&EPA
          United States
          Environmental Protection
          Agency
             Office of Solid Waste and
             Emergency Response
             (5305W)
EPA/530-R-98-015
December 1998
www.epa.gov/osw
Pollution Prevention
During Permitting, Inspection
and Enforcement

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Pollution Prevention Solutions During Permitting,
            Inspection and Enforcement
             U.S. Environmental Protection Agency
          Office of Solid Waste and Emergency Response
                   Washington, DC 20460

                          and

                        Region 4
          Air, Pesticides, and Toxics Management Division
                     Atlanta, GA 30365
                      December 1998

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                          Disclaimer

This document is a field handbook that catalogues information
obtained from EPA Regions and states on innovative pollution
prevention concepts and approaches used during environmental
permitting, inspection, and enforcement activities. The discussions,
descriptions, and examples contained in this handbook are not
intended to set, interpret, displace, or otherwise alter any EPA or
state regulation, policy, or guidance, nor should the information  be
construed to do so.

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Table of Contents
Section                                                                         Page

             Acknowledgments	v

             Executive Summary	ES-1

    1.0       Pollution Prevention Basics	1-1
             1.1  What Is Pollution Prevention 	1-1
             1.2  What Are the Benefits of Pollution Prevention in
                  Permitting and Compliance?	1-3
             1.3  Is Pollution Prevention Required  	1-4

    2.0       Pollution Prevention in the Permitting Process	2-1
             2.1  What Do I Need to Know?	2-1
             2.2  Examples of Approaches  	2-8
                  2.2.1  Prepermitting Interviews and Information Distribution	2-9
                  2.2.2  Permit Avoidance through Pollution Prevention 	2-12
                  2.2.3  Pollution Prevention Preapproval—Avoidance of Permit
                         Modifications  	2-14
                  2.2.4  Pollution Prevention Planning  	2-18
                  2.2.5  Explicit Pollution Prevention Conditions in Permits	2-29
                  2.2.6  Pollution Prevention through Permit Process Incentives 	2-35
                  2.2.7  Pollution Prevention through Whole-Facility Permits	2-36

    3.0       Promoting Pollution Prevention through Inspection Activities	3-1
             3.1  What Do INeed to Know?	3-1
             3.2  Examples of Approaches  	3-5
                  3.2.1  Distribution of Pollution Prevention Literature 	3-5
                  3.2.2  Review of RCRA Waste Minimization Program-in-Place
                         Certifications	3-7
                  3.2.3  Joint Inspections by Compliance and Pollution
                         Prevention Staff  	3-9
                                                                                    iu

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                                                                      Table of Contents
Section
Page
                  3.2.4  Providing Pollution Prevention Technical Information and
                         Recommendations during Inspections  	3-11
                  3.2.5  Referral to State Pollution Prevention Technical Assistance
                         and/or Successful Companies	3-14
                  3.2.6  Multimedia Inspections	3-16
                  3.2.7  Compliance Assistance Linked to Inspections and Pollution
                         Prevention	3-19
                  3.2.8  Participation/Reward/Sticker Programs 	3-22

   4.0        Incorporating Pollution Prevention into Enforcement Activities  	4-1
              4.1  WhatDo INeedto Know?	4-2
              4.2  Examples of Approaches 	4-8
                  4.2.1  Promotion of Pollution Prevention Supplemental Environmental
                         Projects	4-9
                  4.2.2  Examples of Pollution Prevention Measures in Injunctive
                         Relief	4-16

Appendix

    A         Pollution Prevention Information Resources	  A-1
                                                                                      IV

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Acknowledgments
The Project Team wishes to thank the many persons who provided information to complete this
handbook. Most of your names are listed in the individual project descriptions. Many others
contributed, and your help is greatly appreciated.

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Executive Summary
Does  It Make  Sense to Invest Time and Money in
Pollution Prevention?
In 1995, the nation's largest industrial users of
toxic chemicals released 2.2 billion pounds of
toxic chemicals into the environment (U.S.
EPA, 1995 Toxic Release Inventory) and
spent billions of dollars managing pollution
control technology systems to prevent that
number from being higher. If one were to add
in the purchase price of the raw materials that
eventually escaped as 2.2 billion pounds of
chemical waste (instead of product), the price
tag grows even larger. Many companies have
made progress reducing waste generation,
improving compliance, and increasing profits.
However, these figures suggest there is  still a
long way to go. Why are these figures so high?

