18.1 INTRODUCTION A pollution prevention opportunity assessment (PPOA) is defined as a systematic, planned procedure with the objective of identifying ways to reduce or eliminate waste, preferably at the source. Generally, the assessment is preceded by careful planning and organization to set overall pollution prevention goals. Next, the actual assessment procedure begins with a thorough review of a plant’s operations and waste streams and the selection of specific areas of the plant to assess. Once an area is selected as a possible “minimization” or “opportunity” area, various options with the potential for reducing waste generation can be developed and screened. The technical and economic feasibility of each option is evaluated, and finally, the most cost effective and technically feasible options are implemented. Initiating a successful program must begin with a secure commitment from top management, allocation of adequate funding and technical expertise, appropriate organization, and a good understanding of the goals of the assessment and planning required to make it effective. To be successful, pollution prevention must become an integral part of a company’s operations. The PPOA offers opportunities to increase production efficiency, reduce operating costs, reduce potential liability, and improve the environment, while also improving regulatory compliance. Much of the material presented in this chapter has been drawn from the Environmental Protection Agency’s (EPA’s) original “waste minimization opportunity assessment” procedure (U.S. EPA 1988). This procedure has been modified and adapted to apply to what is defined earlier as a pollution prevention opportunity assessment. Figure 18.1 depicts the pollution prevention opportunity assessment procedure. As shown, the assessment procedure can be divided into four phases, which include the following: 1. Planning and organization phase, during which management buy-in and commitment are obtained, overall assessment goals are identified, and an assessment team is assembled. 2. Assessment phase, consisting of the collection of data and identification and screening of potential pollution prevention options. 3. Feasibility analysis phase, consisting of the technical and economic evaluation of each option. 4. Implementation phase, where recommended options are put into place, their performance is monitored, and feedback is provided for the next round of pollution prevention assessment activities at the facility. Each stage depicted in Figure 18.1 is discussed in detail in the following sections. 18.2 PLANNING AND ORGANIZATION This section deals with aspects that are critically important to the ultimate success of any pollution prevention program. First, a commitment from top management to improve the environmental performance of the facility and reduce waste generation must be secured. To do this, the benefits, specifically economic ones, gained from pollution prevention must be clearly demonstrated. Top management must be made aware that the necessary personnel and financial resources must be committed for the program if it is to be a success. Support at the top management level only, however, will not be sufficient in maintaining a successful pollution prevention program. Personnel at every level in the company must be dedicated to the common goal of pollution prevention for it to succeed. Initial contact with employees includes solicitation of their views of how the assessment should be performed and which areas of the facility are likely candidates for pollution prevention. Gaining further employee support can be sought through incentives, bonuses, and awards for pollution prevention achievements. Employees are directly involved in the production of waste and can be instrumental in the overall pollution prevention program if they can be properly motivated. Recognition and rewards can increase employee cooperation and participation, as shown in the Waste Reduction Always Pays (WRAP) program detailed in Chapter 16. FIGURE 18.1 Pollution prevention opportunity assessment procedure. Once a company has committed to minimizing the generation of waste, a task force must be established to conduct the actual assessment and convey its findings to management. A team leader should be selected who serves as the motivator of the project. This individual needs to be an effective communicator with the rest of the team. This task force should comprise individuals from all groups within the company who have an interest in the outcome of the program. The size of the group should reflect the size of the company and the complexity of the processes being evaluated. Members of different departments within the company bring varying perspectives and suggestions to the program. The task force should be separated into different teams concentrating on different areas of the plant with which they have the most knowledge. Some example task forces, often referred to as audits teams in industry, are provided here. Metal finishing department in a large aerospace corporation • Metal finishing department manager (audit team leader) • Process engineer responsible for metal finishing processes • Facilities engineer responsible for metal finishing department • Wastewater treatment department supervisor • Staff environmental engineer Small pesticide formulator • Production manager (audit team leader) • Environmental manager • Maintenance supervisor • Pesticide industry consultant Cyanide plating operation at a government defense facility • Internal audit team • Environmental coordinator (audit team leader) • Environmental engineer • Electroplating facility engineering supervisor • Metallurgist • Materials science group chemist • External audit team • Chemical engineers (two) (audit team leader) • Environmental engineering consultant • Plating chemistry consultant Large offset printing facility • Internal audit team • Plant manager (audit team leader) • Photoprocessing supervisor • Printing supervisor • External audit team • Chemical engineers (two) (audit team leader) • Environmental scientist • Printing industry technical consultant The top priority of the task force is to select the specific pollution prevention goals to be achieved as an outcome of the opportunity assessment. The scope of goals can be limited to one certain process or can be applied to an entire department. Quantifiable goals should be established (a commitment to reduce 10% of the overall waste generation per year is an example). Goals are not unchangeable and should be reviewed periodically. As the ultimate scope of the program is more clearly defined, goals should be reevaluated and updated or revised. As the assessment activities progress, the goals may be altered accordingly. Pollution prevention is an ongoing process and goals need to reflect this. UNIT III STUDY GUIDE Pollution Prevention Audits Course Learning Outcomes for Unit III Upon completion of this unit, students should be able to: 1. Describe federal laws related to pollution prevention. 