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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
415-947-3530 (fax)

                      "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                                                                        
                      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
 -----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

      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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