists of a functional design effort, preparation of permit applications, completion of the detailed design, and development of bid packages and specifications. Finally, as required, modifications may be made in operational procedures, informational systems and reporting documents. 2

4 Phase v - nstallation and Start-up finalizes the procurement effort for equipment and contractor services to complete the project. METHODOLOGY n completing the efforts associated with Phases and 11, it is important to realistically characterize the production operations and establish credible baseline. One method found to be extremely useful is called DEF (ntegrated Computer-aided Manufacturing Definition Methodology). DEF is a function analysis methodology developed for the U.S. Air Force which permits defining any process by a series of functions or nodes. Each function or node (Figure 2) can be described in terms of inputs, outputs, the controls or constraints on the function and the mechanisms which transforms the inputs into outputs. Depending upon the size of the project, node-specific information would typically include production operating data and procedures, production costs (direct and indirect), financial parameters and environmental factors. The added value of a baseline cost model is to help identify those operations which are high cost drivers. Analytical resources can then be focused on those operations or variables which yield the greatest return, environmentally and/or operationally. Among the modelling tools used is a software package called SAMS (Standard Assembly Line Manufacturing ndustrial Simulation) (Reference 2) which calculates a unit production cost for a process or system, as described in Figure 3. This value can then be used to compare improvement alternatives developed in Phase 11. For smaller or more focused projects, individual processes and functions can be analyzed utilizing alternate analytical techniques. Proven methods include: Statistical sampling programs or charting of historical data; Taguchi and other Design of Experiment process diagnostic techniques; and Traditional alternatives analysis methods based on rate of return, unit cost, risk analysis or other decision criteria. Once the baseline model is validated and viable alternatives are developed, structured decision making plays an important role. deally, the favored approach to decision making in an uncertain environment is a blend of qualitative and quantitative methods to maximize benefits. Figure 4 illustrates a means of evaluating various alternatives. n comparing operational improvement potential vs. environmental improvement potential, the decisbn-makingprocess is greatly refined and offers alternatives to the client. The value of low or negative return mitigation projects can be weighed against more proactive solutions. Decision criteria may include such items as: Environmental mprovement Potential: amount and type of pollutant; potential for disruption or legal action; level of mitigation technology; compliarice safety margin provided by control technology; and permittability of technology. 3

5 m Operational mprovement Potential: contribution to increasing inventory turns or reducing lead times (speed); reduction in set-up times, relating to product differentiation and mix (flexibility); reduction of product loss and/or rework (quality); and lower operating and capital costs. This approach may be contrasted with an environmental compliance "end-of-pipe" solution, where no benefit from operational improvement is achieved. n addition, negative cash flow is experienced from the purchase and operation of new control technology equipment. On the other hand, a solution combining both operational improvement and environmental improvement can offer an increase in productivity with a return on invested capital. SUMMARY This approach has now been successfully implemented with large firms (13,000 employees and over $500 million in sales) as well as smaller firms (65 employees and $10 million in sales) and in industries as diverse as aircraft production and consumer product packaging. This approach has accomplished the primary goal of achieving environmental compliance while at the same time realizing one or more of the following benefits: Compliance can normally be achieved at reduced installed cost (30 percent to 75 percent) less than "end of pipe" solutions. Operating costs of affected operations have been reduced by as much as 8 to 10 percent. Product quality has increased with a reduction in scrap, rework and defects from 50 percent to 90 percent. The causes of liabilities and impact to operations through legal actions are mitiguted. Waste minimization of industrial waste stream from the beginning to the end of the process can be implemented. Productivity increases through more efficient material management and process improvement in it ia t ives. A significant positive return on investment can be achieved on equipment, facilities and services. A Master Plan can be developed which prioritizes "fast track" projects through to longer term program objectives. a

6 REFERENCES 1. United States Air Force, Wright-Patterson Air Force Base, ntemated Computer-Aided Manufacturing (CAM). Function Modeling Manual (DEF), UM , June, Jet Propulsion Laboratory, Pasadena, California, Standard Assemblv-Line Manufacturing ndustrv Simulation (SAMS) PC User s Guide, SAMTS Release 6.0, December,

7 .. / 4 - t PHASE BASELN E ALTERNATVE CHARACTERaATlON - PHASE 1 PHASE 111 PHASE N DESGN AND lnstallatlon DEVELOPMENT OPERATONAL AN0 START-UP PUNNNQ FGURE - PROJECT ELEMENTS c FGURE 2 - DEF FUNCTONAL DAGRAM r d