There are many economic, technological, and
political reasons that make environmental
compliance costs so high—most government
agencies and companies are familiar with
these. The purpose of this manual is not to
review  all of those reasons, but to focus on
how to get to the root of the problem. How-
ever, one reason that does deserve discussion
is the way our environmental compliance
system is designed. Compliance standards
have historically been based on the perfor-
mance of costly end-of-pipe pollution con-
trols. Consequently, government permitting,
inspection, and enforcement procedures often
focus on achieving compliance through end-
of-pipe control methods, which in turn causes
companies to install costly end-of-pipe con-
trols rather than look for more cost-effective
site-specific solutions that may reduce the
amount of waste generated, managed, and
released.

This handbook summarizes a menu of
approaches developed by environmental
agencies and companies working together to
incorporate cost-effective pollution prevention
solutions into permitting, inspection, and
enforcement. Many of the approaches are
designed to: (1) explore pollution prevention
solutions that may reduce the amount of pollu-
tion generated, (2) reduce the cost of environ-
mental controls, and (3) meet or go beyond
environmental standards.

This Executive Summary provides a "quick
glance" at these approaches. Section 1 defines
pollution prevention and waste minimization
and summarizes EPA policy. Sections 2
through 4 provide examples of approaches
used to incorporate pollution prevention in
permitting, inspection, and enforcement
activities under the air, water, and RCRA
programs. Appendix A provides a list of
pollution prevention resources.
                                                                              ES-1

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                                                                      Executive Summary
This quick-glance digest summarizes 17
categories of examples of the use of pollution
prevention during permitting, inspection, and
enforcement activities in several dozen states
and EPA Regional offices. These categories
are summarized in Tables ES-1, ES-2, and
ES-3, corresponding to permitting, inspection,
and enforcement, respectively.
            Table ES-1. Pollution Prevention During Permitting Activities
                Prepermitting Interviews and Information Distribution

           Permit Application Worksheet and Prepermitting Review
           Massachusetts Department of Environmental Protection
                                    Air
 A permit application worksheet queries the permittee on pollution prevention and provides basic
 information that would be helpful to permit writers when reviewing the permit to determine if source
 reduction opportunities exist at the facility. The worksheet lists available toxic use reduction
 techniques available and suggests the permit applicant talk to the DEP project manager; it also refers
 the applicant to the Office of Technical Assistance.
           Advertisement in Cover Letter Accompanying Permit
           Ohio Environmental Protection Agency
                                    Air
  When Ohio EPA processes an air permit, they include a cover letter urging the permittee to
  investigate pollution prevention and energy conservation.
           Advertisement in Permit Application
           Michigan Department of Environmental Quality
                                  Water
  The Michigan DEQ includes an "advertisement" that encourages pollution prevention in its NPDES
  permit applications.
           Information Packages for Permit Applicants
           Connecticut Department of Environmental Programs
                              All Media
  The Connecticut DEP sends pollution prevention promotional and technical assistance materials to all
  companies that apply for permits.
                    Permit Avoidance through Pollution Prevention

            Best Management Practices for Vehicle and Equipment Wash              Water
            Water Discharges
            Washington Department of Ecology

  As part of an educational campaign, Washington's Department of Ecology (DOE) developed a best
  management practices manual for preventing pollution from vehicle wash water discharges. If the best
  management practices are followed, most companies are able to eliminate the need for a discharge
  permit.

                                                                               (continued)
                                                                                     ES-2

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                                                                      Executive Summary
                               Table ES-1 (continued)
         Avoiding NPDES Discharge Permits through Pollution                    Water
         Prevention                                                          	
         Washington Department of Ecology

Washington's DOE uses permit language to require companies to determine whether it is feasible to
reach zero discharge of wastewater through pollution prevention. Several companies have reached
zero discharge and have retired their NPDES permits.
                                  Permit Flexibility

          Incorporating Preapproval of Pollution Prevention-Based                    ~Air~
          Changes Using a General Permit Condition                               	
          Massachusetts Department of Environmental Protection

The Massachusetts DEP uses general condition air permits to preapprove process or formulation
changes that reduce toxic chemical use, volatile organic compound (VOC) emissions, or hazardous
waste generation.
          Title V Permit Containing Preapproved Changes
          Oregon Department of Environmental Quality
Air
Oregon's DEQ issued Intel a permit that preapproves process changes that reduce VOC emissions
without triggering Minor New Source Review if the process changes do not eclipse a VOC emissions
cap.
          Permit Flexibility
          New Jersey Department of Environmental Protection
Air
Schering-Plough Corporation received a whole-facility permit from NJDEP that allowed Schering to
make certain process changes without going through preconstruction review. Such changes are
preapproved if they do not increase the permitted concentration or rate of emission of any air
contaminant for the entire facility or for a single production process, and the change is consistent with
the facility's pollution prevention plan.
          Flexible VOC Emissions Cap Permit
          Minnesota Pollution Control Agency
Air
The Minnesota Pollution Control Agency (PCA) issued 3M a permit that locked facility-wide VOC
emissions at 3M's previously voluntary level, improved monitoring at the facility, and eliminated the
need for the permit amendment process for most operational changes.

