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TOTAL ENVIRONMENTAL MANAGEMENT

AN APPROACH TO

POLLUTION PREVENTION

CONFERIENCE FOR SOUTHERN STATES ON HAZARDOUS WASTE MINIMIZATION,

POLLUTION PREVENTION AND ENVIRONMENTAL REGULATIONS

BILOXI, MISSISSIPPI

SEPTEMBER 22, 1992

GARRICK .T. SOLOVEY, P.E.

I 't

TOTAL ENVIRONMENTAL MANAGEMENT AN APPROACH TO POLLUTION PREVENTION

Garrick J. Solovey, P.E.

Malcolm Pirnie, Inc.

INTRODUCTION

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 101-508, 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 Inventory (TRI) reporting requirements of SARA Title 111.56 Federal Register 46475 (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.

DISCUSSION

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

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.

It 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. Improved material handling schemes which control spills or reflect an improved process.

4. Improved 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 o f

Phase I - 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 I1 - 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 111 - 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.

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Phase Iv - Installation and Start-up finalizes the procurement effort for equipment and contractor services to complete the project.

METHODOLOGY

In completing the efforts associated with Phases I and 11, it is important to realistically characterize the production operations and establish credible baseline. One method found to be extremely useful is called IDEF (Integrated Computer-aided Manufacturing Definition Methodology). IDEF 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 SAMIS (Standard Assembly Line Manufacturing Industrial 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. Ideally, 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.

In 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 Improvement 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.

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m Operational Improvement 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. In 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:

1.

2.

3.

4.

5.

6.

7.

8.

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

REFERENCES

1. United States Air Force, Wright-Patterson Air Force Base, Intemated Computer-Aided Manufacturing (ICAM). Function Modeling Manual (IDEF), UM11023 1100, June, 1981.

2. Jet Propulsion Laboratory, Pasadena, California, Standard Assemblv-Line Manufacturing Industrv Simulation (SAMIS) PC User’s Guide, SAMTS Release 6.0, December, 1985.

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PHASE I

BASELIN E CHARACTERaATlON

/ 4

t

PHASE 111 PHASE N PHASE I1 - ALTERNATIVE DESIGN AND - lNsTALLATlON DEVELOPMENT OPERATIONAL AN0 START-UP

PUNNINQ

I

FIGURE I - PROJECT ELEMENTS

c FIGURE 2 - IDEF FUNCTIONAL DIAGRAM

d

r

I .

I LOADEASKZrS

I OEGREASE

TAP WATER RINSE

NITRK: mCH

I WWATERR/NSE

I OVEN DRY

UNLOAD 6ASKETS

Annual Cost by Process

b

PRODUCT

COST - Annual Cost by Expense

Item

FIGURE 3 - COMPONENTS OF SAMIS MODEL k

High A 8 cn E 3

e 8. 0

LOW

SELECT MOST ATTRACTIVE ALTERNATES (TWO OR MORE) FOR EACH PROJECT

CAN FUND ENVlRONMEHTAL IMPROVEMENTS

I I 4 REDUCES

RISK

Key: Clrclesize propoltionel to reguired cqxd inveu&"t

I Pdentrd fw Emronmental lmpmement

LOW High

FIGURE 4 - STRUCTURED DECISION MAKING \\

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TOTAL ENVIRONMENTAL

MANAGEMENT "A comprehensive operations and engineering solution to environmental problems"

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PRODUCTION

MANAGEMENT

MANAGEMENT

REGULATIONS

9

. ..

. .

I TOTAL ENViRONMENTAL MANAGEMENT

INCORPORATES

0 RESPONSIBLE CARE

0 QUALITY MANAGEMENT

0 BEST MANAGEMENT PRACTICES

0 POLLUTION PREVENTION

0 WASTE MINIMIZATION

0 HEALTH & SAFETY

0 COMMUNITY AWARENESS

e EMERGENCY RESPONSE

10

I- o . .

..

\

0 Q)

VI aD

0 QD

Lo Icl

0 Icl

Lo CD

0 CD

VI Lo

a v)

v) P

0 *

In c)

P

0' a w

. .

