Monthly Archives: June 2008

The “Power of SEPs” – Or, How an Innovative Enforcement Settlement Can Have Wide Benefits

About the author: Joshua Secunda is the Innovations Coordinator and a Senior Enforcement Counsel with EPA’s Boston office.

Earlier this year, our Region and the U.S. Veteran’s Administration (VA) won an Environmental Business Journal’s 2007 Achievement Award for the creation of innovative pollution prevention and compliance tracking software. The software will perform tasks that cannot be achieved by software systems currently on the market. The VA committed to spend a minimum of $500,000 to design and implement the Supplemental Environmental Project (SEP). Actual costs may reach a million dollars.

In 2003, the Region inspected the VA campus in White River Junction, Vermont. While there, our inspectors discovered potentially explosive hazardous waste on-site. The lab building was evacuated, and the containers removed and detonated. The explosive power of the wastes equaled several sticks of dynamite. Numerous other RCRA (hazardous waste) violations were found.

Although the Region’s Federal Facility program had provided hands-on compliance assistance and lead multimedia inspections since 1994, the VA remained in chronic noncompliance. This puzzled us. Apparently, enforcement actions succeeded in getting the VA’s attention.

Nonetheless, enforcement alone didn’t measurably improve their performance. We decided to use this enforcement action to identify basic causes of the VA’s environmental difficulties, and formulate solutions that might be implemented through a SEP. A SEP is an environmentally beneficial project that a violator voluntarily undertakes as part of an enforcement action settlement.

The best way to do that was in collaboration with the VA itself. We concluded that the VA’s outdated and inaccurate chemical and waste tracking systems were a key contributor to their problems. Due to these inadequate systems, the VA didn’t know where its hazardous materials or wastes were located, their quantities, or whether chemicals were being double or triple ordered.

Working with White River Junction VA personnel, we identified the critical tasks that a computerized “cradle to grave” management system would have to perform: automatically notify on-line chemical purchasers of non-toxic substitutes; reduce the total amount of hazardous products purchased through a chemical “adoption” inventory system; maintain an inventory of hazardous products and wastes and where they are stored; and provide access to a MSDS electronic library.

To achieve these capabilities, a new software system would have to be designed. Ultimately, the VA agreed to create this innovative system and test it at all eleven New England VA hospitals. If successful, the VA hopes to implement it nationwide. The VA is the largest health care organization in the world. Thus, the SEP’s ultimate environmental impact could be significant.

Elements of this story are worth noting. The costs to EPA of achieving environmental improvement go up steadily, while the resources to achieve them shrink. Thus, while litigating, we should simultaneously explore collaborative strategies that identify solutions to institutional environmental problems, and pose solutions to them. EPA has multiple tools to achieve compliance in addition to enforcement. Leveraging enforcement actions to address root causes of chronic noncompliance is an additional tool. Designing SEPs that focus on a sector’s systemic environmental problems should be a central goal of our work.

Suggested Links:

EPA Region 1 Healthcare Sector Assistance

Press Release on this settlement

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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On the Green Road: Grey Towers

About the author: While Karen Reshkin of our Chicago office enjoys her vacation, she’s sending along environmentally relevant thoughts and pictures.

Milford, PA: The view from Grey Towers, home of James Pinchot, the first Chief of the US Forest Service. The mansion itself is amazing. It was donated to the USFS in 1963. It’s a key site in the history of conservation in the US.

View from Grey Towers down the lawn and across a valley


Editor’s note: thanks to Dee for catching the mistake on Gifford Pinchot’s first name.

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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Shall We Gather At The River?

About the author: Lars Wilcut joined EPA’s Beach Team in 2004. He helps oversee EPA’s beach monitoring and notification grants to coastal states and territories.

A couple weeks ago I went to see a baseball game at Nationals Park, which has some great views of the Anacostia River. As I stood there gazing up and down the river, I thought about how nice it is to be on the water.

Lars Wilcut in a kayakI love kayaking, and I paddled the Anacostia even before I joined the Office of Water. From my experience with water quality standards issues, I know how far the river is from meeting its designated uses. I still like it, though. It can be so tranquil out on the water, despite the bustle on the other side of the tree-lined riverbanks. Often, I was the only person on the river, feeling acutely like everyone else thought the river was a nuisance and didn’t want to be on or near it. I didn’t think much about the river before I started kayaking. Once I did get out there, though, I began to value it as an important part of our community that I wanted to protect.

So, if I could come to appreciate the Anacostia, can’t other people as well? Building public facilities like ballparks along urban waterways is a big step toward getting people to value their local water resources. What a great thing to have people come out of the ballpark after a game and stroll along the river! When a city reclaims its urban waterway as a community gathering place and surrounds it with public green space and ballparks, those waterways become as much a symbol of the city as the local sports teams.

Through the water quality standards-setting process, we can all participate in protecting our waters. Standards help define what we want our waters to be used for and how we want to make that happen. The people I work with are an integral part of the water quality standards process: EPA reviews and approves state water quality standards to make sure they meet the requirements of the Clean Water Act.

Here in DC, as I return to Nationals Park over the coming seasons, I’m hopeful that we’ll see an improvement in the Anacostia’s water quality; I know EPA will do its part. Then, the next time I’m out there paddling, I won’t be the only one on the water.

Find out about your state’s water quality standards, from EPA’s Repository of water quality standards.

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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Question of the Week: How far do you live from where you work or play? Why?

Each week we ask a question related to the environment. Please let us know your thoughts as comments. Feel free to respond to earlier comments or post new ideas. Previous questions.

Location, location, location: A few weeks ago, we asked Why are you or aren’t you biking to work? We got hundreds of comments and many of you answered that it depends on where you live. We wanted to follow up on this point because where you live affects how you get around – to work, to school, to anyplace – and this affects the environment.

How far do you live from where you work or play? Why?

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En español: Cada semana hacemos una pregunta relacionada al medio ambiente. Por favor comparta con nosotros sus pensamientos y comentarios. Siéntase en libertad de responder a comentarios anteriores o plantear nuevas ideas. Preguntas previas.

Todo depende del lugar: Hace un par de semanas preguntamos el por qué viaja al trabajo en bicicleta. Recibimos cientos de comentarios y muchos de ustedes contestaron que dependía del lugar en que vivían. Estamos interesados en dar seguimiento a esta pregunta porque el sitio donde vive influye en cómo usted se transporta – al trabajo, la escuela, a cualquier sitio – y esto influye en el medio ambiente.

¿Cuán lejos vive de su trabajo o del lugar para recrearse? ¿Por qué?

Editor's Note: The opinions expressed here are those of the author. They do not reflect EPA policy, endorsement, or action, and EPA does not verify the accuracy or science of the contents of the blog.

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