Workshop N Effective Facility Environmental Management of Change: - - PDF document

Workshop N

Effective Facility Environmental Management of Change: Evaluation of New Materials, Equipment, and Processes & Their Impact on Reporting, Permitting, and Compliance Tuesday, March 26, 2019 2 p.m. to 3:15 p.m.

Biographical Information

Hope Manning, Senior Project Manager/Multi-Media Leader Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7238 hmanning@eqm.com Hope has over 16 years of technical and compliance management experience in the environmental field in both consulting and industry. She has been involved in a broad range of programs including air compliance and permitting, NESHAP Boiler GACT compliance, NPDES permitting and compliance, SPCC, and SWPP Plans generation, and EPCRA SARA Title III, Section 312 and 313 reporting, and auditing. Currently Hope leads the Multi-Media group at EQM which is comprised of individuals who have expertise in air, water, SPCC, and EPCRA reporting. She is also the primary environmental auditor for EQM. Prior to her joining EQM in 2015, Hope was the Corporate Environmental Compliance Manager at Darling Ingredients, Inc., and was responsible for environmental compliance to federal, state, and local requirements for

• ver 50 locations in over 15 states. These activities included assisting in minor and

major permitting, regulatory compliance, regulatory interpretation, regulatory reporting, permit compliance and internal auditing. Prior to her time at Darling Ingredients, Inc., Hope was the Water Quality Specialist for The Seminole Tribe of Florida. She was responsible for the water quality program for all surface waters on the Seminole Tribe of Florida reservation lands. Because the Seminole Tribe of Florida is a federally recognized Indian Tribe, she dealt directly with USEPA Region 4 personnel on behalf of the Seminole program. Hope holds a Bachelor of Science Degree in Chemical Engineering from The University

• f Cincinnati.

Lewie Chandler Site Environmental Leader / Site Sustainability Leader P&G Lima Plant chandler.jl@pg.com Lewie has been with Procter & Gamble Lima Plant for 21 years. During his tenure he has held many roles including production technician, maintenance lead and department

• lead. He has been the Site Environmental / Sustainability Leader at the Lima Plant for 3

years. Lewie attended The Ohio State University and is a veteran of the U.S. Army, 82nd Airborne Division.

Biographical Information

Dawn D. Miller, P.E., Vice President Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7213 dmiller@eqm.com Dawn is a chemical engineer by training and has more than 29 years of experience in environmental compliance and management. Her primary role at Environmental Quality Management is leading the commercial environmental compliance group. She has particular expertise in assisting industrial, municipal, commercial and institutional clients with air permitting, regulatory applicability evaluations, air compliance strategy development and execution, and air program auditing. She is involved in a broad range

• f programs including major and minor new source air permitting, MACT/NESHAP and

Title V compliance, Risk Management Planning under 112r, EPCRA Compliance, chemical process engineering/toxics release analysis, and environmental compliance auditing. Dawn graduated from the University of Kentucky with a B.S. in Chemical Engineering and is a registered Professional Engineer in Ohio, Florida, and Kentucky. Julie A. Wagner, P.E., Senior Project Manager Environmental Quality Management, Inc. 1800 Carillon Boulevard, Cincinnati, Ohio 45240 513-742-7244 jwagner@eqm.com Julie is a Chemical Engineer and Senior Project Manager at Environmental Quality Management, Inc. in Cincinnati, Ohio. She has over 26 years of multimedia environmental compliance experience in the areas of air quality compliance and permitting, EPCRA compliance, wastewater, storm water, and drinking water. Her multimedia experience in the environmental field includes a diverse work background with environmental consulting, academia, and research and development, including work with the U.S. Environmental Protection Agency and U.S. Army Construction Engineering Research Laboratory (CERL). Areas of experience include regulatory compliance with the CAA, RCRA, CERCLA, SARA, and CWA; environmental permitting (NPDES, storm water, Title V, PSD); toxicity reduction evaluations; environmental compliance audits and ASTM Phase 1 Environmental Site Assessments; storm water and wastewater monitoring; air dispersion modeling/ambient air monitoring; and drinking water cross-connection control and evaluation. For the past 10 years, she has provided as-needed onsite environmental compliance assistance for multiple clients as part of EQ’s outsourcing services. Julie graduated from the University of Cincinnati with a B.S. in Chemical Engineering and is a registered Professional Engineer in Ohio.