                                                                             (continued)
                                                                                    ES-3

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                                                                      Executive Summary
                               Table ES-1 (continued)
          Using Pollution Prevention to Change Status from Major Source
          to Synthetic Minor
          U.S. Environmental Protection Agency
Air
Facilities seeking to avoid a Title V permit could use pollution prevention measures to restrict the type
or amount of air polluting material stored, combusted, or processed to become a synthetic minor. EPA
has seen the number of major air sources drop from 40,000 to 25,000 nationwide and a concomitant
increase in the number of synthetic minors.
                            Pollution Prevention Planning

          Title V Permits Requiring Development of Pollution Prevention
          Plan (two examples)
          Oregon Department of Environmental Quality

The Oregon DEQ issued Intel a Title V permit that requires development of a pollution prevention plan
after the permit is issued. The permit lists several elements that must be described in the plan,
including pollution prevention goals, commitment, and progress measurement. The Oregon DEQ
issued Composite Technologies, Inc., an air contaminant discharge permit that requires the
subsequent development and eventual implementation of a pollution prevention plan. The plan must
include an analysis of potential changes in process, raw material, and final product that could reduce
pollution.
          Pollution Prevention Plan as Part of the Permit Application
          Process
          New Jersey Department of Environmental Protection
 Air
Schering-Plough Corporation was required to develop a pollution prevention plan as part of the
application process for a whole-facility permit. The plan was used in development of the permit, but
was not included as an enforceable part of the permit. The plan was, however, a major factor in
Schering's initiating two major pollution prevention projects.

           Granting POTWs the Authority to Require Their Significant                Water
           Industrial Users (SlUs) to Develop and Implement Waste                	
           Reduction Plans
           North Carolina Department of Environment, Health, and Natural
           Resources
 North Carolina changed its administrative code to give POTWs the authority to require their SlUs to
 develop a waste reduction plan and implement waste reduction technologies. Some North Carolina
 POTWs now require pollution prevention plans, while others only encourage their SlUs to develop
 plans—both methods have had great success in promoting pollution prevention.

                                                                               (continued)
                                                                                      ES-4

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                                                                      Executive Summary
                               Table ES-1 (continued)
          Permit Allowing Termination with Implementation of Best                 Water
          Management Practices                                              	
          Washington Department of Ecology

The Washington DOE allows a permittee to retire the permit if the permittee uses best management
practices including pollution prevention techniques.
          Model Wastewater and Storm Water Permit Language
          Washington Department of Ecology
                                                                               Water
This model permit requires the permittee to develop and implement a best management
practices/pollution prevention (BMP3) plan for wastewater and storm water discharges within 6
months of the effective date of the permit. The permittee must also conduct a waste minimization
assessment (WMA) to determine the actions that can be taken to reduce waste loadings and chemical
losses to all wastewater and storm water. The WMA must be implemented as soon as practical after
development.
                                                                               RCRA
          Submission of Waste Minimization Plans as a RCRA Permit
          Requirement
          EPA Regions 2, 5, and 7
          Ohio Environmental Protection Agency
          Arizona Department of Environmental Quality

Both Region 2 and Ohio require waste minimization plans to verify that companies have a waste
minimization program in place (required by RCRA). Arizona, which also requires submission of a
hazardous waste reduction plan, cites both the requirement for a waste minimization program in place
and the omnibus permitting provision in its RCRA permits.

EPA Region 5 requires a Hazardous Waste Reduction Plan (HWRP) to fulfill the requirement for a
waste minimization program in place and an annual Waste Reduction Implementation Report (WRIR)
to measure and summarize actual reductions and compare accomplishments to HWRP goals. In
contrast to Region 2, most states in Region 5 do not have corresponding state pollution prevention
facility planning requirements.

Region 7 requires permittees to submit an annual certification and report that documents compliance
with the waste minimization program in-place certification.
          Require Written Description of Plans to Reduce Pollution
          North Carolina Department of Environment, Health, and Natural
          Resources
                                                                         RCRA, Air,
                                                                            Water
North Carolina uses authority contained in its 1989 Hazardous Waste Management Act to require
water quality or air quality permit holders or applicants for a new permit or permit modification to
submit a written description of current and projected plans to reduce the discharge of waste and
pollutants or to reduce the emissions of air contaminants under such a permit by reduction or
recycling. The written description must accompany the payment of the annual permit fee or
application for a new or modified permit. Waste generation fees are to be adjusted to encourage
waste reduction.

