CHAPTER 3, US EPA Facility Pollution Prevention Guide, EPA/600/R-92/088 DEVELOPING AND IMPLEMENTING POLLUTION PREVENTION PROJECTS This chapter outlines how to execute the pollution prevention program plan that resulted from the activities outlined in Chapter 2. The figure to the right illustrates the steps that will be discussed in this chapter and places them in the context of the overall effort. As with the other stages, the degree of formality should be tailored to the size of the company and the diversity of its product lines. Thus, a small company may need to do only one detailed assessment and prepare one implementation plan, while a larger, more diverse company might require several in order to address all production processes. If multiple plans are developed, it will be necessary to examine how they fit together, resolving any conflicts and prioritizing them to fit available resources. DETAILED ASSESSMENT PHASE As part of your program design, you probably did a preliminary assessment of your facility to identify areas of opportunity for pollution prevention. Now, detailed assessments will focus on specific areas targeted by the preliminary assessment. Assessment teams will be assigned to each operational area of the facility to gather data for later analysis. As was the case during the preliminary assessment, they will use existing written materials and site evaluations. However, they will delve much more deeply into each production process, interviewing workers and compiling necessary data that may not have been collected before. During this process, the team may identify some options that can be implemented quickly and with little cost or risk. It is likely, however, that many options will be more complex and will require in-depth analysis later. Designate the Detailed Assessment Team(s) The detailed assessment phase should be started by a member of the pollution prevention task force, which was identified during program design. Unless your company is small enough that the task force and the detailed assessment team are the same, you will need to name additional staff to comprise one or more detailed assessment teams. The focus of each assessment team will be relatively specific. It is likely that three to six people will prove to be a workable number for an assessment team. Specialists can be consulted as needed. Ideally, one member of the task force will be included on each team; this will facilitate communication. The additional team members should be people with direct responsibility for and knowledge of the waste streams and/or areas of the facility under consideration. A multidisciplinary team is likely to be more successful in achieving a comprehensive assessment and providing the best input possible to the data analysis and option definition stages. To the extent practical, you should consider engineers, supervisors, and production workers as well as finance and accounting, purchasing, and administrative staff when selecting the team members. Aside from field of expertise, consider a candidate's ability to work on a team, apparent interest in and commitment to the program, and capacity for looking at situations from new perspec- tives and for thinking creatively. Areas of expertise to consider for detailed assessment teams:  Management  Engineering  Quality control  Production and maintenance  Accounting and purchasing  Legal  Health and safety  Research and development Examples of Detailed Assessment Teams: Metal finishing department in a large defense contractor: - Metal finishing department manager - 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 supervisor - Environmental engineer - Maintenance engineer Cyanide plating operation: * Environmental engineer - Electroplating facility engineering supervisor - Plant chemist Large offset printing facility: Internal assessment team * Environmental engineer - Film processing supervisor - Pressroom supervisor Outside assessment team (possible alternative team) * Engineer from within establishment - Environmental scientist - Printing industry technical consultant * = Recommended team leader Box 12 The box on the preceding page (Box 12) gives examples of assessment teams that might be designated for facilities of various sizes and in different industries. Note that for each team, the team leader is someone who has day-to-day operations responsibility and experience. Review Data and Sites Numerous data sources probably exist for a given site. Many of these may have been identified during the preliminary assess- ment. The detailed assessment team for that site will search for additional sources of data that will be useful in studying the targeted processes, operations, or waste streams. However, most of their effort will be directed toward perform- ing a thorough site review and interviewing workers. This will help them understand the data already collected and identify factors that are not well documented and for which data will need to be collected. Site review guidelines are outlined in Box 13. Site reviews supplement and explain existing data. Site reviews should be well planned.  Prepare an agenda in advance that covers all points that still require clarification. Provide staff contacts in the area being assessed with the agenda several days before the inspection.  Schedule the inspection to coincide with the particular operation that is of interest (e.g., makeup chemical addition, bath sampling, bath dumping, startup, shutdown, etc.).  Monitor the operation at different times during all shifts, and if needed, during all three shifts, especially when waste generation is highly dependent on human involvement (e.g., in painting or parts cleaning operations).  Interview the operators, shift supervisors, and work leaders in the assessed area. Discuss the waste generation aspects of the operation. Note their familiarity with the impacts their operation may have on other operations.  