veep and environmental management systems
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VEEP and Environmental Management Systems. VEEP and Environmental Management Systems. 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? - PowerPoint PPT PresentationTRANSCRIPT
VEEP andVEEP andEnvironmental Environmental
Management SystemsManagement Systems
VEEP and VEEP and Environmental Management SystemsEnvironmental Management Systems
What does an EMS mean? (EMS What does an EMS mean? (EMS elements)elements)
What’s different in facilities that have an What’s different in facilities that have an EMS?EMS?
How does it relate to DEQ staff?How does it relate to DEQ staff? Why do facilities participate in VEEP?Why do facilities participate in VEEP? What are potential regulatory benefits What are potential regulatory benefits
(incentives)?(incentives)?
What does an EMS mean?What does an EMS mean?
An EMS is an organized approach to An EMS is an organized approach to managing environmental impacts at a facilitymanaging environmental impacts at a facility
Provides a consistent review of all operations Provides a consistent review of all operations to determine the environmental impacts and to determine the environmental impacts and focus resources on the most important issuesfocus resources on the most important issues
Covers all requirements; regulatory, Covers all requirements; regulatory, Corporate or company requirementsCorporate or company requirements
Includes activities and impacts that are not Includes activities and impacts that are not covered by regulationscovered by regulations
Elements of an EMS Elements of an EMS
EPA’s EMS elements:EPA’s EMS elements: Environmental PolicyEnvironmental Policy Regulatory Requirements Identification/TrackingRegulatory Requirements Identification/Tracking Roles/ResponsibilitiesRoles/Responsibilities Training and CommunicationTraining and Communication Environmental Control and MonitoringEnvironmental Control and Monitoring Compliance Change ManagementCompliance Change Management Corrective and Preventative ActionsCorrective and Preventative Actions Records and RecordkeepingRecords and Recordkeeping Audits and InspectionsAudits and Inspections Management ReviewManagement Review
Can also be “home-grown”Can also be “home-grown”
What’s different in facilities that have What’s different in facilities that have an EMS?an EMS?
Usually the facilities are well run and have other Usually the facilities are well run and have other management systems (safety, quality, financial, management systems (safety, quality, financial, etc.)etc.)
Generally have progressive environmental programs Generally have progressive environmental programs and good compliance history.and good compliance history.
Often involved in “beyond compliance” activitiesOften involved in “beyond compliance” activities Participate in voluntary environmental, health and Participate in voluntary environmental, health and
safety programs (VEEP, Performance Track, VPP safety programs (VEEP, Performance Track, VPP Star)Star)
Employee engagement and management supportEmployee engagement and management support Reducing environmental impacts becomes Reducing environmental impacts becomes
everyone’s job, not just the EHS staffeveryone’s job, not just the EHS staff
How does VEEP relate to DEQ staff?How does VEEP relate to DEQ staff?
Facilities within VEEP are usually the “good Facilities within VEEP are usually the “good guys”guys”
May expect to be treated with more trust May expect to be treated with more trust and respect – because of their performanceand respect – because of their performance
Often willing to consider alternative Often willing to consider alternative approaches that make sense for the approaches that make sense for the company, the environment and the DEQ.company, the environment and the DEQ.
Why “waste” DEQ time inspecting facilities Why “waste” DEQ time inspecting facilities that are in compliance?that are in compliance?
Why does a facility participate in Why does a facility participate in VEEP?VEEP?
RecognitionRecognition Community and Community and
EmployeesEmployees RegulatorsRegulators Corporate ManagementCorporate Management Environmental, Safety Environmental, Safety
and Health Staffand Health Staff EHS viewed as an asset EHS viewed as an asset
by plant managementby plant management Plant managers usually Plant managers usually
hear only problems, we hear only problems, we bring good news and bring good news and positive recognitionpositive recognition
Who is in VEEP?Who is in VEEP?
29%
2%
34%
33%
2%
CommercialManufacturingFed GovtLocal GovtState Govt
VEEP Participation (Cont.)VEEP Participation (Cont.)