                                                                              (continued)
                                                                                     ES-5

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                                                                      Executive Summary
                               Table ES-1 (continued)
          Require/Encourage Commercial TSDFs to Work with                     RCRA
          Generators to Reduce Waste                                         	
          California Department of Toxic Substances Control

California requires Treatment, Storage, and Disposal Facilities (TSDFs) to work with their generators
to reduce waste under California's Health and Safety Code, Title 22. The permit for the Kettleman
Hills Facility requires "a detailed description of any programs the permittee may have to assist
generators of hazardous waste in reducing the volume or quantity and toxicity of wastes they
produce." In addition, the permit requires Kettleman to provide information on customers utilizing
Kettleman's services to the state.
          Coordination of TSDF Permit Provisions and State Waste                 RCRA
          Minimization Facility Planning Requirements                          	
          California Department of Toxic Substances Control

California law SB14 requires certain permittees and generators to develop waste minimization plans
that are intended to be reviewed by permit writers during permitting activities.
RCRA,
          Include Pollution Prevention Incentives in the MACT Rule for
          Hazardous Waste Incinerators, Cement Kilns, and Lightweight
          Aggregate Kilns
          U.S. Environmental Protection Agency

 EPA is incorporating pollution prevention/waste minimization incentives in its maximum achievable
 control technology (MACT) combustion rule for hazardous waste incinerators and hazardous waste-
 burning cement kilns and lightweight aggregate kilns. The pollution prevention incentives encourage
 facilities that generate and incinerate hazardous wastes on site to consider pollution prevention
 alternatives as a means of meeting the MACT standards for hazardous waste combustion units.
                 Pollution Prevention Conditions as Part of a Permit

          Temporary Increase in Emissions in Exchange for Long-Term
          Pollution Prevention                                                    	
          Massachusetts Department of Environmental Protection

 The Massachusetts DEP agreed to a temporary increase in a company's VOC emissions to allow for
 expanded production in exchange for a pollution prevention permit condition that will lead to greater
 long-term reductions in facility-wide emissions.

                                                                               (continued)
                                                                                      ES-6

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                                                                      Executive Summary
                               Table ES-1 (continued)
                                                                                   Air
          Pollution Prevention Implementation in Exchange for Reduced
          Monitoring and Recordkeeping
          North Carolina Department of Environment, Health, and Natural
          Resources

North Carolina reasonably achievable control technology (RACT) rules allow use of a low-VOC
emission "compliant coating" as an alternative to a permit-prescribed, numerical daily emission limit.
Consequently, a company's required recordkeeping is reduced from a daily calculation of emissions
to merely certifying use of a compliant low-VOC emission coating.

          Permit Requires Evaluation of Substitute Material for BACT                   ~Ajr~
          Standard Determination                                                 	
          Massachusetts Department of Environmental Protection

The Massachusetts DEP issued Dow Jones & Company a permit that is conditioned on testing and
installing a low-VOC cleaning solution to meet the best available control technology (BACT) standard.
          Guidance for Incorporating Pollution Prevention into Permits
          Massachusetts Office of Technical Assistance
                                                                                  Air
The Massachusetts Office of Technical Assistance (OTA) prepared training materials to guide permit
writers in incorporating pollution prevention in permits. The guidance lists the domains in which pollu-
tion prevention measures may be considered for incorporation.
                                                                                Water
          Three-Tier Storm Water Permit System Using Less Record-
          keeping, Monitoring, and Inspections as Incentives
          Wisconsin Department of Natural Resources

Wisconsin's Department of Natural Resources (DNR) uses a three-tier storm water permit system to
promote pollution prevention. A company can move to a higher tier by using pollution prevention; the
company's permit will require reduced recordkeeping, monitoring, and inspections by moving up a
tier.
                                                                                Water
          Pollution Prevention Requirements in Significant Industrial
          User Permits
          Palo Alto Water Quality Control Plant

Palo Alto developed a set of pollution prevention measures called "Reasonable Control Measures"
(RCMs) to implement in significant industrial user (SIU) permits to meet the copper discharge limit in
its NPDES permit. Metal finishers had the choice of amending their permits to require implementation
of the RCMs or developing pollution prevention projects on their own to control copper discharges.