2. Examine life cycle analyses. 3. Explain pollution prevention audits. 3.1 Summarize the three phases of a pollution prevention audit. 3.2 Discuss steps taken on a pollution prevention audit of a particular product of choice. Required Unit Resources Chapter 18: Pollution Prevention Opportunity Assessment Unit Lesson Introduction We are moving right along. In Unit I, we learned about the pollution prevention (P2) hierarchy. In Unit II, we learned about life cycle analysis. In Unit III, we will learn about P2 audits. P2 audits are also known as P2 opportunity assessments (Dupont et al., 2017). However, whatever phrase is used, the idea is to analyze a situation to find ways to produce less waste and reduce costs while having at least as good a result. The situation can involve running a production line at a factory, an office space with workers at desks using computers, a household, an entire worldwide corporation, or a small farm or a multinational agribusiness; the list is endless. The use of P2 audits is wide-ranging. However, P2 audits are most common for analyzing an industrial production process. This lesson will discuss the reasons for a P2 audit and how to conduct one. P2 Audit Purpose P2 audits formally came into being as a result of the 1990 U.S. Pollution Prevention Act (PPA). The act aimed to bring together many of the seminal environmental laws passed since 1970—primarily the Clean Water Act (CWA), Clean Air Act (CAA), Safe Drinking Water Act (SDWA), and Resource Conservation and Recovery Act (RCRA). While still on the books and still key to U.S. environmental protection, the laws focused on treatment. The U.S. Congress desired a way to encourage companies to look at the beginning of their production lines in order to reduce having to treat or dispose of waste at the end. The PPA introduced the P2 hierarchy as shown below, which was introduced in Unit I. The government aimed to improve the environment by encouraging companies to focus first on P2 (source reduction/chemical substitution) and then on reuse, recycling, treatment, and disposal (in that order). Note that disposal is the least desirable item in the hierarchy. ENV 6301, Advanced Pollution Prevention 1 UNIT x STUDY GUIDE Title P2 hierarchy (Adapted from U.S. Environmental Protection Agency [EPA], n.d.) Lawmakers wished to establish legislation to encourage regulators to work with companies to help them improve the environment—by acting in accordance with the P2 hierarchy—while at the same time reducing corporate costs—by using fewer or more environmentally friendly raw materials and reducing treatment and disposal costs. P2 Audit Tasks and Initiation The P2 audit has three phases: planning, assessment, and analysis. A fourth phase, implementation, could also be included. However, it is not a part of the actual facility audit; it is management’s response to the audit. We will discuss the components below. P2 audits are nearly always initiated by upper management (Dupont et al., 2017). Managers determine why they want to have a P2 audit. Most often, they have been in contact with upper-level management at other companies and with regulators; those parties have then relayed the cost-saving capabilities and waste reduction aspects that can result from a P2 audit. The managers may also have had conversations with their staff regarding P2 audits. Staff with experience in P2 audits, waste management, and regulatory impacts may have an influence on management’s decision to go forward with a P2 audit. ENV 6301, Advanced Pollution Prevention 2 Planning is the first phase of the P2 audit. Management has approved the go-ahead the audit. Either an UNIT xfor STUDY GUIDE outside auditor (or team) is hired or in-house staff will conduct the audit. Review the graphic below to see Title some of the typical steps in the assessment phase. The audit team could include leaders from various departments in the facility as well as floor workers in order to add a different perspective. Upper management has probably laid out the audit objectives, but probably only broadly, such as reducing costs and waste. The P2 audit team will identify ways to achieve those goals (e.g., by focusing on source reduction, process improvements, and chemical and materials substitution). For a production facility, a list of the unit operations used to produce the end product must be drawn up. This could include material and chemicals entering the facility, material preparation, product production, waste collection, and product and waste exiting the facility. Depending on the size of the facility and type of production, there could easily be 10 or 100 or more unit processes. While the plant operations are being delineated, documentation about permits and plant inputs and outputs can be assembled. This will give the team an idea of the waste generation, air emissions, and water emissions, as well as quantities of raw materials entering the facility and products leaving the facility. The last item in the planning phase is to gather the team, possibly around a conference table, and conduct a mock walkthrough of the facility. Since all aspects of the facility are most likely represented by one staff member each, this will involve input from all members of the team. The leader can begin the walkthrough by saying, “Our first process is where materials enter our plant. Mary, you are in charge of receivables. Please describe this process for us.” Then, the audit leader would have the next person in the process describe the next process and so on. People around the table should understand the plant’s flow and be thinking of where to look for improvements. The staff presenting their particular areas may not have a big-picture view of how to improve their areas and may be reluctant to change methods. However, the audit leader needs to make it