Pollution Prevention: Doing it right from the start

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Pollution Prevention Doing it right from the
start!

• Sponsored by IDEMs Office of Pollution
  Prevention Technical Assistance through funding
  from U.S. EPA

Cam Metcalf Executive Director
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Agenda

• What is pollution prevention (P2)?
• Why should P2 be important to me as an employee
  of IDEM?
• What are some ways that I can promote P2?

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1. What is Pollution Prevention (P2)?
Part 1
www.kppc.org
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The Big Squeeze is on! There is a new global
business environment!
Inefficient use of Resources
Market
Environmental
Water Climate Resources Life Cycle Management
Globalization E-Commerce
Cost Containment Developing Countries
Organization
Social Interested Parties
Legal Other Requirements
Regulations Homeland Security Take Back Laws Self
Reporting
Responsibility Roles Transparency Accountability
Resource Scarcity
Core Values
Technology Diffusion
Corporate Values Leaders Values Societal Values
Materials P2 Technologies Connectivity
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Our Universal Backyard

• NIMBY
• NOTE
• BANANA
• CAVE
• NOPE

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90 Pollution Prevention (P2) Act Defines Source
Reduction as
Any practice which reduces the amount of any
hazardous substance, pollutant, or contaminant
entering any waste stream or otherwise released
into the environment (including fugitive
emissions) prior to recycling, treatment, or
disposal and reduces the hazards to public
health the environment associated with the
release of such substances, pollutants, or
contaminants.
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Waste Management Hierarchy
Source Reduction/E2
Reuse/Recycling
Energy Recovery
Treatment
Disposal
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P2 is SellingMulti-Media Approaches

• W ater
• A ir
• S olids
• T ime
• E nergy Efficiency (E2)

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P2 Means

• Process modifications
• Feedstock substitutions
• Product reformulation
• Management practices or housekeeping alterations
• Recycling within industrial processes or
• Equipment replacement or modifications.

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P2 Source Reduction

• P2 means Source Reduction
• other practices that reduce or eliminate the
  creation of pollutants through
• Increased efficiency in the use of raw materials,
  energy, water or other resources or
• Protection of natural resources by conservation.
• Resource Management

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Cross-Media Transfer
Waste
Gaseous/ Particles
Gaseous/ Particles
Waste Processing
Wastewater
Wet Scrubber
Air Stripper
Solid Residuals
Gaseous/ Particles
Watercourse
Land
Air
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Cross-Media Transfer (cont.)

• An example of cross-media transfer
• Facility installs a wet scrubber VOCs
  transferred from air to water, which is
  discharged into a nearby stream.
• Discharge to stream requires water permit
  modification air stripper is installed to meet
  permit requirements--VOCs transferred back to the
  air.
• New air stripper requires another air permit.
• After 3 permits, 3 years, 3,000,000 the same
  amount of contaminants are reaching the air!
• Pollution Prevention Review, Steven Anderson
  Jeanne Herb

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Evolution of an Organizations Environmental
Management
Sustained
Sustainability
Eco-efficiency
Product stewardship Design for
Environment Life-Cycle assessment
Competitive Advantage
Environmental Management Accounting Environm
entally Preferable Purchasing
Environmental Management Systems
(EMSs) Energy, Water Resources Conservation
Pollution Prevention
Market Driven
Pollution control compliance
Compliant
Noncompliance waste pollution
Reactive
Unprepared
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P2 Value Added
Tool for an organizations environmental
performance!

• Add Value
• Fulfillment
• Expectations
• Exceed Expectations

• Prevent Waste
• Involvement or
• Commitment

Owner Employees
Suppliers Contractors
Customer Delight
Process
Customer Satisfaction is Worthless Customer
Loyalty is Priceless!
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P2 Sustainable Phases
OPERATIONS
EQUIPMENT/ SYSTEMS
PRODUCTION PROCESS
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Source Reduction Operation Phase
Recognized Need
Start
Assessment Training
PHASE ONE
Good Housekeeping
Waste Separation
0-6 months, Big Return on Investment
Simple Recycling
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The P2 Policy Drives Objectives Targets
Conserve natural resources
P2 Policy
Objective
Reduce water usage
Reduce water consumption 25 (from 2005 baseline)
Target
Environmental performance measurable
results based on the policy, objectives targets!
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Source Reduction Equipment Phase
Process Controls
Equipment Modifications
PHASE TWO
In-process Reuse Recycling
6 months - 2 years Some Return on Investment
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Source Reduction Process Phase
Complex Recycling, Refining, Reuse
Process Changes
PHASE THREE
Raw Material and Catalyst Changes
Product Reformulations
2 years - 5 years Little Return on Investment
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2. Why should P2 be important to me as an
employee of IDEM?
Part 2
www.kppc.org
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Regulatory Barriersto P2

• End-of-Pipe Focus
• Media-Specific Focus
• Data Gathering Management
• Regulatory Program Evaluation Criteria
• Regulatory Inflexibility
• Regulatory Uncertainty
• Pollution Fees (KYs fee per lb. generated)

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Integrating P2 into an Organizations Existing
Programs

• Productivity Enhancement
• Quality Management Systems
• Preventive Maintenance
• Operation Automation
• Inventory Control (JIT)
• Product Development
• Computer Integrated Mfg.
• Employee Health Safety
• Environmental Management

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P2 Regulatory Integration

• What is It?
• Can save agency time money by re-working
  existing programs
• Often is voluntary incentive-based
• Benefit for business (financial savings)

• What is it not?
• Another expensive effort for agency to overlay
  on existing programs
• Another mandatory program to enforce
• Another burden for business

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Primary Mechanisms forP2 Integration

• Leverage the Regulatory Process to affect P2
• View generators/emitters as suppliers
• What can you do to get them to supply the highest
  quality product (compliance) for the least cost
  to you?
• Help them to reach regulatory agency goals
  compliance, risk reduction P2
• Identify implement internal P2 opportunities
• Dont be a Barrier!

