environment
OPPOSITES ATTRACT AT DOW CHEMICAL Production managers and Dow critics hammer out capital spending plan to reach 35% waste reduction goal Jeff Johnson C&EN Washington
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iane Hebert doesn't like Dow Chemical Co. very much. In fact, Hebert has led environmentalists in battles with Dow for many of the 20 years she has lived a few miles from the huge Midland, Mich., chemical complex. But now she is advising its chemical engineers on how they should spend the company's money to make process changes to cut wastes in Midland. Hebert is one of five environmental activists taking part in an experimental program called the Michigan Source Reduction Initiative. The activists, some of whom represent environmental groups, bring to the table decades of experience with Dow's permits, wastes, and impacts on the community. The group includes only one representative of a national organization, the Natural Resources Defense Council (NRDQ, which put together the enterprise. No state or federal government agency or trade association is involved. The initiative is "inventing a transportable template" that can be used by other communities and chemical companies, says Bill Bilkovich, a pollution reduction expert and Dow consultant. "I've done pollution prevention for a decade at 200 different plants and I can tell you nothing drives pollution prevention like the exposure of people in the manufacturing business to environmental activists." Under the program, a committee of the activists and Dow production managers has selected 26 chemicals on which to focus pollution reduction efforts. Dow has agreed that by next April 30, after it makes its annual capital allocation decisions, it will have approved projects to reduce air and water emissions by 35% and cut the overall amount of waste generated, as measured against output, by 35%. This second figure will be the toughest to meet because it is indexed to production output. It also can't include treatment 34 AUGUST 17, 1998 C&EN
techniques. Consequently, a slump in chemical business, closing a particularly wasteful product line, or incinerating waste won't help Dow meet this target. The project's emphasis is on preventing pollution, not controlling it, activists and plant personnel say, but the way Jeff Feerer—environmental, health, and safety manager for Dow's Michigan operationssees the project, it is as much about education as it is about preventing pollution. Feerer says the initiative works like this: Facility managers from each of Midland's eight global business units, which are product-based profit centers, meet with activists at least quarterly to discuss how they intend to reach the pollution reduction goals. "Business groups bring projects with them, and they discuss the economics and the waste reduction that might be achieved through the projects," he says. "Sometimes production managers say they don't see any way pollution prevention can be applied to their product lines. Then the activists ask questions: 'Have you considered a substitute for this solvent? ç
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Bilkovich: prevention viewed as risky
What about recycling the waste rather than shipping it off-site?' The businesspeople then go away and think about it and come back with another plan. "Our activist friends," Feerer says, "bring a diversity of points of view that helps us pick the right projects to work on. This has really opened up the thought process of our business leaders about what really concerns citizens groups and ways we can accommodate those concerns that make business sense." Feerer and Hebert say their goal is to foster institutional changes within Dow that will shift company thinking from struggling to comply with environmental regulations to proactive pollution prevention as well as get environmental thinking into core business planning. "This is not a complete answer," Hebert stresses, but she says the project might lend support to "progressive people within Dow who would like to move a little faster." Feerer adds that Dow also wants to help educate environmental critics so they understand how a business works and how capital decisions are made. Another goal is to see what can actually be gained by using pollution prevention techniques and to make the results known to the public and the industry. Like many in the chemical industry, Feerer believes regulation-driven controls have produced about as much pollution reduction as they can, and he blames regulations for end-of-pipe treatments, which predominate in the industry. "What typically happens," Feerer says, "is the Environmental Protection Agency comes out with a regulation; it doesn't give companies enough time to implement it; companies wait until the last minute and then say, 'Gosh, we've got to do something.' Then they go out and buy a giant scrubber or something that makes no economic sense. "What we want to do is step back and without pressure find some economical way and business value way to achieve the same ends with pollution prevention." The two groups have been discussing the project since April 1996, and both sides have their experts—Dow has hired Bilkovich, president of Environmental Quality Consultants, Tallahassee, Fla., to assess waste, and the activists are relying on Steve Anderson, a consultant formerly with New Jersey's waste reduction program. The initiative grew from a smaller pollution prevention agreement tried at Dow's La Porte, Texas, facility between
