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”