Establishing Regulatory Compliance in a New Plant

Abstract

Lenox China has built and started up two new plants in the past 10 years. Insightful project leadership assured that environmental concerns were addressed from the outset of each project. Some lessons have been learned from serendipity and, unfortunately, some from project oversights. Elements of these lessons also were applicable to major re-engineering of the 40-year-old Lenox China plant in Pomona, N.J., and to major process changes in all Lenox plants in a program of continuous improvement. It is conceptually easy to design a greenfield plant and its processes to minimize environmental impacts and incorporate waste minimization. The effect of this design process ripples through the design of the facility, equipment specifications, job descriptions and operations. There is an opportunity to set up the entire environmental future of the plant, i.e., to be proactive. Top management should craft an environmental policy for the plant to guide the design team. The design team, including an environmental expert, should determine the environmental concerns early in the process and open a dialog with appropriate regulatory agencies. Where wastes must be generated, an environmentally and economically sound-recycling program should be part of the design, including negotiations with the outside contractors who will transport andmore » recycle the wastes. Many opportunities can be found to optimize all areas of plant design.« less