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Managing the Constancy of Change Managing the Constancy of Change

Managing the Constancy of Change - PowerPoint Presentation

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Managing the Constancy of Change - PPT Presentation

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

change management environmental amp management change amp environmental strategy data cement permitting search operational systems iso compliance process opportunity

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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

7

#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

8

#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

9

#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

11Slide12

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

12Slide13

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

13Slide14

14

#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

15

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

16

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

17

Mike’s 6 P’

s for Managing Regulatory Change

P

roactive

P

lanning

P

romotes

P

rodigious

P

lantPerformanceSlide18

Thank You!

18