Transcript Results from: Environmental Management System

VEEP and
Environmental Management
Systems
VEEP and
Environmental Management Systems
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What does an EMS mean? (EMS elements)
What’s different in facilities that have an EMS?
How does it relate to DEQ staff?
Why do facilities participate in VEEP?
What are potential regulatory benefits
(incentives)?
What does an EMS mean?
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An EMS is an organized approach to managing
environmental impacts at a facility
Provides a consistent review of all operations
to determine the environmental impacts and
focus resources on the most important issues
Covers all requirements; regulatory, Corporate
or company requirements
Includes activities and impacts that are not
covered by regulations
Elements of an EMS
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EPA’s EMS elements:
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Environmental Policy
Regulatory Requirements Identification/Tracking
Roles/Responsibilities
Training and Communication
Environmental Control and Monitoring
Compliance Change Management
Corrective and Preventative Actions
Records and Recordkeeping
Audits and Inspections
Management Review
Can also be “home-grown”
What’s different in facilities that have an
EMS?
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Usually the facilities are well run and have other
management systems (safety, quality, financial, etc.)
Generally have progressive environmental programs
and good compliance history.
Often involved in “beyond compliance” activities
Participate in voluntary environmental, health and
safety programs (VEEP, Performance Track, VPP Star)
Employee engagement and management support
Reducing environmental impacts becomes everyone’s
job, not just the EHS staff
How does VEEP relate to DEQ staff?
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Facilities within VEEP are usually the “good
guys”
May expect to be treated with more trust and
respect – because of their performance
Often willing to consider alternative
approaches that make sense for the company,
the environment and the DEQ.
Why “waste” DEQ time inspecting facilities that
are in compliance?
Why does a facility participate in VEEP?
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Recognition
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Community and Employees
Regulators
Corporate Management
Environmental, Safety and
Health Staff
EHS viewed as an asset
by plant management
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Plant managers usually
hear only problems, we
bring good news and
positive recognition
Who is in VEEP?
2%
29%
34%
2%
33%
Commercial
Manufacturing
Fed Govt
Local Govt
State Govt
VEEP Participation (Cont.)
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Improved communication with
regulators
Opportunity to “show off”
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Potential regulatory relief
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It’s enjoyable working with other
facilities on their EMS goals
180 RCRA Waste Storage
MACT reporting reductions
More pending with EPA
Improved image with Customers
Cost Savings
Low cost of participation
Role of Incentives in Voluntary Programs
From the EPA Performance Track web site:
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Incentives are being designed and implemented to:
 Recognize and reward environmental
accomplishments
 Encourage facilities to perform beyond basic
compliance
 Allow members to operate more efficiently, and,
 Demonstrate that innovation is integral to EPA’s
evolving framework
Desirable Features of Good Incentives
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Apply to a broad range of industry or really attractive to one
segment
Easy to understand, implement and verify
Will save time and money for both industry and government
Result in measurable environmental improvements (preferably at
lower cost)
Attractive enough to encourage membership by all sizes of
companies including small to medium size businesses
Improve the environment faster than otherwise expected (can also
reduce non-point source pollution or releases of non-regulated
pollutants)
Significantly increase the number of members so the environment
will show measurable improvement
Possible Non-Regulatory Incentives
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Time
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Priority Permitting (also known as Expedited Permitting or Top of
Pile)
Reduced inspection priority
Faster permitting for pollution control projects
Insurance benefits
Financial
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Preferred buying list for the government
Tax benefits
Revolving loans
Possible Non-Regulatory Incentives
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Flexibility
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Access
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Flexible permits – changes made quickly, encourages innovative
technologies, improves speed to market
Someone to talk to for new permits and concerns
Publicity
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Recognition for “beyond compliance”
Benefit of doubt if compliance issue occurs
Socially responsible investment organizations give credit for
membership
Practical Experience Implementing
Incentives
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Facility unique priorities
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Regulatory change is hardest
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Every facility seems to have their own issues and priorities
making the selection of a broad based incentive difficult
Non-regulatory changes are the most likely to succeed
Culture Change has been slow
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Many people and organizations accept the inefficiencies of the
existing regulatory structure and are uncomfortable with change
Change will come slowly to those willing to invest time and effort
and some changes have been happening lately
EPA Incentives Initiatives
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EPA Administrator is championing Performance
Track
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Other organizations involved
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Air, water and waste initiatives being studied
ECOS
PTPA
EPA regulatory and Performance Track Program
changes
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Visit EPA’s web site for more details
Current EPA Incentive Initiatives
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Air
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Water
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Flexible permits rulemaking – PT permit applications ahead of
others
Reduced frequency of MACT reporting for PT sites (April 2004
rule)
Expired NPDES permits, PT permits first
Trade ambient water quality data for reduced permit monitoring
data
Waste
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Extension of onsite storage times for hazardous waste (April
2004 rule)
Specific EPA Incentives (Air)
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Facilities that are members of Performance
Track that are governed by Maximum
Achievable Control Technology (MACT)
provisions of the Clean Air Act (CAA)
benefit from reduced reporting frequency
(annual instead of semi-annual). In certain
cases, they may submit annual
certification statement in lieu of annual
reports.