TOTAL ENVIRONMENTAL MANAGEMENT

1 REGULATORY DRIVERS 1 0 CERCLA

0 RCRA

e SARA 111

CLEAN AIR AMENDMENTS

0 POLLUTION PREVENTION ACT

e NPDES PERMITS 0 STATE 8t LOCAL REGULATIONS

12

TOTAL ENVIRONMENTAL MA NAG EMENT 0%

OTHER DRIVERS I

0 LEGISLATIVE TRENDS

0 DISPOSAL OPTIONS

0 GOBAL MARKET

0 COMPETITIVENESS

13

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TRADITIONAL APPROACH

I ENVIRONMENTAL COMPLIANCE ISSUES

1

I 1

ENVIRONMENTAL

REGULATIONS

TREATMENT, STORAGE & DISPOSAL

REQUIREMENTS

I t

"END OF PIPE" ALTERNATIVES

SOLUTION u 14

I "END OF PIPE" SOLUTIONS

BENEFITS

0 ACHIEVES COMPLIANCE

0 LI-ITLE "SHOP FLOOR" IMPACT

0 GENERALLY EXPEDIENT

DISADVANTAGES

0 CAPITAL INTENSIVE

NOPAYBACK

0 INCREASES O&M COSTS

WASTE STREAMS UNCHANGED

CREATES OPERATIONAL LIMITATIONS

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. .

"TEM" APPROACH

OBJECTIVES

ENVIRONMENTAL COMPLIANCE

INVESTMENT PAYBACK -

IMPROVED OPERATIONS

REDUCED $/UNIT

HEALTH & SAFETY BENEFITS

16

"TEM" APPROACH

PROCEDURAL CHANGES

0 MATERIAL SUBSTITUTIONS

MATERIAL HANDLING MODIFICATIONS

IMPROVED INFORMATION SYSTEMS

PROCESS CONTROL ENHANCEMENTS

0 PROCESS SEQUENCE CHANGES WITH MINIMAL

EQUIPMENT & FACILITY MODIFICATIONS 17

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INTEGRATED MANUFACTURING AND ENVIRONMENTAL PROJECT ORGA NIZA TlON

"INTEGRA TED"

i I I I h SAFETY A

- TOXEOLOGIST

-RISK ASSEYENT

ENVLAONYENTAL ENGINEEWQ &

CONPUANCE

-REGULATORY ANALYST

-ENVlRONUENTAL ENGINEER

-CONTROLS ENGINEER

OPERATIONS & FACILITIES I ENGINE€ RING

- MANUFACTURING ENGINEER

-INDUSTRIAL ENGINEER

-FACILITIES ENGINEER

:OST ESTIMATING FACILITIES & EQUIPMENT

- ESTIUATORS

- PURCHASING

- PLANNERS

MANAGEMENT SY STE M S

-CHEMICAL ENGINEER

-DESIGN ENGINEER

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TOTAL ENVIRONMENTAL MANAGEMENT

PHASE II PHASE I

BASEUNE ALTERNATIVE CtiARACTERIZATK)N DEVELOPMENT

>

APPROACH

PHASE 111

DESIGN AND OPERATIONAL

PLANNING +-

PROJECT ELEMENTS

PHASE IV

INSTALIATION AND START-UP

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...

. .

ALTERNATIVE DEVELOPMENT

ACTIVITIES

0 FUNCTIONAL ANALYSIS

0 "DESIGN OF EXPERIMENTS" (D.O.E.)

0 ALTERNATIVE ANALYSIS

STRUCTURED DECISIONMAKING

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DEVELOPMENT I ~~

OBJECTIVES

0 DEVELOP ALTERNATIVES

EVALUATE ALTERNATIVES -

a SELECT PREFERRED SOLUTION(S)

0 DEFINE "MASTER" PLAN

I PROJECT DEFINITION C 21

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EXAMPLE:

FUNCTION DIAGRAM CONTROLS

VAPORS

GREASY PARTS DlnT L GREASE

DEGREASEO (CLEAN) PARTS

I OPERATOR SOLVENT OEGRE ASER

TANK

MECHANISMS

INPUTS CONTROLS AAE THE CONSTRAINTS WHICH ARE PLACED UPON THE ACTIVITY.

OUTPUTS ARE THE RESULTINQ PAOOUCTS

MECHANISMS AAE THE ACTUAL MEANS BY WHICH INPUTS ARE TRANSFORMED INTO THE OUTPUTS.