                                                                              (continued)
                                                                                     ES-7

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                                                                      Executive Summary
                               Table ES-1  (continued)
          Require Licenses/Permits for Generators with Pollution                   RCRA
          Prevention Provisions                                               	
          Broward County and Dade County, Florida

Broward County Department of Natural Resources Protection is developing industry-specific pollution
prevention best management practices (BMPs) in industrial/commercial sectors identified as pollution
risks. These specific pollution prevention BMPs are incorporated in licenses for those sectors.

Dade County's Department of Environmental Resources Management (DERM) requires annual
operating permits for all polluters. Industry-specific multimedia pollution prevention BMPs are included
as attachments to the permits; the BMPs are generally treated as recommendations to the businesses
rather than as enforceable elements of the permits.
              Pollution Prevention through Permit Process Incentives

          Pollution Prevention Commitment in Exchange for Expedited
          Permit
          Michigan Department of Environmental Quality
   Air
Michigan's Clean Corporate Citizen program allows companies that have demonstrated environ-
mental stewardship, including a commitment to pollution prevention, to benefit from expedited permit
review, waiver of preconstruction permit requirements, and a facility-wide emissions cap.
          Use of Permit Fees as an Incentive
          Washington Department of Ecology
   Air
 Permit fees are set to encourage reduction in emission rates using pollution prevention methods.
                Pollution Prevention through Whole-Facility Permits

          Multimedia Pollution Prevention Permitting Pilot Project
          New Jersey Department of Environmental Protection
RCRA
 New Jersey's voluntary pilot project for multimedia whole-facility permits for 18 companies is based on
 developing a pollution prevention plan as a baseline requirement in permit development. The first
 draft permit was completed in the fall of 1994, consolidating multiple air and water requirements into a
 single permit. According to NJDEP staff, basing the permit on a multimedia pollution prevention plan
 was the most important factor in preventing the resulting permit from simply being a compilation of
 existing requirements.

                                                                              (continued)
                                                                                     ES-8

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                                                                      Executive Summary
                               Table ES-1 (continued)
 32
Multimedia Permitting Pilot Project
Delaware Department of Natural Resources and Environmental
Control
RCRA
In November of 1992, DNREC formed an internal multimedia permitting focus group to develop and
issue a multimedia permit which incorporates a pollution prevention approach. DNREC's program
examined a pilot facility on a process-by-process basis rather than looking at each environmental
media separately. DNREC considered potential cross-media impacts and opportunities to incorporate
operational flexibility into the multimedia permit. Although extremely successful in many aspects, a
multimedia permit was never issued to the pilot facility.
                                                                                    ES-9

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                                                                       Executive Summary
         Table ES-2. Pollution Prevention During the inspection Process

                   Distribution of Pollution Prevention Literature
          Distribution of Fact Sheets and Brochures
          Alaska Department of Environmental Conservation
    All Media
Alaska's inspectors are required to distribute pollution prevention literature during the inspection,
including fact sheets or brochures prepared by the Pollution Prevention Office. Facilities make their
own decisions about pollution prevention strategies.
          Pollution Prevention Survey during Inspection
          Connecticut Department of Environmental Protection
    All Media
In addition to distributing a booklet on pollution prevention options and fact sheets for specific
industries, inspectors conduct a facility pollution prevention survey. Inspectors also ask facilities
pollution prevention questions.
       Review of RCRA Waste Minimization Program-in-Place Certifications

          Audit Program to Evaluate Waste Minimization Programs in               RCRA
          Place
          EPA Region 2
 EPA Region 2 started a RCRA inspection initiative in 1995 that assesses waste minimization efforts at
 RCRA large quantity generators (LQGs) that handle ozone depleting chemicals and generators that
 send hazardous waste to boilers and industrial furnaces. Forty audits were scheduled during 1995.
 The pollution prevention/waste minimization audit protocol is more extensive than the standard RCRA
 inspectors' protocol.
           Pollution Prevention Program Review of Facility Waste
           Minimization Plans
           Mississippi Technical Assistance Program
RCRA, EPCRA
 One of the primary objectives of Mississippi's pollution prevention hazardous waste program is to
 ensure that facilities have a waste minimization plan that meets the requirements of the Mississippi
 Multimedia Pollution Prevention Act of 1990. This law requires hazardous waste generators and TRI-
 reporting facilities to develop a waste minimization plan and to file annual progress reports. Inspectors
 visit the facility, review the waste minimization plan, and discuss the plan with the facility personnel.
 After the site visit, the inspector sends the facility a letter either approving the plan or identifying
 deficiencies and specifying a date by which the plan should be revised.
                                                                                (continued)
                                                                                      ES-10