Improved communication with Improved communication with regulatorsregulators
Opportunity to “show off”Opportunity to “show off” It’s enjoyable working with other It’s enjoyable working with other
facilities on their EMS goals facilities on their EMS goals Potential regulatory reliefPotential regulatory relief
180 RCRA Waste Storage180 RCRA Waste Storage MACT reporting reductionsMACT reporting reductions More pending with EPAMore pending with EPA
Improved image with Improved image with CustomersCustomers
Cost SavingsCost Savings Low cost of participationLow cost of participation
Role of Incentives in Voluntary Role of Incentives in Voluntary ProgramsPrograms
From the EPA Performance Track web site:From the EPA Performance Track web site:
Incentives are being designed and implemented to:Incentives are being designed and implemented to: Recognize and reward environmental Recognize and reward environmental
accomplishmentsaccomplishments Encourage facilities to perform beyond basic Encourage facilities to perform beyond basic
compliancecompliance Allow members to operate more efficiently, and,Allow members to operate more efficiently, and, Demonstrate that innovation is integral to EPA’s Demonstrate that innovation is integral to EPA’s
evolving frameworkevolving framework
Desirable Features of Good Desirable Features of Good IncentivesIncentives
Apply to a broad range of industry or Apply to a broad range of industry or really attractivereally attractive to one to one segmentsegment
Easy to understand, implement and verifyEasy to understand, implement and verify Will save time and money for both industry and governmentWill save time and money for both industry and government Result in measurable environmental improvements (preferably Result in measurable environmental improvements (preferably
at lower cost)at lower cost) Attractive enough to encourage membership by all sizes of Attractive enough to encourage membership by all sizes of
companies including small to medium size businessescompanies including small to medium size businesses Improve the environment faster than otherwise expected (can Improve the environment faster than otherwise expected (can
also reduce non-point source pollution or releases of non-also reduce non-point source pollution or releases of non-regulated pollutants)regulated pollutants)
Significantly increase the number of members so the Significantly increase the number of members so the environment will show measurable improvementenvironment will show measurable improvement
Possible Non-Regulatory Possible Non-Regulatory IncentivesIncentives
TimeTime Priority Permitting (also known as Expedited Permitting Priority Permitting (also known as Expedited Permitting
or Top of Pile)or Top of Pile) Reduced inspection priorityReduced inspection priority Faster permitting for pollution control projectsFaster permitting for pollution control projects Insurance benefitsInsurance benefits
FinancialFinancial Preferred buying list for the governmentPreferred buying list for the government Tax benefitsTax benefits Revolving loansRevolving loans
Possible Non-Regulatory Possible Non-Regulatory IncentivesIncentives
FlexibilityFlexibility Flexible permits – changes made quickly, encourages Flexible permits – changes made quickly, encourages
innovative technologies, improves speed to marketinnovative technologies, improves speed to market AccessAccess
Someone to talk to for new permits and concernsSomeone to talk to for new permits and concerns PublicityPublicity
Recognition for “beyond compliance”Recognition for “beyond compliance” Benefit of doubt if compliance issue occursBenefit of doubt if compliance issue occurs Socially responsible investment organizations give credit Socially responsible investment organizations give credit
for membershipfor membership
Practical Experience Implementing Practical Experience Implementing IncentivesIncentives
Facility unique prioritiesFacility unique priorities Every facility seems to have their own issues and Every facility seems to have their own issues and
priorities making the selection of a broad based incentive priorities making the selection of a broad based incentive difficultdifficult
Regulatory change is hardestRegulatory change is hardest Non-regulatory changes are the most likely to succeedNon-regulatory changes are the most likely to succeed
Culture Change has been slowCulture Change has been slow Many people and organizations accept the inefficiencies of Many people and organizations accept the inefficiencies of
the existing regulatory structure and are uncomfortable the existing regulatory structure and are uncomfortable with changewith change
Change will come slowly to those willing to invest time Change will come slowly to those willing to invest time and effort and some changes have been happening latelyand effort and some changes have been happening lately
EPA Incentives InitiativesEPA Incentives Initiatives
EPA Administrator is championing EPA Administrator is championing Performance TrackPerformance Track Air, water and waste initiatives being studiedAir, water and waste initiatives being studied
Other organizations involvedOther organizations involved ECOSECOS PTPAPTPA
EPA regulatory and Performance Track EPA regulatory and Performance Track Program changesProgram changes Visit EPA’s web site for more detailsVisit EPA’s web site for more details
Current EPA Incentive Current EPA Incentive InitiativesInitiatives
AirAir Flexible permits rulemaking – PT permit applications Flexible permits rulemaking – PT permit applications
ahead of othersahead of others Reduced frequency of MACT reporting for PT sites (April Reduced frequency of MACT reporting for PT sites (April
2004 rule)2004 rule) WaterWater
Expired NPDES permits, PT permits firstExpired NPDES permits, PT permits first Trade ambient water quality data for reduced permit Trade ambient water quality data for reduced permit
monitoring datamonitoring data WasteWaste
Extension of onsite storage times for hazardous waste Extension of onsite storage times for hazardous waste (April 2004 rule)(April 2004 rule)
Specific EPA Incentives (Air)Specific EPA Incentives (Air)
Facilities that are members of Facilities that are members of Performance Track that are governed Performance Track that are governed by Maximum Achievable Control by Maximum Achievable Control Technology (MACT) provisions of the Technology (MACT) provisions of the Clean Air Act (CAA) benefit from Clean Air Act (CAA) benefit from reduced reporting frequency (annual reduced reporting frequency (annual instead of semi-annual). In certain instead of semi-annual). In certain cases, they may submit annual cases, they may submit annual certification statement in lieu of annual certification statement in lieu of annual reports.reports.