Photograph or videotape the area of interest, if warranted. Pictures are valuable in the absence of plant layout drawings. Many details can be captured in pictures that otherwise could be forgotten or inaccurately recalled at a later date.  Observe the "housekeeping" aspects of the operation. Check for signs of spills or leaks. Visit the maintenance shop and ask about problems in keeping the equipment leak- free. Assess the overall cleanliness of the site. Pay attention to odors and fumes.  Assess the organizational structure and level of coordination of environmental activities between various departments.  Assess administrative controls, such as cost accounting procedures, material purchasing procedures, and waste collection procedures. Box 13 A careful site review will provide the assessment team with a systems perspective of the process, operation, or waste stream in question and of how it fits into the overall facility operation. This perspective is a prerequisite for thorough assessment of options in later phases of the pollution prevention plan development cycle. If consultants are on the assessment team, the site review enables them to become familiar enough with the facility to utilize their expertise effectively. The site review should not be performed perfunctorily, even though the assessment team members who are employed at the facility will all be familiar to some extent with the work-site being reviewed. Those who are not involved in the day-to-day operation in that area will see factors that otherwise would be overlooked. Furthermore, personnel assigned to that specific site will often see it in a new light when performing a pollution prevention assessment. Some of the information that can be gathered through site reviews is summarized in Box 14. Site reviews provide a systems perspective. Typical questions to ask during site reviews include:  What is the composition of the waste streams and emissions generated in the company? What is their quantity?  From which production processes or treatments do these waste streams and emissions originate?  Which waste materials and emissions fall under environmental regulations?  What raw materials and input materials in the company or production process generate these waste streams and emissions?  How much of a specific raw or input material is found in each waste stream?  What quantity of materials are lost in the form of volatile emissions?  How efficient is the production process and the various steps of that process?  Are any unnecessary waste materials or emissions produced by mixing materials - which could otherwise be reused with other waste materials?  Which good housekeeping practices are already in force in the company to limit the generation of waste materials?  What process controls are already in use to improve process efficiency? Box 14 Site visits should be well-planned to ensure that maximum benefit is obtained without excessive expenditures of time. While multiple visits to check or supplement data will usually be required, good planning can minimize such repetitions. Several suggestions for preparing for site visits are given below. Review existing documentation, such as operators' manuals and purchasing and shipping records. This will enable the team to focus on the topics to be investigated. Decide on data collection formats to ensure that the data collection will be rigorous and compatible with the compilation and analysis stage described on the following page. In particular, it is worthwhile to predetermine the boundaries and bases for calculating the energy and material balances that will be worked out during that stage. Doing a preliminary balance during the data collection phase can help identify data gaps and determine sampling requirements. The worksheets in Appendix A can be used for data collection, or you may decide to customize them or create entirely new ones to conform to the nature of the specific site. Appendices B and C may be helpful in developing new worksheets. Photographs are an excellent means of capturing extensive detail quickly and accurately. Prepare an agenda and make sure that all team members and supervisors at the site receive it in advance. Schedule site visits by contacting the staff in the area to be visited. Ask when they will be performing the operations you are particularly interested in assessing. Observe operations as they are actually performed by different shifts and under various circumstances. Process units may be operated differently from the methods described in their operat- ing manuals, or the equipment may have been modified without being so documented in the flow diagrams or equipment lists. Interview workers and supervisors to determine how aware they are of what wastes are generated by their operation. They may have suggestions on reducing these wastes. Follow the process from beginning to end, from the point where input materials enter the work-site to the point where products and wastes exit. This will help identify all suspected sources of waste. Waste sources to inspect include the production process; piping; maintenance operations; storage areas for raw materials, finished product, and work-in-process. Examine house- keeping practices and the waste treatment area, as well. Make follow-up visits as missing or unclear data are identi- fied during the analysis stage. Good planning is essential for efficient site reviews. Decide on data sources and collection procedures. Look at procedures as they are performed in the production envi- ronment. Identify waste sources. Organize and Document Process Information Analyzing process information involves preparing material and energy balances as a means of analyzing pollution sources and opportunities for eliminating them. Such a balance is an organized system of accounting for the flow, generation, consumption, and accumulation of mass and energy in a