Dallas TX May 18 2016 Mike Remsberg PE 1 2 Overview Importance of Change Management Considerations in Improving Change Management Processes OpportunitiesRisks Where Operational Change and Environmental Regulatory Change Meet ID: 531628
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Slide1
Managing the Constancy of Change
Dallas, TX ♦ May 18, 2016Mike Remsberg, PE
1Slide2
2
Overview
Importance of Change Management
Considerations in Improving Change Management Processes
Opportunities/Risks Where Operational Change and Environmental Regulatory Change MeetSlide3
3
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 ContinuouslySlide4
4
Pillars of Inevitable Change
Economic
Product Sales
Operational
Staff Turnover
Technological
Productivity/Automation
Environmental/RegulatorySlide5
5
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 changeSlide6
6
Three Opportunities
To Manage Regulatory Change
Operational Strategy and Permitting Change Management
Updates to ISO 14001 Environmental Management Systems
The Public, What They Know and How Can They Use It?Slide7
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#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 opportunitiesSlide8
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#1 – Operational Strategy and Permitting Change Management (2/3)
Good strategy concepts
Define process constraints in process early
When will a clinker cooler need to be replaced?
Can we respond timely to alternate fuel/raw material opportunities?
Identify permitting applicability and alternatives
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?Slide9
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#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 NO
x
, SO
2
, and GHGs.
Path B – In 2016, existing kilns required to add NOx RACT, and possible SO
2
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 business’s decision makers?
How will you factor these issues on the horizon into your operations strategy?
GHGs NSPS for cement
Anti-coal/coke movement
SO
2
Data Requirements Rule (NAAQS)
PM
2.5
NAAQS
Ozone NAAQS
Process Safety Management/Risk Management Plans
CISWI Compliance
Changes to dispersion modeling requirements, etc.Slide10
10
#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!Slide11
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 site’s 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
Key ISO 14001 Thematic Changes
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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
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Timing Considerations
Date of publication – September 2015Official 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
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#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., EPA’s 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
Google!Slide15
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Opportunities for Detailed Data Mining
Example cement plant data:
Air quality:
380,000 pounds of toxic air releases (2002)
2 million tons of CO
2
!
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 slidePM test on cement kiln – May 2015IPT 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
Complies with PC MACT 0.07 lb/ton clinker?
Yes!
Phew!Slide16
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Highly Granular Data – e.g., Mercury
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
Is this your plant?
What happened to the cement industry in 2000?Slide17
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Mike’s 6 P’
s for Managing Regulatory Change
P
roactive
P
lanning
P
romotes
P
rodigious
P
lantPerformanceSlide18
Thank You!
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