Pollution Prevention Program

Scenario 1

You are the newly appointed, and first, Environmental Manager of a major home products manufacturing plant in a major southern U.S. city. Your facility manufactures a wide range of household cleaning products and is a three shift operation that employs over 300 workers. The plant ships out finished products in all sizes of containers from household spray and liquid bottles to industrial sized 55 gallon drums and 500 gallon totes. There is a shipping and receiving warehouse facility with 20 bays for tractor trailer trucks. There are 6 large diked outdoor storage tank farms for raw materials and finished products. There is a private railroad car spur that unloads raw material hazardous chemicals into 5-10,000 storage tanks. There is also an attached $1 million dollar enclosed building used to unload the gas chlorine (approximately 20 million tons per year) that is utilized in many of your products (this facility is fully sealed off with protective alarms and gas scrubbers in case of a chlorine leak). You have a TSD permit that allows you to operate a wastewater recycling operation on site that treats both your aqueous and solvent based wastewaters. You utilize these recycled waters in both cleanup operations around the plant and in the actual product manufacture when quality control permits. The TSD was secured by the corporate environmental engineering department and the recycling operations themselves were run by the production department. There has never been a full time environmental manager on site.

Recently a survey and audit has determined that your VOC emissions from the manufacturing plant floor operations have jumped above the 50 ton mark for the first time. There have been persistent leaks that have allowed small amounts of sodium hydroxide and other hazardous chemicals to migrate outside the plant into the sewer system that adjoins the property. It appears that these leaks have come from the caulking materials that are at the base of the wall and floor of your unlined raw material tank farms.

There have also been problems with the air emissions from older designed ink production date coders and the blow molding presses where the plant makes its own polyethylene bottles. Finally, the number of spills on the bottle filling lines has increased dramatically over the past six months and caused a measurable amount of finished product (both solvent based and water based) to be swept into the floor drains that are on the production floor. These drains lead to the city water treatment systems and not to your recycling operations. The plant manager is tired of hearing of all of these problems and the loss of product. He is irate about the repeated visits from the local city water treatment plant official (who he hates and is a fan of a rival SEC football team); along with the most recent annoying visit from the state water permitting authority. That is why he requested corporate headquarters to allow him to hire a full time Environmental Manager. Here is where you enter the scene - as you arrive for your first day at work he lays out the litany of problems, spills, and complaints. He wants to know your plan for addressing these issues and how you can put a halt to all this mess and institute a full Pollution Prevention plan for the plant. And he wants it - Yesterday! He finishes his mini-tirade with a warm "Welcome to the Big Time World and, remember - I don't ever want to be part of the six o'clock news - you get my drift!"

In your response, please identify and be specific about what you would do, what programs would you address and implement to remedy the problems. Where would your priorities lie for creating the complete Pollution Prevention Program for your facility? You do have support from corporate environmental engineering and in-house production engineering staff along with a reasonable budget, but the plant employees themselves are rather cool to the idea of any extra work that might be created for them. Aside from his initial gruffness, the plant manager has subsequently and sincerely pledged his support for all your programs.