Pollution Prevention Northwest Newsletter
Published by the Pacific Northwest Pollution Prevention Resource Center
Spring 1999

Featured Topic: The P4 Project
   The Pacific Northwest has been a testing ground for experimental approaches to environmental regulation, including the Pollution Prevention in Permitting Pilot project (P4). This edition of P2 Northwest explores P4 and other alternative regulatory approaches, including lessons learned and ramifications for pollution prevention.
dot P4: A Look Back, A Look Ahead
dot The National Picture
dot On the Ground: P4 on the Plant Floor
   • Intel's Story
   • Lasco Bathware's Story
dot Pilot Lessons
dot Resources
dot PPRC News
dot P2 Digest
dot Info Resources
dot About this Newsletter
'In a philosophical sense, we're stuck in the wrong paradigm for excellent achievers ... We need to change the adversarial relationship with the achievers. They need more support, more technical assistance. Companies that get it have a market incentive to comply. They don't need us on their case.'
Jim Nolan, enforcement chief, Puget Sound Air Pollution Control Agency
'If you see a couple of successful examples, you create a template. People in our agency are open to including flexibility or creativity in permits. It's less a cultural shift than having an availability of models and a commitment from managers to provide models and encouragement. But it's not appropriate for every company.'
Kevin Masterson, P2 assistance, Oregon DEQ
P2 Focus The P4 Project:
A Look Back, a Look Ahead

        Four years ago, a Northwest manufacturer and its regulators decided to try something new with an environmental permit - make it more flexible and require some pollution prevention in the bargain.
        A goal was to develop a practical regulatory approach that incorporates P2 as a strategy for reducing emissions and meeting air quality requirements. Another goal was to create a regulatory structure that pushes businesses to implement P2 as an alternative to end-of-pipe controls, in order to meet both environmental performance and competitiveness goals.
        The experiment, with the ungainly title of "pollution prevention in permitting pilot project" (P4 project for short), was implemented at Intel Corporation's semiconductor manufacturing complex in Aloha, Oregon. The same approach is being tried out at five other manufacturing plants across the U.S. that are required to have facility operating permits under Title V of the 1990 Clean Air Act. Title V permits pull together all the enforceable air quality requirements for a facility, including compliance, monitoring and reporting requirements.
        Each of the permits is structured somewhat differently because of differing regulatory requirements and industry needs. Their common elements are:
        • Pre-approval of defined operational changes that otherwise would trigger review and modification of facility permits.
        • Conditioning pre-approval upon commitments to P2 for reducing emissions and staying under emissions ceilings. These commitments vary, but commonly take the form of goals, training, investigation, implementation, tracking and reporting.
        According to Rob Greenwood of Ross & Associates, which co-authored a P4 benefits assessment for the Western States Air Resources Council (WESTAR), the pre-approval aspect of the P4 approach complements the business strategy of "lean manufacturing," which in turn encourages P2 - continuous improvement to root out waste and get the most value for the least expenditure of resources. Contrarily, the conventional permitting approach of reopening facility permits to review operating changes can inhibit P2 innovations because of time-consuming review procedures and resulting regulatory uncertainty.
        Has the P4 approach resulted in pollution prevention that would not have happened otherwise? In Intel's case, "it's not a clean answer. We have a very active P2 program. Those activities were underway before (P4) and they continued," said Tim Mohin, Intel's corporate environmental manager. Between 1995 and 1997, when Aloha's Fabrication Plant (Fab) 15 came on line, volatile organic compound (VOC) emissions from the campus fell from 15 tons per billion production units to 8 tons per billion. "Would it have happened without P4? Probably. But would it have happened as fast as it did? No," Dave Dellarco, an EPA P4 project coordinator, said in reference to the permit's pre-approval provisions.
        Mohin said the emissions caps focus attention on obtaining emissions reduction results. "In this case, we came out and said publicly, 'this is what we'll emit and no more.'" Consequently, he explained, the caps are pushing the company to design waste out of its operations. Dellarco said the P4 approach increases the potential that companies will look for and implement efficiency improvements.
        Dellarco said measurement is critical for making the P2 conditions work as intended and to make them practically enforceable. To get credit for P2 emissions reductions, he said, companies must be able to document them.
        Measurement will be a challenge in facilities regulated under emissions caps, notes a 1998 paper on the Intel Project XL agreement published by Resources for the Future. "Movement away from technology-based standards means movement toward more difficult forms of compliance monitoring," the paper noted.
        Participating companies like the permits' pre-approval provisions. In a letter to EPA last year, Intel said the permit's flexibility provisions enabled the company to implement process changes and P2 projects without unnecessary delay, critical in an industry where continuous change is essential for remaining competitive and profitable.