Workshop N - March 26, 2019 1

WORKSHOP N – EFFECTIVE FACILITY MANAGEMENT OF CHANGE: EVALUATION OF NEW MATERIALS, EQUIPMENT, AND PROCESSES AND THEIR IMPACT ON REPORTING, PERMITTING, AND COMPLIANCE

Workshop N - March 26, 2019 2

Effective Facility Management

• f Change
• Welcome & Introductions
• Hope Manning – EQM
• Dawn Miller – EQM
• Lewie Chandler – P&G
• Julie Wagner - EQM
• Agenda
• Day in The Life
• Management of Change
• Examples
• Data Harmony

Workshop N - March 26, 2019 3

Workshop N - March 26, 2019 4

Text Your Questions

Workshop N - March 26, 2019 5

A Typical Day in the Life of an EHS Professional

Workshop N - March 26, 2019 6

A Typical Day in the Life of an EHS Professional

• Routine tasks
• Seasonal reports
• Long timeline facility projects
• Short turn around facility projects
• “Put out the fire” items
• Facility emergencies

Workshop N - March 26, 2019 7

Tools of an EHS Professional

• Old fashioned To-Do lists, calendars,

and planners

• Outlook calendar/task lists/Excel task

tracking

• Purchased regulatory compliance

software

• Consultants, stack test firm
• Publications, internet
• Training
• Relationships with regulators

Workshop N - March 26, 2019 8

Non-Routine & Non-“Emergency”

• New material clearance
• New product
• Equipment replacement or process modification
• Production speed increase/decrease
• Change to process safety
• Increase to amount of a raw material stored
• Quick turnaround construction projects
• Proposed work within wetland boundary

Workshop N - March 26, 2019 9

How Do You Prioritize?

• Loudest person?
• Easiest item to

resolve?

• Closest deadline?
• Highest compliance

risk if delayed?

• Highest potential

$loss to business if delayed?

Workshop N - March 26, 2019 10

Priorities

• Projects with milestones that are out of your control
• Environmental Compliance items
• Reports
• Inspections
• Monitoring & Recordkeeping
• Long environmental timeline
• 4 to 12 months to obtain an environmental permit
• Breaking ground for new building – regulations may preclude some

construction

• Environmental testing must be done within 3 months of permit issuance
• Multiple organizations with differing priorities
• Process safety
• Industrial hygiene
• Engineering
• Production

Workshop N - March 26, 2019 11

Priorities

• Situations that require quick response
• Equipment upgrade or process optimization is

needed to meet production demands

• Unexpected environmental release
• Boiler failure in coldest months of year
• Gas curtailments
• Unannounced Agency inspection
• Control device/CEMS failures
• Resolving a safety issue and the solution has

environmental impacts

Workshop N - March 26, 2019 12

Priorities

• Regulatory Changes (longer timeline)
• Change to NAAQS attainment status for your

county for ozone NA

• Ozone Depleting Substances / Refrigerants
• Banning of previously acceptable HFCs
• Changes to leak detection procedures
• RCRA hazardous waste management requirements
• Tier II hazard categories change
• New Regulatory Programs (GHG, MACT, RICE,

NESHAPS)

Workshop N - March 26, 2019 13

How Does This Apply to Management of Change Process?

• System to handle all of these issues
• Helps you handle timelines & prioritize
• Engages other resources/people
• Documents the process and results

Workshop N - March 26, 2019 14

"No man ever steps in the same river twice.”

• r

“Everything changes and nothing stands still.”

Greek Philosopher Heraclitus

• c. 535 to 475 BC

Workshop N - March 26, 2019 15

Management of Change

• Life = change
• Must be able to manage change
• To improve the way we operate our business
• Support the changing needs of our customers
• Manage change well for our personal survival
• Inability to manage change can be disastrous
• Human health and safety
• Environmental
• Financial

Workshop N - March 26, 2019 16

• Management of Change (MOC) is a

structured process used to ensure that safety, health and environmental risks are controlled when making changes in

• perations, facilities, documentation or

critical personnel.