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                                                                       Executive Summary
                                Table ES-2 (continued)
         Joint Inspections by Compliance and Pollution Prevention Staff
          Joint Inspections Process
          Washington Department of Ecology
                                                                                RCRA
The Southwest Regional Office in Washington conducts joint inspections with toxic reduction technical
assistance specialists and RCRA inspectors. Team members clarify their individual roles as
compliance inspectors and as pollution prevention technical assistance specialists. DOE policy
requires that inspectors  not use information gathered during the joint pollution prevention inspection
for enforcement purposes unless a substantial threat to public health and the environment is
observed.
                                                                                RCRA
          Hazardous Waste/Pollution Prevention Joint Inspections-
          Assistance Project
          Delaware Department of Natural Resources and Environmental
          Control

DNREC's Hazardous Waste and Pollution Prevention Programs experimented with three successful
approaches to integrate pollution prevention assistance into compliance inspections. The approaches
included: (1) joint site visits including hazardous waste inspection and pollution prevention staff; (2)
inspector-only visits with inspectors referring facilities to the pollution prevention program; and (3)
inspector-only visits with inspectors conducting a compliance inspection and providing pollution
prevention assistance.
          Joint RCRA/Pollution Prevention Inspections
          Ohio Environmental Protection Agency
                                                                           All Media
Ohio EPA pollution prevention staff sometimes accompany hazardous waste inspectors on
information visits. More frequently, pollution prevention staff provide information and technical
assistance to inspectors and facilities on pollution prevention options that could return the facility to
compliance and/or eliminate waste generation.
             Providing Pollution Prevention Technical Information and
                       Recommendations during Inspections
          Compliance Inspectors' Varying Activities
          Ohio Environmental Protection Agency
                                                                           All Media
Ohio EPA inspectors are encouraged (but not required) by management to actively promote pollution
prevention. Inspectors may distribute pollution prevention literature and/or refer facilities to the
technical assistance staff. Some inspectors work with the facility to identify pollution prevention
opportunities. Some note these opportunities in standard inspection followup letters to facilities.

                                                                              (continued)
                                                                                    ES-11

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                                                                       Executive Summary
                                Table ES-2 (continued)
          Hazardous Waste Management Division Inspectors
          San Diego County, California
    RCRA
Inspectors are asked to help facilities spot pollution prevention opportunities. Time constraints often
limit the degree to which pollution prevention is incorporated in inspections.
          Public Health Services Inspections
          Orange County, California
All Media
Inspectors often discuss pollution prevention during the initial visit. If a company has major
compliance problems that require more immediate attention, the inspector may schedule a second
visit to explore pollution prevention concepts. At a minimum, inspectors distribute pollution prevention
information or refer the business to the pollution prevention staff. Experienced inspectors ask in-depth
questions about pollutants generated during each step in the manufacturing process.
          Viewing Companies as Clients
          Delaware Department of Natural Resources and Environmental
          Control
All Media
During compliance inspections, inspectors discuss pollution prevention strategies and practices.
There is, however, no written guidance or policy on how to incorporate pollution prevention into the
inspection. Most inspectors rely on their own experience and knowledge. Compliance inspectors
distribute industry-specific pollution prevention handouts prepared by the Delaware Hazardous Waste
Management Division. If, however, inspectors encounter a question or issue that exceeds their level
of expertise, the inspectors refer the business owner to Delaware's pollution prevention staff.
            Referral to State Pollution Prevention Technical Assistance
                            and/or Successful Companies
          Mississippi's Technical Assistance Program (MISSTAP)
          [Agency Name]
All Media
RCRA inspectors often refer facilities to the Mississippi Technical Assistance Program (MISSTAP) for
pollution prevention assistance for compliance assistance, or as part of penalty negotiations.
MISSTAP offers assistance to the facility in preparing a waste minimization plan that meets or
exceeds the minimum requirements of the Mississippi Multimedia Pollution Prevention Act.
           Permanent Pollution Prevention Program
           Tennessee Natural Resources and Conservation Commission
 All Media
TNRCC's Permanent Pollution Prevention Program staff work with regional inspectors to identify
companies that could benefit from pollution prevention technical assistance. These companies are
invited to training seminars and offered site assistance.