Better Suited for Fast-Changing Industries

        Which brings up one of the lessons of P4. It's better suited for industries in the fast lane. Companies that make frequent process changes to stay ahead in fluid, highly competitive industries will likely have greater interest in P4's flexibility provisions than companies in industries that change more slowly. In an article published in the journal Resources, entitled "The Pollution Prevention Puzzle: Which Policies Will Unlock the Profits?" Resources for the Future analyst Jim Boyd noted that "firms engaging in the total redesign of products and processes ... are best motivated by regulations that favor inherently speculative types of innovation."
        For a slowly changing company that needs to make only one facility permit revision per year, "P4 probably is not worth the up-front costs," Dellarco said. "But if you're making a change every month, all of a sudden the scale changes. The need for predictability increases the value of the P4 permit."
        Which brings up a second lesson. A significant investment of time and resources is required to successfully negotiate a permit with unconventional features. Companies must submit "more information, more narrative and evaluation data than is required in a regular application," and the negotiations alone could take months, according to a 1997 paper from the Georgia Environmental Protection Division about the P4 negotiations for a Searle Chemical plant. "The tricky part of this that needs to get managed is that a lot of dialogue is necessary between the permit authority and EPA so that the approach will be accepted," Dellarco said.
        To transfer knowledge gained from the pilots, EPA has contracted with the Western States Air Resources Council to develop a training course to help permit writers understand and apply the P4 approach. A series of workshops for permit writers is being held this year. As additional P4 projects are brought into play and a technical assistance infrastructure is put in place to help permit writers, the stage will be set for broader adoption of P4. (To find out more about the permit writers' training, contact WESTAR at 503-387-1660, info@westar.org)

No Guarantees

        However, there is no guarantee the P4 approach will become part of the permitting mainstream. Currently, P4 is in a transition zone between experimentation and integration. Making the leap runs up against "a lot of conservatism" and inclinations to stick with the "tried and true," Dellarco commented. Another potential obstacle, in his view, is that P2 programs lack an understanding of regulatory frameworks necessary for getting P2 integrated into regulatory programs.
        "Just because it can work, doesn't mean it will be implemented," he cautioned.
        Still, companies and agencies that have worked on P4 projects have transferred the concepts to other projects. Pre-approvals and emissions caps were incorporated into the XL agreement for an Intel manufacturing complex in Arizona. With the encouragement of EPA Region 1, three companies in New England-a printer, tool maker, and a fabric manufacturer- have adopted elements of the P4 approach, including emissions caps and pre-approvals. end
P2 Focus Enterprise Seeks Out
New Policies, New Innovations

