Define Test Approaches: Choosing and Developing the Pilots
Completed in May 1997
How Were Pilot Projects Chosen?
The factors for choosing pilots were: potential for learning, potential for
environmental improvement, potential for cost savings and other efficiencies, potential for transferability
across companies and industries, potential for flexibility within the laws and regulations, and the willingness
of agencies and companies to volunteer to work on the pilot. The Stakeholders reviewed the "straw poll" of issues
best suited for pilots and discussed the merits of and concerns about each issue at the second Stakeholder
meeting on October 28, 1996 (see discussion of "scoping" under Project Definition). In a
Herculean and intense yet very positive effort, we sorted candidate issues into six groups, ranging from "full pilot"
to "no action." Since we only have resources to pursue a limited number of pilots, we chose four pilots.
In some cases, we consolidated several issues into a single pilot. We briefly discussed follow-up for the
other issues. We then organized ourselves into teams for each of the pilots. Finally, the Stakeholder Group
agreed that if one of the chosen pilots could not be pursued for some reason, another pilot topic would be
selected from the list.
What Are the Pilots?
The pilots selected by the Stakeholder Group included materials recycling,
compliance assistance, flexible track for good environmental performers, and trading local effluent pretreatment
limits. The core of the teams for each pilot was formed at the meeting and more team members were added
to provide additional perspectives or expertise as appropriate. The pilots are described briefly below. For a more
detailed description of the pilots, see the Testing and Analysis section, or click on the
desired pilot title below.
Materials Recycling:
Can material that is a "waste" for one facility be productively and safely used
at the same facility or by another facility? This pilot developed a series of possible scenarios to improve
resource use and process efficiency by facilitating safe and efficient recycling of materials. The Pilot Team
then explored which scenarios are allowed under current rules and developed a report to help guide other
facilities in their efforts to increase materials recycling. The Pilot Team worked to implement several of the scenarios with facilities and has documented the benefits observed in their overall report.
Compliance Assistance:
This pilot explored what topics and forms of compliance assistance would be
most useful to the batch chemical industry. The Pilot Team then worked in conjunction with Compliance Assistance
staff in EPA and NJ DEP to develop a set of Compliance Assistance Materials to help facilities better understand
and meet the requirements of specific environmental regulations. The materials are available from NJ DEP via
their website at http://www.state.nj.us/dep/enforcement/home.htm or in a printed version. The Pilot Team also sponsored two compliance assistance workshops
during October 1998. The Pilot Team has documented how they used an Industry-Government Team approach to develop compliance assistance materials for New Jersey companies in their overall report.
Flexible Track:
This pilot has explored what constitutes being a "good environmental performer"
facility, and what permitting, inspection, and/or reporting flexibility can be granted as a incentive for facilities
to become and continue to be "good performers." A paper that presents the framework of this "alternative track"
program is available. The work of the Pilot Team served as the foundation for NJ DEP's Silver and GOld Track Programs. The Silver Track Program was implemented in September 1999. NJ DEP is continuing to work with a group of stakeholders from industry and environmental groups in developing the Gold Track Program.
Effluent Trading:
This pilot arranged an agreement between facilities within a POTW service area
to trade local limits of pollutants to allow the required reductions in pollutants to be achieved more economically.
The trading agreement between these facilities also retires some of the allowable discharge to produce a "cleaner"
result. The Pilot report documents these experiences and provides clear guidance for implementing trading of
local pretreatment limits in your area. Since completion of the pilot, additional companies have expressed interest in trading and a second trading agreement has been signed.
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