• • • • • Pollution Prevention Planning requires a detailed understanding of how a company does business, and how it makes its products. The P2 Plan ultimately should provide a mechanism for the comprehensive and continuous review of the company's activities as they pertain to environmental issues. The major elements of a P2 Plan are: Building support for the plan throughout the company Organizing the program Setting goals and objectives Performing an assessment of P2 options Identifying potential problems and solutions Commitment from Top Management An important role of top management is to articulate a clear, compelling sustainable business intent, and to embed the principles that will govern the company’s policies within the P2 program. Specifically, the top manager at a company (often the Chief Executive Officer, or CEO) is in a key position to convince the company that pollution prevention is a corporate goal. The CEO needs to lead the company is setting sustainability policies and making key environmental decisions. The CEO conveys the company’s position of pollution prevention to employees and other stakeholders – customers, shareholders, etc. Often times, this communication takes the form of a letter from the CEO that expresses the goals, policies, and strategies for the company. An example of this is from Walmart: CEO Walmart.pdf If not in written form, the CEO Commitment can take the form of a video, such as this example from Bausch & Lomb: Baush and Lomb's CEO Statement So, in conclusion, it is the responsibility of management to initiate, communicate, and implement the sustainability values and policies throughout the organization. To do this, they should (1) integrate environmental issues into corporate decisions at all levels, and (2) develop measures to identify, measure, report, and manage the environmental impacts of the organization. Task Force Top management support is not enough...personnel at every level must be dedicated to the P2 effort. • • A task force should be organized to develop the P2 plan, including: A team leader - serves as the motivator of the project and must be an effective communicator with the larger team. Team members - from all groups within the company. The size of the team is dependent on the size of the company and the complexity of the processes. The team leader is usually (but not always!) the Environmental Engineer/Manager (= probably you at some point!). Other team members may include the Production Manager, Process Engineer, Maintenance Supervisor, Finance, etc. Page 255 in Chapter 18 of your text has a list of other example team members. The ultimate role of the task force is to conduct the actual Pollution Prevention Assessment and convey the results/findings to Management. So, the first priority of the task force is to select the specific goals to be achieved. Quantifiable goals should be established, keeping in mind that goals are not unchangeable and should be reviewed periodically. The task force must also be ready to recognize potential barriers - commonly caused by the fear that a P2 program/project will impact product quality and/or slow production while P2 is being implemented. There are other common barriers as well - we'll look at these later in the class. The ultimate purpose of the Assessment Phase is to develop a comprehensive list of potential P2 options. To accomplish this, a detailed analysis of the plant needs to be performed: Detailed Plant Analysis 1. Identify and charactize all waste streams For each waste stream, preliminary information can be obtained from various common environmental reports - waste manifests, environmental audits, Toxic Release Inventory reports, etc. 2. Compile gathered information on flow diagrams and material balances It's preferable to prepare individual flow diagrams/material balances for each process, versus a large area of the facility. 3. Prioritize waste streams Once all waste streams have been identified, priorities shoudl be assigned, taking into consideration (1) complaince with future/present regulations, (2) costs of waste disposal/treatment, (3) potential environmental liabiilty, (4) quantity of waste and hazardous makeup, (5) potential for minimization, and (6) available budget. Worth mentioning - one practical approach is to choose a process/waste stream with a high probablity of successful waste reduction - the proverbial low hangng fruit!. It's a good way to get your P2 efforts rolling successfully, and accomplishing easy projects will also help secure commitments for future P2 efforts. 