        Alternative regulatory approaches such as P4 bring to mind broader questions about structuring the regulatory system to deliver environmental results more efficiently through pollution prevention. In the past few years, several reports by prominent policy groups have proposed frameworks for addressing those questions.
        In a 1998 Environmental Forum article, former EPA Administrator William Ruckelshaus commented, "There is remarkable agreement among (the reports) about what an improved environmental protection system would look like." Ruckelshaus was referring to a 1996 report from the President's Council on Sustainable Development, a 1997 report from the National Academy of Public Administration (NAPA), and a 1998 set of recommendations from Enterprise for the Environment (E4E), a broad-based group of business, political, agency and environmental leaders which Ruckelshaus chaired.
        In general, the reports recommend a performance-based protection system that is focused on results, encourages pollution prevention, integrates efforts across environmental media, and allows for a variety of regulatory and economic approaches. The system would be supported by an accountability framework reliant on high-quality information.
        For example, Chapter 4 of the E4E report proposes more use of facility-wide permitting to address air, water and waste issues together, and identifies opportunities for using pollution prevention to reduce emissions and waste. Corporations are urged to integrate stewardship into their operations, through tools such as life-cycle costing and goal-oriented incentives.
        These changes cannot happen overnight, Ruckelshaus wrote. The E4E report recommended a measured approach to change, through a series of "stepping stones" that build confidence and provide learning opportunities.
        Since the reports were issued, there has been some movement toward implementing their recommendations. The Progressive Policy Institute, a D.C.-based think tank, is working with about 20 members of Congress from both political parties on draft legislation to be introduced this spring. The legislation would put in place the "information infrastructure that you need to support performance-based" regulation, said Dr. Debra Knopman, who directs the institute's Center for Innovation and the Environment. Another section of the draft would give EPA legal authority to carry out innovative approaches to regulation within an enforcement framework. One of the NAPA report's recommendations was that alternative approaches such as XL need a statutory foundation, in order to reduce the uncertainty that lessens industry's interest in participating.
        A central purpose of the legislation, Knopman explained, is to give "more focus" to alternative regulatory approaches, to integrate them into agency activities if they work and to evaluate their lessons if they don't.
        In February of this year, EPA released its Action Plan for Achieving the Next Generation in Environmental Permitting. The plan proposes continued testing and evaluation of performance-based approaches to permitting that allow facilities to meet enforceable numerical emission standards through their choice of prevention or control projects. "The features and strategies in P4 are now being considered for more regulatory situations and more permitting authorities, and for broader application as a component of Title V permitting in all regions," the plan noted. "Further applicability to other media permitting is also being considered." The action plan is available on-line at http://www.epa.gov/permits/pap0299.pdf.
        In May, an EPA task force will recommend ways to use incentives and voluntary approaches more broadly. Last year, Congress asked NAPA to oversee a review of federal, state and community efforts to improve the effectiveness of environmental protection. NAPA will deliver the report in 2000. end
Find out more:
President's Council on
Sustainable Development:
P2 Focus
On The Ground: P4 On The Plant Floor
  Intel's Story
        computerIn 1981, a personal computer with a molasses-in-January clock speed of 4.8 MHz and a trifling 64 KB of RAM would have set you back $3,000. In 1999, you can pick up a desktop machine with a clock speed of 400 MHz and 1,000 times as much RAM for less than half that amount. Better, cheaper, and faster is the essence of the computer industry.
        Intel Corporation makes the microprocessors that run nearly 90 percent of the world's personal computers. Making them requires process chemicals containing volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). Making them better, cheaper and faster requires frequent process and tool changes. Therein lay Intel's problem.
        Process and tool changes can require review and modification of facility operating permits required under the Clean Air Act's Title V for major air pollution sources. Permit reviews, designed to assure that changes conform with air quality standards, take time. Time is a luxury that semiconductor manufacturers say they do not have in a highly competitive business. Can permit flexibility and enforceable environmental performance be reconciled through pollution prevention? Intel's Aloha, Oregon manufacturing complex was the first P4 pilot that was developed in order to find out.
        Intel's P4 permit, issued in 1995 and expiring later this year, pre-approves defined operating changes and includes plant-wide emissions caps for specific pollutants. The idea was that pre-approvals and emissions caps would give the company an incentive to use P2 to drive down emissions per production unit, so it could expand and modify production operations quickly without exceeding the limits and without triggering a permit review. A pre-existing VOC cap of 190 tons per year was folded into the permit, but in 1996, Intel agreed to cut 30 tons off the cap to reflect emissions reduction progress. Also included were annual ceilings of 10 tons each for organic and inorganic HAPs. Pre-approvals are in effect as long as the plant-wide caps are not exceeded.
        Intel's incorporation of P2 into its operations did not begin with the P4 permit. Instead, the permit built on Intel's existing P2 efforts by including requirements for P2 training, a process to establish performance goals for adhering to the VOC and HAP limits through P2, and reporting results of P2 projects.
        According to Tim Mohin, Intel's corporate environmental manager, it's difficult to say whether the permit itself resulted in P2 that otherwise would not have occurred. But a benefit of emissions caps, he continued, is that they push the company to design waste out of new manufacturing processes in each retooling cycle. Under the company's "copy exactly" policy, environmental improvements in new processes can be replicated at Intel plants elsewhere.
