This week's post was written by guest blogger Sarah Medearis; Sarah is a Senior Consultant with Antea Group’s Baltimore Office and is the company’s Operational Performance and Assurance Practice Leader.

Twenty-first century environmental regulations require more detailed pollutant accounting than their 20th century predecessors, and rely on increasing public demand for transparency and corporate social responsibility to green industrial operations. Ontario’s Ministry of Environment (MOE) is one of many agencies in North America requiring manufacturers to track and publicly account for toxic substances at their facilities under its new Toxics Reduction Act (TRA) regulations (O. Reg. 455/09). Finalized in December 2009, reporting requirements for some of the listed toxic substances were due for the first time on June 1 of this year.

These new and more rigorous regulations draw on each other, creating a complex diversity of similar requirements throughout North America. The MOE drew upon the Massachusetts Toxics Use Reduction Act (TURA) and New Jersey’s Pollution Prevention (P2) Act to develop the TRA requirements. Ontario’s TRA regulations focus on specific industrial operations at a facility that create or use toxic substances, not just those that result in pollutant emissions from the facility as a whole. Accounting for individual toxic substances is a more complex process than previous requirements. It starts by organizing facility operations into distinct “Stages” within which there are one or more processes using, creating or emitting toxic substances.

At the process level, measurements and calculations must be performed to quantify the amount of toxic substances used, created, transformed, destroyed, contained in the product, released or disposed of, or transferred to another process or medium. The data and quantification methods must be evaluated for accuracy with mass balance checks performed to identify any imbalances between input and output so that all quantities can be explained.

As part of the drive towards transparency, and to ensure there are no hidden icebergs under the water, MOE requires firms to also report costs associated with these industrial operations in its P2 plan due at the end of the year. MOE is particularly interested in all the “indirect costs” that the agency believes really drive P2, including:

• Environmental, health and safety compliance
• Pollution liability
• Waste disposal
• Hazardous material storage & handling
• Worker protective equipment, ventilation
• Container labeling, packaging (CLP), material safety data sheets (MSDS)
• Administrative burdens
• Public relations
• Energy, operation and maintenance for pollution control equipment

As part of the expected corporate social responsibility, the P2 plan must identify at least one method for reducing toxic substances under each of seven P2 categories. Both feasible and non-feasible options must have a rough toxic substance reduction estimate. For those options that are considered technically feasible, the P2 plan must document the anticipated cost savings. The net present value and timelines for implementing feasible P2 options must be outlined, along with the anticipated cost savings of both direct and indirect (and co-benefits) including:

• Total Savings
• Return on Investment (ROI) and Payback Period
• Replaces Equipment Scheduled for Repair/Replacement
• Energy Efficiencies
• Reductions in Byproducts
• Reduced Worker Exposure (including reductions in claims, comp time, PPE costs)

The increased complexity of these newer pollutant regulations and the sharing of regulatory requirements across North America do have benefits. Despite the variations among regulations, environmental professionals experienced with, or certified under, TURA and the New Jersey P2 Act can support firms in meeting Ontario’s 2011 TRA accounting, planning and reporting requirements. As the reach of these regulations expands, so does the professional expertise to stream-line and more efficiently meet the regulatory requirements as well as reap the benefits of P2 plans. In addition, while annual pollutant reporting and compound-specific P2 plans are required, implementing P2 measures remains voluntary. But with increasing public pressure for corporate social responsibility, together with the effort spent preparing compound-specific P2 plans, companies can make both social and environmental gains by greening their operations.

This past Tuesday, a dust storm unlike any other hit the Phoenix area, obscuring the sun and pretty much everything else. In its wake it left downed trees, power outages, and a thick layer of dust over everything. 

Dust storms are not uncommon in our area during the monsoon season (roughly June through September), but this one left even life-long residents in awe.

Deemed a haboob (which in Arabic means “strong wind”), this dust storm was estimated to be around 5,000 feet high and up to 100 miles wide, reaching speeds of 50 miles-per-hour.

This storm also traveled an unusually long distance, around 150 miles from where it originated near Tucson. 

Phoenix residents had plenty of warning that the storm was on its way, but it never hurts to remember that we need to be prepared – for another haboob, a major thunderstorm, or whatever other disaster, natural or not, may strike.

The importance of being prepared in an emergency applies to businesses as well as individuals. 

For example, Sky Harbor International Airport in Phoenix had to shut-down for approximately 45 minutes during the haboob.  That meant delaying flight take-offs and re-routing flights scheduled to land in Phoenix.  They also had to deal with the unexpected occurrence of having the smoke alarms go off in the baggage claim area due to the dust blowing in through the doors.

Any business, regardless of what line of work it is in, should have an emergency preparedness plan.  This is extra important for businesses that are tasked with the protection of public health and safety. 

This issue has come up most recently in this blog by way of nuclear facility safety – during earthquakes, tsunamis, flooding and wildfires. 

Our business helps organizations stay aware of, and therefore be prepared for, changes in regulations that are put into place to help them remain safe. 

The haboob was a great big dusty reminder of why it is important to always have your eyes open to safety and to know what to do when something unexpected happens.

I’m sure the general public is more attuned than usual to the effects of natural disasters on nuclear facilities, given all of the recent media attention set off by the Fukushima disaster this past March.

Most recently, the Missouri river floods in Nebraska and the Las Conchas fire in New Mexico have threatened two nuclear power stations and the Los Alamos National Laboratory, respectively. 

With the media’s eye on these incidents, it makes one wonder…how prepared are places like this to handle natural disasters, big or small?

Recently, there has been a lot of focus on the Nuclear Regulatory Commission (NRC) and its (real or perceived) lack of action regarding nuclear safety. 

Gregory Jaczko, NRC chairman, recently visited the Cooper Nuclear Station during the flooding. 

Mr. Jaczko was shown firsthand the measures that the plant was taking to prevent the floodwaters from entering sensitive areas of the plant.  He seemed satisfied with the measures taken at Cooper Nuclear Station, stating that, “Fundamentally, this is a plant that is operating safely.”  So far, this appears to be true.

More recently, the 36 square miles that house the 2,000 buildings that make up the Los Alamos National Laboratory (LANL) were threatened by the Las Conchas wildfire, now the largest wildfire in New Mexico’s history. 

Audits conducted by the Department of Energy (DOE) on LANL in 2007 and 2009 identified fire vulnerabilities at the facility and stated that, “there are increased risks associated with fire-related events…If such an event were to occur, not only would the safety and health of employees and the public be impacted, but the environment could be damaged as well.” 

As the Las Conchas fire moved closer to LANL, they shut the facilities down and evacuated everyone.  As of today, the lab is reopened, after a thorough check of all of the buildings for any damage.

In both of these cases, it seems like the worst-case scenario was avoided…unlike the Fukushima event.  

Most of the time, that is the case.  Even in the Fukushima event, they had all of their safety measures in place, but it was no match for what Mother Nature unleashed on the area. 

It just goes to show that, try as we might, even with all of the computer models and everything else we use to make predictions, we can never really know the extent of what can happen.

All we can, and should, do, is try our best, learn from our mistakes and in the meantime, hope that nothing too catastrophic happens.