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 over 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 of 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, 82 nd 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 of 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 – EFFECTIVE FACILITY MANAGEMENT OF CHANGE: EVALUATION OF NEW MATERIALS, EQUIPMENT, AND PROCESSES AND THEIR IMPACT ON REPORTING, PERMITTING, AND COMPLIANCE Workshop N - 1 March 26, 2019
Effective Facility Management of 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 - 2 March 26, 2019
Workshop N - 3 March 26, 2019
Text Your Questions Workshop N - 4 March 26, 2019
A Typical Day in the Life of an EHS Professional Workshop N - 5 March 26, 2019
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 - 6 March 26, 2019
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 - 7 March 26, 2019
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 - 8 March 26, 2019
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 - 9 March 26, 2019
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 - 10 March 26, 2019
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 - 11 March 26, 2019
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 - 12 March 26, 2019
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 - 13 March 26, 2019
"No man ever steps in the same river twice.” or “Everything changes and nothing stands still.” Greek Philosopher Heraclitus c. 535 to 475 BC Workshop N - 14 March 26, 2019
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 - 15 March 26, 2019
• Management of Change (MOC) is a structured process used to ensure that safety, health and environmental risks are controlled when making changes in operations, 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 - 16 March 26, 2019
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