Just outside pollution-plagued Mexico City, a paint plant has been working to eliminate toxic air emissions. It has not achieved the goal, but its efforts are already paying off: When other plants have to shut down on bad air quality days, the paint plant continues to operate — which means higher profits.
The plant, owned by E.I. DuPont de Nemours and Co., isn’t required to make the pollution cuts. Instead, it’s striving to achieve the corporation’s goal of zero pollution.
At a Bay Program forum on toxic pollution last year, Paul Tebo, DuPont’s vice president of Safety, Health and Environment, used that example to explain why the company’s policy — “The Goal is Zero” — makes sense for his industry, and others.
Now, the Bay Program is embracing its own “zero” goal. Its new Chesapeake 2000 Agreement calls for voluntary efforts that “strive for zero release of chemical contaminants from point sources, including air sources.”
The agreement doesn’t say when the goal would be attained. But the Bay Program’s draft toxics reduction strategy, expected to be finalized this fall, outlines a series of measurable steps that move in that direction.
“I think just having the concept of trying to have zero release is laudable,” said Kelly Eisenman, toxics coordinator with the EPA’s Bay Program office. “It sets the bar very high.”
Lofty as it may be, the goal still wouldn’t achieve the Bay Program’s long-standing objective of a toxics-free Chesapeake. The goal doesn’t apply to toxics that arrive from air outside the watershed. Nor does it apply to runoff from roads, parking lots and other land uses. Both are considered major sources of toxic pollution.
But for “point sources” — facilities with water discharge pipes or smokestacks that need permits — zero release goes beyond any previous Bay toxics goal. Before, the Bay Program objective for point sources was more ambiguous; it called for reducing chemical contaminants so there were no impacts on living resources or humans.
That is difficult — if not impossible — to quantify. The Bay Program has concluded that many areas of the Chesapeake have low levels of contamination, but no one knows what long-term impact those pollutants have on fish and other Bay inhabitants.
The new goal eliminates that issue. It says, in effect, that any chemical contaminant release is too much.
“If you are looking at your long-term goal, then zero is the right answer,” said David Johnson, deputy director of the Virginia Department of Environmental Quality. “If it isn’t zero, then at what level are you satisfied? Anything other than that is arbitrary.”
“The Chesapeake Bay Foundation feels very strongly that we need to get to zero release,” agreed Kim Coble, staff scientist with the CBF’s Maryland office. “Otherwise, we will be spending our careers debating over whether something is harmful.”
That being said, many acknowledge that zero release won’t be achieved anytime soon. So, why bother? Because, proponents say, the continual striving toward zero release forces people to look at things differently. They may find ways to prevent some pollution altogether by changing a manufacturing process; eliminating the use of a harmful chemical by using a more benign one; recycling wastes into new products; or even developing new control technologies.
“In industry, zero release is a concept that acts as a driver for technology and technological change,” said Steve Farkas, of the Maryland-based Constellation Energy Group, who chairs the Bay Program’s Pollution Prevention Workgroup. “It’s a concept that brings us into thinking about going beyond regulatory requirements. Getting there would be difficult for everyone.”
One of the Bay Program’s steps toward zero release is to end, through voluntary means, the use of mixing zones by 2010 for chemicals that bioaccumulate in food chains or persist in the environment. Mixing zones are areas beyond the end of a discharge pipe where a chemical is allowed to exceed water quality standards as it becomes diluted.
That goal will be difficult; it would essentially mean that some chemicals could not be used at all. Yet even if the goal is not achieved, Coble said it will force dischargers to take a new look at their operations and will almost certainly yield improvements.
“If all mixing zones are not phased out by 2010, did we fail? No,” Coble said. Mixing zones are allowed under the Clean Water Act, she noted, so any movement toward phasing them out goes beyond what might otherwise be required.
In zero-release thinking, regulations are seen as the minimum that must be done. Voluntary actions that go beyond those regulations are encouraged and can often result in further reductions at less cost. “That’s the whole theme of the toxics strategy — to get ahead of the regulatory curve,” Eisenman said.
Regulations can be expensive for businesses to implement, and often stir fights between regulatory agencies and industry over whether the benefits are actually worth the cost.
“If you have to go to the regulatory process, there is a time lag,” Johnson said. “It could take years from the time you think of a regulation and the time it is actually implemented and you see an environmental effect. But if it is voluntary, and you make the right case, it can be implemented immediately.”
For industry, he and others say, there are several payoffs. First there is image: Who wants to argue that pollution is good? Also, less waste can mean less paperwork and — if zero release is attained — it could mean no regulation. In some cases, alternatives can mean saving money: If there is less waste — especially less toxic waste — it’s cheaper to dispose of.