• Relates to the technical side of change
• May be formal or informal
• Need upper management buy-in/formal

policy to “enforce”/ensure this process is used

Workshop N - March 26, 2019 17

MOC Risk Review

• Who must use MOC risk review process?
• Project manager
• Design engineer
• Maintenance personnel
• Corporate/Upper Management
• Purchasing
• Utilities Manager
• Industrial Health & Safety/Process Safety
• Environmental

Workshop N - March 26, 2019 18

Environmental Risk Review

• What “risk” areas must be included?
• Will it impact air, stormwater, wastewater?
• Does it generate a new waste stream or increase waste
• utput?
• Does it use, process or manufacture a regulated

chemical?

• Is reporting of storage, use, or releases required?
• Does it subject the facility to a new regulatory program?
• Is the change or proposed project or chemical subject to

a Federal environmental program?

• Does it align with the facility sustainability goals?

Workshop N - March 26, 2019 19

Environmental Risk Review Content

• Change description
• Detailed description of project
• Raw materials to be used, quantities, SDSs
• Equipment specifications
• Process flow diagram
• Project schedule
• Environmental impacts
• Air emissions, water discharge, waste quantification
• New control device needed/impact on existing ones
• Chemical manufacture, storage, and use
• Energy consumption
• Regulatory review
• Applicable regulations
• Action items
• Compliance timeline

Workshop N - March 26, 2019 20

• 1. New Raw Material
• Is it on the List of Lists?
• Is it considered an oil?
• Quantity to be used and how much will be present onsite
• How & where stored (e.g., tank, ambient temperature, spill

containment, outside, etc.)

• Downstream impacts (process in which it will be used)
• Air permit changes or need for a new permit
• Any wastewater permit implications (NPDES, POTW, etc.)
• EPCRA reporting (Sections 302/304; Sections 311/312;

Section 313)

Workshop N - March 26, 2019 21

• 2. Equipment Changes
• ID equipment to be replaced or refurbished
• Is the equipment part of an air or wastewater

permitted process?

• If so, does it generate pollution? And will

amount generated change?

• Is the replacement “in-kind”?

Workshop N - March 26, 2019 22

• 3. New Process or Equipment
• Detailed description of the new system
• Process flow diagram
• Air emissions and water discharges
• Chemicals to be made, processed or used
• Equipment specifications
• Speed, heat input, technology, etc.
• Site disturbances/building additions
• Facility map with proposed changes
• Project schedule
• break ground, deliver equipment, first production

Workshop N - March 26, 2019 23

LIMA SITE ENVIRONMENTAL OVERVIEW NA F&HC’s 1st ZWTL Site

Lewie Chandler

PROCTER & GAMBLE

Lima Plant Environmental Vision

Be an Environmental Leader of our Community and Our Corporation. Have Environmental Awareness Fully Integrated into Our Business. Maintain a Proactive Position with ALL Regulatory Agencies. Make reductions in ALL our Waste Streams Striving for an Ultimate GOAL of ZERO Discharge.

Site Programs

• Major Waste Streams
• Solid & Hazardous Waste
• Recycle Program
• Wastewater
• Stormwater
• Air Emissions (tanks, boilers, process

equipment, fuel burning equipment)

Site Emissions Map

Site

Compactors

Dumpsters

pH

Air Emissions

Recycle Area

City Wastewater Treatment Plant - POTW

Tank Farms B2 B1

Process Water & Effluent

Boiler House

Effluent

Alternative Use Facility

Process Water & Effluent

B3 B4

Stormwater Outfalls: 10 million gallons per year

EQM Resources: Jill Binzer & Hope Manning

• Prevention plans (SWP3, Oil SPCC)
• New technology recommendations
• Permit Studies
• Environmental Calendar
• Outfall flow studies/ Discharge Calculations

Stormwater

N.P.D.E.S. (National Pollutant Discharge Elimination System) Permit

Air Emissions

EQM Resources: Dawn Miller, Hope Manning & Stephen Fischer

• Air Emissions Inventory maintenance
• Permit Evaluation/Fee Emission Reports
• New Equipment Permit Applicability Evaluations
• Applications / Report Preparations
• Compliance Calendar
• Permit Studies