Specific EPA Incentives (RCRA)Specific EPA Incentives (RCRA)
The Resource Conservation and The Resource Conservation and Recovery Act (RCRA) regulations were Recovery Act (RCRA) regulations were revised to allow hazardous waste revised to allow hazardous waste generators who are members of generators who are members of Performance Track up to 180 days (and Performance Track up to 180 days (and 270 days if waste is transported 200 270 days if waste is transported 200 miles or more),miles or more), to accumulate their to accumulate their hazardous waste without a RCRA permit hazardous waste without a RCRA permit or interim status. or interim status.
Current Virginia Incentives for Current Virginia Incentives for Env. Excellence ParticipantsEnv. Excellence Participants
Discounts to the annual permit fees will be Discounts to the annual permit fees will be applied for solid waste, hazardous waste applied for solid waste, hazardous waste and water fees issued during the summer and water fees issued during the summer of 2005 for facilities that were in the of 2005 for facilities that were in the program prior to January 1, 2005 and program prior to January 1, 2005 and remain in good standing.remain in good standing.
The following slides explain the reductions The following slides explain the reductions for Solid Waste Permit, Hazardous Waste & for Solid Waste Permit, Hazardous Waste & Water Permits.Water Permits.
Solid Waste Permit Fees Solid Waste Permit Fees ReductionReduction
Potentially up to a 10% discount for Potentially up to a 10% discount for E2 facilities (maximum of three E2 facilities (maximum of three years)years)
Potentially up to a 20% discount for Potentially up to a 20% discount for E3 facilitiesE3 facilities
(see 9 VAC 20-90-117) (see 9 VAC 20-90-117)
Hazardous Waste Permit Fees Hazardous Waste Permit Fees ReductionReduction
Potentially up to a 5% discount for E2 Potentially up to a 5% discount for E2 (maximum of three years)(maximum of three years)
Potentially up to a 10% discount for Potentially up to a 10% discount for E3E3
(see 9 VAC 20-60-1286)(see 9 VAC 20-60-1286)
Water Permit Fees Water Permit Fees ReductionReduction
Potentially up to a 2% discount for E2 Potentially up to a 2% discount for E2 (maximum of three years)(maximum of three years)
Potentially up to a 5% discount for E3Potentially up to a 5% discount for E3 (see 9 VAC 25-20-145)(see 9 VAC 25-20-145)
Alternate Compliance MethodsAlternate Compliance Methods
Rule issued (March 24, 2005) giving Rule issued (March 24, 2005) giving Virginia Environmental Excellence Virginia Environmental Excellence members (E3 and E4 levels) the members (E3 and E4 levels) the option of “alternate compliance option of “alternate compliance methods”methods”
Chesapeake Bay Nutrient Chesapeake Bay Nutrient StrategyStrategy
Alternate Compliance Method for Alternate Compliance Method for Virginia E3 & E4 membersVirginia E3 & E4 members Suspension of applicable Technology-Suspension of applicable Technology-
based effluent concentration limitationsbased effluent concentration limitations Permittee must fully-implement their EMSPermittee must fully-implement their EMS EMS specifically addresses nutrientsEMS specifically addresses nutrients Facility maintains nutrient removal Facility maintains nutrient removal
technologies at the treatment efficiency technologies at the treatment efficiency levels for which they were designed.levels for which they were designed.
How to Request Regulatory How to Request Regulatory FlexibilityFlexibility
Each site should request specific Each site should request specific regulatory flexibility items in writing to regulatory flexibility items in writing to Sharon Baxter (Pollution Prevention Group Sharon Baxter (Pollution Prevention Group at DEQ Central Office). They should copy at DEQ Central Office). They should copy their DEQ Regional Director on this their DEQ Regional Director on this request.request.