Employee teams at Newport News-based Siemens Automotive Corp. operate in teams to identify such pollution prevention opportunities. In 1998, one team helped the company reduce its use of a cleaning solvent by 82 percent, saving $93,300.
A single change in a single manufacturing process at DuPont’s Waynesboro Plant in Virginia slashed its hazardous waste generation by 50 percent, saving $500,000 annually.
“Zero release gives us a target, and in some areas we’ve achieved that,” said Bob Dunn, DuPont’s environmental and community affairs manager in Richmond. By changing part of the process for making Teflon‘, it totally eliminated carbon disulfide, a highly flammable toxic chemical. DuPont’s Spruance Plant in Richmond has also eliminated in its manufacturing process the use — and therefore the disposal of — chlorine, carbontetrachloride, perphloroethylene and mythlene chloride.
“There are some areas where we can’t get to zero,” he added, “but we can get close.” Its Richmond facility has cut emissions of chemicals that must be reported under the EPA’s Toxics Release Inventory program by 93 percent since 1987, and overall air emissions have been cut 79 percent, even though production increased 40 percent. Solid waste has been reduced 50 percent, from 50 million pounds in 1994 to 25 million pounds in 1998.
But not everything saves money, and some efforts can have big price tags, Dunn said. “Those cases are very difficult,” he said. “We have to look at the return on investment and the priorities of other projects, and then balance competing needs.”
Actions that improve health and safety get approved “without much question,” while others may wait.
In new products, he said, the company tries to avoid that issue by putting pollution considerations up front. “As new products, and the processes to manufacture them, are designed, we put the concept of ‘the goal is zero’ in from the beginning,” Dunn said. By not creating pollution to begin with, he said, the company doesn’t have to deal with it after-the-fact.
That’s the kind of thinking zero-release proponents encourage. In adopting a zero-release goal for Pennsylvania three years ago, Department of Environmental Protection Secretary Jim Seif summed up the philosophy: By rethinking operations from top-to-bottom, businesses can not only avoid regulations on what comes out of the pipe, but “no pipe might be necessary if we could all stop pollution in the first place.”
Pennsylvania-based AMP Inc. has adopted a global corporate goal of “zero discharge” which is credited with helping the company to adopt innovative techniques that reduced wastewater discharges 51 percent from 1990–95 at 17 facilities, and a 100 percent reduction — from 14,500 gallons a day to zero — at one facility in Italy.
Indeed, from breweries in Germany, where wastes are shipped to farmers who use them to grow mushrooms, to Africa, where some new business parks are designed so the wastes of one industry are used by another, companies and governments are embracing zero release. The United Nations has created an organization, the Zero Emissions Research Initiative, based in Japan, to promote the idea around the world.
To promote concepts and technologies being practiced elsewhere, the Bay Program is planning a zero-release conference next year to stimulate more thinking, and action, on the issue.
Some, like Tom Griffin, who heads the Virginia DEQ’s pollution prevention program, believe the day is coming where industrial parks here will do such things as using each other’s wastes in manufacturing processes. Zero release may sound impossible today, he said, but the striving to get there is constantly changing people’s perception of what can be done. “Our challenge,” he said, “is to set up intermediate goals to get there.”
As it strives for its zero-release goal, the Bay Program’s draft toxics strategy sets out a number of measurable toxics reduction milestones.
The draft calls for a 10 percent reduction, from 1998 levels, of Toxics Release Inventory chemicals — a list of 640 substances for which the EPA requires major industries to report releases.
While the EPA only requires industries to report TRI releases, the draft toxics strategy goes further by seeking a 10 percent reduction in those chemicals from public wastewater treatment plants. It’s the first time they have been included in a specific Bay Program toxics reduction goal.
To attain that, the Bay Program plans to work with local governments that operate wastewater plants to expand “pretreatment” activities by industries that discharge to the plant (rather than having their own, separate, permit). The goal of pretreatment programs is to help companies find ways to reduce the pollutants sent to wastewater plants.
The strategy calls for the Bay Program’s Businesses for the Bay initiative, which promotes pollution prevention at businesses and local governments, to expand to 1,000 participants by 2005. About 260 participate now. Of the new participants, half are to be small businesses with fewer than 100 employees, because they often have less expertise in exploring pollution prevention options. To help them, the program will recruit 300 “mentors” from larger industries to offer advice.
In addition, the strategy is calling for Businesses for the Bay participants to prevent at the source, or recycle, a total of 1 billion pounds of hazardous substances by 2005, measured from a 1999 baseline.