Pollution Prevention Planning

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Chapter 8

• Pollution Prevention Planning

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Basis of Pollution Prevention Planning

• requires a detailed understanding of how a
  company does business and how it makes its
  products
• the plan should provide a mechanism for
  comprehensive and continuous review of companys
  activities as they pertain to environmental issues

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Major Elements of aPollution Prevention Plan

• building support for the plan throughout the
  company
• organizing the program
• setting goals and objectives
• performing a preliminary assessment of P2
  opportunities
• identifying potential problems and solutions

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Organizing the Program

• essential that all company executives buy into
  the value of the plan from the start
• they should convey this message to all
  employees, probably in the form of a formal
  policy statement
• a team should be organized to develop the plan
  that represents all facets of the company, from
  the janitorial staff to the boardroom

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P2 Program Overview
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Preliminary Assessment

• objective of this phase is to review and
  evaluate existing data and establish priorities
  and procedures for detailed assessments
• two primary factors to consider
• goal should be a multi-media approach to P2
• objective is P2, not extensive data gathering

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Considerations for Prioritizing Waste Streams for
Further Study
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P2 Program Plan Development

• use the information from the preliminary
  assessment to write a detailed P2 plan
• plan should
• define the P2 program objectives
• identify potential obstacles and solutions
• define the data collection and analysis
  procedures to be used in later P2 studies
• the P2 plan does not include recommendations for
  P2 projects it describes current practices and a
  methodology for evaluating proposed projects

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Components of a P2 Plan
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Developing and ImplementingP2 Projects

• first step of plan implementation is to conduct
  detailed assessments of potential areas of
  opportunity identified during preliminary
  assessment
• assessment team then proposes and screens P2
  options
• prioritize the options for implementation

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Prioritizing Options

• use a system such as the EPAs Option Rating
  Weighted Sum Method
• determine important criteria in terms of the
  programs goals
• weight the criteria on a scale of 0 (no
  importance) to 10 (highly important)
• rate each option on each criterion and multiply
  by the weight of the criterion
• the sum of these products is the options overall
  rating

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Example ORWSM
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Measuring P2 Progress

• amount of P2 achieved should be continually
  measured so that everyone sees the value of the
  P2 philosophy
• should document both successes and failures
• P2 progress should be measured on a quantitative
  basis
• should normalize the results for changes in
  production

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Environmental Management Systems

• P2 planning procedures previously described are
  now unified into a comprehensive system for
  managing environmental impacts by industry
• ISO 14000 standards establish benchmarks for
  environmental management performance, and
  describe the measures that must be taken by
  industry to conform to these standards

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Environmental Management Systems

• that part of the overall management system
  which includes organizational structure,
  planning, activities, responsibilities,
  practices, procedures, processes and resources
  for developing, implementing, achieving,
  reviewing and maintaining the environmental
  policy.

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ISO 14000 EMS
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ISO 14000 EMS Model Principles

• ISO 14000
• Commitment and Environmental Policy
• Environmental Management Plan
• Implementation
• Measurement and Evaluation
• Continual Review and Improvement

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Components of an EMS
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Environmental Audits

• Objective is to identify and characterize the
  waste streams associated with a process or
  service so that intelligent decisions can be made
  concerning pollution reductions.
• A systematic, documented, periodic, and objective
  review by regulated entities of facility
  operations and practices related to meeting
  environmental requirements.

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Types of Audits
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Audit Data
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Toxic Release Inventory

• The Emergency Planning and Community
  Right-to-Know Act (EPCRA)
• provide information to the public concerning the
  presence and release of toxic and hazardous
  chemicals in the community
• must file written reports, provide notification
  of spills/releases, and maintain toxic chemical
  inventories
• report annually on toxic chemical releases to the
  environment and P2 activities in place (Toxic
  Release Inventory)

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Who should report? TRI

• Firms with ten or more full-time employees
• Included in the Standard Industrial
  Classification codes 20 through 39
• Firms that manufactured or processed a reportable
  toxic chemical in quantities exceeding 25,000
  pounds per year

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TRI Reporting Requirements

• Amounts of each listed chemical released Amounts
  shipped from the facility for recycling, energy
  recovery, treatment or disposal
• Amounts of each chemical recycled, burned for
  energy recovery, or treated at the facility
• Maximum amount of chemical present on-site at the
  facility during the year

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TRI Reporting Requirements (cont.)

• Types of activities conducted at the facility
  involving the toxic chemical
• Source reduction activities
• The efficiency of waste treatment
• Environmental permits held
• Name and telephone number of a contact person

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TRI Chemicals

• 586 toxic chemicals
• 28 chemical categories for 1995

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TRI Releases and Transfers, 1995
TRI Releases TRI Transfers Pounds Pounds
Total releases 2,208,749,411 Total
transfers 3,534,827,951 Fugitive air
85,094,609 To recycling 2,213,731,389 Point
source air 1,177,227,609 To reuse
512,029,726 Surface water 136,315,624 To
treatment 287,576,863 Underground
234,979,709 To POTWs 239,836,516
injection To disposal 279,222,397 On-site
land 275,131,965 Other off-site
2,431,060 releases transfers
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Top Ten TRI ChemicalsReleased in 1995
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Top Ten OSHA CarcinogensReleased in 1995
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Problems with TRI Data

• Discrepancies between reported and actual figure
• Limited number of chemicals covered
• Quantities reported not quality
• how release and transfers are reported
• no information about toxicity of the chemical