Innovative Approach and Multi-Media Pollution Prevention. This Project s innovation involves an entire industry sector voluntarily requesting permits and developing an industry-specific EMS and auditing program. Each EMS will be multi-media in order to address all significant environmental impacts, both regulated and unregulated, using pollution prevention approaches whenever practicable. Participating facilities will also be required to implement a series of critical management programs, and associated BMPs. If, through the 3rd party audits, it was determined that any of the critical management programs were not being adequately implemented, the facility would not initially qualify for coverage under an NPDES general permit or could not continue to be covered unless corrective actions were taken. Participating facilities will also have to develop CNMP s over time, consistent with EPA s AFO/CAFO Strategy, that also contribute to pollution prevention.
Innovative Approach and Multi-Media Pollution Prevention. OARM is considering instituting a program to train, certify and coordinate a network of university and non-profit organizations identified as Regional Centers of Excellence (RCE). As currently envisioned, the Centers will promote the Labs21 Initiative and work with OARM and OEPI to craft case-specific agreements to enable environmental performance of Labs21 participants, as appropriate. As the Labs21 Initiative expands beyond its initial focus on energy efficiency and water conservation to address other pollution prevention and environmental parameters, each RCE, in turn, will support the expanded nature of the initiative.
C. Transferability
Innovative Approach and Multi-Media Pollution Prevention. Transferability of the Approach to Other Entities or Sectors
Innovative Approach and Multi-Media Pollution Prevention. This project provides EPA with a concrete opportunity to compare the environmental improvements that can result if a mill accepts numeric effluent limits tailored to the specific mill in place of more flexible narrative BMP requirements. It also gives EPA the opportunity to evaluate applicable technologies to determine the extent of environmental improvement that may result from their implementation at the Androscoggin Mill and similar xxxxx for which such technologies are available. The project also offers EPA the possibility of exploring how to use a collaborative process to encourage companies to continuous improvements beyond the requirements of applicable regulations.
Innovative Approach and Multi-Media Pollution Prevention. The project will be a test of an innovative approach to encourage remining with an emphasis on BMPs as opposed to numeric effluent standards. The use of BMPs without numeric limits is an innovative approach that focuses on preventing pollution at the source(s) in the abandoned mine land areas of the watershed regardless of whether they will be disturbed (encountered) during the remining. This project will provide EPA’s Office of Water with data and experience as it examines coal mining effluent limitations and the effect of the BMP approach on the overall water quality in degraded streams. This XL project will also allow PADEP, EPA and the reminers to gain more experience in how to implement BMPs, develop new BMPs and refine the application of existing BMPs, as well as provide data on the most effective BMPs and information on possible improvements in their use.
Innovative Approach and Multi-Media Pollution Prevention. The IP XL Project is innovative from technical, scientific and regulatory perspectives. PEMS are an innovative technology that provide valuable continuous information on particulate matter and other pollutant emissions. While PEMS have been developed for simple stacks (such as gas-fired boilers), they have had very limited application for complex stacks such as waste fuel incinerators. This proposal would seek to develop and use PEMS to estimate PM and other pollutant emission rates from a complex saturated stack. This would be one of the first applications of this technology to such a complex emission source. Successful implementation of this project would provide continuous information on PM emission rates for sources that – to date– have no federally-approved methods to monitor particulate matter on a continuous basis from saturated stacks. Perhaps more importantly, PEMS can provide a linkage between emission rates and the operational parameters that affect them. The IP XL Project will promote pollution prevention both through identifying source reduction opportunities for preventing pollution at its source and through setting voluntary goals to reduce emissions through preventative measures. Traditional monitoring techniques are often considered “end- of-pipe” and measure emissions but do not provide information on operational parameters affecting the emissions or how to reduce those emissions. The PEMS identifies operating parameters and uses them to predict emissions and link them to statistically significant parameter settings. The operator can then use this information to decrease emissions while maintaining production. Understanding the relationship between process variables and subsequent emissions is one of the first steps in pollution prevention planning. To that end, as discussed in Section III.A, IP aspires, as part of the project, to reduce emissions from the WFI by 10 percent of permitted limits.
