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Toxic Chemicals
63 percent, hazardous air pollutants (HAPs) by 94 percent, water use by 74 percent,
hazardous waste by 69 percent, and solid waste by 78 percent. In 2002, the company
and the Environmental Cooperative Compliance Program entered into an agreement
that included an innovative regulatory approach. This resulted in a decrease from
roughly 2.5 construction permits being issued to the NEC annually prior to 2002
to an average of 1 permit per year after 2002. This resulted in a savings of over
1,000 hrs to state engineers and 3,000 h annually to the company in reduced paperwork during the first year of the agreement (as well as approximately 4,000 pages of
paper and 2,500 million cubic feet of natural gas at two different locations during the
first year of the agreement).
In addition, in 2004, due to the commitments of 3M to environmental improvement, the DNR and EPA approved a flexible permit (under Title V Part III) for 3M
(Menomonie site). From 2005 to October 2007, 12 new construction projects were
submitted and approved without going through traditional permitting processes,
18 mo of startup time were saved, and 315 hrs of 3M administrative time and over
1,500 h of DNR time were saved.
OTHER BENEFITS
Other benefits of a toxic chemical usage reduction program could be the establishment of spin-off or demonstration projects. There are numerous examples of these
types of projects that are either in place or currently being set up in the United States
(e.g., Oregon, Kentucky, Arizona, and New Hampshire). One of the projects that are
highlighted here, however, has a different aspect to it than the others.
The California Assembly Bill (AB) 2588 Air Toxics “Hot Spots” program
(California Environmental Resources Board 2010) is a spin-off of the air toxics program in California. The Air Toxics “Hot Spots” Information and Assessment Act
(AB 2588, 1987, Connelly) was enacted in September 1987. This law and implementing regulations have done more to reduce air toxics air emissions than any other law
or regulation. What makes the program unique is that the Air Toxics “Hot Spots”
Act establishes a formal air toxic emission inventory risk quantification program
for districts to manage. The goal of the Air Toxics “Hot Spots” Act is to collect
emission data indicative of routine predictable releases of toxic substances to the air,
to identify facilities having localized impacts, to evaluate health risks from exposure
to the emissions, and to notify nearby residents of significant risks. Senate Bill (SB)
1731, which amends the “Hot Spots” program, added a requirement that facilities
determined to have a significant risk must conduct an airborne toxic risk reduction
audit and develop a plan to implement airborne toxic risk reduction measures. Due
to SB 1731, another goal of the program is to reduce risk below the determined level
of significance.
Information gathered from this program has complemented the California Air
Resources Board (ARB) existing toxic air contaminant program by locating sources
of substances that were not under evaluation and by providing exposure data needed
to develop regulations for control of toxic pollutants. In addition, under the program,
the reporting and the requirements to do the risk assessments are mandatory; the
subsequent reductions are voluntary. The program has been a motivating factor for