PrintOctober 10, 2009
Never Cleaner
"The environment has never been cleaner in my lifetime than now".... is the way I begin a part of my guest lecture to the business classes at a local college here in Pennsylvania. The look on the faces of the products of our public school educational system is one of disbelief.
As a nearby, familiar example, I try to relate to the future of America students the conditions when Pittsburgh was truly the Steel City. Coke plants, tar plants, steel mills, glass manufacturers, and ancillary other heavy industry lined the banks of the rivers, producing the raw products of the country's industrial revolution.
Donora, Pennsylvania, the location of one of the worst air pollution incidents in our country's history lies just down-river from Pittsburgh. In October 1948, 20 people died and over 7,000 were hospitalized or became ill as a result of an air inversion that trapped the air emissions from the Donora Zinc Works and other nearby industrial operations in this small town's valley (Donora Smog). Industrial wastewater discharges were pumped into any nearby stream or river to severely test the buffering capacity of the natural system to absorb such a flux of pollutants. Wastes were disposed in a manner that simply got them out of the way from the production area so as not to be an impediment to work. This was the state of the environment up until even the 1970s.
Recognizing these issues, and the work of addressing the obvious environmental concerns, President Richard Nixon began and established the groundwork for many of the alphabet soup of major environmental laws: National Environmental Policy Act (NEPA), Clean Water Act (CWA), Clean Air Act (CAA), Resource Conservation and Recovery Act (RCRA), etc. In addition, he established the U.S. Environmental Protection Agency to oversee these programs. The results of these programs had, and still have, tremendous immediate and long-lasting return on the efforts.
"The problem," I tell the students, "is similar to the experience when watching the Steelers play on Sunday with your wife or girlfriend, while eating potato chips and French onion dip. At first, each chip is generously covered with dip, a good return on each effort of chip dipping, you can even do it with peripheral vision and focus on the game. As the dip volume decreases, some adjustments have to be made; additional efforts, focus and attention are expended. Initially, the extra effort is simply turning the dip tub to a more favorable angle for your chip dipping success, after all, it is in your girlfriend's or wife's best health interest, almost an altruistic act on your behalf.
"Then additional effort is expended to actually retrieve the dip tub and closely focus on ferreting out sufficient dip for each chip way down in the bottom crease or under the lip of the lid. This is ultimately followed by the effort of the finger swipe and mouth chip/dip mixing. It is at this point that some reasonable person needs to stop the process. There is no longer a sufficient benefit to continuing efforts to try to ingest the last dip residue ... don't lick that dip tub ... is the admonishment from your better half."
This is the analogy to the history and current story of our environmental regulations. Where once contamination was emitted almost freely into the environment, now, it is not so extreme. We continue to expend more and more efforts to seek those last molecules of contamination to satisfy our environmental appetite for cleaner.
Pennsylvania passed a law that disallows diesel engines to idle for more than 5 minutes in an hour. Think about that as a truck driver working your way through traffic to deliver your goods from point A to point B.
A tar plant spills about a gallon or so of tar on the ground in its facility and spends numerous man-hours and costs to notify the national emergency response center, document the spill event, clean up the material and dispose of it, and submit follow-up reports to the regulatory agencies. At the same time, the entire road through town outside the gates of the tar plant is being paved with the same material.
A former industrial site is required by the regulators to be cleaned up by a past owner to a regulatory-mandated human health risk assessment level of 1 x 10-6. That is as if just one person in one million people may (not will, but may) be harmed if they were to accidentally ingest a certain amount of contaminated soil from the site every day for seventy years.
Simply because a facility manufactures a certain product, it falls into a category in which there is a mandate to spend capital to install, monitor, operate and maintain a natural gas-fired thermal oxidizer (incinerator) to destroy any air emissions from tanks containing this product. Capital costs total hundreds of thousands of dollars initially and ultimately millions of dollars over time. The amount of air emission "pollutants" from the product storage tanks destroyed is trivial in comparison to the excessive amount of air emission pollutants caused by burning the natural gas to operate the thermal oxidizer equipment.
This is the current story of our environmental regulations. It is well past time for reasonable people to say to the politicians and government regulators: "Don't lick that dip tub."
