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RE: Industry environmental initiative waning?



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