4. Select the process - conduct a site inspection Once the process is selected, the task force should conduct a site inspection, to gain a clear understanding of the nature/causes of waste generation. The site inspection should identify all areas of waste generation - production processes, maintenance operations, storage areas, finished products, and work-in-progress. Two things to remember in the Assessments Phase: 1. The effort should be a multi-media approach to P2. While we use the term "waste," make sure you are assessing all media - solid waste, water/wastewater, air emissions, etc. Don't forget the objective - pollution prevention. Not data gathering! It's easy to get caught up in endlessly identifying, gathering, compiling, assessing data. Get as much as you need to make intelligent, informed decision, and then keep moving With waste generation understood, the task force can then begin the second part of the Assessment Phase - generating a set of P2 options. This process should follow the pollution prevention hierarchy: source reduction options are looked to first, followed by on site recycling, treatment, and lastly disposal. The task force can use a variety of tools to generate P2 options: their educational knowledge, practical work experience, technical literature, vendors, plant personnel, and regulatory agencies. Each P2 option must then undergo a preliminary qualitative evaluation. the purpose of which is to eliminate options that appear marginal or impractical. One method to determine the most attractive option is called the weighted sum method, also known as the weighted scoring model. Generally, a set of criteria is identified and each criteria is assigned a specific numeric value related to its relative importance (= weighting!), as determined by the task force/assessment. Then, each P2 option is rated against each criteria, and a final "weighted rating" is calculated for each P2 option. Whew! Say what? Raise your hand if you hate statistics! Once the Assessment Phase has identified potential P2 opportunities, the Feasibility Phase is used to determine whether these options are technically and economically feasible. The Technical Evaluation determines whether the P2 option, once it's in place, will really work as intended. Typical considerations for a Technical Evaluation include the following: 1. Technical reliability 2. System safety 3. Maintenance of product quality 4. Space requirements 5. Compatibility with existing systems 6. Downtime necessary for installation 7. Special expertise requirements 8. Added labor, equipment, and utility requirements Perusing that list, it is clear that accomplishing this evaluation requires a comprehensive knowledge of: • • ▪ ▪ pollution prevention techniques relevant manufacturing processes ▪ ▪ resources and limitations vendors Take particular note of that last bullet - vendors. You can't really expect yourself to be an expert on all the various P2 options out there, so when it comes time to technically evaluate them, plan to call in some experts - vendors! They know their product, they know its applications, and they are more than willing to provide answers to those 8 considerations listed above. Granted, they are trying to sell you a product, so a dose of reality needs to be applied to these vendor answers (especially if every one is "yes, we can do that!"). Nonetheless, using outside vendors during the technical evaluation is a sound strategy, and if bench-scale or pilot-scale testing of a P2 option is desired (as it often is), vendors are another great source in that regard. At the conclusion of the Technical Evaluation, all P2 options that are shown to be impractical should be dropped from further consideration - done with those! The Economic Evaluation is conducted using standard economic measures - profitability, return on investment, net present value, etc. Costs should be broken down into capital and operating costs. Module 3 will cover economic evaluation tools in depth, so at this point, just know that once this evaluation is completed, any P2 options shown to be economically impractical can be excluded at this point. All results of the Technical Evaluation should be summarized into some sort of final report that contains the recommendations for implementation of the chosen P2 project(s). This final report can serve an important purpose - justifying the P2 project in order to obtain funding. But wait - you're proposing new or improved processes (dare I say it - you seek change!?!), and now you ask for money on top of that! Oh, the humanity! Kidding aside, it is likely that you will encounter as much resistance at this point as anywhere else, so it's time to fall back on that critical component we started with - Management Committment. During the Implementation Phase, that Management Committment is critical to overcoming resistance to change, securing funding, and keeping the project moving! Pollution Prevention Incentives There are tangible incentives to implementing pollution prevention, consisting of economic benefits, regulatory compliance, reduction in liability, and enhanced public image. Please review and familiarize yourself with Section 18.6 - 18.6.4 in your book, which covers this material in depth. Impediments to Pollution Prevention Impediments to the success of pollution prevention efforts are many, including management apathy, lack of financial commitment, and production concerns, among others. Please review and familiarize yourself with Section 18.7 in your book, which covers some of typical success deterrents. 
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