        Between 1995 and 1997, VOC emissions per production unit at Aloha fell 47 percent. Production at Aloha increased 70 percent from 1996 to 1997, during which time the campus was reconfigured - relocation of a product development center, closure of Fabrication Plant (Fab) 4, and rampup of Fab 15 to full production. Use of P2 to reduce per-unit emissions saved the company $2 million in control costs, according to a company estimate. An example of a P2 project implemented at Fab 15 was a cleaning process change that reduced emissions of hexafluoroethane, a potent greenhouse gas, by 50 percent per wafer.
        Speed and flexibility to expand were key drivers for seeking the P4 permit. A related factor was the company's goal that all U.S. plants become minor sources and avoid the need for Title V permits and their possible regulatory delays. P2 was not necessary to stay below emissions caps, but was necessary to meet the minor sources goal, Aloha representatives wrote EPA in September 1998.
        The "biggest negative" of P4 was the transaction costs, Mohin said. "It was a two-year process." Communications barriers between and within agencies were one of the difficulties.
graph         The flexibility of the P4 approach was useful enough to be adapted for plants in Texas, Massachusetts, and one in Arizona governed by a 1996 Project XL agreement, Mohin said. The agreement includes an enforceable air operating permit with pre-approval provisions for process changes and enforceable plant-wide caps on VOCs and HAPs. The agreement also includes commitments to increase water efficiency, improve solid waste recycling and reduce employee-related vehicle miles traveled. The XL project was attended by considerable public controversy over the level of health and environmental protection it provides. For more information about the Arizona project, see the following:
        • "Alternative Compliance Model: A Bridge to the Future of Environmental Management," by Tim Mohin, published in Semiconductor Fabtech, July 1998 http://www.fabtech.org/toc/mag_6/article/081/page_12.html
        • Natural Resources Defense Council's letter to EPA, 1996 http://yosemite.epa.gov/xl/xl_home.nsf/all/nrdc-fpa-comments.html
        • "Intel's XL Permit: A Framework for Evaluation," discussion paper published by Resources for the Future, January 1998 http://www.rff.org/disc_papers/PDF_files/9811.pdf end
Chart shows VOC emissions reductions at Intel's Aloha manufacturing site. The left vertical axis and the bars refer to total VOC emissions in tons per year. The right vertical axis and the line refer to emissions per billion production units,measured in tons.
Source: Intel letter to Oregon DEQ, Sept. 23, 1998
  Lasco Bathware's Story
        bathtubHouses need bathtubs and showers. Lasco Bathware makes bathtubs and showers at its plant in Yelm, Washington. When more houses are built, more bathware is needed. Making more bathware can result in more emissions of styrene, a hazardous constituent of resins used in fiberglass fabrication. Therein lay Lasco's problem.
        Unpredictable product demand can necessitate process changes that could trigger time-consuming review of the facility operating permit that major air pollution sources must obtain under the Clean Air Act's Title V. Not good. Not only is styrene a hazardous air pollutant (HAP), but using resins inefficiently is expensive. Not good either. Enter the P4 pilot project.
        Lasco Bathware's P4 facility permit was issued in 1997 by the Olympic Air Pollution Control Authority. The permit incorporates annual and daily caps on VOC emissions. Also, the permit pre-approves defined operational changes ahead of time as long as they meet technology requirements, rather than through case-by-case permit review that might hinder the company's need to rapidly adjust production. Adding a spray booth is an example of a pre-approved change. Pre-approvals are conditioned on implementation of a P2 program, which includes performance goals.
Lower Styrene Resins
        According to Lasco's 1998 P2 progress report, the company is training spray gun operators on techniques to reduce overspray and subsequent emissions. An accounting system is used to ensure that excessive materials are not being used during manufacturing. The company has introduced lower styrene resins, and is studying two other P2 measures - more efficient spray equipment and zero-styrene resins. Energy efficiency measures also are under study.
        Lasco's interest in P2 predates the P4 permit. The primary driver is the bottom line - cost-cutting, increased efficiency, and improved competitiveness. The company adopted a P2 plan in 1992. Since then, product engineers have implemented techniques for reducing resin atomization, which both cuts emissions and results in a stronger product. The annual emissions cap was adopted in 1996 to clear up a potential compliance issue with a previous air permit. Another permit element is updating emissions estimating formulas. As part of the Title V permit application, "stack tests"were performed in 1996 to determine site-specific formulas. A retest performed in 1997 showed that P2 measures, such as lower styrene resins, had reduced estimated emissions significantly. (For details, see "Fiberglass Fabrication Industry: Northwest Pollution Prevention and Regulatory Perspectives," source testing section, http://www.pprc.org/pprc/sbap/fiber/regissue.html#SourceTesting)
        Expedited updating of emissions estimating formulas can be accomplished via flexible permits, said Mark Goodin, the Olympic engineer who helped write the P4 permit. "One of the things that was an eye-opener in this whole process was that there are more opportunities to write flexible permits than meets the eye," he said.
Public Outreach
        Plant odors have been an ongoing issue in the community. Public education through workshops and printed materials was an important aspect of negotiating the permit, said Craig Weckesser, Olympic's public information officer. An important lesson was reassuring the community "that we wouldn't give away the store," Weckesser said. Under the permit, Lasco is obligated to take part in an annual community meeting to report on its P2 program.
        For more information:
        • Lasco Bathware's P4 permit http://www.wln.com/~oapca/lasaop.pdf
        • Permit technical support document http://www.wln.com/~oapca/latsd.pdf
        • "Economic Prosperity and Environmental Progress," Washington Community, Trade and Economic Development Department, 1996 http://www.cted.wa.gov/features/success/lasco.html end
P4 Permits Issued
Intel Corporation
Aloha, Oregon
Intel Contact:
Audrey Holes
Permit Contact:
Kevin Masterson
Oregon DEQ

