Procedure To Evaluate New Plant Designs

1. Conduct initial screening and predesign assessments.

2. Assign project environmental leadership responsibility.

3. Define the project's environmental objectives.

4. Identify the need for any permits.

5. Determine the environmental compliance requirements.

6. Perform an overall waste minimization analysis.

7. Apply best environmental practices for emission-free and discharge-free facilities.

8. Determine waste treatment and disposal requirements.

9. Perform engineering evaluations of waste management options.

10. Complete project environmental overview.

STEP 1—PERFORM INITIAL ASSESSMENTS

The initial screening of the project is performed to:

• See if any environmental issues exist

• Perform an environmental site assessment evaluation

• Define and evaluate environmental baseline information

The initial screening answers the following questions:

Does the project involve the use of chemical ingredients? Does the project involve equipment containing fuels, lubricants, or greases? Does the potential exist for reducing or eliminating waste, internally recycling materials, or reusing by-products? Do potential problems exist with the existing site conditions, such as the presence of contaminated soil or groundwater?

Does the project have the potential to contaminate or impair groundwater or soil? Does the project involve the storage or transport of secondary waste?

If the responses to all of these questions are negative, then the responses are documented, and no further review is required. However, if the answer to any of these questions is yes, then environmental leadership responsibility for the project is assigned (Step 2), and the remaining steps are followed.

Many projects suffer delays and unforecasted expense due to site contamination. Therefore, the site should be checked for potential contamination as soon as possible. The site assessment should do the following:

Determine whether site remediation is needed before construction

Define the proper health and safety plans for construction activities

Determine the appropriate disposal options for any excavated soil

Identify the regulatory requirements that apply

Environmental site assessments include a review of the files about past site operations, an examination of aerial photographs, tests for potential soil and groundwater contamination, and the identification of the environmental constraints that can delay or prevent construction. The time and expense for the assessment should be incorporated into the project time-line and cost estimates. Environmental baseline information usually includes:

Background air quality prior to project start up Current emissions at existing sites and potential impact of these emissions on a new project Monitoring equipment needed to verify environmental compliance after start up

Impact of the construction and operation of a new facility on existing waste treatment facilities and current air, land, and water permits Determination of whether an environmental impact analysis (EIA) should be performed. EIAs are common at greenfield sites, especially in Europe, and are generally performed by outside consultants.

STEP 2—ASSIGN LEADERSHIP RESPONSIBILITY

The leader's role is to identify and coordinate all resources and ensure that the environmental analysis steps outlined in this procedure are followed. This role should be assigned as early as possible.

STEP 3—DEFINE ENVIRONMENTAL OBJECTIVES

Environmental objectives include a statement supporting government regulations and company policy, a list of specific goals for emissions and discharges or reduction of emissions and discharges, and other project-specific objectives. These objectives focus preferentially on source reduction and recycling rather than waste treatment.

Table 3.9.2 is an example of an environmental charter. Table 3.9.3 presents a hierarchy (prioritized list) of emissions and discharges, and Table 3.9.4 lists the types of emissions and discharges. The charter and these lists serve as a starting point and should be modified to suit the project. The hierarchy of emissions and discharges varies depending on the geographical location (for example, CO2 can rank higher in the hierarchy in Europe than in the United States).

STEP 4—IDENTIFY PERMIT NEEDS

Obtaining permits to construct and operate a new facility is often the most critical and time-limiting step in a project schedule. Therefore, this step should be started as early as possible in the project.

Permit requirements or limits are not always clearly defined and can often be negotiated with government regulatory agencies. The types of permits required depend on the process involved, the location of the facility, the types of existing permits at an existing facility, and whether new permits or modifications to the existing permits are needed. Typically, permits are required for any part of a process that impacts the environment, such as:

Any treatment, storage, or disposal system for solid or hazardous waste

The exhaust of anything other than air, nitrogen, oxygen, water, or carbon dioxide (Carbon dioxide may require a permit in the future.) The use of pesticides or herbicides Incineration or burning

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