the national metal finishers strategic goals program (sgp) formerly the common sense initiative, csi...
TRANSCRIPT
The National Metal Finishers Strategic Goals Program (SGP)
formerly the Common Sense Initiative, CSI
The Strategic Goals Program
for Metal Finishers: New Strategies for Success
Winston-Salem, N.C. Dec. 12, 2000
Julie Woosley N.C. Division of Pollution Prevention
and Environmental Assistance (DPPEA)
Common Sense Initiative Joint EPA/industry/stakeholders (1993) Industry sector focus Six industry sectors selected Metal Finishing -
Most developed initiative Seeking 80 percent participation by 2002 1998: Strategic Goals Program (SGP)
Federal Categorical Regulation Consistent nationwide Apply to six metal finishing operations
Most Common 1. Electroplating 2. Coating (phosphating, chromating)
Sample for seven metals and CN once per six months Many frustrating aspects MP&M (Metal Products and Machinery) Effluent
Guidelines will change current regulations
Metal Finishing Regulations(40 CFR Part 433)
Strategic Goals ProgramReinvent Environmental Protection- Seeking a more flexible, cost effective and environmentally effective approach to regulations tailored to the needs of both industries and stakeholders.
1. Smarter2. Cheaper 3. Cleaner
Environmental Regulation
Means Municipality signs up as participant Local industries sign up as participants and
commit to series of goals Municipalities offer regulatory flexibility
or other incentives to industries for progress toward goals
State provides supporting role
CSI / SGP Goals
Cleaner Cheaper Smarter
Environmental Performance
“Cleaner” - Reduction in hazardous emissions & exposure
90% reduction in organic TRI emissions 50% reduction in metal releases to air & water 50% reduction in land disposal of hazardous sludges Reduction in human exposure to toxics
(indoor and ambient)
Goals:
“Cheaper” - Increased economic payback and decreased environmental costs
- 50% reduction in cost of unnecessary permitting, reporting and monitoring- Fewer long-term liabilities
- Economic benefit from more efficient (cleaner, smarter) system
Goals:
“Smarter” - Improved resource utilization
98% utilization of metal on product 50% reduction in water purchased (1992) 25% reduction in facility-wide
energy use
Goals:
Benefits of SGP
Industry Operational flexibility Less resource-intensive
regulations Technical assistance Improved public image Opportunity to change
regulatory system
POTW Reduced pollutant
loading Implement more efficient
permitting system Improved relations with
industries Opportunity to change
regulatory system
North Carolina’s Action Plan Outreach
Technical assistance - DPPEACompliance assistance - DPPEAMeet with IU’s - Julie
Positive recognition of participants Pretreatment analysis and support - DWQ Increased enforcement of “rogue” firms –
DWQ / EPA Energy assessment – DPPEA / NCSU Utility bill insert – DPPEA EMS Workshops – EMS and Government
Jan. 31, 2001: 8 a.m. – noon, Gastonia, N.C.
SGP Current Status Statesville
- 13 platers – 6 participating - incentives granted for progress on goals
Raleigh - 10 platers – 6 participating – 4 new!- incentives granted for progress on goals
Charlotte -19 platers – 2 participating- mentoring and public recognition program
Gastonia-? Platers – 2 participating
16 North Carolina participants; 448 total nationwide
Industry Incentives Proposed Reduced monitoring frequency City Reduced metals monitoring City Eliminate metals monitoring EPA Reduced monitoring costs City No Charge BDL City Volume of discharge EPA Phosphaters EPA Reduced enforcement City
Technical/regulatory assistance (DPPEA) State
Public Recognition City/StateMentoring City
Observations to Date
EPA – Limited assistance- On-line Toolbox, Contacts
Emphasis on continual improvement EMS Recruit more metal platers – 80% goal – that’s YOU! Great opportunity for reduced pollutant discharges and
less resource-intensive regulations Improved relationship b/w POTW’s and IU’s Problems identifying incentives to offer – input? Worksheets due! – 1992 baseline is flexible
New Information for SGP Participants: EPA MP&M Guidelines:
Metal Products and Machinery Effluent – due out October 2000
TRI (Toxics Release Inventory) data- nitrates reporting
Energy conservation Calculation/worksheet training Incentive identification and assistance?
Workshop TODAY
TRI Reporting of Nitrates
TRI Reporting of Nitrates The Emergency Planning and Community Right
to Know Act (EPCRA, Title III of SARA, the Superfund Amendments Reauthorization Act, 1986)
Section 313: Release Reporting Requirements, Toxic Chemical Release Inventory Rule, 1988.
Purpose: To inform government officials and the public about releases of toxic chemicals into the environment: air, water and land.
TRI Reporting of Nitrates See EPA publication, 745-R-99-008:
TOXICS RELEASE INVENTORYList of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance for Reportingwww.epa.gov/tri
Metal finishers that use nitric acid may be creating nitrates that have to be reported!
Who Must Report SIC Codes 2000-3900 (manufacturing) A facility with 10 or more full-time employees A facility that manufactures, imports, processes
or otherwise uses any of the toxic chemicals listed on the EPCRA section 313 list in amounts greater than the “threshold” quantities
- nitric acid and dissociable nitrate compounds (must report BOTH!)
Thresholds
If a facility manufactures, imports or processes any of the listed toxic chemicals (includes “coincidental manufacture”): - 25,000 pounds/toxic chemical or category over the calendar year
If a facility otherwise uses any of the listed chemicals:- 10,000 pounds/toxic chemical or category over the calendar year
Small Business Compliance Policy Pardon Mechanism for Small Businesses (<100
employees) Allows business to state they were not aware of the
requirement and will now comply. EPA will eliminate or reduce civil penalties if the business:
Discovers the violation voluntarily Discloses the violation fully and in writing to
EPA or state within 21 calendar days Corrects the violation with the shortest
practicable period of time
More TRI Information Reports due July 1 each year Civil penalties up to $27,500 a day EPA Region IV Contact for TRI:
Stacy Bouma, (404) 562-9192 EPCRA Section 313 TRI and contact for Charlotte,
NC TRI Workshop, April 30 – May 1, 2001:Ezequiel Velez, (404) 562-9191
TRI Hotline: 1-800-424-9346TRI Website: http://www.epa.gov/tri
For More P2 or SGP Information: DPPEA offers free onsite SGP assistance P2 resources online for metal finishers:
www.p2pays.org/indsector.htm Online assistance for SGP available at:
http://www.strategicgoals.org/ and
http://www.epa.gov/sustainableindustry/metfin.htm
State SGP Contact:Julie Woosley, N.C. DPPEA
(919) 715-6527
or 800-763-0136