Shifting of Risk Burden. The proposal does not shift or minimize any environmental risks. The regulatory flexibility does not request the minimization or elimination of any reporting or recordkeeping requirements. The requested flexibility only integrates changes in formatting, delivery method, signatory requirements, and data archival procedures.
Shifting of Risk Burden. The project does not result in the transfer of risk. The implementation of the modified cleaning process results in reduced environmental risk through the reduction of the emissions of global warming gases from the semiconductor manufacturing process. Any risks associated with the treatment of the copper plating rinsewaters are the same regardless of whether the process is or is not regulated under the RCRA F006 provisions, though the risks associated with the process, the treatment of the rinsewaters and the management of the sludge are believed to be minimal.
Shifting of Risk Burden. MSD’s project is expected to have no negative environmental impacts and no adverse shifts in loadings across media. Environmental benefits will be evenly distributed across the community and watershed. MSD’s current pretreatment program requirements to protect worker health and safety will remain in place.
Shifting of Risk Burden. There is no known shifting of risk from one population to another associated with this proposed pilot project. Although the project is requesting some relaxation of programmatic aspects of the Pretreatment Program requirements, the City of Xxxxxx will continue to closely monitor IU compliance. One primary goal of this project is the use of remote sensing and sampling of the watershed and storm events. This greatly reduces the potential safety risks to staff and students in meeting compliance requirements of the Storm Water Program. The project must be consistent with Executive Order 12898 on Environmental Justice. These criteria are described in detail in the following Federal Register documents: 60 FR 27282, May 23, 1995 and 62 FR 19872, April 23, 1997. REFERENCES
Shifting of Risk Burden. Because this project will provide better environmental performance than the status quo and the existing regulatory approaches, the proposal is consistent with section 2-2 of Executive Order 12898 (59 Fed. Reg. 7629, Feb. 11, 1994), "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations." Imation Xxxxxxxxx'x project increases environmental performance at the plant, will ensure worker safety , and will not create unjust or disproportionate environmental impacts. Furthermore, the Imation Camarillo FPA's reporting provisions increase accountability of the facility by providing public access to simplified monthly emissions data and the results of pollution prevention activities.
Shifting of Risk Burden. The Department believes that there will not be any shifting of risk burden impacts under the Gold Track Program. The safeguards provided under current laws and regulations to minimize the shifting of risk burdens will be applied to Gold Track participants. This will be more fully examined as the specific regulatory flexibilities to be offered become better defined. There are many tools available that participants willbe encouraged to utilize, including evaluating environmental performance at the process level, measuring total releases from an operation and materials accounting, that can serve to evaluate shifts of risk across media as well as changes in exposure and risk burdens to different populations. Addtionally, the air addenda will require air emissions modeling to ensure that no adverse human health or environmental impacts occur as a result of establishing facility-wide air emissions caps.
Shifting of Risk Burden. IV. Description of the Requested Flexibility and the Implementing Mechanisms Page 21 A. Requested Flexibility B. Legal Implementing Mechanisms V. Discussion of Intentions and Commitments for Implementing the Project Page 22 A. NJDEP’s Intentions and Commitments B. USEPA’s Intentions and Commitments
Shifting of Risk Burden. This project would diminish risk burden, not shift it. Moreover, the greatest reduction of risk to human health and the environment and public safety would be achieved in congested urban areas where many of these remote sites are located. This will be achieved by transporting hazardous waste to a secured location as soon as the collection of hazardous waste has ended, thereby also restoring normal traffic patterns. The public is protected from the risk of exposure to unsecured hazardous waste, even though the danger of release or exposure may only last for a few days per event. The public is also protected from the physical dangers of extended disruption of normal traffic patterns.
Shifting of Risk Burden. The parties to this Agreement believe this F006 Sludge Recycling Project XL involves no transfer of risk. Inherent to the concept of legitimate recycling, the hazardous waste will contain no significant increase in hazardous constituents relative to the raw materials that would otherwise be used, so there is no expected increase in risk in the product produced. Prior to being recycled, the sludge will be transported and stored in a manner protective of public health and the environment. The management standards for transport and storage of the sludge in a manner protective of public health and the environment (including storage at the cement kiln) are presented in Section 3.8 – Evaluation, Monitoring and Accountability. Also, since the cement kiln where the sludge will be processed is already in existence, there are no siting issues such that additional unjust or disproportionate environmental impacts are foreseen. Since the facilities are already in existence, are currently properly permitted and are in compliance with such permits, and are located in either industrial or a heavy commercially zoned area, no foreseeable unjust or disproportionate environmental impacts are apparent.
Shifting of Risk Burden. The project is consistent with Executive Order 12898 which states “each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations in the United States and its territories…” The proposed pilot project will not impose inequitable environmental or health risks or cost burden to any segment of the population. It will, in fact, improve the environmental health of a marine inlet that can be enjoyed and easily accessed by all Kitsap County residents and visitors.