                                                                               (continued)
                                                                                     ES-12

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                                                                     Executive Summary
                               Table ES-2 (continued)
                                                                          All Media
                               Multimedia Inspections

          Comprehensive Reorganization/Conversion of All Inspections
          to Multimedia Basis                                           	
          Massachusetts Department of Environmental Protection

The Massachusetts DEP operates a statewide, pollution prevention-based approach to compliance
and enforcement called Waste Prevention Facility-wide Inspections to Reduce Sources of Toxics
(FIRST). All environmental inspections are pollution prevention-based, multimedia, and facility-wide,
with a strong emphasis on source reduction and toxic use reduction to return to compliance.
          Multimedia Pollution Prevention-Based Inspections of Largest
          Generators
          New York Department of Environmental Control
                                                                          All Media
The New York Department of Environmental Control's (DEC'S) multimedia pollution prevention
program focuses on the 400 facilities responsible for 95% of New York's waste and/or TRI releases.
The DEC'S nine regions form teams that conduct multimedia inspections for about 10% of each
region's facilities per year.
          Multimedia Inspection and Permitting Action Team
          Vermont Department of Environmental Control
                                                                          All Media
Having placed top priority on industrial facilities that have compliance problems, the Vermont DEC
completes multimedia inspections that focus on pollution prevention solutions at these facilities.
     Compliance Assistance Linked to Inspections and Pollution Prevention
          Sector-Focused Compliance Assistance and Pollution
          Prevention Inspections
          Washington Department of Ecology
                                                                          All Media
The Washington DOE focuses compliance assistance on industry sectors that are comprised of small
companies. The first two "Shop Sweep" campaigns focused on automotive repair shops and the
printing industry. The sweep inspections provide information to the shops on compliance and pollution
prevention opportunities.
          Multimedia Compliance Assistance Program
          City of Santa Rosa, California
                                                                          All Media
The Compliance Incentive Program was designed to help small businesses comply with
environmental laws by providing technical assistance, multimedia regulatory streamlining, and public
recognition and awareness. The Compliance Incentive Program issues "Sonoma Green Business"
stickers to companies in full compliance with the county's environmental laws. Multimedia inspectors
provide participating shops with information on pollution prevention-based Best Management
Practices (BMPs) to assist in compliance and avoid future violations.

                                                                             (continued)
                                                                                   ES-13

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                                                                      Executive Summary
                               Table ES-2 (continued)
          Contract with the Small Business Development Center's                 RCRA
          Business Environmental Program                                   	
          Nevada Department of Environmental Protection

The Nevada DEP uses RCRA 3011 state grant money to contract for compliance and waste
minimization assistance with the University of Nevada-Reno's Small Business Development Center's
Business Environmental Program (BEP). The Nevada DEP RCRA inspectors distribute BEP
brochures and fact sheets (e.g., pollution prevention tips on reducing solvent rags and used oil) during
inspections and refer facilities in need of compliance assistance to the BEP. BEP staff meet with
Nevada DEP inspectors and enforcement personnel in a monthly "regulatory forum" to discuss
compliance issues, ensure consistent interpretation of regulations, and develop pollution prevention
fact sheets.
                                                                         Hazardous
                                                                           Waste
                      Participation/Reward/Sticker Programs

          Progressively Increased Awards for Actions Beyond
          Compliance
          Seattle-King County Local Hazardous Waste Management
          Program
The Seattle-King County Local Hazardous Waste Management Program's "Enviro Stars" sticker
program encourages compliance and pollution prevention. Companies earn 2- to 5-star ratings that
reflect their effectless in managing hazardous waste and the extent to which they demonstrated
beyond compliance pollution prevention activities.
          Association of Bay Area Governments (ABAG) Award Sticker
          Program
          San Francisco Bay Area, California
                                                                          All Media
The ABAG operates a sticker program that recognizes top environmental performers. Built on
successful local models, the program covers four of the nine Bay Area counties. The program
encourages multimedia training of inspectors who work with companies and make referrals to
pollution prevention experts where potential violations are spotted.
           "Sonoma Green Business" Stickers
           City of Santa Rosa, California
                                                                           All Media
 Santa Rosa issues "Sonoma Green Business" stickers to shops that participate in the city's
 compliance incentive program. The county advertises the program to encourage consumers to
 support facilities displaying the green business emblem. Violations at facilities that have previously
 been issued a Sonoma Green Business sticker could result in loss of sticker. Once a sticker is
 confiscated, a company must demonstrate 6 months of compliance before that sticker is reissued.
                                                                                    ES-14

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                                                                         Executive Summary
               Table ES-3. Pollution Prevention During Enforcement
                    Pollution Prevention SEPs During Settlement