Innovative Approach and Multi-Media Pollution Prevention. The project will be a test of an innovative approach to writing coal remining permits with an emphasis on BMPs as opposed to numeric effluent standards. The use of BMPs without numeric limits is an innovative approach that focuses on preventing pollution at the source(s) in the abandoned mine land areas of the watershed regardless of whether they will be disturbed during the remining. This testing will provide EPA’s Office of Water with data and experience as it examines coal mining effluent limitations and the effect on overall water quality in degraded streams. This XL project will also allow PADEP, EPA and the reminers to gain more experience in how to implement BMPs, develop new ones and refine the application of existing BMPs as well as provide data on the most effective BMPs and information on possible improvements. BMPs are pollution prevention tools rather than end of pipe treatments. Practices such as preventing or diverting water from contacting acid forming rock materials, applying lime to the rock to neutralize its acid potential, or segregating and isolating acid producing rock strata during mining will stop water from picking up acidity and leaching iron, aluminum and manganese from the mine overburden. Reclaiming, regrading and revegetating the land can eliminate ponding water, reduce water infiltration and provide for water transpiration/respiration by plants. The goal of these BMPs is to reduce or eliminate the formation of acid mine drainage that would otherwise have to be collected and treated. Remining may be the only economically viable solution for reducing highly degraded or high volume abandoned mine discharges, since long term end of pipe treatment is usually not viable or is cost prohibitive. In-stream water quality monitoring is the most effective way to measure the performance of AMD remediation activities within the watershed as the water quality impact of all remining, reclamation, and abatement activities are manifest at this point. The water quality baseline will use concentration, rather than loading data, because: 1) in-stream concentration data are more stable than load data, rendering a higher quality statistical summary; 2) concentration data are much easier and less costly to collect than load data; 3) pollution loads from individual discharges are manifested in the in-stream concentration; and 4) loading data, particularly in large streams, tend to be dominated by flow, which makes it difficult and impractical to moni...
Innovative Approach and Multi-Media Pollution Prevention. OMP’s proposal – to treat small quantities of mixed wastes generated by R&D activities utilizing a bench-scale high-temperature catalytic oxidation process to destroy the organic component of the waste while capturing the radioactive component in a highly controlled laboratory environment – represents an innovative alternative approach to currently available methods for the management and treatment of LLMW. As previously discussed, the current commercially available method requires the off-site transportation and treatment of mixed wastes via incineration at a permitted TSD facility. OMP’s proposal would capture the radioactivity from this wastestream and allow for the potential recovery and reuse of the radioisotope tracers (see Section 3.2.1 and Section 5.1 for more details on this potential recycling alternative). OMP recognizes that pollution prevention is the cornerstone of a proactive waste management program. While this Project focuses specifically on the “end-of-pipe” treatment of mixed wastes unavoidably generated during R&D operations due to current FDA protocol, OMP has made a concerted effort at minimizing all other Spring House R&D wastes at the source (i.e. pollution prevention) through the implementation of a comprehensive Waste Minimization Program (WMP). This WMP, which was implemented in January 1998, uses a performance- based approach to encourage the implementation of new and innovative ideas to minimize all R&D wastes at their point of generation. The WMP targets hazardous and radioactive wastes as well as air emissions, wastewater discharges, and biohazardous and non-hazardous wastes. The goal of the program is to have each R&D department (13 in all) submit 3 waste minimization ideas per year and to implement at least one new waste minimization practice per year. The WMP has been endorsed by upper management and has been very successful. To date, 26 waste minimization practices have been implemented resulting in the following benefits: Waste Minimization Cost Savings Hazardous Waste – reduced by 34,605 pounds Biohazardous Waste – reduced by 3,905 pounds Radioactive Waste – reduced by 275 pounds Non-Hazardous Waste – reduced by 93,530 pounds Wastewater – reduced by 700,000 gallons Labor Costs = $ 20,200 Total Savings: $125,205 Miscellaneous Benefits – Recycling – increased by 6,105 pounds Labor – reduced by 2,016 man-hours The OMP Waste Minimization Program was recognized by the Commonwealth of Pennsylvania with the Governor’s Award fo...
Innovative Approach and Multi-Media Pollution Prevention. Pollution Prevention is the central aspect of this Agreement. The P2 Framework devised by EPA’s Office of Pollution Prevention and Toxics is an innovative approach to assessing chemicals where data are limited. The application of the Framework early in a product development cycle is a best practice among companies that are attempting to design products with minimal environmental impact. The sharing of this technology by the EPA and the communication of its benefits by Kodak represents a cooperative approach to pollution prevention. In addition, reducing the length of time before manufacture to 45 days will allow Kodak to manufacture and market innovative products more quickly and reduce the length of time between innovations.
Innovative Approach and Multi-Media Pollution Prevention. The NBC Pretreatment XL Project will promote pollution prevention through several activities including identifying source reduction opportunities, process optimization and input substitution. By reallocating resources from top performers to “under performers,” NBC hopes to apply resources where the end results will be improved compliance as well as measurable reductions in pollution that go beyond what is required by regulation. NBC has set goals to reduce process water usage, total metal concentration in wastewater, and F006 waste generation from the Tier 2 facilities selected for this project. Additionally, NBC has also set the goal of reducing the number of violations as measured by the total number of enforcement actions of the selected Tier 2 companies by 75% as a result of increased NBC oversight (see Table 3).
