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Pollution Prevention and Control Technologies for Plating Operations
Section 2 - General Waste Reduction Practices
2.2 POLLUTION PREVENTION AND SOURCE CONTROL
2.2.2 Pollution Prevention Programs
2.2.2.1 Pollution Program Organization
2.2.2.2 Pollution Prevention Policy
2.2.2.3 Task Force Organization
2.2.2.4 Pollution Prevention Goals
2.2.2.5 Pollution Prevention Planning
2.2.2.6 Assessment/Feasibility Analysis
2.2.2 Pollution Prevention Programs
This section presents an approach for establishing a pollution prevention program and initiating the assessment and implementation of pollution prevention measures. The overall approach includes an organizational framework needed for creating a pollution prevention program, guidelines for pollution prevention planning and goal setting, procedures for collecting and organizing information and data, techniques for evaluating and ranking pollution prevention options and methods for implementing, monitoring and assessing program elements.
Portions of the approach are extracted from EPAís waste minimization strategy (ref. 26), which is presented in Exhibit 2-5. Also included are successful elements of existing corporate pollution prevention programs and field proven techniques which have been identified during the NCMS survey.
The Users Survey (see description in Section 1), asked platers if their shops had established a formal pollution prevention program. A summary of responses to this question and others relating to pollution prevention programs and good operating practices is presented in Exhibit 2-6. Of the 318 plating shops responding to the survey, 161 (or 50.6%) indicated that they have established a formal pollution prevention program. The average success rating given by respondents for this pollution prevention method was 3.69. This rating is slightly lower than the average rating for all good operating practices. It should be noted that, although its rating is below the average for all methods, it still received a rating in the upper one-half of the rating scale (see description of rating scale on Exhibit 2-6), as did all of the methods.
2.2.2.1 Pollution Program Organization
The regulations and incentives which create a need for pollution prevention were identified in Section 2.2.1. To meet these needs effectively, small companies, corporations and Federal facilities must initially develop a well defined pollution prevention policy and establish a pollution prevention organization or task force with the committed fiscal and administrative authority. Without top management support and a well defined organization with functional and financial capabilities, a pollution prevention program will be short lived and will not have a substantial impact on waste generation. Some guidelines for pollution prevention policy development and task force organization are presented in the following subsections.
2.2.2.2 Pollution Prevention Policy
A pollution prevention policy is a statement which reflects the general goals of the program. The following example is a pollution prevention mission statement used by a major aerospace corporation (Source: confidential contribution).
ìOur goal is to implement an effective pollution prevention program to eliminate liquid, solid and gaseous waste generation. Program priorities shall emphasize the protection of employees, community and the environment while maintaining product quality and business objectives.î
Both the pollution prevention policy and the task force should be established in a manner that cuts across the entire organization, involving all employees and especially the workers with direct contact with waste generation. Pollution prevention will not be effectively achieved without the acceptance and cooperation of the operators. Often, operators cause waste and they are in the best position to prevent it.
Policy statements can be written to communicate clearly that pollution prevention is an important measure of employee performance, like production yield and quality. Waste generation tracking should be instituted at the most basic level possible to provide quantitative measures of performance.
Of the 318 plating shops responding to the Users Survey, 158 (or 49.7%) indicated that they have established a formal policy statement with regard to pollution prevention and control. The average success rating given by the respondents for this pollution prevention tool was 3.58 (see Exhibit 2-6).
2.2.2.3 Task Force Organization
The size of the program task force will depend heavily on the size of the company. At a minimum, the task force should include members of any group or department in the company that manages, generates, handles or in some other manner affects wastes. Some members, who work directly with waste generation, may be constantly involved in the program while others, who have less direct contact with the waste generating processes, may only attend major planning meetings. Potential departments and personnel that would be appropriately involved from a major manufacturing company include (ref. 26):
- Plant vice president
- Metal finishing department manager
- Process engineer responsible for the operation of metal finishing processes
- Facilities engineer responsible for the maintenance of metal finishing equipment
- Wastewater treatment department supervisor
- Staff environmental engineer
- Hazardous waste coordinator
Larger companies, with successful programs, typically have 10 to 20 people on the task force. Some small companies have successful programs with as few as 2 to 4 members. In any case, a single person should not be given the sole responsibility for the program. This will isolate the program from the employees and generate a narrow range of ideas.
The organization of the task force may be dictated by a companyís structure. As with any group, a leader is needed to chair meetings, motivate members and maintain communications. In large companies, the leader typically comes from the environmental department. The leader should be an experienced individual with knowledge of both environmental and production issues. Besides a task force leader, the organizational structure may consist of committees, headed by committee leaders, with well defined responsibilities. These committees could be organized by production areas, specific pollution prevention projects or task force responsibilities such as data collection. Typically, the organization structure and size will change as the program matures through the assessment phases and into implementation. The scope of the program will determine whether full-time participation is required by the leader or other team members (ref. 26, 303).
Employees can become involved in the program through working groups and motivated with financial incentive programs. Larger companies with Total Quality Management can utilize this organizational structure to encourage the generation of pollution prevention ideas.
The Users Survey requested shops to provide information about categories of employees and technical resources available at their sites. Their responses provide some insight to the types of personnel that are available to participate on a task force. A partial summary of these data is shown in Exhibit 2-7. Additional data identifying labor categories (e.g., process engineers, chemists, skilled trades, etc.) employed by the survey respondents is contained in the database.
2.2.2.4 Pollution Prevention Goals
The first priority of the task force should be to establish goals that are consistent with the policy adopted by management (ref. 26). The general policy of the program establishes broad and long-term objectives, whereas program goals should be quantifiable to establish a clear guide as to the success of the program. The following are two examples of goals used by major companies.
- Goal Example 1: A chemical company has adopted a corporate-wide goal of 5 percent waste reduction per year with waste specific goals for individual facilities (ref. 26).
- Goal Example 2: An aerospace company has set the following waste reduction goals, using 1988 as a base year: 30 percent reduction by 1993, 50 percent reduction by 1995 and 80 percent reduction by 1997. In addition to general waste reduction goals, certain priority chemicals (e.g., chlorinated solvents) were identified for which specific reduction goals were established (ref. confidential contribution).
2.2.2.5 Pollution Prevention Planning
The task force should have the responsibility of developing a strategic pollution prevention plan and periodically updating the plan (e.g., annually). The plan should outline an approach to meeting program goals by: identifying specific action items; indicating a time frame for their planned completion; and indicating the responsible person or department. Early plan elements should focus on data collection and assessment and subsequent elements should focus on implementation. As the program progresses the plan will become more defined.
2.2.2.6 Assessment/Feasibility Analysis
The assessment/feasibility analysis is the engineering phase of the pollution prevention program (See Exhibit 2-5). It involves the collection of baseline data, data evaluation, identification of pollution prevention targets, and the identification, evaluation and selection of pollution prevention options. EPA has published assessment manuals (ref. 25, 26) that contain worksheets that can guide the user through these various steps. The problem with using the EPA manuals is the resultant mass of worksheets generated from performing an assessment and feasibility analysis for all but the smallest of operations. For an average size manufacturing plant, use of the EPA manual will generate 200 to 500 pages of forms. As an alternative methodology, firms can utilize the basic EPA approach and develop their own forms that are tailored to their production processes and treatment operations. Use of the manual in this manner is encouraged by EPA.2