Attachment II
Lessons Learned for Future Partnerships
Enforcement programs can get too busy with enforcement cases to conduct adequate follow-up:
EPA provided on–site audits to six companies during 2005 and 2006. The audit reports were sent to the companies in 2006 with
recommendations for specific improvements, but there was no follow-up to assess and report what improvements the companies
made in response to the audit findings. The reason was that the government agency personnel who conducted the audits were too
busy taking enforcement against other, higher priority facilities throughout EPA Region IX. As a result, there are no details of what
improvements were made at each audited IC/GN facility. However, we do know from data logs at the National Response Center
that during 2005-2008 there were no accidental releases reported by the six companies audited, or the other two accident
prevention facilities originally signed onto the partnership.
Companies leave the partnership for many reasons:
For the emissions reduction facilities, five companies dropped out of the partnership. Such attrition is not unusual and resulted
from facility closure, other environmental priorities taking precedence, change of facility ownership, inability to normalize data
accurately, loss of interest/perceived benefit.
Community members have very limited time available, and may not want to speak publicly in favor of the project, but their
participation is very helpful: Participation by community residents in the partnership was low throughout, but still meaningful.
Attendance at early meetings by community members really helped initially to get environmentally proactive companies to join. The
companies that didn't join expressed reservations at exposing themselves to the community and press and very likely would not
have joined a partnership like this under any circumstances. Some community members expressed dissatisfaction with the IC/GN
partnership in the press but nearly all community members involved privately expressed their support for its goals and activities.
Despite the few companies that take full advantage of it, a large investment in technical assistance is essential: A series of five
Environmental Management Systems (EMS) workshops was conducted in 2006. The workshops were of very high quality and were
designed to help each company build an EMS step-by-step, so they were of direct benefit to each facility. Nevertheless, attendance
dropped from 18 companies at the first workshop to six by the last workshop. Despite this attrition, the six companies completing
the EMS workshop series took advantage of the very significant telephone and on-site technical assistance available benefited
greatly from the assistance. These six companies are the ones who stayed with the partnership to the end and contributed heavily
to the reduction numbers achieved. This large investment in technical assistance, including the telephone and on-site data
collection efforts, was essential to the project's success.
Correlating results to improved community health may not be possible:
Correlating the environmental results achieved to improved community health is a very difficult link to make. One expected health
benefit for reducing 85,313 pounds of air pollution, and reducing the power plant emissions associated with conserving 60 million
kWh of electricity is less asthma , particularly for sensitive individuals, but we have no way to make that direct link. Asthma
admissions to local emergency rooms were not tracked because they couldn't be correlated to the project activities due to the many
other asthma irritants generated by other activities in the Phoenix valley that far outweigh the IC/GN emission reductions. It is
possible that a cancer case may have been prevented, although less certain. The partnership targeted chemicals for reduction that
were among the higher toxicity chemicals released in the Phoenix valley (see list below). What is certain is that the individuals living
in the South Phoenix area experienced less chemical exposure than they otherwise would have, especially those individuals living in
the immediate vicinity of the partnering facilities.
How the chemicals were selected for this list:
- They were listed by ADEQ and the Maricopa County Environmental Services Division as being toxic chemicals of concern for
the South Phoenix area. - They ranked in the top 98% of chemicals that posed the highest risk to residents due to their inherent toxicity, quantity
released, prevailing wind conditions, and population profile of residents downwind of each release. The model used to
make this determination is EPA's Risk Screening Environmental Indicator's (RSEI) model: http://www.epa.gov/oppt/rsei/ - It is a chemical that would trigger a facility to develop a Risk Management Plan under SARA Title III requirements:
http://www.epa.gov/OEM/guidance.htm - It is a chemical that was involved in a past release in south Phoenix . These chemicals appeared in Table 5 of the October
6, 2003 report prepared by SECOR International, Inc. entitled Available Documentation of Toxic Chemicals in South
Phoenix for the Arizona Department of Environmental Quality. - It is one of EPA's list of the 33 air toxics that present the greatest threat to public health in the largest number of urban areas
(source: http://www.epa.gov/ttn/atw/urban/list33.html )
Sustained leadership is critical:
Several people played leadership roles in implementing the project from beginning to end. The primary EPA representative,
MCAQD representative, MCAQD press person, industry representative/chairperson for the outreach committee and the EPA
Contractor provided project leadership throughout the partnership. This leadership was critical because key components of the
partnership required constant refining and maintenance: relationships, data reporting, the website, etc.
EPA award at the end of the partnership because it was involved in an enforcement case. EPA's policy is to not provide awards when
there is an on-going enforcement case. Perhaps this could have been avoided if the company had conducted a more thorough
compliance self-audit, and/or the partnership had provided more detailed compliance training workshops.