process. In its simplest form, a material balance is drawn up according to the mass conservation principle: Mass in = Mass out - Generation + Consumption + Accumulation If no chemical or nuclear reactions occur and the process progresses in a steady state, the material balance for any specific compound or constitutent is as follows: Mass out = Mass in A material and energy balance for a given substance will reveal quantities lost to emission or to accumulation in equipment. The first step in preparing a balance is to draw a process diagram, which is a visual means of organizing the data on the energy and material flows and on the composition of the streams entering and leaving the system. Such a diagram shows the system boundaries, all streams entering and leaving the process, and points at which wastes are generated. An example of a flow diagram appears as Figure 4. (Figure 4 is deleted from this electronic version of this document. A fax of this figure may be requested from the Ohio EPA, Office of Pollution Prevention by calling 614/644-3469. Note this figure is page 33 of the manual.) A process diagram organizes data graphically. Figure 4. Example Flow Diagram Boundaries should be selected according to the factors that are important for measuring the type and quantity of pollution prevented, the quality of the product, and the economics of the process. The amount of material input should equal the amount exiting, corrected for accumulation and creation or destruction. A material balance should be calculated for each component entering and leaving the process. When chemical reactions take place in a system, there is an advantage to performing the material balance on the elements involved. The limitations of material and energy balances should be understood. They are useful for organizing and extending pollu- tion prevention data and should be used whenever possible. However, the user should recognize that most balance diagrams will be incomplete, approximate, or both.  Most processes have numerous process streams, many of which affect various environmental media.  The exact composition of many streams is unknown and cannot be easily analyzed.  Phase changes occur within the process, requiring multi- media analysis and correlation.  Plant operations or product mix change frequently, so the material and energy flows cannot be accurately character- ized by a single balance diagram.  Many sites lack sufficient historical data to characterize all streams. These are examples of the complexities that will recur in analyzing real world processes. Despite the limitations, material balances are essential to organize data, identify gaps, and permit estimation of missing information. They can help calculate concentrations of waste constituents where quantitative composition data are limited. They are particularly useful if there are points in the production process where it is difficult or uneconomical to collect or analyze samples. Data collection problems, such as an inaccurate reading or an unmeasured release, can be revealed when "mass in" fails to equal "mass out." Such an imbalance can also indicate that fugitive emissions are occurring. For example, solvent evaporation from a parts cleaning tank can be estimated as the difference between solvent put into the tank and solvent removed by disposal, recycling, or dragout. Each component should have a material balance calculated. Material and energy balances have some limitations. Imbalances indicate that the data are inaccurate and should be reviewed or that fugitive emissions of waste are occurring. DEFINE POLLUTION PREVENTION OPTIONS Once the sources and nature of wastes generated have been described, the assessment team enters the creative phase. In a two-step procedure, they will propose and then screen pollution prevention options. Their objective is to generate a comprehensive set of options, ranked as to priority, that merit detailed feasibility assessment. Propose Options As with other planning efforts, the best results will be achieved in an environment that encourages creativity and inde- pendent thinking by each assessment team member. Brainstorming sessions are useful for encouraging creative thought because they provide a nonjudgmental, synergistic atmosphere in which ideas can be shared. Then, these ideas can be developed by means of group decision-making techniques. This approach will enable the assessment team to identify options that the individual members might not have come up with on their own. Worksheet 7 in Appendix A is a suggested format for describing each option as it is proposed. Structuring option definition sessions according to the U.S. EPA hierarchy (Chapter 1, Figure 1) will encourage the team to look first at true source reduction options, such as improved operating procedures and changes in technology, materials, and products. Then, options that involve reuse, or closed-loop recy- cling, would be examined. Finally, the team would consider off- line and off-site recycling and alternative treatment and disposal methods. Encourage creativity in option definition sessions. Screen Options Many proposed options may result from the previous step. Since detailed technical, economic, and environmental feasibility analysis can be costly, the proposed options should be screened by the assessment team. Some options will be found to have no cost or risk attached; these can be implemented immediately. Others will be found to have marginal value or to be impractical; these will be dropped from further consideration. The remaining options will generally be found to require feasibility assessment. This screening does not require detailed and costly study. Screening procedures can range from an informal review with a decision made by either the program manager or a vote of the team members, to the use of quantitative decision-making tools. Box 15 on the next page shows questions