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Iowa Water Program Leads Regulatory Integration Efforts through a P2 in the Metal Finishing Sector Initiative
Time and money are in increasingly short supply in environmental regulatory agencies throughout the country. Limited assets need to be invested where they are most needed, that is, where they accomplish the greatest environmental good. The theory is that sector based pollution prevention initiatives delivered within the context of a compliance framework can lead a well intended and directed facility into beyond compliance performance and off of the regulatory radar screen. Agency resources are thus liberated to focus on those facilities truly in need of costly inspections, permitting, and enforcement. The Iowa Department of Natural Resources' (DNR) Water Bureau Chief, a senior P2 champion in his agency, recognized the potential in this management strategy and inspired his bureau to work closely with the P2 program in a P2 initiative for the metal finishing sector.
The seeds for this initiative began in 1997, before the Water Bureau's involvement, when the P2 program hired a consulting firm to conduct a P2 regulatory integration training for staff throughout the agency. Working with this firm, the P2 program mapped the inspection process and examined possibilities for a sector initiative. Together they identified the Water Bureau, with its management support, as likely champions and metal finishing, with a vast national store of P2 resources already developed and available, as a sector with much potential. In 1999, a technical "P2 in Metal Finishing" training including a hands-on site visit was conducted for the water inspector's team. Together they then worked with a representative of the local chapter of the metal finishing trade association to create a P2 protocol, in advance of the training. The P2 program developed a checklist and folder for water inspectors to distribute during interactions with facilities. Then during and after inspections, when appropriate, facilities were referred to the P2 Program for technical assistance. Pollution Prevention Incentives for States grants have funded the catalyzing activities of and materials production by the P2 staff, but the actual delivery of P2 support to industry and inclusion of P2 in permits and inspections by the water staff is paid for with non PPIS funds that support the water bureau. Most of the P2 integration activity in Iowa has come out of the water program but as successes have been achieved, the demand for P2 support and materials has also has been generated by other compliance staff and media programs.
Positive Results
Iowa's "Pollution Prevention Regulatory Integration Inspections Report - September 1, 1999, to December 31, 2002" documents both evidence of the success of P2 Regulatory Integration and the projected environmental and economic results of technical assessments resulting from P2 referrals by compliance staff. For example, there were 58 documented uses of pollution prevention language in inspection reports, which resulted in 44 referrals for onsite consultations and technical assistance. P2-based services were or will be utilized by 19 of these businesses during this reporting period. For those that did receive P2 assessments, the projected economic and environmental benefits are impressive in scale and multi media in scope: 15,585,800 gallons of wastewater reduced; 840 drums, 165 gallons, and 2.9 tons of hazardous waste reduced; 1,172.4 tons of solid waste reduced; and 2,768,944 kWh, 322,999 MMBtu, and 23,200 therms of energy conserved. Iowa P2 Program staff projected a savings of $3,019,973 by companies implementing the recommended pollution prevention measures. Actual savings are hard to quantify because of lack of data, the lag between assistance and result, and the presence of intervening factors, but the P2 Program has been able to document the following actual results: 2.6 tons of hazardous waste reduced, 50 pounds of solid waste per year reduced, and 84,072 kWh energy conserved. Total associated cost savings are quantified at $73,568. Ancillary compliance achieving effects included the creation of a spill prevention control and countermeasures plan by one facility, compliance with universal waste rules for lamps and switches by another, and the application for air quality construction permits by two more.
Key Elements, Suggestions, and Challenges
The Iowa P2 program staff attributes the success of this project primarily to the high quality, knowledgeable work of the consulting firm and the leadership provided by the Water Bureau Chief. It was extremely helpful to have a comprehensive strategy packaged and laid out in advance. Iowa also drew heavily on EPA's National Strategic Goals Program and publications developed elsewhere such as EPA's sector notebook and Colorado's metal finishing toolkit. Very early in the project, a stakeholder meeting was held during which the elements of the program were discussed by representatives from the Water Bureau, field offices, Publicly Owned Treatment Works, the Iowa Waste Reduction Center (IWRC), the DNR P2 Program, and the American Electroplaters and Surface Finishers Society. The input from this meeting ensured the initiative's relevance and accessibility. Later, about 4 months before the training, the consulting firm conducted a focus group with 8 metal finishers. This helped to define what type of technical assistance would be helpful to the audience and to find out the form in which they would like to receive it. Throughout the process of developing the project, through training and the outreach and technical assistance to businesses, IWRC was supportive. DNR's P2 Program [Pollution Prevention Services] provides technical assistance to facilities with more than 100 employees and IWRC provides technical assistance to facilities with less than 200 employees. Therefore, IWRC's participation was critical to assist those businesses that were out of DNR's purview.
With a comprehensive plan prepared, support within the agency, and input from the industry trade association, Iowa reported few major barriers to progress in the early days on this initiative. The major challenge facing Iowa's P2 Regulatory Integration efforts in water and in all media is to keep the momentum going. Success requires that energy and enthusiasm be nurtured, which in turn requires continuous interaction between the P2 program and the compliance staff. More success generates more need for the P2 program staff's time which reduces the amount of time available to each opportunity. With limited resources to grow the program to meet an increased demand, success effectively eats away at itself. This situation is compounded in Iowa by the difficulty of providing outreach to six geographically dispersed field offices. Another challenge facing Iowa and indeed all states that are trying to measure the environmental results of P2 is the long cycle of inspection, referrals, assistance, facility action, availability of data, and reporting.
More Information
Pollution Prevention Services, P2 and Metal Finishing