Change Management Levels

• Chemical Clearance
• New raw material or ancillary material
• Level 1
• Work process or documentation change
• Level 2
• Department funded changes
• Level 3
• Equipment/process changes
• All other technical changes

Change Management Keys

• Establish change control process
• Train organizations on process
• Work approvals into funding process
• Hold organization accountable for change approval
• Hold change board accountable for approvals /

follow ups

• Review process at some frequency to identify
• utages

Example: Rental Boiler

• New business created a need for increased steam capacity
• Operating department worked with budget owner to get money freed up
• Funding paperwork asks questions that trigger change management review

board involvement

• Operating department worked with facilities to identify a vendor and scope
• f project
• Vendor stated no permit was needed
• Project brought to change review board
• Once scope was identified, contacted EQM for guidance on right questions to ask
• Once right questions were asked, data provided to EQM
• EQM / P&G determined proper air permitting required
• EQM prepared permit application paperwork
• P&G submitted application

THANK YOU !

QUESTIONS ?

Workshop N - March 26, 2019 34

Interruptible Gas Contract

• Added a 30,000 gallon Propane Tank

Workshop N - March 26, 2019 35

Interruptible Gas Contract

• Company has an uninterruptible gas

contract

• Can save ~ $300,000 if change to interruptible

contract

• Accounting approaches facility leadership to

change

• Leadership decides to change
• Leadership tells Engineering and EHS

Workshop N - March 26, 2019 36

Interruptible Gas Contract

• When/Who to complete the MOC??
• Does management do it?
• Does Engineering do it?
• Does EHS do it?
• As the EHS professional, if no one else does it, you

need to complete one.

Workshop N - March 26, 2019 37

Interruptible Gas Contract

• Impacts of adding propane
• What will this impact?
• Tier II reporting
• Air permitting
• DOT issues (location)
• Risk Management Plan/Process Safety Management
• Fire/safety hazards
• Storm water impacts

Workshop N - March 26, 2019 38

Review of project after completion

• Was it installed as designed
• If any changes made, impact of those changes

Workshop N - March 26, 2019 39

Tools to manage and track facility changes and ensure ongoing compliance

• Compliance calendars
• Database to maintain/track materials status

(current, past, possible future)

• Facility unscheduled walk-throughs/internal audits
• Ensure “Environmental” is part of project review/

incorporated into MOC process

• Data harmony

Workshop N - March 26, 2019 40

Data Reporting

• Various Levels of Environmental

Compliance Reporting

• Federal Reporting (USEPA)
• State Reporting (OH-KY-IN)
• Ohio: Ohio EPA
• Kentucky: KYDEP
• Indiana: IDEM
• Local Reporting (County-City-Municipality)

Workshop N - March 26, 2019 41

Typical Environmental Reports

• AIR
• Emission Statements / Fee Emission Reports
• GHG Reporting
• MACT
• CEMS/HAPs
• WATER
• NPDES Reporting (Wastewater/Storm Water)
• Industrial Pretreatment Programs
• EPCRA
• State Tier II Reporting (312)
• TRI - Toxic Release Inventory (313)
• RCRA
• Biennial Hazardous Waste Report

Workshop N - March 26, 2019 42

Report and Data Overlap

• Multiple reports (multimedia components)
• Different reporting formats
• Varying reporting thresholds
• All this DATA gets submitted to the Local,

State & Federal Agencies

Workshop N - March 26, 2019 43

Report and Data Overlap

So “HOW” is this data used once submitted?

• Data is used to compile statewide emission

inventories to support different state initiatives and federal programs (i.e., Development of Regional and National Air Toxics Inventories)

• Also used for:
• Planning
• Trends Analysis
• Modeling
• Billing

Workshop N - March 26, 2019 44

Age of Electronic Reporting

• Online e-portals for report/data submission
• CDX (E-GGRT, CEDRI, TRI-MEweb, RMP)
• CAMD Business System (ECMPS)
• State-specific Portals:
• Ohio EPA: e-Business Center
• IDEM: EMITS (Emission Inventory Tracking System)
• KYDEP: Electronic Submittals Website (gateway eportal)
• Allows for easier data compilation, evaluation

and cross-checking (by the Agencies)

• Creates a need for “Data Harmony” at facility

Workshop N - March 26, 2019 45

What Is Data Harmony?