to be considered in option screening. The informal review is a procedure by which the assessment team selects the options that appear best after discussing and examining each option. As is the case when the team is proposing options, their approach to screening should employ group decision-making techniques whenever possible. In more complicated situations, the team may need to use the weighted sum method (see Appendix E) or another, similar technique designed for use in complex decision-making situations. Categorize proposed options as:  no risk or cost: implement immediately  marginal value or impractical: drop  complex: perform feasibility analysis DO FEASIBILITY ANALYSES The final product of the option definition phase is a prioritized list of pollution prevention options. These options now should be examined to determine which are technically, environmentally, and economically feasible and to prioritize them for implementation. Option screening should consider these questions:  Which options will best achieve the goal of waste reduction?  What are the main benefits to be gained by implementing this option (e.g., financial, compliance, liability, workplace safety, etc.)?  Does the necessary technology exist to develop the option?  How much does it cost? Does it appear to be cost-effective, meriting in-depth economic feasibility assessment?  Can the option be implemented within a reasonable amount of time without dis- rupting production?  Does the option have a good "track record"? If not, is there convincing evidence that the option will work as required?  What other areas will be affected? Box 15 Depending on the resources currently available, it may be neces- sary to postpone feasibility assessments for some options. However, all options should be evaluated eventually. Technical Evaluation The assessment team will perform a technical evaluation to determine whether a proposed pollution prevention option is likely to work in a specific application. Technical evaluation for a given option may be relatively quick or it may require extensive investigation. The list in Box 16 suggests some criteria that could be used in a technical evaluation. Some of these are more detailed versions of questions asked during the option screening phase. All groups in the facility that will be affected directly if the option is adopted should contribute to the technical evaluation. This might include people from production, maintenance, QC/QA, and purchasing. In some cases, customers may need to be consulted and their requirements verified. Prior consultation and review with these groups will ensure the viability and acceptance of an option. If the option calls for a change in production methods or input materials, carefully assess the likely effects on the quality of the final product. If after the technical evaluation the option appears impractical or can be expected to lower product quality, drop it. For options that do not involve a significant capital expenditure, the team can use a "fast-track" approach. For example, procedural or housekeeping changes can often be implemented quickly, after the appropriate review, approvals, and training have been accomplished. Material substitutions also can be accomplished relatively quickly if there are no major production rate, product quality, or equipment changes involved. Technical evaluations require the expertise of a variety of people. Some options can be implemented right away. Typical technical evaluation criteria:  Will it reduce waste?  Is the system safe for our workers?  Will our product quality be improved or maintained?  Do we have space available in our facility?  Are the new equipment, materials, or procedures compatible with our produc- tion operating procedures, work flow, and production rates?  Will we need to hire additional labor to implement the option?  Will we need to train or hire personnel with special expertise to operate or maintain the new system?  Do we have the utilities needed to run the equipment? Or, must they be installed at increased capital cost?  How long will production be stopped during system installation?  Will the vendor provide acceptable service?  Will the system create other environmental problems? Box 16 Equipment-related options or process changes are more expen- sive and may affect production rate or product quality. Therefore, such options require more study. The assessment team will want to determine whether the option will perform in the field under conditions similar to the planned application. In some cases, they can arrange, through equipment vendors and industry contacts, visits to existing installations. Experienced operators' comments are especially important and should be compared with vendors' claims. A bench-scale or pilot-scale demonstration may be needed. It may also be possible to obtain scale-up data using a rental test unit for bench-scale or pilot- scale experiments. Some vendors will install equipment on a trial basis, with acceptance and payment after a prescribed time, if the user is satisfied. Options that can affect production or quality need careful study. Environmental Evaluation In this step, the pollution prevention assessment team will weigh the advantages and disadvantages of each option with regard to the environment. Often the environmental advantage is obvious Ä the toxicity of a waste stream will be reduced without generating a new waste stream. Most housekeeping and direct efficiency improvements have this advantage. With such options, the environmental situation in the company improves without new environmental problems arising. Environmental considerations:  effect on number and toxicity of waste streams  risk of transfer to other media  environmental impact of alternate input materials  energy consumption Unfortunately, the environmental evaluation is not always so clearcut. Some options require a thorough environmental