8 7. LOADEASKZrS OEGREASE TAP WATER RNSE NTRK: mch WWATERR/NSE OVEN DRY UNLOAD 6ASKETS b Annual Cost by Process Annual Cost by Expense tem PRODUCT COST - FGURE 3 - COMPONENTS OF SAMS MODEL k SELECT MOST ATTRACTVE ALTERNATES (TWO OR MORE) FOR EACH PROJECT High 8 cn E 3 e 8. 0 A CAN FUND ENVlRONMEHTAL MPROVEMENTS 4 REDUCES RSK Key: Clrclesize propoltionel to reguired cqxd inveu&"t LOW LOW Pdentrd fw Emronmental lmpmement High \\ FGURE 4 - STRUCTURED DECSON MAKNG

9 .. TOTAL ENVRONMENTAL MANAGEMENT "A comprehensive operations and engineering solution to environmental problems" 8

10 PRODUCTON MANAGEMENT MANAGEMENT REGULATONS 9...

11 .. TOTAL ENViRONMENTAL MANAGEMENT NCORPORATES 0 RESPONSBLE CARE 0 QUALTY MANAGEMENT 0 BEST MANAGEMENT PRACTCES 0 POLLUTON PREVENTON 0 WASTE MNMZATON 0 HEALTH & SAFETY 0 COMMUNTY AWARENESS e EMERGENCY RESPONSE 10

12 0 Q) V ad 0 QD Lo cl 0 cl Lo CD 0 CD - o.. V Lo a v).. \ v) P 0 * 0' w a n c) P

13 .. TOTAL ENVRONMENTAL MANAGEMENT 1 REGULATORY DRVERS 1 0 CERCLA 0 RCRA e SARA 111 CLEAN AR AMENDMENTS 0 POLLUTON PREVENTON ACT e NPDES PERMTS 0 STATE 8t LOCAL REGULATONS 12

14 TOTAL ENVRONMENTAL MA NAG EMENT 0% OTHER DRVERS 0 LEGSLATVE TRENDS 0 DSPOSAL OPTONS 0 GOBAL MARKET 0 COMPETTVENESS 13

15 .. TRADTONAL APPROACH ENVRONMENTAL COMPLANCE SSUES 1 1 ENVRONMENTAL REGULATONS TREATMENT, STORAGE & DSPOSAL REQUREMENTS t "END OF PPE" u ALTERNATVES SOLUTON 14

16 "END OF PPE" SOLUTONS BENEFTS 0 ACHEVES COMPLANCE 0 L-TLE "SHOP FLOOR" MPACT 0 GENERALLY EXPEDENT DSADVANTAGES 0 CAPTAL NTENSVE NOPAYBACK 0 NCREASES O&M COSTS WASTE STREAMS UNCHANGED CREATES OPERATONAL LMTATONS 15

17 .. "TEM" APPROACH OBJECTVES ENVRONMENTAL COMPLANCE NVESTMENT PAYBACK - MPROVED OPERATONS REDUCED $/UNT HEALTH & SAFETY BENEFTS 16

18 "TEM" APPROACH PROCEDURAL CHANGES 0 MATERAL SUBSTTUTONS MATERAL HANDLNG MODFCATONS MPROVED NFORMATON SYSTEMS PROCESS CONTROL ENHANCEMENTS 0 PROCESS SEQUENCE CHANGES WTH MNMAL EQUPMENT & FACLTY MODFCATONS 17

19 .. NTEGRATED MANUFACTURNG AND ENVRONMENTAL PROJECT ORGA NZA TlON "NTEGRA TED" i A h SAFETY - TOXEOLOGST ENVLAONYENTAL ENGNEEWQ & CONPUANCE -REGULATORY ANALYST OPERATONS & FACLTES ENGNE RNG - MANUFACTURNG ENGNEER :OST ESTMATNG FACLTES & EQUPMENT - ESTUATORS MANAGEMENT SY STE M S -RSK ASSEYENT -ENVlRONUENTAL ENGNEER -NDUSTRAL ENGNEER - PURCHASNG -CONTROLS ENGNEER -FACLTES ENGNEER - PLANNERS -CHEMCAL ENGNEER -DESGN ENGNEER 18

20 TOTAL ENVRONMENTAL MANAGEMENT APPROACH PROJECT ELEMENTS PHASE PHASE PHASE 111 PHASE V BASEUNE CtiARACTERZATK)N > ALTERNATVE DEVELOPMENT +- DESGN AND OPERATONAL PLANNNG NSTALATON AND START-UP 19...