Dow and NRDC. Bilkovich also conducted the assessment there. That assessment, according to Linda Greer, NRDC senior scientist, identified several pollution prevention options that Dow could have taken to reduce emissions, save money, and shut down a hazardous waste incinerator. However, Dow chose not to take them. Pollution prevention is risky, Bilkovich says, and the La Porte message is that just because there is a monetary benefit in pollution prevention, it doesn't mean the company will take it. On the other hand, end-of-pipe pollution controls are mandatory, he says. "You have to do them." Bilkovich says if a chemical engineer chooses a pollution prevention solution, he or she must change the production process. That process is at the core of a business' profitability, Bilkovich notes. It is why an engineer goes to work in the morning. "If you mess up the production line, you are in big trouble. Your job is at stake and your kids might not go to college. "If you choose end-of-pipe pollution controls, you are doing what is expected of you. You don't have to fight for capital because you have to do it. And if it fails for you, it probably failed for everyone else too. Join the crowd." He adds that the engineer can probably avoid culpability—the failure is usually seen as the fault of the regulation and EPA. He says end-of-pipe pollution control also has a long, rich history, going back to EPA's roots in the early 1970s. Congress and corporate America did not want EPA regulating processes inside the plant. "So regulations were written for end-of-pipe controls, and industry placed one guy at the plant line and told him to stop pollution. Everybody else worked on processes in the plant to make money," Bilkovich says. "But you can't see anything from the end of the pipe, except all this waste coming out. "Once you start moving up the pipe toward processes, you see so many more opportunities but you also see so much greater risk. You really need a corporate culture that mitigates the risk of pollution prevention, of fiddling with the process." In Dow's case, he says, when the company set a series of global emissions reductions goals in 1996, one of them was to reduce waste per pound of production by 50%. "Dow backed itself into a corner out of which there is only one door—pollution prevention." Feerer agrees that the 2005 goals are
Dow and activists pick 26 compounds for cuts Acrylonitrile 1,3-Butadiene Chlorine Chloroethane Chloromethane Chromium 1,2-Dichloroethane 2,4-Dichlorophenol 2,4-Dichlorophenoxyacetic acid Ethylbenzene Formaldehyde Hydrochloric acid (air releases and burned only) Methylene chloride Phosgene Styrene 1,1,1,2-Tetrachloroethane Tetrachloroethylene Toluene 2,4,6-Trichlorophenol Vinyl chloride Vinylidene chloride Five process-specific mixed wastes helping drive pollution prevention. Consequently, he says, Midland's trial initiative may become a corporate model. "This is a very big facility with a lot of opportunities," he says. Still, he notes that "bonus points" might be necessary to encourage corporate bean counters to select pollution prevention projects that might save some money but have a smaller or longer payback. "With this project, we are trying to figure out what a 'bonus point' might be and trying to find some way to institutionalize the community concerns this group brings to our business decisions." Health and environmental decisions, he notes, for instance, weighted with community interest, might exceed solely economic considerations. Bilkovich adds that companies often underestimate the true cost of waste. Most but not all companies today list disposal costs in cost accounting calculations, but they frequently don't list raw material costs. They hardly ever consider what he calls "conversion costs." These costs, Bilkovich says, are generated when a company is tying up valuable production machinery by making what is going to wind up as a waste because of inefficiencies. "When you add in those costs, the numbers get high real fast," he says. Also complicating pollution prevention's application is the kind of production taking place in today's chemical industry, he says. Chemical company pro-
cesses are becoming more like those of the pharmaceutical industry, in which there may be 10 steps and tons of solvents used to make a small quantity of very valuable molecules. The result is high reluctance to change a process and risk damaging an expensive product, despite the generation of large volumes of wastes. In Midland, Bilkovich says, waste-toproduct ratios vary hugely—from 10 lb of waste per 1 million lb of product to 85 million lb of waste per 1 million lb of product. Typically, the ratio runs at about 6,000 lb of waste per 1 million lb of product. Because of Midland's size and diversity of products and waste, a spreadsheet for all the company's wastes runs 4,500 rows long, with some waste only being 1 lb while others are 1 million lb. Although Bilkovich works for Dow and has a confidentiality agreement with the company, he is respected by Hebert, who calls him "a kind of waste detective. He's almost obsessed with finding ways to reduce pollution." She says some in the group are quite worried about being used by Dow. "They fear," she says, "that the company might just say, 'Okay. We have pollution prevention now, and we don't need laws or regulations.' We also are worried that our peer groups will say we sold out." Some also would like to broaden the discussion, Hebert says. "Members are concerned that Dow's products are not sustainable. They want to sell chlorinated products, for instance, and we want to phase them out. We don't want to participate in making a better cigarette," she says. There have been reservations on the Dow side, too, particularly over whether anything will come of all the meetings. But Feerer stresses that at each meeting's conclusion, "everyone has left pleased." "Still, there are tremendous differences between us and some of the activists," he says. For instance, the day before the July 16 press conference announcing the initiative, a group Hebert leads—called Dow Dioxin Watch—issued a press release claiming Dow's dioxin emissions exceed safe levels. Dow disagreed, but an article wound up on the front page of the local paper. "The next day, the same people were sitting down with us and talking about cooperation," Feerer says. Adds Hebert: "We are trying to be so polite. But it is not always easy. We've had our moments. But I've always found Dow works best under a little pressure."^ AUGUST 17, 1998 C&EN 35