Lasco Bathware
Yelm, Washington
acrylic bathware
Ph: 360-458-3900
Permit Contact:
Mark Goodin, OAPCA
Imation Enterprises
Weatherford, Okla.
Computer diskettes
Imation Contact:
John Metzger

Permit Contact:
Dawson Lasseter
Oklahoma DEQ

P4 Permits Drafted
Cytec Industries
Wallingford, Connecticut
Specialty chemicals
Cytec Contact:
Lon Solomita
Permit Contact:
Chris James
Connecticut DEP
Rio Grande Portland Cement
Tijeras, New Mexico
Portland cement
Ph: 505-281-3311
Permit Contact:
Angel Martinez,
Albuquerque Air Pollution
Control Division
Searle Chemical
Augusta, Georgia
Ph: 706-303-5000
Permit Contact:
Cindy McAlpine,
Georgia Environmental
Protection Division,
P2 Focus
Pilot Lessons: Perspectives from Other Alternative Regulatory Approaches
Experimenting with new approaches to regulation, such as the P4 pilots, is an exercise in diffusing innovation. Diffusion of innovation takes time, and the results of experimental approaches may be unpredictable. Each, however, is an opportunity to learn. Below are thumbnail sketches of other Northwest experiences with regulatory alternatives, with observations and potential lessons for advancing P2 through alternative regulatory approaches.
        Program: In 1997, the Washington Legislature adopted an "Environmental Excellence" law allowing businesses to try different approaches to environmental protection. Participating businesses can enter into agreements with a regulatory agency that supersede existing state requirements. The different approach must deliver improved environmental results compared to existing requirements or the business' performance history, or achieve equal results at lower cost. The legislation was supported by the business community as a way to make regulation more flexible, and opposed by environmental organizations concerned that it would lead to lower environmental standards.
        farmingExample: Only one proposal has been submitted since the law took effect in July 1997. Land Recovery, Inc. negotiated an agreement allowing the company to sell partially composted yard waste to farmers as a soil amendment, without farmers needing to obtain a solid waste disposal permit that otherwise would be required. The solid waste permit requirement was seen as a barrier to marketing the product. Application of the product must take place under the supervision of an agronomist in order to prevent leaching of nutrients to water resources. The material has been pilot-tested on rhubarb and tulip fields.
        • Land Recovery, Inc. made a substantial commitment of resources to research, communication and negotiation in order to reach agreement with the agencies. The effort was worthwhile, and the law "allowed a good thing to happen." What organic recyclers need, however, are consistent regulations for composting facilities, but there is little will to revisit current law. - Jeff Gage, director of recycling services, Land Recovery, Inc.
        • Four possible reasons why business has shown little interest in the program: 1) Companies that may have been interested changed their priorities, 2) Transaction costs and political opposition to the program are too high, 3) Criticizing the existing system is easier, 4) The program covers only state law, not federal requirements, limiting its appeal. - John Williams, Environmental Excellence coordinator, Washington Department of Ecology
        • From another perspective, four possible reasons for the lack of business interest: 1) The opportunity to take part doesn't arise until a permitting issue comes up, 2) There are competing priorities for company resources, 3) Vetoing of the law's exemption from the State Environmental Policy Act may have sent a message that the state was not committed to making the program attractive to business, 4) The state has not marketed the program well. - Scott Hazlegrove, environmental affairs, Association of Washington Business
         For More Information: http://www.wa.gov/ecology/options/eepa
        Program: Project XL is an EPA pilot program that tests alternative approaches to protecting the environment and public health. Projects must show they will achieve environmental results superior to what would be achieved through the standard regulatory approach, produce cost savings and regulatory flexibility benefits, demonstrate stakeholder support, and achieve pollution prevention. Ten pilot project agreements have been implemented so far. Issues associated with the program include high transaction costs and the quality of stakeholder involvement.
        Example: Elmendorf Air Force Base is negotiating an XL agreement with EPA and the Alaska Department of Environmental Conservation involving air quality permitting. The base is seeking flexibility that would save an estimated $1.5 million in paperwork and monitoring costs involving minor air pollution sources. The savings are to be spent on an estimated 80 vehicles fueled by compressed natural gas and on other projects, such as hazardous air pollutant (HAPs) reductions.
        viewUnder current permitting procedure, Elmendorf would be required to obtain a single permit covering all pollution sources on base, which would require analysis and reporting for hundreds of minor sources such as backup generators. The XL proposal provides that only the base's gas-fired central heat and power plant, which emits about 60 tons per year of carbon monoxide, would be subject to permitting requirements. The base originally planned to spend the savings on a plant upgrade, but substituted the vehicle proposal based on input from the Municipality of Anchorage. CNG vehicles emit about 95 percent less carbon monoxide than gasoline-fueled vehicles, and Anchorage is not in attainment with ambient carbon monoxide standards.
        Observations: The process is "exceptionally political and politics are never easy or fast." The anticipated benefits of the project were worth the effort, but the transactions costs were higher and the process took longer than expected. Organizations considering an XL project should be certain ahead of time that benefits will outweigh transaction costs. - Dave Bennett, air and water quality program, Elmendorf Air Force Base
For More Information: http://yosemite.epa.gov/xl/xl_home.nsf/all/elmendorf.html
        Program: The program is similar in approach to XL, but targeted at local governments and community organizations.
        Example: The Portland Water Bureau is negotiating an agreement with EPA to accept a multi-pronged lead hazard reduction program as a substitute for full pH treatment of drinking water. Treatment keeps slightly acidic water from leaching lead and copper from plumbing. The city says its program would provide better public health protection by attacking lead hazards more broadly, including likelier pathways of lead exposure: deteriorating paint in aging homes and household dust. Tests conducted in Multnomah County between 1993 and 1997 showed that 5 percent of tested children had unsafe levels of lead in their blood. The city program includes pH treatment, but at a reduced scale, and includes home maintenance services to reduce lead dust exposure. In November 1997, the state Health Division approved the city's lead hazard reduction program as meeting pH treatment requirements.
        The home lead reduction program started as a pilot in 1997. Priority goes to homes with children exhibiting elevated blood lead levels. Homes in targeted neighborhoods have received lead hazard reduction services, such as repainting and cleaning with a special vacuum. In the first year, lead hazard reduction work was done on 38 homes. Homes needing more extensive work are referred to a Housing Bureau program. The program is to be expanded to other communities in the service area of the city's Bull Run reservoir. Additionally, the city is completing a study to assess the extent of lead dust hazards in older housing.
        paint canThe program was developed with broad input from public health, community, and environmental justice organizations working on lead hazard reduction, including the Urban League and Physicians for Social Responsibility. As a result of community outreach, a lead summit was held to exchange information and explore opportunities for organizations to collaborate on lead hazard reduction projects. The summit will be held annually.
        Observations: The effort expended in building relationships with health agencies and community organizations was worthwhile in broadening support for the city's lead hazard prevention program and building a community-based lead hazard reduction network - Stacey Edwards, outreach coordinator, Portland Water Bureau
        For More Information: http://www.epa.gov/ProjectXLC/xlc_a3.htm
        Program: The state has instituted the Environmental Management System Incentives Project (EMSIP) as an approach to implementing Green Permits legislation. The goal of Green Permits is to achieve environmental results that go beyond compliance, through approaches not otherwise provided for in existing regulations. Four volunteer companies were selected to take part in the pilot, which will provide regulatory incentives for instituting environmental management systems and achieving environmental performance greater than compliance with existing standards. Possible incentives may include reduced frequency of inspections and reporting. The project requires participating companies to have stakeholder involvement programs.
        power poleExample: PacifiCorp, an electric utility, volunteered for the pilot in order to upgrade the environmental management system (EMS) for its Medford service center, where power distribution equipment is maintained and repaired. Another goal was to improve the company's rocky relationship with the Oregon Department of Environmental Quality.
        • From a practical standpoint, only large companies have the resources to take on a project of EMSIP's magnitude, including investigation of innovative P2 approaches to environmental performance, and management of a stakeholder involvement process.
        Companies must be willing to take an in-depth look at their processes to identify business opportunities in waste reduction. The state should find ways for small companies to participate in alternative regulatory approaches that go beyond compliance. A great deal of pollution comes from smaller companies, but large companies are under the most scrutiny. - David Wilson, lead environmental engineer, PacifiCorp.
        • The stakeholder involvement component is a big issue, because industries don't have the resources for engaging in extensive community education and involvement programs.
        Companies with a "philosophical P2 mentality that goes beyond compliance" are the best candidates for the program. "Compliance is the bare minimum. It's like getting D's in college."
        Companies must measure performance in order for their environmental efforts to have credibility. "You have to prove that you're improving." - Laurie Patterson, formerly with Oki Semiconductor, now environmental manager of JAE Oregon, Inc.
For More Information: http://www.deq.state.or.us/hub/greenpermits.htm end
'(P2) can't come from one department dreaming this up. It has to be embedded in the business culture, as one component of the business system ... I have to believe that grass-roots employee programs, a positive awards program, will work.'
Alan Schuyler, environmental consultant, ARCO Alaska
'Studies demonstrate that strong standards are what lead to pollution prevention. True environmental excellence is making standards stronger ... rather than creating a bureaucratic nightmare in which equal rights are negotiated away on a site by site basis.'
Carol Dansereau, Washington Toxics Coalition, 1997 letter of comment on Washington Environmental Excellence legislation  
'A big lesson for stakeholder involvement is clarity of objective. The more you can lay out the objectives up front, the better ... Another is rules of engagement - know why people are there and what their expected input is going to be.'
Tim Mohin, corporate environmental manager, Intel Corporation  
'Involvement of stakeholders is innovation and it must be looked at like that. That involvement will create a new way of doing business by changing boundaries and creating incentives and a different sense of community. We need to see how others see things.'
Ely Dorsey, Howard University, from 1997 Project XL roundtable  
'Persuasion can achieve much, and building a social consensus around achieving key environmental objectives provides a good foundation for making even more progress. But there will always be some polluters who resist persuasion and incentives, and for these there must be a credible threat of real punishment. The old saying holds: "walk softly but carry a big stick."'
From 'Persuasion and Incentives: New Ways to Achieve a Cleaner World,' Environment Matters, winter/spring 1997 edition, published by World Bank Environment Department http://www.worldbank.org/
'While government must set environmental and worker protection standards, there are important economic and environmental benefits in allowing risk managers and stakeholders greater flexibility in determining how to meet those standards. Greater flexibility must be coupled with agency monitoring and enforcement, however, to ensure that the expected level of environmental protection is being achieved.'
Presidential/Congressional Commission on Risk Assessment and Risk Management, 1997  
Little Known P4 Fact
Meeting location near good restaurants is critical to success. Source: P4 Permit Writers Workshop, Seattle, 1998
Resources for Innovative Approaches
EPA Office of Reinvention
Commission on Risk Assessment and Risk Management

