Pollution Prevention in Enforcement
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Pollution Prevention in Enforcement
Mead Paper – Case Study
August, 1998
The Mead Corporation in Chillicothe, Ohio used a P2 SEP (pollution prevention supplemental environmental project) to settle an enforcement action with Ohio EPA. The project involved replacing 36 solvent-based degreasers with 17 aqueous parts washers, resulting in:
elimination of 34 tons per year of volatile organic compound (VOC) emissions
elimination of over 33,000 lbs. of hazardous waste
reduction in worker exposure to solvents and solvent vapors
Introduction
The Mead Corporation, like many companies today, is realizing substantial environmental and financial benefits from incorporating pollution prevention into their standard operating practices and environmental management systems. Pollution prevention (P2) avoids or reduces generation of waste at the source.
Pollution prevention can be incorporated into environmental enforcement settlements via P2 supplemental environmental projects (SEPs). SEPs are environmentally beneficial projects that a company agrees to undertake when settling an enforcement action. P2 SEPs use P2 techniques to reduce waste generation beyond what is required by law.
Ohio EPA has developed a number of case studies that document the inclusion of P2 SEPs in enforcement settlements. This case study was developed by OPP and Ohio EPA’s Division of Air Pollution Control (DAPC) and the Mead corporation, to illustrate the benefits of using P2 SEPs in enforcement cases.
Facility description
The Mead Corporation, Chillicothe Operations (Mead) is an integrated pulp and paper mill that employs approximately 2500 people. The mill produces coated and uncoated paper, carbonless paper, and paper for greeting cards. Facility operations include an integrated Kraft pulp mill, seven paper machines, five coating machines, two supercalendering machines, and numerous finishing machines. In 1997, Mead sold over half a million tons of paper products, for sales of $669 million.
Pollution prevention prior to enforcement
Pollution prevention is an important concept at Mead’s international headquarters, located in Dayton, Ohio. In the past, the corporate office has supported P2 projects at the Chillicothe facility.
Mead was aware of the benefits of P2 prior to the enforcement case, and had implemented a number of projects to decrease their use of hazardous materials and reduce risk to the community from a possible spill or accident. Aware that conservation of raw materials, water, and energy make good business sense, Mead has formed employee problem-solving teams to analyze their use of raw materials, water and energy.
One of Mead’s most significant P2 projects involved elimination of chlorine gas from the pulp mill, where wood is processed for use as a raw material in the paper mill. The pulping process involved large quantities of potentially hazardous chlorine gas, used to bleach the pulp. Mead voluntarily redesigned its pulping process to an elemental chlorine-free process for its bleaching operations.
Teamwork
In the early 1990’s, Mead and Ohio EPA’s Southeast District Office committed to a cooperative regulatory problem solving process. The team acknowledged that 1) Mead was going to continue its presence as a leader in the paper industry and in Ohio’s business community, and 2) that environmental protection agencies and regulations to protect the environment are here to stay. The team works towards facilitating Mead’s efforts to go beyond regulatory compliance, and do more than is what is required by law to protect the environment.
Enforcement case
Environmental violations at Mead, alleged by Ohio EPA’s Division of Air Pollution Control (DAPC), involved repeated violations of air pollution control regulations over a period of several years. During enforcement negotiations, Mead and DAPC agreed that the case had the potential for a P2 SEP.
Mead proposed two P2 SEPs: replacing the solvent-based parts cleaners with aqueous units; and increasing the combustion efficiency of their #6 wood-waste boiler (used to generate heat for the pulping process) by adding an over fire air system. Ohio EPA and Mead settled in May of 1997; the final findings and orders (F&O’s) included both P2 SEP projects.