• Consistency among environmental release

values within public reports

• Air emissions of a HAP, if also a TRI chemical,

should be the same in FER and TRI reports

• Methods for estimating emissions should be

consistent between programs

• Water discharges should be consistent and

methods of estimation the same in permit applications and TRI reports

Workshop N - March 26, 2019 46

Checking for Data Harmony

• Reporting Practices
• Same person/department completing the various

reports (plant level, corporate)?

• If not, is there communication between preparers for

consistency?

• For similar pollutants being reported in different reports,

are calculation methodologies consistent?

• Using outdated emission factors or mass balance

calculations?

• Reporting Thresholds
• Vary by report type and pollutant

Workshop N - March 26, 2019 47

Data Harmony

• How to ensure reported data harmony and consistency

across the multimedia spectrum (e.g., between State Agency and U.S. EPA; and FER versus TRI reporting)

• Agencies are looking at this
• Tracking how facility-reported data is being utilized by

local/state/federal agencies (i.e., air permit deviation reporting)

• Public versus confidential data
• How data can be obtained by public (i.e.,

environmental groups, etc.)

Workshop N - March 26, 2019 48

Data Harmony – Example 1

Consistency across multimedia spectrum (Lead reporting: FER vs. TRI)

• USEPA contacts facility about discrepancy in

reported lead air emissions

• Lead (Pb): TRI (lbs) FER (lbs)
• Asked facility to go back and re-evaluate data
• Determine if there is need to revise and resubmit any

reports

Workshop N - March 26, 2019 49

Data Harmony – Example 1

Consistency across multimedia spectrum (Lead reporting: FER vs. TRI)

• Facility Evaluation
• Comparison based on facility-wide total (lbs)
• Different Reporting Thresholds
• FER: facility-wide actual emissions for lead >0.5 TPY
• TRI: Lead (pb) threshold is 100 lbs
• Estimation methodologies
• FER: Used AP-42 factors/stack test data to calculate air

emissions

• TRI: Used alternate approved methodology for certain

sources to determine specific HAPs (of which lead was included)

Workshop N - March 26, 2019 50

Data Harmony – Example 2

Consistency between State Agency and U.S. EPA Reporting (i.e., GHG Reporting)

• Title V Facility required to submit both annual GHG

Report (USEPA’s E-GGRT) and annual FER (State Fees Program) – Unit: Natural Gas-fired Boiler

• GHG Reporting (CO2, CH4, N2O)
• Mandatory CO2, CH4, N2O
• Weighted annual average HHV (specific fuel or default HHV)
• Default EF or unit-specific EF
• FER Reporting
• Additional/Voluntary Reporting of GHG Pollutants and HAPs
• How do these compare?

Workshop N - March 26, 2019 51

Data Harmony – Example 2

Workshop N - March 26, 2019 52

Data Harmony – Example 2

Workshop N - March 26, 2019 53

Data Harmony

On-line publicly available data

• US EPA ECHO (https://echo.epa.gov)
• US EPA Envirofacts (https://www3.epa.gov/enviro)
• MyRTK - My Right-To-Know (https://www.epa.gov/toxics-

release-inventory-tri-program/my-right-know-application)

• State websites
• Ohio e-docs

(http://edocpub.epa.ohio.gov/publicportal/edochome.aspx)

• Indiana
• Kentucky

Workshop N - March 26, 2019 54

U.S. EPA ECHO

Workshop N - March 26, 2019 55

U.S. EPA ECHO – Example Data Downloads

Workshop N - March 26, 2019 56

U.S. EPA Envirofacts (https://www3.epa.gov/enviro/)

Workshop N - March 26, 2019 57

My Right-To-Know Application

Workshop N - March 26, 2019 58

Ohio EPA eDocument Search

(http://edocpub.epa.ohio.gov/publicportal/edochome.aspx)

Workshop N - March 26, 2019 59

Data Harmony - Thoughts

• Your facility data is out there…..
• Is your data consistent throughout the

various reporting mechanisms?

• Check out the Agency websites
• See what the general public can see about your

facility

• Is your data being displayed correctly?

Workshop N - March 26, 2019 60

Questions?