The Alternative Path
Resources for the Future, Regulatory Policy Library
Good Neighbor Agreements

Joint State/EPA Agreement to Pursue Regulatory Innovation
P4 Q&A
P4 Fact Sheet
Cytec Draft P4 Permit Language, Technical Support Document


State Experiences Integrating P2 into Permits,
Research Triangle Institute, 1995

Multimedia Pollution Prevention Permitting Project:
Project Report
The Incentive Plan to the Stars
Autobody shops in the Puget Sound area that are high environmental achievers will be eligible for 80 percent reductions in their annual air permit fees, under a three-year pilot project being implemented jointly by the Puget Sound Air Pollution Control Agency (PSAPCA) and counties that offer the EnviroStars recognition program. Autobody shops in King, Snohomish and Kitsap counties car that are four or five-star EnviroStars could have their annual air permit fee cut from $250 to $50. Autobody shops that are EnviroStars at any level would not be subject to regular inspections. EnviroStars, developed by the King County Local Hazardous Waste Management Program (LHWMP), gives public recognition to businesses that reduce hazardous waste.
For More Information: Read the article in FlashPoint, the LHWMP's monthly newsletter, http://www.metrokc.gov/hazwaste/lhwmp/fpnov98.html#Fee end
p2 news New Resources on PPRC's Web Site  
All four reports from a series of shipyard roundtables and a pollution prevention technology demonstration sponsored by PPRC are now on line at http://www.pprc.org/pprc/sbap/ship.html. Included in the set are the following:
        • Depainting Technology Demonstrations: P2 Benefits & Production Issues. Three alternatives to dry abrasive blasting were demonstrated at the Portland Shipyard in June 1998.
        • Large Shipyards in Oregon: Coating Choice Drivers & P2 Opportunities. The report explores issues related to alternative antifoulants and low-VOC coatings.
        • Small Shipyards and Boatyards in Oregon: Environmental Issues and P2 Opportunities. The report explores sandblasting grit disposal issues, and real-world waste reduction practices in the areas of grit reuse, alternative coatings and equipment, and waste fluids management.
        • Large Shipyards in Washington: P2 & BMP Opportunities. The report explores waste reduction opportunities offered by alternatives to dry abrasive blasting.
        Hard-copy versions of the reports were published previously.
        Contact: Chris Wiley, cwiley@pprc.org
So, how do you help do-it-yourself mechanics fix their cars without venting CFCs or oiling up creeks containing endangered salmon runs? Hand them the Do-It-Yourselfers P2 Quiz, part of PPRC's Auto Repair Topical Report. The quiz has fun questions and helpful information resources about air conditioner repair, oil changes, car washing, radiator flushing, and general housekeeping.
        The report includes companion fact sheets on auto repair shops, for shop owners and for assistance providers helping auto repair shops identify P2 opportunities. All of the material is on line at http://www.pprc.org/pprc/regional/
        Contact: Catherine Dickerson, cdickerson@pprc.org
If you're an assistance provider helping companies with P2, compliance or manufacturing efficiency, PPRC's monthly "What's New in P2" e-mail bulletin can help you keep up to speed on new P2 resources from PPRC and others, trainings, conferences, and web sites that will help you in your job.
        Contact: Catherine Dickerson, cdickerson@pprc.org
Through mid-March, nearly 70 requests for PPRC's Rapid Response Research Service had been carried out for Northwest assistance providers. Rapid Response gives Northwest assistance providers and non-government organizations (NGOs) a road map to guide them to the answers they need. We provide up to three hours of research per request, and a typical response includes listings of publication titles, web site addresses and contacts. For a catalogue of requests, visit http://www.pprc.org/pprc/

