Taking the Higher Road
A few short weeks before the extraordinary 2000 Presidential Election, the U.S. Environmental Protection Agency's (EPA) ombudsman office released their Preliminary National Ombudsman Report - Waste Technologies Industries (WTI) East Liverpool, Ohio, which recommended the cessation of hazardous waste incineration at the Von Roll WTI state-of-the-art facility. (The final report is expected to be issued in April 2001.) The ombudsman investigation was inspired by WTI's loyal opposition.
The resurgence of activist ire against WTI demonstrates that certain controversial industries continue to be subject to primarily politically motivated attacks, even after scientific, technical, and legal issues on plant operations have been settled. The rehashing of previously defeated arguments in the case of WTI also shows that facilities like WTI have a long way to go to educate the public and the media on the overall positive impact these industries have on the environment and society in general.
The attitude of employees, local residents, government officials, environmental activists and the news media toward a facility can determine how smoothly work progresses.
For the hazardous waste, chemical and nuclear industries, public and media perception of the environmental impact of facility operations has always been very important. These industries, among others, are still quite vulnerable to negative publicity. The attitude of employees, local residents, government officials, environmental activists and the news media toward a facility can determine how smoothly work progresses. To achieve success in both the actual and perceived protection of the environment, all industries would do well to address the entire "environmental system."
The Environmental System
The three components of the environmental system include: 1) sources of emissions or discharges to the environment; 2) the dispersion of the releases; and 3) the receptors (e.g., people, animals, vegetation, structures) that are impacted by the spread of emissions. Each component is important to the severity of pollutant impact. Therefore, care must be taken at each part of the environmental system to ensure the health and safety of the entire system.
Industries have a responsibility and the means to prevent and remedy adverse environmental impacts. Zero impacts are practically impossible, but impacts well within established health and safety standards are feasible. Like any other challenge, a successful outcome is more readily attained if the individual components of the problem are addressed first, then synthesized to reach the goal.
Addressing Each Component
Sources - The origin of environmental contaminants can be examined to find planning and pollution prevention (P3) opportunities. Planning to eliminate waste up front has been added to the traditional pollution prevention (P2) techniques of preventive maintenance, improved housekeeping practices, material substitution/reformulation, waste exchanges, et al. Application of P3 methods will not only benefit by reducing effluents, but can also improve the corporate image, lower risks for chemical spills, accidents and emergencies, and reduce long-term liability and insurance costs.
The three components of the environmental system include: sources of emissions to the environment, the dispersion of the releases and the receptors impacted by the emissions.
Dispersion - Upon release from the source, pollution disperses through the environmental media (air, water, land). Industry needs to estimate this spread through proper measurement and/or modeling. Sampling and analytical techniques have become more precise and accurate, while dispersion modeling has become increasingly sophisticated. Check the latest approved measurement techniques and modeling requirements prior to embarking on a realistic evaluation of your plant's environmental impact. Once results are collected and validated, be ready to clearly communicate them to the public.
Receptors - The better the understanding of the source and dispersion of plant emissions, the better the comprehension of the discharge's impact on the receptors. Human health is the most serious concern. Standards and guidelines have been established for health and welfare and safeguarding the environment. An accurate quantification of potential emissions coupled with appropriate modeling of those emissions will give a good indication of the plant's potential impact on the health and welfare of the community.
Synthesizing and Communicating
For the environmental scientist and engineer, investigation of and reporting on each component of the environmental system is founded upon two basic ideals: objectivity and integrity. Neither ideal has meaning without the other.
Research must be conducted with the highest objective standards. The quality of the environment must be evaluated using the best techniques and equipment to properly quantify observations. All tasks performed, whether they involve organization, administration, observation, dissemination, or the like, must be conducted with integrity. Not only must the data gathered be trustworthy, but so must the messenger delivering the data. The importance of integrity is realized when giving a report at a highly charged public meeting or in court. In these instances, the integrity of the facility and its messenger is integral to the integrity - and acceptance - of the message.
When communicating objective environmental information to the public about your facility, another important goal is clarity. In the "E-World" column of The Wall Street Journal on November 20, 2000, Thomas E. Weber stated that in an information economy, "the ability to convey facts and ideas clearly may be the most valuable skill of all." The ability to communicate clearly to regulatory agencies, the public, media, staff, and others is of great importance. Data must be presented in an understandable, unambiguous, consistent and complete manner. Any limitations associated with the data should also be noted. And, since institutional or media deadlines are frequently imposed, timeliness of data delivery must be a consideration.
A Principled Approach
An honest, objective evaluation of your facility's impact on the environment starts with a principled operations plan of action. This encompassing plan to achieve the noble ends identified should include the following principles. Industries should consider these principles for incorporation into their environmental management system.
Operating Legally and Ethically - Plant operations must always be in compliance with all federal, state and environmental business regulations. But, owners and operators "must do more than what is simply legal, they must always do what is right - that is, operate in a fair and just manner toward their employees and the community." (Sader and Shull, 1999)
When communicating objective environmental information to the public about your facility, another important goal is clarity.
Educating Employees on Benefits and Risks - Ensure that employees are aware of the benefits the plant operations provide to the community. In addition, environmental impacts and relative risks associated with the operation should be explained along with ways to mitigate those impacts and risks.
Listening and Responding Appropriately to the Public - Maintain a commitment to addressing community concerns about facility operations through meetings with concerned citizens. Also consider formation of a community advisory panel.
Properly Disseminating Information to the Media - Provide the media with clear, accurate, succinct, consistent and prompt information on plant operations. Proactive dissemination of information helps maintain a positive influence over public understanding and acceptance of plant operations.
This article appeared in the March 2001 issue of Environmental Protection, Vol. 12, No. 3, on page 81.
This article originally appeared in the 03/01/2001 issue of Environmental Protection.