Preliminary Concept for DEQ Performance Track-Style Program - (Stakeholder consensus comments in black; DEQ proposed comments in red)

Program Concept

Eligibility Criteria

 

Tier

Requirement

Time

 

Incentives

Past/Current Compliance

 

Ongoing Compliance

 

 

Application

How Reviewed

1a

 

 

 

 

 

Develop an EMS

 

 

 

 

 

 

 

 

 

EMS-type plan required within 2 years to stay in Performance Track

Technical assistance in developing EMS

 

 

Applicant is not in Significant Noncompliance and/or has not had a High Priority Violation for one year.

 

No criminal violations for the past three years.

 

No open/unresolved violations -compliance schedule agreed to in writing could constitute adequate resolution of violation for participation.

 

No pattern of noncompliance which indicates a “sloppy shop”

Significant Noncompliance or High Priority Violations will be grounds for removal.

Application to include a summary of what the company does, what permits they hold and regulations they are subject to, and what they hope to accomplish in the program.  It is also to include a summary of the company’s compliance status - including a statement that it is not in SNC or HPV and that all NOVs have been resolved.

Application will be copied and distributed to each division. Each program must agree - with or without conditions.  If acceptance is conditional, the issue must be resolved within a year.

 

“EMS type plan” must follow guideline outlined or ISO-14001

Acceptance decided by DEQ (with comments, as appropriate from Local Health)

 

Application may be shared with EPA if applicant is interested in simultaneously applying to EPA’s program.

1b

Begin implementing EMS - Formal acceptance into program

Technical assistance with EMS (Training, “Turbo-Tax” type CD, response to questions)

 

Recognition - public listing on website

2

EMS implemented for one full cycle.  2-3 ongoing projects to improve environmental performance. (Project is defined as something that is not required by rule. See list) DEQ can do site visits for verification.

 

Public outreach may be required.  Opportunity to mentor others.

Annual reports to document progress.

 

Do not need to move to Tier 3.  May remain in Tier 2 as long as project active and improvements are being made. Renewal term will be set.

May include:

- Selected permit enhancements

- Facility specific incentives (negotiated)

- Reduced % or higher priority on loan funds  (would require Board approval)

- Reduced oversight

- Self-audit

-Annual meeting with DEQ policy leaders

- Publicity

See Above

Significant Noncompliance or High Priority Violations will be grounds for removal.

Application documenting “EMS-type plan” (including ISO-14001) has been implemented for one full cycle plus proposal for 2-3 projects to improve environmental performance.  Project is defined as something that is not required by rule and which falls within guidelines on list. 

 

 

Multi-interest review panel will make recommendation to DEQ based on set criteria.

 

Appeal process needs to be established.

 

3

“Environmental Heroes”

Requirements of Tier 2 met for at least three years. Capstone environmental project. Public outreach may be required.  Opportunity to mentor others.

Annual report to document progress.

 

DEQ can do site visits for verification

See Above.

(Incentives more significant than for Tier 2)

See Above.

Significant Noncompliance or High Priority Violations will be grounds for removal.

Application documenting “EMS-type plan” (including ISO-14001) has been implemented for three full cycles plus proposal for project that makes a significant environmental improvement.

Multi-interest review panel will make recommendation to DEQ based on set criteria.

 

Appeal process needs to be established


ENVIRONMENTAL IMPROVEMENT CATEGORY

(DEQ Revised - 7-2002)

TIER 2

Total pts

TIER 3

Total pts

*Core - 8 points each

Need x

Need x

Waste Reduction - Focus: reduction, substitution

1. Solid Waste - source reduction

2. Hazardous Waste -decrease amounts, material substitution (watch flashpoints)

3. Waste Management - know hauler, where it’s going

Water Management - Focus: efficiency and protection

1. Storm Water

2. Waste Water - pretreatment program

3. Surface Water - ex: bank protection

4. Ground Water - source protection

5. Wetlands

6. Water Conservation

7. Water Efficiency

Air Emissions

1. Reductions below standards

Suggested - 2 points each

Optional

Optional

Transportation Management

1. Clean Fuels and Technology (including fuel cells and technology)

2. Fleet Management

3. Trip Reduction and Consolidation - Reduce company’s vehicle miles traveled

4. Commuter Trip Reduction

    - Support use of mass transit - ex. purchase employee eco passes

    - Flex schedules, compressed work weeks

    - Telecommuting

Recycling

1. Paper/Office

2. Cardboard

3. Metal

Procurement

1. Buy Recycle Products, where practical

2. Purchase Less Toxic Products, where practical

3. Look At Where Production Materials Are Coming From -favor lowest impact

4. Purchase More Efficient, More Protective Products, where practical

Energy Conservation

1. Renewable Energy

2. Energy Efficiency Measures

3. Reduce use of electricity/natural gas

4. Greenhouse Gases

Land Use Management

1. Brownfield or USTfield Development

 

*At least one of the two-three projects under Tier Two and the capstone project in Tier Three must be from the core area


Key Elements of an Environmental Management System (EMS)

         for Utah Performance Track-Style Program

12-13-01 Draft for Discussion Purposes

 

Environmental Policy

Environmental Policy - Develop a statement of your organization’s commitment to the environment.  Use this policy as a framework for planning and action.

 

Planning

Environmental Aspects - Identify environmental attributes of your products, activities and services.  Determine those that could have significant impacts on the environment.

 

Legal and Other Requirements - Identify and ensure access to relevant laws and regulations, as well as other requirements to which your organization adheres.

 

Objectives and Targets - Establish environmental goals for your organization, in line with your policy, environmental impacts, the views of interested parties and other factors.

 

Environmental Management Program - Plan actions necessary to achieve your objectives and targets.

 

Implementation and Operation

Structure and Responsibility - Establish roles and responsibilities for environmental management and provide appropriate resources.

 

Training, Awareness and Competence - Ensure that your employees are trained and capable of carrying out their environmental responsibilities.

 

Communication - Establish processes for internal and external communications on environmental management issues.

 

EMS Documentation - Maintain information on your EMS and related documents.

 

Document Control - Ensure effective management of procedures and other system documents.

 

Operational Control - Identify, plan and manage your operations and activities in line with your policy, objectives and targets.

 


Emergency Preparedness and Response - Identify potential emergencies and develop procedures for preventing and responding to them.

 

 

Checking and Corrective Action

Monitoring and Measurement - Monitor key activities and track performance.  Conduct periodic assessments of compliance with legal requirements.

 

Nonconformance and Corrective and Preventive Action - Identify and correct problems and prevent their recurrence.

 

Records - Maintain and manage records of EMS performance.

 

EMS Audit - Periodically verify that your EMS is operating as intended.

 

 

Management Review

Management Review - Periodically review your EMS with an eye to continual improvement.