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Pollution Prevention Planning
Enforcement targeting was determined through a relative risk analysis of the data
and by evaluating permit exceedances. This helps to prioritize P2 inspections. The
data also help the agency with priority setting through health tracking of cancer, child
blood lead levels, and birth defects; multimedia release reports; and the discovery of
hot spots and chemicals of concern.
On the other hand, the requirements for the New Jersey P2 plans were laid out in
the P2 Act legislation and resulted in some outcomes that did not necessarily lead
to P2. For example, some companies produced products that contained nontoxic
forms of chemicals listed on the TRI lists, such as nickel, chromium, or cobalt in
their alloy forms. Targeting is an option for facilities to streamline their planning
requirements. A facility could choose to target the metal component; however, it is
possible that other more toxic substances also contributed to 90 percent of use, NPO,
or releases and would also be targeted. Targeting does not prevent a facility from
looking at all substances.
In addition, in 1996 the New Jersey DEP commissioned a report by Hampshire
Research Associates (HRA), Evaluation of the Effectiveness of Pollution Prevention
Planning in New Jersey. HRA and the New Jersey DEP visited 115 facilities to evaluate P2 planning, including planning costs and cost savings. The report showed the
following findings:
• Of the 28 facilities able to calculate their annual cost savings, the annual
average cost savings was approximately $254,000, for a total of $7.1 million .
Most facilities calculated only the direct savings in raw material costs for
their reduction projects.
• Eight of the facilities calculated the costs/amounts of both capital investment and annual cost savings, yielding a total (for all eight facilities) capital
investment of $7.2 million and a total annual return of $1.7 million, for an
average payback period of 4.2 yrs.
• Potential capital investment to complete all of the projects in the plans of the
facilities ranged from zero to $19 million for the 48 facilities visited by HRA.
• Of 115 facilities that could place a dollar figure on the cost of their planning,
49 spent an average of $35,000 each.
• Of 115 facilities that could quantify the amount of time necessary to prepare
their plans, 95 spent, on average, 6.5 wks of one person’s time to develop
the plan. Taking an average salary of $50/h yields an average planning cost
of $13,000 per facility.
• Overall, the average cost of planning was less than the average annual
savings per facility found through planning.
LESSONS LEARNED BY NEW JERSEY COMPANIES
Howmet Castings, a division of Alcoa Aluminum Company, located in Dover, New
Jersey, produces a specialty alloy and manufactures turbine blades of various sizes
for jet engines and power plant gas turbines. The alloy facility produces a variety of
superalloys of chromium, nickel, and cobalt to withstand the high temperatures of
gas turbine engines. Alloy scrap is recycled on site.