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Missouri Department of Natural Resources' Pre-Proposal on The Missouri Environmental Management Partnership

Summary Section

Project Title
The Missouri Environmental Management Partnership

The State of Missouri

Name of applicant State agency
Missouri Department of Natural Resources

Contact Name
John Madras

Air and Land Protection Division
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102
Telephone: (573) 751-6892
Fax number: (573) 751- 9277
e-mail: nrmadrj@mail.dnr.state.mo.us

This project is not being executed in cooperation with or funded by another Federal program.

If the program is proven successful, environmental permits defined by the Federal government will be evaluated for various forms of permit flexibility, and that flexibility will be implemented through the various permits administered by the department. In particular, Air Pollution Control Part 70 permits, Air Pollution Control construction permits, National Pollutant Discharge Elimination System (NPDES) operating and stormwater permits, and RCRA hazardous waste registrations will be considered for flexibility opportunities.

The Department of Natural Resources' Director, Steve Mahfood, supports the project.

Summary Budget Information
Annual 3-Year Project

State Leverage Funding: [REDACTED BY EPA]
Project Budget: [REDACTED BY EPA]

Project Narrative

The Missouri Environmental Management Partnership (MEMP) is a program through which the Missouri Department of Natural Resources (MoDNR) will encourage businesses, local governments, state agencies, educational institutions, and other organizations to improve their environmental performance by developing and implementing an Environmental Management System (EMS). The MEMP is strictly voluntary but will hold partners to generally recognized EMS conformance criteria, which includes commitment to regulatory compliance as well as broader environmental goals.

MEMP's objective is to improve overall environmental performance by our program partners. The successful MEMP member will increase environmental performance, have continual environmental improvement, reduce pollution emissions, and practice pollution prevention. MEMP will help motivate partners to go beyond compliance. Because of improved performance, MoDNR would be able to decrease oversight. The reduced amount of MoDNR's oversight will enable us to intensify efforts on other environmental priorities.

MEMP Structure

MEMP has three levels of participation. An organization can participate as a Partner on the first level. The second level consists of the Certified Partner and the Advanced Partner. The third level combines all program characteristics and an organization would participate as a Certified Advances Partner.

A Partner must document conformance with the ten basic EMS elements:

A. Policy Statement F. Recordkeeping and Reporting

B. Environmental Impacts G. Training

C. Legal Requirements H. Emergency Response

D. Roles and Responsibilities I. Assessment

E. Objectives and Targets J. Corrective Action

They must demonstrate consistent and ongoing implementation of the documented EMS, a commitment to environmental compliance and submit an annual progress report. A MEMP EMS is subject to on-site evaluation by MoDNR.

A Certified Partner must document conformance with the ten basic EMS elements (listed above) and other Partner requirements, as well as have third-party certification to ISO 14001 or another, credible EMS standard.

An Advance Partner must document conformance with the ten basic EMS elements (listed above) and other Partner requirements. They must also document conformance with four additional elements, including objectives specifying performance levels more protective than regulatory standards, continual improvement resulting in source reduction (pollution prevention, annual performance assessment, and regular community involvement

A Certified Advanced Partner must document conformance with the ten basic EMS elements (listed above) as well as all Certified Partner and Advanced Partner requirements.


To encourage organizations to develop an EMS and to recognize the potential environmental benefits associated with their efforts, the MEMP program confers a series of incentives to the partners.

Recognition incentives are based on the member's level. The incentives include:

A. Wall plaques

B. Articles in MoDNR sponsored magazines

C. Listing in the "Honor Roll" on MoDNR's web page

D. Inclusion of partners' names in a MoDNR-produced EMS brochure

E. Use of MEMP logo for member advertising

F. Local media news releases in a member's community

G. Letters to trade or municipal associations about a member

H. Provision of MEMP signs or sign attachments

I. Acknowledgement of MEMP partners in presentations outside the agency

MEMP has several permitting incentives a member may receive. They are based on the member classification. The incentives will support faster change and new ideas resulting in improved environmental performance. They include:

A. Expedited permitting

B. Reduction or elimination of permit requirements duplicated by the EMS

C. Regulatory report streamlining and scheduling

D. Flexibility in permitting new technology

E. Cooperative permit consideration, possibly instituting a comprehensive, multi-media permit that considers a Partner's entire environmental impact.

This project will provide the resources to develop the procedures for these permit incentives and to implement them into the permitting system. This process would involve EMS participants in stakeholder roles and permit staff that would establish the procedures for EMS based permitting improvements. This work will build from the permit efficiency efforts in recent years, including but not limited to Governor Holden's Missouri Results Initiative for Operating and Construction Permits for air pollution control. This will include providing the resources to develop outreach efforts regarding the permits as well product availability on the web.