Promoting P-Track & VEEPPromoting P-Track & VEEP
These “road shows” including the P2 These “road shows” including the P2 staff presentation in the springstaff presentation in the spring
Providing brochures and posters to Providing brochures and posters to each Regional Officeeach Regional Office
Announcements of recognition Announcements of recognition ceremonies on the P2 web siteceremonies on the P2 web site
Identifying P-Track & VEEP Identifying P-Track & VEEP membership in the CEDS database on membership in the CEDS database on the “facility” screenthe “facility” screen
Environmental Innovation Environmental Innovation ProjectProject
International PaperInternational PaperFranklin, VAFranklin, VA
(example of regulatory (example of regulatory flexibility awarded to EPA PT flexibility awarded to EPA PT
and VA DEQ E4 site)and VA DEQ E4 site)
Purpose of Innovation Purpose of Innovation ProjectProject
Partnership ApproachPartnership Approach
Innovative & Cost EffectiveInnovative & Cost Effective
Exceed RegulationsExceed Regulations
Maximum Benefit to Environment, Maximum Benefit to Environment, Community & MillCommunity & Mill
Traditional Environmental Traditional Environmental EPA MACT RulesEPA MACT Rules
EPA Cluster Rule MACT I Phase II EPA Cluster Rule MACT I Phase II requires collection and incineration requires collection and incineration of methanol air emissions from of methanol air emissions from sources in the paper mill.sources in the paper mill.
Cost estimate for Franklin: $32 MM Cost estimate for Franklin: $32 MM by year 2006. by year 2006.
Innovation ConceptInnovation Concept
Identify more cost effective means to Identify more cost effective means to collect equivalent amount of methanol as collect equivalent amount of methanol as EPA regulations requireEPA regulations require
Invest half of the avoided capital cost in Invest half of the avoided capital cost in voluntary environmental improvement voluntary environmental improvement projects at the plantprojects at the plant
Use a Stakeholder Group to identify Use a Stakeholder Group to identify which voluntary environmental projects which voluntary environmental projects were chosenwere chosen
Innovation ConceptInnovation Concept
Collect equivalent amount of Collect equivalent amount of regulated air emissions (methanol)regulated air emissions (methanol)
Identified alternate sources of same Identified alternate sources of same amount of methanol air emissions for amount of methanol air emissions for collection to what rule requiredcollection to what rule required
Cost estimate : $22.5 MM (Provides Cost estimate : $22.5 MM (Provides avoidance of $9.4 MM in capital costs)avoidance of $9.4 MM in capital costs)
Innovation ConceptInnovation Concept
Invest half of capital avoidance dollars Invest half of capital avoidance dollars for voluntary superior environmental for voluntary superior environmental projects at Franklin millprojects at Franklin mill
Stakeholder team selected projectsStakeholder team selected projects
Proposed spending: $7 MM (75% avoided Proposed spending: $7 MM (75% avoided cost)cost)
Superior Environmental Superior Environmental Performance ProjectsPerformance Projects
What IP is Offering What IP is Offering to Voluntarily to Voluntarily ImplementImplement
Voluntary Environmental Voluntary Environmental Improvement ProjectsImprovement Projects
Voluntary projects focused on all media (air, Voluntary projects focused on all media (air, water and waste reductions)water and waste reductions)
Projects included air system improvement in Projects included air system improvement in boiler, process changes to reduce fugitive boiler, process changes to reduce fugitive dusting, recycle of waste water, recycle of solid dusting, recycle of waste water, recycle of solid waste, effluent treatment system improvements)waste, effluent treatment system improvements)
Significant environmental benefits from projects:Significant environmental benefits from projects: Air emissions reduction (560 tpy SO2, 75 tpy NOx)Air emissions reduction (560 tpy SO2, 75 tpy NOx) Fugitive dust reduction (8 tpy)Fugitive dust reduction (8 tpy) Groundwater withdrawal reduction (0.5 MMGPD)Groundwater withdrawal reduction (0.5 MMGPD) Solid waste reduction (8600 lb/day)Solid waste reduction (8600 lb/day) Effluent quality improvement (2000 lb/day COD)Effluent quality improvement (2000 lb/day COD)
Environmental InnovationEnvironmental Innovation
Environmental Innovation Project is beneficial Environmental Innovation Project is beneficial to:to: the environment due to the same amount of the environment due to the same amount of
regulated methanol being collected, as well as $7 regulated methanol being collected, as well as $7 MM of voluntary environmental improvement MM of voluntary environmental improvement projects being implemented (air, water and waste projects being implemented (air, water and waste reductions)reductions)
The community, Va DEQ, EPA and International The community, Va DEQ, EPA and International Paper due to partnerships formed in finding an Paper due to partnerships formed in finding an Innovative way to meet environmental regulationsInnovative way to meet environmental regulations
““Win-Win for environment, the community, and the Franklin Win-Win for environment, the community, and the Franklin mill”mill”