        Contact: Catherine Dickerson, cdickerson@pprc.org
Easier URL
PPRC has an easier address for its home page. It is now http://www.pprc.org. You no longer have to tag on another forward slash and an extra "pprc."
PPRC gratefully acknowledges SiteConnect for hosting our web site and providing us with Internet services
p2 digest P2 Digest      
  Idaho Environmental Conference
        The 1999 Intermountain Conference on the Environment (formerly known as the Conference on Hazardous Wastes and Materials) is holding a conference for environmental professionals, featuring presentations, vendors, and awards, on March 29-30 in Pocatello, Idaho.
        Presentation topics will include success stories, pollution prevention, small quantity generators, agricultural issues, air, water, ecosystems, solid, hazardous and mixed wastes, policies, regulations, and emerging technologies.
        For more information, contact 208-236-3155 or send e-mail to isuconed@isu.edu.
Washington P2 Awards
        The 1998 Washington Governor's Pollution Prevention Awards were presented to five businesses and three government agencies for leadership in preventing pollution at their facilities.
        The winners of the 1998 awards are: Ace Galvanizing, Inc., Seattle; Cablecraft, Tacoma; Fairchild Air Force Base, near Spokane; Hansville Repair, Hansville; Thurston County Waste Program, Olympia; and United Paint and Coatings, Greenacres. Praegitzer Industries of Redmond received an honorable mention for efforts to reduce hazardous waste generation. The U.S. Navy's Subase Bangor in Silverdale received an award for "continuing leadership in pollution prevention."
        For more information about the winners' waste reduction achievements, visit http://www.wa.gov/ecology/pie/
EPA Evergreen Award
        IKEA, the home furnishing store in Renton, Washington, is the 10th Northwest company to earn the U.S. Environmental Protection Agency's Evergreen Award for Pollution Prevention. The Evergreen Award is presented to Northwest companies for strong leadership in pollution prevention and sustainable business practices.
        IKEA was selected for its IKEA Green program, the Green Steps process for making business decisions, reduced use of packaging and electricity, and increased use of sustainably harvested wood.
        For more information about the Evergreen Award, contact Carolyn Gangmark at EPA Region 10, 206-553-4072, or gangmark.carolyn@epa.gov.
  Environmental Health Course
        Middle and high school teachers throughout the Northwest can learn about environmental health in a free course taking place in August 1999 and in May 2000. The course will include lectures, discussions and lab work on human and ecological health, air and water quality, food protection, toxic substances, occupational safety and health, waste management, radiation, communication, and societal well-being. Application deadline is April 23, 1999. For details, contact Marina Cofer-Wildsmith at the University of Washington Dept. of Environmental Health, 206-616-2643 or mcofer@u.washington.edu
Canadian P2 Roundtable Meeting
        The next Canadian P2 Roundtable will be held in Vancouver, British Columbia April 22-23. The roundtable will include sessions on case studies, reaching small businesses, practical approaches to P2, environmental reporting and performance, and tools.
        A workshop on pollution prevention planning will be held the day before the roundtable. It will focus on elements of P2 planning; application of P2 planning within the context of ISO 14000 and regulatory programs; drivers supporting implementation of P2 planning in Canada; and planning tools.
        For information, visit the Canadian Centre for P2 conference web site at http://c2p2.sarnia.com/conferences/
, or call 519-337-3423.  
Recycle Building Materials
        Reusable Building Materials Exchange (RBME) is a new pilot program for residents of King, Mason, Pierce, and Thurston counties to exchange small or large quantities of used or surplus building materials.
        For more information, call 206-296-6542, send e-mail to julie.mitchell@metrokc.gov or, browse the listings at http://www.rbme.com/wa/

