Managing the Constancy of Change Dallas, TX May 18, 2016 Mike Remsberg, PE 1 Overview Importance of Change Management Considerations in Improving Change Management Processes Opportunities/Risks Where Operational Change and Environmental Regulatory Change Meet 2 Best Practices Turn Change into Opportunity Evolve or perish? Create an evolutionary process
in your organization which may include: A Clear Vision Sound Strategies Great Execution Improved Continuously 3 Pillars of Inevitable Change Economic Product Sales Operational Staff Turnover Technological Productivity/Automation
Environmental/ Regulatory 4 Forces in Change Management Controllable Forces Employee investment Business processes Compliance management Stakeholder engagement Corporate strategy Knowledge Management Less Predictable Forces
Economic conditions Political climate Regulatory change 5 Three Opportunities To Manage Regulatory Change 1.Operational Strategy and Permitting Change Management 2.Updates to ISO 14001 Environmental Management Systems 3.The Public, What They Know and How Can They Use It? 6 #1 Operational Strategy and Permitting Change Management (1/3) Two current operational drivers:
Stronger Cement Sales Drive Increased Demands on Cement Plants (i.e., increased utilization after a long period of excess capacity) More fuels choices and flexibility desires (e.g., low natural gas prices) Permitting can be lengthy and complicated and controversial Plants/Companies with good strategies can capitalize on opportunities 7 #1 Operational Strategy and Permitting Change Management (2/3) Good strategy concepts
Define process constraints in process early Identify permitting applicability and alternatives When will a clinker cooler need to be replaced? Can we respond timely to alternate fuel/raw material opportunities? Is the trade for lower/new limits worth the time value or permit feasibility? Defend existing permit limits, realize the glide path on emissions over the long-term is generally down (unless a modernization occurs and significant resources are expended in a major permitting action)
Is pushing an SNCR a bit more optimally the best near term strategy? Should we enhance SO2 removal or blend fuels to reduce pollutants? Often, making a change to reduce emissions before it is mandated can be turned into an opportunity Is voluntary action an opportunity? 8 #1 Operational Strategy and Permitting Change Management (3/3) Case Study: Path A In 2013, modernize to fuel efficient kiln via minor NSR permit for NOx, SO2, and GHGs. Path B In 2016, existing kilns required to add NOx RACT, and possible SO2 controls for DRR rule. Any modernization now likely subject to PSD/NNSR,
additional controls and more stringent limits. Was this a missed opportunity? If so, how could the value of the opportunity been better quantified for the businesss decision makers? How will you factor these issues on the horizon into your operations strategy? GHGs NSPS for cement Anti-coal/coke movement SO2 Data Requirements Rule (NAAQS) PM2.5 NAAQS Ozone NAAQS Process Safety Management/Risk Management Plans
CISWI Compliance 9 requirements, etc. Changes to dispersion modeling #2 Updates to ISO14001 Environmental Management Systems Many cement plants operate in conformance with ISO14001 Environmental Management Systems Many have other similar Environmental Management Systems, not certified Updates to ISO 14001 offer an opportunity to: Integrate PC MACT and CISWI work practices into Environmental Management Systems Perhaps improve management of change processes relative to plant operations The EMS process integrates continuous improvement processes into your plant
Plan, Do, Check, Act..continuously improve! 10 Key ISO 14001 Thematic Changes Area More emphasis compared to current version of ISO 14001 Strategic environmental management Ensuring environmental issues are addressed in strategic planning Integrating the EMS into the sites business model Leadership Increasing accountability among management team
Protecting the environment Implementing proactive initiatives P2, sustainable resource use, climate change mitigation, biodiversity Environmental performance Improving environmental metrics by establishing measurable performance indicators Focusing on outcomes and results Deploying risk based thinking to reduce impacts Lifecycle thinking Examining life cycle impacts of products and services
Communications Focusing on identifying stakeholder needs & expectations Improving outreach to address stakeholder concerns Documentation Recognizing the use of electronic systems Flexibility in establishing procedures to ensure effective process control 11 What Did the ISO Study Group Recommend? ISO Study Group identified 11 important themes needing to be addressed
Being part of sustainability and social responsibility Including environmental performance improvement Including compliance with legal and other external requirements Linking to overall (strategic) business management Linking to conformity assessment Facilitating uptake in small organizations Considering environmental impacts in the value/supply chain Considering stakeholder engagement Managing parallel or sub systems (Greenhouse Gas, Energy) Reflecting external communication (including product
information) Being part of (inter)national policy agendas 12 Timing Considerations Date of publication September 2015 Official transition period 3 years ISO 14001:2004 standard will be completely retired by September 2018 Actual transition period may be ~2 years (registrars logistical preference) Dual system during transition period May get certified to either standard Presents logistical challenges for registrars & internal audit teams 13
#3 The Public, What They Know About You Matters The public has long had a Right to Know emissions and releases from your plant Today, the public has easy and instant access to your data EPA would like to continue to enhance data availability to the citizenry bordering on real-time monitoring (i.e., EPAs Next Gen compliance) As the owner/operator: Is the data accurate? Do you know what it says? Did you even know the data is available? Some example sources:
EPA Envirofacts - https://www3.epa.gov/enviro/ EPA ECHO - https://echo.epa.gov/ Right to Know Network - http://www.rtknet.org/ Scorecard.org - http://scorecard.goodguide.com/index.tcl 14 Google! Opportunities for Detailed Data Mining Example cement plant data: Air quality: 380,000 pounds of toxic air releases (2002) 2 million tons of CO2! Not in compliance, one $50k civil CAA enforcement in last 5 years Water Quality Permits in current compliance, although one of two permit is expired? Numerous violations in the last 5 years, but no penalties?
Mercury compounds managed in 2014 100 pounds, down 80% in last 5 years Fantastic! See more on next slide PM test on cement kiln May 2015 IPT on kiln stack for PM CPMS Mill Off: PM lb/ton clinker: Run 1: 0.0455, Run 2: 0.0477, Run 3: 0.0377 PM lb/hr: Run 1: 11.7 Production rate during Run 1 257 tons/hr clinker 15 Complies with PC MACT 0.07 lb/ton clinker? Yes! Phew! Highly Granular Data e.g., Mercury Is this your plant?
What happened to the cement industry in 2000? https://oaspub.epa.gov/enviro/P2_EF_Query.master_build_sql?Industry_Search=null&Industry_Search=327310&Chemical_Search=null& Chemical_Search=N458&Year_Search=&Year_Search=2013&State_Search=null&database_type=TRI&page_no=1&pRepOption=2 16 Mikes 6 Ps for Managing Regulatory Change Proactive Planning Promotes Prodigious Plant Performance 17 Thank You! 18
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