Principle in Practice:
Smurfit-Stone's environmental policy places authority and responsibility for compliance with environmental regulations with the manufacturing facilities, where the work is done. We maintain a corporate staff of highly trained and experienced technical professionals who assist the manufacturing facilities with their compliance efforts.
Every month, senior company officials and staff receive a comprehensive report on currently open environmental issues at all company manufacturing facilities. In addition, each facility prepares a comprehensive quarterly report on all environmentally significant events, including the nature of the event and its resolution.
Senior financial staff members are advised quarterly of the status of all identified environmental liabilities, so that adequate financial reserves can be established for these liabilities. Included are such items as Superfund site cleanup obligations, voluntary remediation of contamination, contractual liabilities associated with acquisitions or divestitures, and enforcement actions by regulatory authorities.
An annual report is presented to the Board of Directors in which the status of all aspects of the company's environmental program is reviewed.
One of the keystones of Smurfit-Stone's overall environmental effort is the auditing program. All company facilities are audited for environmental compliance by internal teams made up of corporate staff, operating unit staff, and legal counsel. Audit team members have been fully trained in audit techniques, as well as in regulatory requirements. Audit frequency varies between every two years and every four years, depending on the size and complexity of each facility.
At the conclusion of every audit, the audited facility develops a comprehensive plan and schedule to address any audit findings. This plan, when approved, is monitored by the corporate audit staff until all elements of the plan are satisfactorily completed.
The audit program serves to complement the training program because auditors share best management practices between facilities by recommending improved practices as part of their findings. Audit findings are also analyzed and used to guide the development of training materials, emphasizing those areas where audit results have indicated a need for greater emphasis.
In 1999 and 2000, Smurfit-Stone spent approximately $204 million on environmental improvements to nine of our mills. These improvements allow these mills to meet the requirements of federal environmental regulations known as the Cluster Rule, a package of air and water regulations that exclusively affects paper mills. The spending will result in improvement to SSCC's already high environmental performance and, when fully implemented in 2001, will make possible the production of Elemental Chlorine Free (ECF) bleached pulp at all US mills where this product is manufactured.
SSCC has a system in place to ensure tracking, reporting, and timely resolution of environmental incidents. The system requires that all manufacturing facilities complete and submit to corporate staff an environmental incident report for any spill or release, deviation from permit requirements, notices of violations, warning letters or information requests from government agencies, agency inspections, lawsuits served, citizen or community complaints, and any other significant environmental matters. These quarterly reports also serve to record environmental achievements, such as pollution prevention, awards received, and innovative process improvements.
In 1999, Smurfit-Stone paid civil penalties of approximately $114,000. The company has corrected the problems leading to these penalties and is committed to complying with all regulatory guidelines.
Toxic Release Inventory Releases
The Toxic Release Inventory (TRI), created by Congress under the Superfund Law, requires industries to report the amount of the emissions and discharges of certain compounds to the EPA. Since 1994/1995, Smurfit-Stone has reduced TRI releases by roughly 25 percent through process modification and chemical substitution. We continue to seek out opportunities for further reduction.
Smurfit-Stone regularly monitors the discharge of Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), and the volume of effluent flow. (BOD is the amount of oxygen needed to break down the organic material in mill wastewater. TSS is the amount of fine particulate matter, such as dirt, fiber or sand, in mill wastewater.) The effluent flow discharged by our mills has been reduced by about 10 percent since 1994/1995. Our treatment systems remove 90 to 95 percent of the BOD and TSS from our mill wastewater prior to discharge. Since 1994/1995, Smurfit-Stone has reduced BOD discharges, per ton of paper produced, by more than 50 percent and TSS discharges per ton of paper produced by more than 20 percent.
SSCC regularly monitors the emissions of particulate matter, sulfur dioxide, oxides of nitrogen, volatile organic compounds, hazardous air pollutants, and reduced sulfur compounds. Since 1994/1995, we have reduced the emissions of all of these pollutants as shown on the accompanying chart. Particulate emissions have been reduced by 40 percent, and the others were all reduced by 10-to-30 percent.