evalua- tion, especially if they involve product or process changes or the substitution of raw materials. For example, the engine rebuilding industry is dropping solvent and alkaline cleaners to remove grease and dirt from engines prior to disassembly. Instead, they are using high- temperature baking followed by shot blasting. This shift eliminates waste cleaner but presents a risk of atmospheric release because small quantities of components from the grease can vaporize. To make a sound evaluation, the team should gather informa- tion on the environmental aspects of the relevant product, raw material or constituent part of the process. This information would consider the environmental effects not only of the produc- tion phase and product life cycle but also of extracting and transporting the alternative raw materials and of treating any unavoidable waste. Energy consumption should also be considered. To make a sound choice, the evaluation should consider the entire life cycle of both the product and the production process. Energy conservation is discussed in Chapter 8. Consider energy requirements. Economic Evaluation Estimating the costs and benefits of some proposed pollution prevention projects is straightforward, while others prove to be complex. Despite the ease with which the cost calculations may be done for some options, it is advisable to document all that are adopted and to estimate the economic effects of each. This will help ensure that these real accomplishments of your pollution prevention program will not be overlooked when you measure the program's progress, as discussed in Chapter 4. Document cost calculations so that the full benefit of the pollution prevention program can be quantified. If a project has no significant capital costs, the decision is relatively simple. Its profitability can be judged by whether or not it reduces operating costs and/or prevents pollution. If it does, it can be implemented quickly. Installation of flow controls and improvement of operating practices, for example, probably will not require extensive analysis before they are adopted. Worksheet 9 (in Appendix A) can be used to document analysis of this type. Projects with significant capital costs attached will require more detailed analysis. Worksheet 9 may be a good starting point, but an in-depth evaluation like the example that appears as Appendix F will be required. There are a number of factors that make pollution prevention costs and benefits difficult to calculate for many proposed projects. The total costs of continuing to pollute are not discernible in most corporate accounting systems. Furthermore, many of these costs are probabilistic Ä although the risks are real, it is difficult to predict the cost and even the occurrence date from past experience. The long-term need to avoid the spiraling costs of waste treatment, storage, and disposal as well as future regulatory and liability entanglements are likely to be major elements of your pollution prevention project economic evaluation. Chapter 6 describes the Total Cost Analysis approach and gives an overview of the types of cost and benefit factors that should be examined when studying proposed pollution prevention projects. It suggests some approaches to calculating indirect and probabilistic costs so that their full impact can be included in economic feasibility assessments. It also discusses ways to track the economic effects of pollution prevention projects after they are implemented. Operational changes usually can be installed quickly. Most accounting systems do not reveal the total costs of continuing to pollute. Total Cost Analysis is a useful mechanism for understanding the financial impact of pollution prevention projects. WRITE THE ASSESSMENT REPORT The task force should write a report that summarizes the results of the pollution prevention assessment at the company level. Box 17 shows the report contents. The report will provide a schedule for implementing prevention projects and will be the basis for evaluating and maintaining the pollution prevention program. It may also be needed to secure internal funding for projects that require capital investment, if the members of the pollution prevention assessment task force do not have the authority to commit funds. You may be tempted to omit this step if your company has an owner-manager and only a few employees. A summary assessment report may not be needed to resolve pollution prevention project conflicts among different areas, and your funding approvals probably are not a formal procedure requiring cost justifications. However, an assessment report will help you focus subsequent pollution prevention efforts and will be useful as a record of what aspects of your business you examined for pollution prevention opportunities. Input of the Assessment Teams In a company that has several assessment teams, the task force will need to evaluate the results and resolve any conflicts that might exist among the teams as to approach and resources required for the projects they propose. The report on each proposed project should discuss:  Its pollution prevention potential  The maturity of the technology and a discussion of successful applications  The overall project economics  The required resources and how they will be obtained  The estimated time for installation and startup  Possible performance measures to allow the project to be evaluated after it is implemented Box 17 As input to this integration effort, each assessment team should prepare a summary report, presenting the results of their investigations and listing the options they screened. Each report should describe in some detail the options that the team has determined are feasible and propose a schedule for implementing them. The options recommended for immediate implementation should then be described in detail as proposed projects. These proposals should evaluate each