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RE: Industry environmental initiative waning?
I agree with Bob, except the green eye shade crowd rarely looks at the
environmental benefits of enforcement. While voluntary programs - and P2
in particular - are increasingly required to justify themselves with
quantified reductions and environmental benefits, I have not seen a
similar pressure on the compliance crowd to show how they are improving
the environment. Their success measure continue to be number of
inspections, number of violations, amount levied in fines and penalties
- none of which indicate any benefit to human health or the environment.
Begs the question about the relative benefit of a dollar spent promoting
P2 and a dollar spent on enforcement.
That said, I agree with Leann that a hybrid approach is the most
effective in getting P2 implemented. Combining P2 with compliance
assistance and enforcement improves all the programs - the enforcement
folks get their "beans", the facilities have both the motivation and the
assistance to do the right thing, and we are more likely to see
immediate and long-term reductions through implementation of P2.
John Katz
Pollution Prevention Coordinator
US EPA Region 9
75 Hawthorne Street, WST-7
San Francisco, CA 94105
415-972-3283
415-947-3530 (fax)
katz.john@epa.gov
"Minicucci, Bob"
<rminicucci@des.s To: Mark Johnson <Mark.Johnson@lcra.org>,
tate.nh.us> Melinda.Dower@dep.state.nj.us, NPPR@great-lakes.net,
Sent by: P2Tech@great-lakes.net, Todd_MacFadden@uml.edu
owner-p2tech@grea cc:
t-lakes.net Subject: RE: Industry environmental initiative waning?
12/17/2002 07:33
AM
Please respond to
"Minicucci, Bob"
No one doubts that regulation is a good and useful tool. An insistence
that it be theonly tool seems misplaced however.
On the other hand, in the absence of good cost/benefit accounting,
regulatory pressure has become, arguably, the best way to answer the
"why are we doing this?" question from the green-eye-shade crowd.
Bob Minicucci
NH DES
603-271-2941
-----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
Phone (512) 473- 3200 ext 2868
Fax: (512) 473-3579
Fax (512) 473-3579
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