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Massachusetts Tracks Pollution Prevention in Enforcement

A Massachusetts Department of Environmental Protection (MA DEP) core strategic objective is to eliminate or reduce the volume and toxicity of chemicals used and waste streams generated. The MA DEP also wanted to show that its inspection and enforcement program that has pollution prevention as one of its goals could produce measurable, beneficial results. To meet these objectives, MA DEP turned to P2 tracking. In 1999, compliance and enforcement program staff in one of MA DEP's field offices developed a methodology to measure and track which facilities utilized pollution prevention to resolve enforcement issues. Beginning with fiscal year 2001, MA DEP adopted the methodology statewide and reported the P2 results of enforcement actions in its annual compliance and enforcement report.

In 1999, MA DEP began a pilot project to develop a way to measure the P2 that resulted from its enforcement actions. Working together, Air Quality, Industrial Wastewater, Hazardous Waste, and Toxics Use Reduction staff in MA DEP's Central Regional Office developed a methodology and a simple spreadsheet to track those facilities in enforcement that returned to compliance using P2 techniques. The methodology included both actual calculations and estimates of P2 reductions in hazardous waste generation, volatile organic compound (VOC) emissions, other pollutants, and wastewater discharges. Staff reviewed enforcement documents and conducted interviews with inspectors and permit writers to identify facilities that implemented P2 to return to compliance.

Positive Results

During the first year, MA DEP tracked 38 facilities that undertook P2 measures in response to enforcement actions. P2 reductions that year included 165 tons of hazardous waste (4 facilities), 93 tons of VOCs (10 facilities), 54 tons of sulfur oxides (6 facilities), 31 tons of particulate matter (2 facilities), and small amounts of wastewater, oil, perchloroethylene, and silver (16 facilities). In the second year, P2 reductions at 47 facilities included: 2 tons of hazardous waste (3 facilities), 7 tons of NOX (3 facilities), 20 tons of VOCs (36 facilities), and 2 million gallons of wastewater (5 facilities). Pollution prevention measures that were implemented by these facilities included minor corrections to operations, revised or new management procedures, input substitutions, and operational modernizations.

In September of 1999, Massachusetts signed a Memorandum of Agreement with the Northeast states to utilize a menu of pollution prevention metrics. The menu was developed by P2 representatives from the Northeast states under the auspices of the Northeast Waste Management Officials' Association (NEWMOA). Aspects of MA DEP's methodology to track pollution prevention activities were incorporated into the NEWMOA menu.

In fiscal year 2001, MA DEP implemented the Central Regional Office's methodology statewide and replaced the spreadsheet format with a word processing document tracking system that enabled narrative explanations of results as well as a chart for counting and quantifying P2 by reduction technique. Also beginning in fiscal 2001, DEP began reporting the results of P2 tracking in its annual compliance and enforcement report.

Key Elements, Suggestions, and Challenges

Tracking P2 reductions has demonstrated the value of systematic inspections on targeted industrial sectors. For instance, wood and metal coaters yielded substantial VOC reductions. The tracking has shown that enforcement actions taken in response to non compliance can provide a strong motivation for regulated entities to consider changes in operations to reduce toxics. For example, enforcement for air quality violations at a manufacturing plant in Taunton led the company to replace a degreasing unit that emitted volatile organic compounds with a water based unit, preventing the release of 3,300 pounds per year of trichloroethylene, a 99 percent decrease. Similar enforcement actions involving companies using paint spray booths, stripping furniture, and molding plastics often led them to solutions that eliminated or substantially reduced emissions below permitted levels.

Once the pilot project results were analyzed, it was evident that tracking pollution prevention through enforcement was doable so long as the original efforts were organized with a goal of measurement in mind. Incorporating pollution prevention into the job descriptions and performance evaluations of more regulatory staff, having support for sustainability principles from top management, receiving cooperation and information from businesses, and working across organizational lines as a team helped facilitate the pilot project and ultimately create an institutionalized program.

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