project under different scenarios. For example, the profitability of each could be esti- mated under both optimistic and pessimistic assumptions. Where appropriate, sensitivity analyses indicating the effect of key variables on profitability should be included. Each should outline a plan for adjusting and fine-tuning the initial projects as knowledge and experience increases. The proposals should include a schedule for addressing those areas and waste streams with lower priorities than the ones selected for the initial effort. Each assessment team summarizes:  results of assessment effort  options proposed  results of option screening  results of feasibility analysis  project proposal for each selected option Evaluate the project under various scenarios. Preparing and Reviewing the Assessment Report The task force will use the assessment teams' reports and project proposals to prepare the summary assessment report and implementation plan. The report should include a qualitative evaluation of the indirect and intangible costs and benefits to your company and employees of a pollution prevention plan. It will provide the basis for obtaining funding of pollution prevention projects. Pollution prevention projects should not be sold on their technical merits alone; a clear description of both tangible and intangible benefits can help a proposed project obtain funding. Before the report is issued in final form, managers and other experienced people in the production units that will be affected by the proposed projects should be asked to review the report. Their review will help to ensure that the projects proposed are well-defined and feasible from their perspectives. While they probably were involved in the site reviews and other early efforts of the task force, they may spot inaccuracies or misunderstandings on the part of the assessment teams that were not apparent before. In addition to ensuring the quality of the assessment report and implementation plan, this review will help ensure the support of the people who will be responsible for the success of the project. The summary assessment report is used for:  QA of implementation plan  funding decisions  building support for plan IMPLEMENT THE POLLUTION PREVENTION PLAN Select Projects for Implementation Final decisions on which projects will be implemented and what the schedule will be are made at this point. If the task force or company executives question aspects of some projects, the assessment teams or pollution prevention program champions may be asked to produce additional data. They should be flexible enough to develop alternatives or modifications. They should also be willing to do background and support work, and they should anticipate potential problems in implementing the options. Above all, they should keep in mind that an idea will not sell if the marketers are not convinced. Obtain Funding The task force will seek to secure funding for those projects that will require expenditures. There will probably be other projects, such as expanding production capacity or moving into new product lines, that will compete with the pollution prevention program for funding. If the task force is part of the overall budget decision-making procedure, it can make an informed decision that a given pollution prevention project should be implemented right away or that it can wait until the next capital budgeting period. The task force will need to ensure that the project is reconsidered at that time. Some companies will have difficulty raising funds internally for capital investment. If this applies to your company, look to outside financing. Private sector financing includes bank loans and other conventional sources of financing. Financial institutions are becoming more cognizant of the sound business aspects of pollution prevention. Government financing is available in some cases. It may be worthwhile to contact your state's department of commerce or U.S. Small Business Administration for information regarding loans for pollution control. Some states can provide financial assistance. Appendix D includes a list of states providing this assistance and addresses where you can write for information. In 1989, the Bank of Boston started a unit focused strictly on environmental lending. Environmental Business Journal, October, 1991. Install the Selected Projects Many pollution prevention projects will require changes in operating procedures, purchasing methods, or materials inventory control. Company policies and procedures documents and employee training will also be affected by the changes. For projects that involve equipment modification or new equipment, the installation of a pollution prevention project is essentially the same as any other capital improvement project. The phases of the project include planning, design, procurement, construction, and operator training. As with other equipment acquisitions, it is important to get warranties from vendors prior to installation of the equipment. Training and incentive programs may be needed to get em- ployees used to the new pollution prevention procedures and equipment. Installing a pollution prevention project generally involves the same considerations as for other capital improvement projects. Review and Adjust The pollution prevention process does not end with implemen- tation. After the pollution prevention plan is implemented, track its effectiveness versus the claims made - technical, economic, etc. Options that do not meet your original performance expectations may require rework or modifications. Above all, reuse the knowledge gained by continuing to evaluate and fine-tune pollution prevention projects. Chapter 4 provides details on measuring progress after implementation and evaluating it against goals. Chapter 5 deals with ways to maintain and enhance a program after it is implemented. Reiteration of the process will yield maximum success.