Specific EPA Incentives (RCRA)
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The Resource Conservation and Recovery
Act (RCRA) regulations were revised to
allow hazardous waste generators who are
members of Performance Track up to 180
days (and 270 days if waste is transported
200 miles or more), to accumulate their
hazardous waste without a RCRA permit
or interim status.
Current Virginia Incentives for Env.
Excellence Participants
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Discounts to the annual permit fees will be
applied for solid waste, hazardous waste and
water fees issued during the summer of 2005 for
facilities that were in the program prior to
January 1, 2005 and remain in good standing.
The following slides explain the reductions for
Solid Waste Permit, Hazardous Waste & Water
Permits.
Solid Waste Permit Fees
Reduction
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Potentially up to a 10% discount for E2
facilities (maximum of three years)
Potentially up to a 20% discount for E3
facilities
(see 9 VAC 20-90-117)
Hazardous Waste Permit Fees
Reduction
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Potentially up to a 5% discount for E2
(maximum of three years)
Potentially up to a 10% discount for E3
(see 9 VAC 20-60-1286)
Water Permit Fees
Reduction
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Potentially up to a 2% discount for E2
(maximum of three years)
Potentially up to a 5% discount for E3
(see 9 VAC 25-20-145)
Alternate Compliance Methods
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Rule issued (March 24, 2005) giving
Virginia Environmental Excellence
members (E3 and E4 levels) the option of
“alternate compliance methods”
Chesapeake Bay Nutrient Strategy
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Alternate Compliance Method for Virginia
E3 & E4 members
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Suspension of applicable Technology-based
effluent concentration limitations
Permittee must fully-implement their EMS
EMS specifically addresses nutrients
Facility maintains nutrient removal
technologies at the treatment efficiency levels
for which they were designed.
How to Request Regulatory
Flexibility
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Each site should request specific regulatory
flexibility items in writing to Sharon Baxter
(Pollution Prevention Group at DEQ Central
Office). They should copy their DEQ Regional
Director on this request.
Promoting P-Track & VEEP
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These “road shows” including the P2 staff
presentation in the spring
Providing brochures and posters to each
Regional Office
Announcements of recognition ceremonies
on the P2 web site
Identifying P-Track & VEEP membership in
the CEDS database on the “facility” screen
Environmental Innovation Project
International Paper
Franklin, VA
(example of regulatory flexibility
awarded to EPA PT and VA DEQ
E4 site)
Purpose of Innovation Project
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Partnership Approach
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Innovative & Cost Effective
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Exceed Regulations
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Maximum Benefit to Environment,
Community & Mill
Traditional Environmental
EPA MACT Rules
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EPA Cluster Rule MACT I Phase II requires
collection and incineration of methanol air
emissions from sources in the paper mill.
Cost estimate for Franklin: $32 MM by
year 2006.
Innovation Concept
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Identify more cost effective means to
collect equivalent amount of methanol as
EPA regulations require
Invest half of the avoided capital cost in
voluntary environmental improvement
projects at the plant
Use a Stakeholder Group to identify which
voluntary environmental projects were
chosen
Innovation Concept
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Collect equivalent amount of regulated air
emissions (methanol)
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Identified alternate sources of same amount
of methanol air emissions for collection to
what rule required
Cost estimate : $22.5 MM (Provides avoidance
of $9.4 MM in capital costs)
Innovation Concept
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Invest half of capital avoidance dollars for
voluntary superior environmental projects
at Franklin mill
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Stakeholder team selected projects
Proposed spending: $7 MM (75% avoided
cost)
Superior Environmental
Performance Projects
What IP is Offering to
Voluntarily Implement
Voluntary Environmental
Improvement Projects
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Voluntary projects focused on all media (air, water and
waste reductions)
Projects included air system improvement in boiler,
process changes to reduce fugitive dusting, recycle of
waste water, recycle of solid waste, effluent treatment
system improvements)
Significant environmental benefits from projects:
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Air emissions reduction (560 tpy SO2, 75 tpy NOx)
Fugitive dust reduction (8 tpy)
Groundwater withdrawal reduction (0.5 MMGPD)
Solid waste reduction (8600 lb/day)
Effluent quality improvement (2000 lb/day COD)
Environmental Innovation
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Environmental Innovation Project is beneficial
to:
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the environment due to the same amount of
regulated methanol being collected, as well as $7 MM
of voluntary environmental improvement projects
being implemented (air, water and waste reductions)
The community, Va DEQ, EPA and International Paper
due to partnerships formed in finding an Innovative
way to meet environmental regulations
“Win-Win for environment, the community, and the Franklin mill”