Alaska Training Forum
        The Alaska Forum on the Environment, a cooperative environmental training and education conference, is scheduled for April 5-9, 1999 at the Egan Convention and Visitor's Center in Anchorage. The purpose of the conference is to expand the audience and scope of environmental training and education by combining existing separate training efforts into one event.
        For more information, contact the Alaska Department of Environmental Conservation at 907-269-7631. end
p2info P2 Info      
  New EPA Statistics Database
        The Center for Environmental Information and Statistics (CEIS) is the U.S. Environmental Protection Agency's (EPA) new one-stop source of data and information on environmental quality, status and trends. It is part of EPA's national effort to improve public access to the agency's information resources.
        Database users can access a collection of environmental statistics from many EPA databases, including the Toxics Release Inventory (TRI), hazardous waste (BRS), air quality (AIRS), and surface and drinking water quality (state 305b/SDWIS). Users search by county or zip code to develop an environmental profile of statistics that can help evaluate a community's environmental quality, status, and trends.
        The CEIS also features a searchable digital library and an environmental atlas for integrating and displaying environmental information. A mapping tool allows the creation of community-level maps identifying all EPA regulated facilities, pollutant sources, and monitoring facilities. Visit the database at http://www.epa.gov/ceis/.
Manufacturing Sector Profiles
        EPA is piloting the Sector Facility Indexing Project to consolidate and improve access to information about regulated facilities. The project brings together information about compliance, chemical releases, production, and surrounding community demographics for five sectors: petroleum refining, pulp manufacturing, smelting of aluminum and other non-ferrous metals, iron and steel production, and automobile manufacturing, totaling about 640 facilities.
        The project is expected to help businesses track their environmental performance, enable citizens to examine and compare facility environmental performance records, and assist agencies with planning and analysis.
        Visit http://es.epa.gov/oeca/sfi/index.html.
  Materials Exchange Resources
         Materials exchanges help businesses find markets for surplus, waste or out-of-spec materials. Exchanges serving the Northwest include:
        • IMEX, the Industrial Materials Exchange
Service: General exchange for Northwest
Contact: 206-296-4899, imex@metrokc.gov
Find out more: http://www.metrokc.gov/

        • Portland State Chemical Consortium
Service: Laboratory chemical exchange for schools, hospitals, and government agencies
Contact: 503-725-4273
Find out more: http://www-adm.pdx.edu/user/

        • Alaska Materials Exchange
Service: General exchange for Alaska
Contact: 907-296-7600
Find out more: http://www.state.ak.us/local/akpages/

        • Other exchanges
        Directory available at http://www.recycle.net/

Earth's 911
        Earth's 911 is a free, 24-hour resource listing information about local environmental and recycling programs, important phone numbers, buying recycled products, handling household hazardous waste, and answering other waste-related questions, including old phone books, rechargeable batteries, construction waste, packing peanuts, and automotive items, including used tires, oil, oil filters, and batteries.
        Local information can be found by clicking on your state or province on a map of the U.S. and Canada, or entering your postal code in an interactive locator. For more information, call 1-800-CLEANUP or visit http://www.1800cleanup.org. end


Editor & Designer: Jim DiPeso
Technical Editors: Madeline M. Sten
Web Version Format: Crispin Stutzman

Pollution Prevention Northwest is published bimonthly by the Pacific Northwest Pollution Prevention Resource Center. To receive a free subscription (please specify electronic or hard copy), link to the newsletter order form or contact the PPRC, 1326 Fifth Ave.,
Suite 650, Seattle, Washington 98101
Phone: 206-352-2050; Fax: 206-352-2049
E-mail: office@pprc.org

About this Newsletter
Articles from this newsletter may be printed or distributed electronically only in their entirety with written permission from the PPRC. Please credit the author (if any), followed by "Pollution Prevention Northwest, Pacific Northwest Pollution Prevention Resource Center."

About the Pacific Northwest Pollution Prevention Resource Center
       The Pacific Northwest Pollution Prevention Resource Center (PPRC) is a nonprofit organization that is the region's leading source of high quality, unbiased pollution prevention information. PPRC works collaboratively with business, government and other sectors to promote environmental protection through pollution prevention. PPRC serves Alaska, Idaho, Oregon and Washington, and also takes part in projects with benefits beyond the Northwest.
       Financial support for PPRC is broad-based, with contributions from organizations such as the U.S. Environmental Protection Agency, the U.S. Department of Energy, the Northwest states, The Boeing Company, Intel Corporation and others. The PPRC accepts environmental settlement moneys to further its work on pollution prevention.
       Significant in-kind support has been provided by organizations such as: Hewlett-Packard Company, Battelle/Pacific Northwest National Laboratory, Battelle Seattle Research Center, Microsoft Corporation, Ross & Associates Environmental Consulting, Ltd. and The Fluke Corporation.

Staff: Madeline M. Sten, Executive Director; Catherine Dickerson, Technical Lead; Chris Wiley, Industry Outreach Lead; Jim DiPeso, Communications Director; Crispin Stutzman, Research Associate; Cathy Buller, Research Associate; Scott Allison, Chief Financial Officer; Dawn Elmer, Administrative Assistant

Board of Directors: Richard Bach, President, Stoel Rives, Portland, Ore.; Joan Cloonan, Vice President, J.R. Simplot Company, Boise, Idaho; Kirk Thomson, Vice President, The Boeing Company, Seattle, Wash.; Dana Rasmussen, Secretary, Seattle, Wash.; William June, Treasurer, On Point Communications Strategists, Portland, Ore.; Rodney Brown, Marten & Brown, LLP, Seattle, Wash.; Charles Findley, U.S. EPA Region 10, Seattle, Wash; Scott Forrest, Forrest Paint Co., Eugene, Ore; Tom Korpalski, Hewlett-Packard, Boise, Idaho; Langdon Marsh, Oregon Department of Environmental Quality, Portland, Ore; Alan Schuyler, ARCO Alaska, Anchorage, Alaska; Randy Tucker, 1000 Friends of Oregon, Portland, Ore.

© 1999, Pacific Northwest Pollution Prevention Resource Center
phone: 206-352-2050, web: www.pprc.org