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Preventing Industrial Pollution at its Source
A Final Report of theMichigan Source Reduction Initiative


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INTRODUCTION

In the fall of 1996, the Natural Resources Defense Council (NRDC) and the Dow Chemical Company joined with two local activists-Diane Hebert and Mary Sinclair, Midland residents; and three regional environmental groups-Citizens for Alternatives to Chemical Contamination, Lone Tree Council, and the Ecology Center of Ann Arbor (Appendix I)-to reduce toxic wastes and emissions from the Dow Chemical Midland, Michigan site. The project, called the Michigan Source Reduction Initiative (MSRI), was also designed to foster broader institutional changes within Dow that would further shift the company's thinking from traditional environmental compliance to pollution prevention and further integrate health and environmental concerns into core business decisionmaking. The group relied on an expert pollution prevention assessor hired by Dow as well as a professional facilitator who assisted in the design and implementation of the project.

Dow's Midland site is home to eight of Dow's 15 global business lines. It occupies 1900 acres, employs 4200 people, and manufactures more than 500 products including pharmaceuticals, plastics, and pesticides. These products are manufactured by mixing various raw materials together and allowing them to react under very precise engineering conditions. Wastes and emissions are generated during manufacturing from: raw materials that are not totally consumed in the reaction, solvents used to dissolve the ingredients, unwanted by-products of the reactions designed to manufacture the products, and products themselves which do not meet specifications. The most toxic of these wastes and emissions are required by Federal law to be reported annually to the public in the Toxic Release Inventory, or TRI. (Table 1)

At the start of the project in 1996, the Dow Midland facility was Michigan's eighth largest emitter of TRI releases and the sixth largest generator of TRI wastes. Its total TRI emissions had been approximately level for the prior 5 years, and its TRI wastes (except HCl) had risen slightly. Dow Midland was a particularly significant source of numerous chemicals of concern to this initiative, as Michigan's top ranked emitter of acrylonitrile, formaldehyde, butadiene, dichlorophenol, tetrachloroethylene, vinyl chloride, and six other chemicals. (Table 2) It was a nationally significant source of many compounds of concern as well, contributing more than 10 percent of the nation's loading of 2,4-D, dichlorophenol, trichlorophenol, vinylidene chloride, and tetrachlorethane. (Table 2)

The participants in the project had diverse perspectives and motivations for participating in MSRI. Dow Chemical is a global company that develops and manufactures a portfolio of chemicals, plastics, and agricultural products. It began its operations at the Midland, Michigan site, where it also maintains its corporate headquarters. Dow had participated with the Natural Resources Defense Council (NRDC) on a collaborative pilot pollution prevention project in LaPorte, Texas designed to better understand pollution prevention opportunities and barriers to their implementation. The company was motivated to participate in this project to find good pollution prevention opportunities which it could implement at Midland and to better understand outside views on its operations and environmental affairs.

NRDC is a national non-profit organization of scientists, lawyers and environmental specialists dedicated to protecting public health and the environment. NRDC had a brief history of involvement with Dow from the Dow LaPorte project. It had also debated Dow and its trade associations extensively on a wide variety of Federal environmental and public health regulatory and legislative initiatives for more than two decades. NRDC was motivated to undertake this project to learn about the extent to which profitable pollution prevention projects could meaningfully reduce the nation's pollution loads and to better understand barriers that exist within companies that preclude greater reliance on this technique.

The local activists had a long (more than 20 years) history of interaction with Dow at Midland that consisted of filing lawsuits against the plant, voicing objections to various Dow proposals at public hearings and permits proceedings, and educating the public and the press about their views on problems at the company. Their interest in the project stemmed from their desire to shut down waste treatment facilities at the site as well as their concerns about dioxin, plant wastes, and emissions. They also had profound reservations about some of the products that Dow manufactures. Because this project was destined to be a finite, short-term initiative lasting two years, the activists had a strong stake in participating to ensure that follow-up to the project would take place.



THE MSRI PROJECT

The specific goals of the 30-month MSRI project were:

  • To reduce waste and emissions of 26 priority chemicals generated at Dow Midland by 35 percent by April 30,1999, using only pollution prevention techniques;

  • To foster institutional changes throughout Dow that would further shift the corporation's thinking from regulatory compliance to pollution prevention and further integrate health and environmental concerns into core business planning and decision making;

  • To develop and rely upon a participatory process that leads to changes in business decision making throughout Dow and that provides an opportunity for the citizen participants to gain an understanding of the company's business decision-making process; and

  • To monitor waste reduction and pollution prevention accomplishments and provide accountability of the project results to the general public.

The list of 26 priority chemicals is provided in Table 3. MSRI was committed to achieving its reductions using only pollution prevention techniques, defined as in Figure 1.

All parties entered the MSRI project skeptical that it would reach its reduction goals. Dow businesses doubted they would uncover good opportunities. Activists and environmental participants were concerned that Dow would not implement the opportunities the project found. Much of the skepticism on both sides derived from the fact that participants did not know of a single example of successful similar work.

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