clear that they are looking to make positive changes in the facility; their goal is not to make anyone look bad. The audit team must have a supportive mindset with no one getting overly defensive if someone suggests changes to another's area of the facility. Now that the P2 team is assembled, the primary work begins. The P2 team must physically walk through the plant. This should happen over an extended period of time; it does not need to be a 1-day or 1-week endeavor. The team can split up and cover different areas. It is helpful if different team members visit the same areas at different times. The idea is to keep an eye out for hose discharges, air leaks, liquid leaks, storage tanks, or areas that seem to be in constant need of cleaning and wiping. The team members will not be experts at the majority of the plant areas they visit. This allows them to see the big-picture functionality of the plant. Plant personnel will likely be ready to answer questions from the P2 team. They will know their job very well. They may even mention things that they have noticed for years and suggested fixes, but the item never got fixed. They may be glad to see a friendly audit team that may finally make some positive changes. However, plant personnel may also be wary that management is looking to downsize some positions, so they may be hesitant to say anything critical of the status quo. ENV 6301, Advanced Pollution Prevention 3 During the assessment phase, the items shown below are important. UNIT x STUDY GUIDE Title Task Always stay focused on the P2 hierarchy. Considerations Are there ways to reduce waste by treatment? Even better, can there be reduced treatment and increased recycling? Even better than that, can there be reduced recycling and increased reuse? Task Identify raw material, chemical, water, energy, and other inputs to the facility. Considerations Are the quantities and items in accord with Phase I discussions? Are there any obvious ways to substitute less harmful chemicals or reduce any inputs? Task Considerations These may be laudable efforts, and the staff may be proud of the amount of recycling. However, while applauding their recycling, try to ask if there are ways to reduce more waste rather than recycling it. Identify current efforts at recycling. After completion of the Phase II assessment, the P2 team assembles its data. This phase could take the longest amount of time. For all suggested changes, costs need to be estimated. For instance, if new, more efficient equipment is suggested, capital and operating costs need to be determined as well as the cost to dismantle and dispose of old equipment. Since this is a P2 audit, there may be a concern about waste. Are there cost-effective ways to reuse or recycle old equipment? Can it be sold to another company? Do personnel need to be trained to use the new equipment? Do process changes require additional or fewer personnel? If environmentally friendly chemical substitutions are suggested, the cost of the new chemicals must be determined. Are there long-term contracts with the old chemical supplier that are costly to terminate? Do process changes need to occur in order to use the substitute chemicals? Reduction or elimination of waste is generally a positive outcome of a P2 audit. However, the company may be tied to long-term disposal contracts. If there are costs to prematurely end any contracts, those costs should be included in the audit. The final step in the analysis phase is to write a report showing all of the findings. It would be helpful to have sections of the report include the components shown below. The cost, timeframe, and overall ease/difficulty of making each change in each section should be indicated. The report will be presented to upper management. Even though management initiated the P2 audit, you may be surprised at their reluctance to go ahead with what may seem like obvious changes. You may not know their motivations. There could be political or familial connections with suppliers or waste disposal companies. Maybe they have an aversion to increasing or reducing personnel. On the other hand, maybe they are looking forward to having the next annual report to show shareholders the positive environmental improvements they are making with a reduction in long-term costs. It is important that the team be prepared to respond to management’s positive and negative comments. ENV 6301, Advanced Pollution Prevention 4 Conclusion UNIT x STUDY GUIDE Title This lesson has presented the purpose and conduction of a P2 audit. The idea is to use the P2 hierarchy as a guide for the audit. Depending on the scope of the audit, the audit could take a month or a year. Having an audit is usually a decision made by upper management. However, the scope is determined in consultation with outside P2 experts or in-house experts. Once the scope is determined, the team members are assembled. In Phase I of the P2 audit, the team plans the audit and lists the unit processes in the plant to make sure the entire team is familiar with more than just their area of plant expertise. The Phase II assessment involves one or more plant walkthroughs. All team members are involved in this phase and note material and process changes that would be helpful. Phase III is the analysis of all of the data. Costs are determined for all proposed changes. Finally, the audit is presented to upper management. At this point, be prepared for questions. However, as the leader, knowledge and familiarity of the audit team lends to a position to defend and advance the suggestions in the audit—knowing that the quality of the audit conducted under leadership, if implemented, will result in cost savings and environmental benefits for the company. References Dupont, R. R., Ganesan., K. & Theodore, L. (2017). Pollution prevention: Sustainability, industrial ecology, and green engineering (2nd ed.). CRC Press. U.S. Environmental Protection Agency. (n.d.). Pollution prevention (P2). https://www.epa.gov/p2 Suggested Unit Resources In order to access the following resource, click the link below. To learn more information about pollution prevention laws and policies, review the web page below. U.S. Environmental Protection Agency. (n.d.). Summary of the Pollution Prevention Act. https://www.epa.gov/laws-regulations/summary-pollution-prevention-act ENV 6301, Advanced Pollution Prevention 5
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