AAE PRODUCTS WHICH AAE TRANSFOAMEO

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I

All1

A112 All <

I FLOW CHARTS

A l l ($30,000) - A1 ($70,000) A12 ($40,000) FUNCTIONAL COSTS

-

POTENTIAL FOR IMPAOVEUENT 3PERATIONAL SCORE ENWRONMENTAL SCOR

cost 4 Source Aeductlon 5

EVALUATIONS

A1 1 1 ($1 0,000) L A1 12 ($20,000)

Schedule 3 Recycling 4 ANALYTICAL TOOLS Quality 1 Technology 3

L

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- .

I INSTALLATION & START- UP

OBJECTIVES

ISSUE BIDS

PERFORM BID REVIEW

0 SELECT CONTRACTOR

0 PROVIDE OVERSIGHT

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I DESIGN & OPERATIONAL

PLANNING

OBJECTIVES

0 PERFORM FUNCTIONAL DESIGN

PREPARE PERMITS

0 DEVELOP SPECIFICATIONS & BID PACKAGE

0 COMPLETE PROCEDURES & SYSTEMS

'5

I BASELINE CHA RACTERIZA TION

ACTIVITIES

0 "HISTORICAL" DATA REVIEW

0 FUNCTIONAL ANALYSIS -

0 STATISTICAL ANALYSIS

0 COMPLIANCE REVIEW

0 BUSINESS FORECAST REVIEW

0 "TRUE COST" ANALYSIS . 26

BASELINE CHA RACTERIZA TION -~

OBJECTIVES

e CHARACTERIZE PROCESSES

DEFINE REGULATORY STATUS

0 DESCRIBE OPERATIONS 8t SYSTEMS

0 ESTABLISH GOALS

I POTENTIAL OPPORTlJNlTlES b

27

I a 3 0 c 0 3 n 0 a a n W cn

4 111 9 0 s 2 0 i=

4

LLt

.. )r

2

C Q)

I m

3 0 4

P

ao EL

EVALUATE POTENTIAL FOR OPERATIONAL IMPROVEMENT

(1)

Criteria

cost

Speed

Quality

FI exi bi I ity

Total

0.4

0.2

0.2

0.2

1.0

(3)

Baseline Wformance

SlOJpart

14 day cue

10/1,000

Limited

(4). Alternative

-loots O +loots

Degrade No Change Improve 1

. +20% $ahart + 2DtS - -. .

10 DAYS +28.6% +2.9pts

1 OJ1,OOO 0%

opts

HIGH +8pts

Improvement Index

(5) Improvement

Score ((2) x (4)i

0.8

0.58

0

1.6

2.98 I ~

30

c

Criteria

Pollutant

EVALUATE POTENTIAL FOR ENVIRONMENTAL

Weight (0-1)

0.2

IMPROVEMENT

Disruption

'I Technology

0.3

0.1

Yes

Safety Margin

high +8 pts Permit a blilty

Total

(3) (4) AI t ern at ive

Baseline I Degrade I NoCPange Improve 1 I C ~

I J

?erformance I -lopts 0 t10pts I

Moderate Low +5 pts

I

None BACT +8 Dts

None high +50% +9 pts

I

Improvement Index

(5) Improvement

Score [PI x (4)1

1 *o

1.5

0.8

0.9

2.4 L

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I _

EVALUATION FACTORS (EXAMPLES)

ENVIRONMENTAL IMPROVEMENT

POLLUTANT

0 LEGAL DISRUPTION

0 CONTROL TECHNOLOGY

0 COMPLIANCE MARGINS

PERMITABILITY

OPERATIONAL IMPROVEMENT

SPEED

0 COSTS

0 FLEXIBILITY

QUALITY

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ENVIRONMENTAL OPERATIONS

SOURCE REDUCTIONS INTERRUPTION

WORK AROUND NON COUPUANCE NEW REQUIREMENTS CAPACITY

"INTEGRATEDkk

CUSTOMER NEED

COMPETITION SCHEDULE

INFORUATlONlDATA PRICE SENSITIVITY

\

33

1 LOAORASKETS

I DEGREASE

DI WATER RlNSE

I OVEN DRY

Annual Cost by Process

Annual Cost by Expense

Item

34

Plating Wastes Chrome/Copper/Rinse Wastes

Thousands

..................................

.......................................

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEE MAR APR MAY JUN JUL

ACT. GAL. DISPOSED AVERAGE PRODUCTION __B__ + -4---

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