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Leverage the Regulatory Process

• Be clear that the goal is P2 - Change perspective
  from seeing limits as goals
• Integrate P2 into your communications with
  generators (dischargers emitters)
• Use (local) authority to set P2 standards for
  both industrial non-industrial generators

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P2 Regulatory Integration
Why do it?

• Agency Benefits
• Less money/staff time to implement programs
• Reduced oversight (for Local, State EPA)
• Environmental Benefits
• Improved compliance
• Reduced emissions/discharges/releases
• Industry Benefits
• Regulatory flexibility
• Internal benefits ( EMS development
• savings)

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3. What are some ways that I can promote P2?
Part 3
www.kppc.org
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Learn about P2 Opportunities for Industry Sectors

• Point out potential P2 areas during inspections
  permit writing
• Provide P2 information, contact persons
  telephone numbers to organizations
• Use the Internet as a resource

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Internal Management

• When possible, revise standard permit
  compliance correspondence to allow for P2 options
• Include P2 in staff training, job descriptions,
  performance evaluations program work plans
• Report P2 successes failures to OPPTA so that
  Indianas P2 can be measured

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Cross-Agency Relations

• Encourage promote innovative practices
• Encourage facility planning
• Make referrals to P2 technical assistance (OPPTA)
• Integrate P2 into compliance assurance
  permitting, etc.
• Encourage facilities to do prevention-based,
  multimedia Emergency Response Plans
• Integrate P2 into new compliance promotion
  programs

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Compliance Assurance (Info)

• Provide P2 info to facilities in inspection
  process
• Refer to OPPTA, those sources needing technical
  assistance or outreach based on publicly
  available data geographic location
• Coordinate with OPPTA on opportunities to target
  sectors or individual facilities with P2
  outreach/ compliance assistance (e.g., target
  Majors close to Minor threshold LQGs close to
  SQG-dom, etc.)

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Compliance Assurance (Process)

• Incorporate P2 suggestions into inspections
• Alter inspection schedule according to P2
  consideration
• Extend compliance schedule for facilities
  attempting to achieve compliance via P2
• Limit amnesty for non-permitted sources
• Include specific P2 conditions in enforcement
  settlements (SEPs)

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Permitting (Information)

• Distribute P2 info during permit application
  process
• Offer pre-permit meeting with P2 staff as part
  of permit renewal letters
• Distribute BMP manuals to sectors to help them
  avoid permits
• Promote Use of P2 Plans Programs at facilities
• Conduct P2 assessments (by agency/facility) when
  NSR application fails risk screening
• Use publicly available data to understand
  target P2-based permitting activities

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Permitting (Process)

• Link size of new treatment systems to P2
  implementation
• Alter permit-renewal schedule according to P2
  consideration
• Integrate P2 language conditions (e.g., air,
  NPDES, etc.)
• Pilot multimedia permits that include a P2 basis
• Include administrative incentives in permit in
  exchange for P2 (e.g., fast-tracking emissions
  credits emissions caps/PALs)
• Identify, in original permits, certain kinds of
  changes that require lesser or no agency review

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Rulemaking

• P2 as means of compliance with rules is optimal
  choice for all involved
• Integrate P2 language, conditions and compliance
  options into proposed rules
• Develop multimedia rules that include a P2 basis
• Draft rules with flexibility to incorporate,
  encourage and reward P2 approach

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Enforcement

• Encourage P2 Supplemental Environmental Projects
  (SEPs)
• Incorporate P2 into Agreed Orders compliance
  action plans

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In the Office

• You Can be a Partner for P2 Too!
• Follow the 3 Rs Reduce, Reuse and Recycle
• Electronic documents, 2-sided printing, purchase
  of green products, recycle office paper, use E85
  fuel in state vehicles when an option, use public
  transportation
• Turn off electrical items when not in use

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Pollution Prevention Assistance

• Please contact
• Office of Pollution Prevention and Technical
• Assistance
• [phone]
• www.in.gov/idem/prevention
• Karen Peterson (Teliha), Branch Chief
• Free, confidential site visits conducted by
  OPPTAs P2 Branch
• Please contact
• J. Brian Eaton (OPPTA)
• [phone]
• beaton_at_idem.in.gov

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Pollution PreventionDoing it Right From the
Start!

• P2 is Good for the Environment and Indianas
  Economy
• All IDEM staff are essential to the agencys
  success and P2 efforts!

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We must walk consciously only part way toward our
goal, and thenleap in the dark to our success.

• Henry David Thoreau