EPA's Performance Track program keeps Mohawk's Beckett mill on track with cutting costs, boosting environmental performance, and attracting customers
March 2007
By Daniel J. Fiorino
Six years old and more than 400 members strong, the U.S. Environmental Protection Agency's (EPA's) National Environmental Performance Track program is a government-industry partnership that benefits the environment while boosting its members' reputations and in many cases their bottom lines. Performance Track recognizes and drives environmental excellence by providing incentives for facilities to go beyond compliance with environmental laws and commit to continuous improvement.
Pulp and paper facilities make up 5% of the program's membership, and many enjoy significant cost savings while improving their environmental results. "Performance Track is a testament to EPA's outreach to the business community to improve the environment while not losing sight of the need to keep American manufacturers competitive," says Juanita Duggan, president and CEO of the American Forest & Paper Assn. (AF&PA).
For the 18 pulp and paper facilities currently participating in Performance Track, environmental improvements can mean redesigning boxes to require less pulp, improving color treatment systems and cutting solid waste production, converting from fossil fuel-generated electricity to renewable sources, and cutting emissions of volatile organic compounds (VOCs).
Since the program's inception, Performance Track members have reduced their water use by 3.5 billion gallons, conserved more than 14,000 acres of land, increased their use of recycled materials by 135,000 tons, reduced greenhouse gas emissions by more than 97,000 tons, and cut smog-causing emissions of nitrogen oxides and sulfur dioxide by 6,000 and 17,000 tons, respectively.
Performance Track Overview
In the past, environmental regulations defined the "ceiling" of environmental protection - the most that EPA expected from businesses, and the most businesses expected to do. Performance Track changes that, with regulations viewed as the "floor" and participating facilities continually improving their performance above it.
Ken Gallant, environmental performance manager at International Paper's Bucksport, Maine, mill says, "We have demonstrated that we are on a track toward continuous improvement and success in environmental performance. Joining Performance Track was another way of challenging us to continue those successes." The Bucksport mill is known for its high-quality, lightweight coated paper, which is used in 24 of the nation's 25 leading publications and catalogs, including TIME, Newsweek, Sports Illustrated, People, Good Housekeeping, Victoria's Secret, Lillian Vernon, L.L. Bean, Better Homes & Gardens, and Money
Such partnerships add a new, voluntary level of protection to the basic assurances provided by law. By offering regulatory incentives and national recognition to environmental leaders, EPA hopes to motivate others to follow and discover that what is good for the environment is also good for business.
In exchange for participating in the program, members receive public recognition from EPA, opportunities to meet and network with other leading environmental performers, and a limited range of regulatory and administrative incentives. The first Performance Track rule, published in April 2004, allows eligible Performance Track members to store hazardous waste on site an extra 180 days beyond requirements set out in the Resource Conservation and Recovery Act (RCRA). An April 2006 rule allows eligible members to reduce self-inspections to once a month under RCRA, from daily or weekly for non-members.
Participation in Performance Track also puts facilities at a lower priority for routine EPA inspections, given their strong compliance records, and EPA encourages state environmental agencies to consider this policy as well.
Performance Track members receive public recognition through photo opportunities with the EPA Administrator and such venues as case studies, promotional materials, and the program's Web site. They also may display the Performance Track logo at their facility and in facility-specific publications such as brochures and annual reports. (Like other members, the Durango-McKinley Paper Company of Prewitt, N.M., displays the logo on the homepage of its Web site.) Other benefits include information sessions with senior EPA officials, special-invitation conferences, workshops, and networks to share successful environmental practices.
EPA works to coordinate Performance Track with similar programs at the state level. For example, Virginia facilities accepted into the program can apply for membership in the Virginia Environmental Excellence Program (which offers its own benefits) at the Exemplary Environmental Enterprise level by simply submitting a letter to the Virginia Department of Environmental Quality. The Virginia program also accepts Performance Track annual reports, meaning facilities that participate in both programs can save on their reporting work.
"The public recognition and the regulatory flexibility provided by Performance Track makes our companies more attractive to investors and heightens their brand recognition," notes AF&PA's Duggan.
Indeed, another benefit of the program is that environmentally conscious investors are gravitating toward its members. Four leading socially responsible investment research and advisory firms—Calvert Group; Innovest Strategic Value Advisors; KLD Research & Analytics, Inc.; and Trucost Plc—use publicly reported Performance Track data in their research. Insofar as it denotes environmental success, Performance Track may be seen as an indicator of smart, strong leadership.
Mohawk Exceeds Goals
Mohawk Fine Papers Inc.'s Beckett Mill was accepted to Performance Track in 2005. And while it began to chart environmental success before that time, membership in the program has given the Hamilton, Ohio, facility a significant boost. "There's an esprit de corps at the plant," says environmental manager Kenneth Long. "All our people know we're involved in Performance Track, so we're always looking for ways to improve our operations."
