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West Virginia Operations South Charleston, WV National Environmental Performance Track Incentives Hold Value for Members National Environmental Partnership Summit May 9, 2007 J. A. Amos amosja@dow.com. Discussion Outline. West Virginia Operations Site - UCC Heritage
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West Virginia OperationsSouth Charleston, WVNational Environmental Performance TrackIncentives Hold Value for MembersNational Environmental Partnership SummitMay 9, 2007J. A. Amosamosja@dow.com
Discussion Outline • West Virginia Operations Site - UCC Heritage • Incentives – Identifying Opportunities • Process for Requesting Incentives • Value Assessment and Lessons Learned • Glossary of Terms • Acknowledgements and Contact Information
Living. Improved Daily West Virginia Operations Heritage Union Carbide Corporation (UCC) Facility as a Wholly-owned Subsidiary of The Dow Chemical Company.
West Virginia Operations South Charleston Facility comprises of two contiguous sites with individual requirements (CAA, CWA, RCRA) under a common management system.
South Charleston Manufacturing Products and Applications End Use Chewing gum (Toll manufacturing) Gas treatment solvents, paint primers Brake fluids, surfactants, hydraulic and metal working fluids Diverse mix of chemical intermediates for agricultural, automotive, and industrial uses Paints and coatings, textile processing, degreasers, industrial laundry applications Product Gum Base AA Amines UCON® Fluids Chemical Mixing TRITON®
Opportunity for Incentives Timing is Everything! • Renewal of Three NPDES Permits in 1Q ’07 • Desire to Test Opportunities Identified at Sept. 2004 Water Incentives Meeting • Attempt to Pilot State’s EEP Rules Incentives
Process Followed • Responded to Solicitation by EPA PT Office for Expedited Permit Renewal Interest • Early Engagement of State Permitting Authorities and Region III Water Program Office (“Conditioning”) • Developed Early Understanding of Request “Boundary” for each Stakeholder Interest • Submitted a Written Request for Incentives Consideration
Process Followed (cont’d.) • Assignment of a Single Point of Contact for All 3 Permits (Permit Supervisor) • Pre-Application Meeting on Incentives Request • Developed Justification Basis for Significant Change Issues in Request (Supporting Data) • Submitted Comments for Reconsideration of Incentives Request not included in Draft Permit Issued for Public Comment
Incentives Value • Reduced Intensiveness in Application Development/Sampling • Changes - Immediate & Future Compliance Cost Impact • Significant Reduction in Sampling and Monitoring Frequency for Several Parameters (e.g. 1/Quarter - pH, Zinc, Chlorides, TOC, Chloroform, Flow) • Reduced Frequency of DMR Submittals (1/Mo. to 1/Quarter) • 7 of 22 Monitored SW Outfalls (Others - Substantially Identical) • No Monitoring for several SWOs with “No Industrial Activity” • Expedited Renewal Process with Predictabe Outcome • Opportunity for cooperation in CWO data mining (TSS, Temp.) • Reassigned Resource for other Environmental Improvement
Some Learnings • Identify and Target Facility-Specific Incentive Opportunities • Much Flexibility/Discretion Exists within Current Programs • Strong Compliance/Performance History is a Great Ally • Challenge of Deviating from Standard Permitting Template • Challenges Traditional Thinking – Learning Experience for All • Changes have No Adverse Environmental Impact!
Leveragable Ideas • Establish Good Compliance and Relationship History • Secure EPA Regional Office Concurrence – Preempt Deflection • Acknowledge/Respect State’s Primacy of Programs • Establish “Boundaries” and Provide Data to Support Request • Early and Continuous Engagement/Communication is Critical
Conclusion • Performance Track and Companion State Environmental Excellence Programs Can Deliver Value for PT Members • Best Opportunities May be Facility-Specific (Customize) • Performance Track and State Environmental Excellence Programs was Leveraged to deliver the Permitting Flexibility and Agency Discretions in Existing Regulatory Programs • To Get Meaningful Benefits, You’ll Likely Have to Ask! (May Get What You Negotiate For, Not Necessarily What You Deserve)
Glossary of Terms • NPDES – National Pollution Discharge Elimination System • SWO – Storm Water Outfall • CWO – Cooling Water Outfall • DMR – Discharge Monitoring Report • TOC – Total Organic Carbon • TSS – Total Suspended Solids • PT – Performance Track • WV EEP – West Virginia’s Environmental Excellence Program • R&D – Research and Development • Temp. – Temperature • UCC – Union Carbide Corporation
Dow South Charleston Facility We’re Proud of Our Performance Track Participation!
Acknowledgements • US EPA Performance Track Program Office • Richard Kashmanian, Water Incentives Program Coordinator • US EPA Region III: • Marie Holman, Performance Track Regional Coordinator • Francisco Cruz, Water Program Office • West Virginia Department of Environmental Protection • Greg E. Adolfson, Deputy Administrator – Office of Innovation • Matt Sweeney, Permit Supervisor – Office of Water & Waste Management • Renee Clevenger, Permit Writer – Office of Water & Waste Management
Contacts • Dow West Virginia Operations • South Charleston Facility NPDES Team • Joseph Amos, amosja@dow.com (304.747.3623) • Charlie Armstead, armsteadcw@dow.com (304.747.5455) • John Hill, hilljg@dow.com ( 304.747.5095) • Beverly Hudson, hudsonbs@dow.com (304.747.2125)