MEMP also provides for mitigation of self-reported violations. Missouri is statutorily allowed discretion to resolve environmental violations through "Conference, Conciliation, and Persuasion". Formal enforcement action may not be required for MEMP partners that self-report violations and proceed with corrective actions.

Schedule Milestones DATES

Statutory Authority

The Missouri Department of Natural Resources has statutory authority for the Clean Air Act section 103 (b)(3); Clean Water Act section 104 (b)(3); Resource Conservation and Recovery Act section 8001; and Safe Drinking Water Act sections 1442 (a) and (c).

Threshold Factors

An EMS is a voluntary, organized, and coordinated process of planning, activities, responsibilities, and resources for developing, implementing, and maintaining an environmental policy. MEMP is a program through which MoDNR will encourage various organizations to improve their environmental factors by developing and implementing an EMS. We plan on assisting organizations in their initial investigations of the pros and cons of an EMS, providing assistance, as needed, in showing an organization what is needed for an EMS, and working with an organization, as needed, while they develop an EMS. An EMS encourages organizations to meet environmental regulatory requirements, prevent pollution, and continually improve environmental performance.

Program Criteria

Target Priority Environmental Areas
The MEMP is a tool for reducing pollution in all media. Its flexibility in permitting new technology should help to improve air quality. MEMP will allow a company to try new technology (such as distributed generation) without being penalized. This should have a positive impact on the St. Louis non-attainment area. Air pollutants, including greenhouse gases and ground-level ozone generators, should be reduced.

An EMS results in employee buy-in throughout an organization on environmental issues. Everyone in an organization knows how their work activity affects the environment. The EMS provides the structure in which employees initiate corrective actions. This will improve such things as stormwater runoff, improper disposal of chemicals, spills, changes of types of chemicals used, reductions of energy, water, and other resources used, etc.

Use of Incentives as a Tool
The member will have access to a single agency contact, called a Gatekeeper, for all issues relating to its MEMP EMS. This in itself is an important incentive. Since the MEMP EMS relates to all environmental regulations, the EMS Gatekeeper will assist partners in their interaction with MoDNR's various environmental Programs. The Gatekeeper will work with the partners to provide incentives including expedited permits, streamlined reporting, and helping the organization work toward the use of innovative technology.

Presently an organization may have to go to several environmental Programs before they can obtain the necessary permits to construct or operate a facility or a piece of equipment. These permits can inhibit the capability to improve processes and expand the organization. The organizations are required to provide standardized compliance reports. The permitting incentives will allow organizations to improve their environmental performance and reduce their administrative effort to comply with permits. The partners will be responsible for remaining below certain emissions limits. Enforcement mitigation will provide a way for an organization to correct past performance and go on to an improved environmental stewardship. Because everyone in an organization is involved in the EMS, it is a means to grasp the full range of an organization's environmental involvement, understand its interactions, and move the whole organization toward environmental stewardship.

The MEMP is modeled after ISO14000. It is consistent with EPA's Performance Track and the Multi-State Work Group (MSWG) EMS programs. We will use data collection and evaluation methods comparable to those used by the MSWG to evaluate MEMP performance. Also, we will compare MEMP facilities to non-MEMP facilities.

Transferring Innovation
MoDNR hopes to continually extend MEMP to facilities in Missouri. Theoretically MEMP could extend to about ten thousand organizations in Missouri that have environmental controls, particularly small businesses and organizations. An EMS advocates continual improvement. This will foster organizations to go beyond compliance, based on disposal, treatment, and recycling, into the elimination of pollution. After that, they will look at the life cycle impacts of the products they produce and use. Ultimately, organizations will improve toward sustainability.

Improvement will not be limited to the various member organizations. MEMP will push MoDNR to evaluate our permitting and enforcement policies and practices. It will show alternative means to achieve and go beyond environmental compliance. MEMP's success could impact future rule changes and how we do business.

Guaranteeing Measures and Accountability
In order to make sure MEMP is accomplishing its objectives of improving environmental performance by our partners, MoDNR needs to measure how we are meeting our goals. The successful MEMP member will increase their environmental performance, have continual environmental improvement, reduce their pollution emissions, and practice pollution prevention. MEMP will help motivate partners to go beyond compliance. Within three (3) years, MoDNR would quantitatively compare compliance, emission / effluent limits, and release quantities of a MEMP member's facility versus a non-MEMP member's facility. Within three (3) years, MoDNR w evaluate the effectiveness of the innovative permits available through MEMP. Within five (5) years MoDNR would evaluate the reduced releases of contaminants to the environment and consistently higher rates of compliance. This performance data will be posted on MEMP's web page and will also be available through MoDNR's document distribution service. Reports and news releases related to the MEMP program will be made on a periodic basis tied to annual budgeting and legislative cycles.

Proposal Budget

Annual Costs:
Total Project Proposed State EPA

Costs Leverage Funds Funding


Project is proposed to extend for a three-year period.

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