The Beckett Mill makes whites, pastels, and deep-colored papers, used extensively in advertising, presentation folders, annual reports, greeting cards, and more. Inherent in that line of work is the production of effluent and suspended solids, mainly fibers, which entails disposal and hauling costs. The mill's first voluntary goal under Performance Track was to bolster efforts to cut these byproducts, and it set a 2008 goal of 359,187 lb, an ambitious, fivefold decrease from the 2003 baseline of more than 1.62 million lb. The mill has already surpassed that mark, producing just 343,224 lb in the latest count for Performance Track.
The mill made a second, related goal under the program: improving management of non-hazardous waste, specifically clarifier sludge. From a 2003 baseline of 4,624 tons, it has already cut production in half, down to 2,270 tons.
Most of the reductions under both goals have come from internally developed technological improvements to the mill's color treatment system, where dye is removed from effluent. This eliminates upsets to the primary clarifier, which previously reduced clarifier solids removal. Overall gains also came from analyzing all of the mill's processes down to fine details, and then looking for improvement opportunities.
Mill staff investigated point-loss sources, replaced old seals with mechanical seals, and provided training to personnel, improving operations and reducing unnecessary losses. For the first goal alone, Long cites a "conservative" estimate of $400,000 in annual cost savings. A corollary savings occurred in water use, which went down 15% as a result of seal and valve replacements, procedural changes, and other mainly small-scale fixes. Taken together, the savings from the first two Performance Track goals and water conservation add up to about $600,000 annually, according to Long.
The mill has been less successful in its third goal, but through little fault of its own. It had hoped to cut use of hypochlorite bleach to meet a Performance Track goal of reduced materials consumption. The mill uses the bleach to strip colors from "broke," internally recycled fiber, and for effluent treatment. It cut its bleach use at first, but a general increase in business and product demand offset this gain. The bleach is not a hazardous waste, Long notes, but can present a challenge for wastewater treatment plants.
As its fourth and final Performance Track goal, the mill pledged to reduce its non-transportation energy use and cut greenhouse gas emissions in the bargain. A 2003 baseline of 1.03 mm Btus was to be cut to 881,226 mm Btus by 2008. And 97,339 tonnes of carbon dioxide equivalent was to be cut to 89,231 tonnes by 2008.
"We knocked the socks off our energy goal," Long says. Plans for a flue-gas heat recovery project that would have saved energy were shelved (but may be dusted off soon), pending corporate restructuring. Meantime, the Beckett Mill simply changed its energy sources by buying 36% of its total electricity in 2005 from a wind farm. The mill then increased its wind power consumption to 50%, cutting fossil fuel consumption from conventional electricity (bought from the city of Hamilton and based largely on coal) even further. As a result, the mill's greenhouse gas emissions fell to 64,746 tonnes of carbon equivalent.
This switchover was supplemented with an aggressive energy conservation program, begun at the mill in September 2005. As with the first two goals, personnel examined operations down to an "unbelievably small scale," Long says. This led to many prosaic, albeit cumulative and valuable, changes. For example, plant employees religiously turned off machinery when not in use and turned out the lights after leaving rooms. Energy use at the plant has already dropped to 862,416 mm Btus.
By participating in Performance Track, the Beckett Mill has leveraged its marketing power. It already made many products from post-consumer recycled fibers, including Forest Stewardship Council- and Green Seal-approved products. A strong company environmental commitment and recycled fibers makes it doubly attractive to many buyers and investors. "You can make money by doing things that are good for the environment, and I don't see anything wrong with that," Long says.
Driving Environmental Excellence
At a ceremony in May 2006 marking Performance Track's fifth anniversary, EPA Administrator Stephen Johnson noted that the program's members "are at the forefront of innovation and environmental stewardship." Performance Track encourages its members to set challenging "stretch" goals for themselves rather than remain in the realm of the comfortable and known.
In working to achieve their goals, members are often forced to come up with new and innovative solutions, pushing the edge of environmental protection technology and know-how into new territory. While doing so, many of them discover that their environmental projects turn out to make solid business sense on their own terms. Performance Track facilities have saved millions of dollars in waste disposal, energy, materials, and water use costs. And just as important, they get public recognition for their efforts while establishing a more collaborative relationship with EPA.
Performance Track provides a reason for facilities to go beyond simple compliance with environmental laws and to commit to continuous improvement. It helps shift facilities' approach to environmental protection from "doing what we're required to do" to "doing all we can." EPA believes this positive approach is a valuable complement to traditional regulation, creating additional benefits for the environment while enhancing competitiveness and fostering innovation. In coming years, EPA hopes to enlist more pulp and paper facilities in the program.
Daniel J. Fiorino, Ph.D., is the director of EPA's Performance Incentives Div. and program director for Performance Track.
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