21 .. ALTERNATVE DEVELOPMENT ACTVTES 0 FUNCTONAL ANALYSS 0 "DESGN OF EXPERMENTS" (D.O.E.) 0 ALTERNATVE ANALYSS STRUCTURED DECSONMAKNG 20

22 ~~ DEVELOPMENT OBJECTVES 0 DEVELOP ALTERNATVES EVALUATE ALTERNATVES - a SELECT PREFERRED SOLUTON(S) 0 DEFNE "MASTER" PLAN PROJECT DEFNTON C 21

23 .. FUNCTON DAGRAM CONTROLS EXAMPLE: VAPORS GREASY PARTS SOLVENT OEGRE ASER TANK OPERATOR DlnT L GREASE DEGREASEO (CLEAN) PARTS NPUTS AAE PRODUCTS WHCH AAE TRANSFOAMEO CONTROLS AAE THE CONSTRANTS WHCH ARE PLACED UPON THE ACTVTY. OUTPUTS ARE THE RESULTNQ PAOOUCTS MECHANSMS MECHANSMS AAE THE ACTUAL MEANS BY WHCH NPUTS ARE TRANSFORMED NTO THE OUTPUTS. 22

24 All < All1 A112 FUNCTONAL COSTS - A1 ($70,000) FLOW CHARTS - All ($30,000) A1 11 ($10,000) L A1 12 ($20,000) A12 ($40,000) L EVALUATONS POTENTAL FOR MPAOVEUENT 3PERATONAL SCORE ENWRONMENTAL SCOR cost 4 Source Aeductlon 5 Schedule 3 Recycling 4 ANALYTCAL TOOLS Quality 1 Technology 3 23

25 -. NSTALLATON & START- UP OBJECTVES SSUE BDS PERFORM BD REVEW 0 SELECT CONTRACTOR 0 PROVDE OVERSGHT 24

26 DESGN & OPERATONAL PLANNNG OBJECTVES 0 PERFORM FUNCTONAL DESGN PREPARE PERMTS 0 DEVELOP SPECFCATONS & BD PACKAGE 0 COMPLETE PROCEDURES & SYSTEMS '5

27 BASELNE CHA RACTERZA TON ACTVTES 0 "HSTORCAL" DATA REVEW 0 FUNCTONAL ANALYSS - 0 STATSTCAL ANALYSS 0 COMPLANCE REVEW 0 BUSNESS FORECAST REVEW 0 "TRUE COST" ANALYSS. 26

28 BASELNE CHA RACTERZA TON -~ OBJECTVES e CHARACTERZE PROCESSES DEFNE REGULATORY STATUS 0 DESCRBE OPERATONS 8t SYSTEMS 0 ESTABLSH GOALS POTENTAL OPPORTlJNlTlES b 27

29 a 3 0 c 0 3 n 0 a n W cn

30 s 2 0 i=.. )r 2 P 4 LLt ao EL C Q) m 3 0 4

31 EVALUATE POTENTAL FOR OPERATONAL MPROVEMENT (1) Criteria (3) Baseline Wformance (4). Alternative Degrade No Change mprove 1 -loots O +loots (5) mprovement Score ((2) x (4)i cost 0.4 SlOJpart $ahart. +20% + 2DtS Speed day cue 10 DAYS +28.6% +2.9pts 0.58 Quality /1,000 1 OJ1,OOO 0% opts 0 F exi bi ity 0.2 Limited HGH +8pts 1.6 ~ Total 1.0 mprovement ndex

32 ~ c EVALUATE POTENTAL FOR ENVRONMENTAL MPROVEMENT Criteria Pollutant Weight (0-1) 0.2 (3) (4) Baseline A t ern at ive Degrade NoCPange mprove 1 C?erformance -lopts 0 t10pts J (5) mprovement Score [P x (4)1 1 *o ' Disruption Technology Moderate None Low +5 pts BACT +8 Dts Safety Margin Permit a blilty Total None Yes high +50% +9 pts high +8 pts mprovement ndex L 31

33 _ EVALUATON FACTORS (EXAMPLES) ENVRONMENTAL MPROVEMENT POLLUTANT 0 LEGAL DSRUPTON 0 CONTROL TECHNOLOGY 0 COMPLANCE MARGNS OPERATONAL MPROVEMENT SPEED 0 COSTS 0 FLEXBLTY QUALTY PERMTABLTY 32

34 ENVRONMENTAL SOURCE REDUCTONS NON COUPUANCE NEW REQUREMENTS OPERATONS NTERRUPTON WORK AROUND CAPACTY "NTEGRATEDkk SCHEDULE NFORUATlONlDATA CUSTOMER NEED COMPETTON PRCE SENSTVTY \ 33

35 1 LOAORASKETS DEGREASE Annual Cost by Process D WATER RlNSE OVEN DRY Annual Cost by Expense tem 34

36 Thousands Plating Wastes Chrome/Copper/Rinse Wastes JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEE MAR APR MAY JUN JUL ACT. GAL. DSPOSED AVERAGE PRODUCTON B