RE: Industry environmental initiative waning?

["Short, Jeffrey" <Jeffrey.Short@em.doe.gov>]

Re:  Case study.  In the Washington DC area, security concerns post-9/11
caused the conversion to the CL alternative at our Blue Plains wastewater
treatment plant (located in southeast DC next to the Naval Research
Laboratory,  near Bolling AFB and across the Potomac from Alexandria, VA).
The health risks from a potential release apparently reached an unacceptable
level due to a (possible) new scenario; P2 was never the issue though the
benefits would accrue similar direct benefits (return-on-investment) as well
as new indirect ones (lower levels of security required, etc.)

-----Original Message-----
From: Mark Johnson [mailto:Mark.Johnson@lcra.org]
Sent: Tuesday, December 17, 2002 10:21 AM
To: Melinda.Dower@dep.state.nj.us; NPPR@great-lakes.net;
P2Tech@great-lakes.net; Todd_MacFadden@uml.edu
Subject: Re: Industry environmental initiative waning?


>From another "closet enforcer" 
 
When it comes to spending money on the Environment, most facility managers
have always questioned why are we doing this?  Especially  if there are no
clear regulatory requirements.  TCEQ has a regulatory requirement that
forced many industries/companies to develop P2 plans.   Without this
regulation, P2 planning in Texas would not be as widespread.    If the
regulation had more teeth, more P2 would have been implemented;
unfortunately over time the regualtion just became a paper exercise (I don't
think there ahve been any enforcemnt actions that resulted in a fine).  If
implementation of the P2 plans was enforced,  more P2 would have occurred.
 
P2 projects still get implemented without regulations if they have really
good paybacks; unfortunately, most low-hanging fruit has been taken and
remaining P2 projects may not be the best investment, especially when
competing with other projects that have equal or better returns on
investment.   
 
In my opinion, environmental regulations provide the trump card during the
cost benefit analysis phase of a P2 project evaluation, especially if
implementation of a P2 project results in the elimination/reduction of a
regulatory burden.  
 
Case Study:
Chlorine is widely used for industrial water treatment, it is cheap to use,
works well, and is familiar to all water chemistry staff.  One big problem,
it has the potential to significantly impact human health and the
environment.    Many years ago, there were several products that could have
been used as a substitute for chlorine usage, but there was little
regulatory pressure to cause change.   Despite readily available
replacements for chlorine and the potential risk to human health, the
project was not implemented.   Several years ago, EPA rules were put in
place that addressed this issue.  The rules required facilities that used
chlorine to develop Risk Management Plans (RMPS).   The RMPs defined the
extent of a maximum release plume and required facilities to identify and
notify all residential/commercial entities located within the area of the
maximum release plume.  In addition, the facility was required to provide
employee training to all personnel associated with the chlorine process.
With regulations in place, and re-occurring compliance costs, the facility
once again looked at substituting chlorine with a less toxic product.    The
cost benefit study was still the same as before; however, the added benefit
of getting out of the RMP requirements provided the incentives necessary to
cause change.   The facility now in the process of converting to a liquid
bleach and is exempt from  RMP requirements.  Management celebrated the
reduction in compliance/training costs.
 
The celebration should have been the elimination of a potential catastrophic
chlorine release (120 people in the community and 400 employees were no
longer at risk).   The risk was eliminated by employing the common P2
practice of product substitution.    
 
Environmental regulations can drive P2 more than any other factor -
conversely if not written correctly, they can also prevent P2 more than any
other factor as they commonly prescribe specific control technologies. 
 
Mark L.  Johnson, PMP., CPEA.
Senior Environmental Coordinator
Lower Colorado River Authority
Email: mark.johnson@lcra.org <mailto:mark.johnson@lcra.org> 
Phone (512) 473- 3200 ext 2868
Fax: (512) 473-3579
Fax (512) 473-3579


>>> "Melinda Dower" <Melinda.Dower@dep.state.nj.us> 12/17/02 08:00AM >>>
Having been a "closet enforcer" for many years, I am heartened to see
everyone's conclusions about the limited effectiveness of voluntary
programs--I feel like I can come out of the closet now. Even here in NJ,
where P2 Planning is mandatory but implementation of P2 measures is
voluntary, I have had numerous corporate representatives comment that
they would be implementing much more P2 if it were mandatory.
Regulations drive corporate behavior far more than anything voluntary
(with the exception of the maybe 10% high performers who are doing great
P2 and have integrated P2 into their own performance measures).
It is also important to note that government has not delivered on its
promises to provide flexibility.

Melinda Dower
Research Scientist
N.J. Department of Environmental Protection

>>> "Todd MacFadden" <Todd_MacFadden@uml.edu> 12/16/02 04:00PM >>>
Hey all,

It's a bit dated now (Nov 23), but I just came across the following NY

Times article in which the late Bill Bilkovich is acknowledged for his
work 
to advance pollution prevention efforts at Dow.

Dialogue on Pollution Is Allowed to Trail Off
By BARNABY J. FEDER

http://www.nytimes.com/2002/11/23/business/23CHEM.html?tntemail1
<http://www.nytimes.com/2002/11/23/business/23CHEM.html?tntemail1>  

The article suggests a disturbing trend that industry is increasingly 
moving away from voluntary and collaborative approaches to P2 - and the

concomitant gains in environmental protection - abetted by a more 
permissive adminstration. (It was, case in point, published the day
after 
Bush hobbled the New Source Review rules).

I am curious to know what people think about the fate and future of 
voluntary environmental initiatives as a tool to protect the
environment. 
For years, industry has pressed EPA and states for flexibility in
standards 
and more non-regulatory approaches to reduce pollutants. And the
approach 
seems to work - but (it would appear) only to the extent that more 
stringent standards are imminent. Does your experience with voluntary 
programs support this view? Are they just smoke and mirrors?

Todd MacFadden
*:-.,_,.-:*'``'*:-.,_,.-:*'``'*:-.,_,.-:*'``'*:*:-.,_,.-:*'*:-.,_
Todd MacFadden
Training Specialist
Toxics Use Reduction Institute
One University Ave
Lowell, MA 01854

978.934.3391
978.934.3050 (fax)

todd_macfadden@uml.edu 
www.turi.org <http://www.turi.org>  

Because not everyone can live upstream.
,.-:*'``'*:-.,_,.-:*'``'*:-.,_,.-:*'``'*:*:-.,_,.-:*'*:-.,_,.-:*'

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