          North Carolina Pollution Prevention SEPs
                                                                            Hazardous
                                                                               Waste
North Carolina's Department of Environment, Health and Natural Resources' Division of Solid Waste
Management does not have a written DEP policy but actively pursues supplemental environmental
projects (SEPs) in enforcement cases. At the beginning of an enforcement action, the Division of Solid
Waste Management suggests considering an SEP as the preferred route to a solution. The facility can
then conduct, either itself or with the assistance of the Office of Waste Reduction technical assistance
staff, a waste reduction audit. The audit can be included in the settlement agreement; however, the
penalty mitigation is based on actual implementation of the pollution prevention and not completion of
the audit. Waste audits and implementation of pollution prevention measures can be considered as
separate SEP elements.
          Ohio Pollution Prevention SEPs
                                                                             All Media
Ohio inspectors assess the potential for pollution prevention solutions and either recommend specific
projects for consideration during enforcement negotiations or consider projects recommended by the
facility. Decisions are based on facility interest, understanding, and resources to undertake pollution
prevention projects and the availability of pollution prevention opportunities for similar facilities or
processes in that industry sector. Ohio EPA considers several factors in determining the amount of
penalty mitigation, including whether the project would not otherwise be economically attractive (either
because of long payback period or high capital cost); the project carries considerable technical risk;
implementation of the project would adversely affect immediate production concerns; and/or
management is unresponsive to the benefits of pollution prevention.
           Florida Pollution Prevention SEPs
                                                                              All Media
The Florida Department of Environmental Protection's (DEP's) 1994 Settlement Guidelines for Civil
Penalties encourages pollution prevention in enforcement actions and outlines activities that may
offset penalties: preparing a pollution prevention plan; designing, installing, and testing a specific
pollution prevention project; training employees to run the project, and/or initial capital investment for
startup.

During the first 2 years of this program, the Florida DEP started or completed more than 30 pollution
prevention SEPs. Pollution prevention coordinators in Florida DEP's districts work closely with Florida
DEP headquarters in Tallahassee on these projects. The six regional districts have tried various
approaches. Coordinators in the southwest and northeast districts, located in Tampa and
Jacksonville, assist facilities in preparing waste audits. Florida DEP's Central District develops
educational materials to encourage companies to consider pollution prevention into their activities.
Florida DEP staff work with companies in its "industry-heroes" program to encourage other companies
to consider pollution prevention methods.

                                                                                 (continued)
                                                                                       ES-15

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                                                                        Executive Summary
                                Table ES-3 (continued)
          EPA Region 1 Pollution Prevention SEPs
All Media
EPA Region 1 negotiated pollution prevention SEPs with (1) the Massachusetts Highway Department,
which paid $100,000 in fines and completed $5 million dollars in pollution prevention and other SEPs
at 148 facilities throughout the state; (2) the General Electric Company, which paid a $225,000 fine
and spent over $1.2 million on a pollution prevention SEP to replace an oil-based coolant with a
water-based coolant for its milling processes; and (3) CPF,  Inc., a beverage bottler, which paid
$160,000 in fines and $99,625 on SEP projects to enhance protection of the Nashua River watershed.
          EPA Region 2 Pollution Prevention SEPs
All Media
EPA Region 2 case officers suggest the opportunity for developing SEP projects to companies early
in the enforcement process. Region 2 has actively promoted SEPs since the early 1990s and has
negotiated numerous pollution prevention based SEPs.
           EPA Region 4 Pollution Prevention SEPs
All Media
EPA Region 4's strategic plan for pollution prevention in enforcement settlements emphasizes
notifying facilities of the opportunity for a pollution prevention SEP project early in the settlement
negotiation process. The office makes it clear that such actions, where feasible, would be advan-
tageous both to the facility and the environment. Facilities are provided with information about state
technical assistance programs and the Region 4 Waste Reduction Resource Center in North
Carolina. Enforcement staff may make a substantial effort to guide the company toward pollution
prevention possibilities, perhaps even providing the facility with contacts in other companies or
regions that have successfully undertaken pollution prevention changes for similar processes.
Enforcement staff,  however, cannot go the additional step of suggesting specific pollution prevention
projects in order to avoid leaving the Agency open to criticism regarding facility-specific proposals.
           EPA Region 5 Pollution Prevention SEPs
     RCRA
 In 1991, Region 5 developed guidance on including pollution prevention in RCRA enforcement
 settlements. It details the process for negotiating pollution prevention SEPs in RCRA settlements and
 provides worksheets for evaluating pollution prevention projects. The Region sends an SEP pamphlet
 to the facility, and the RCRA Technical Assistance Program evaluates the technical elements of SEP
 proposals. Administrative complaints include language that promotes early consideration of pollution
 prevention projects.
                                                                                 (continued)
                                                                                      ES-16

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                                                                        Executive Summary
                                Table ES-3 (continued)
          Examples of Pollution Prevention Measures in Injunctive Relief
          Enforcement/Pollution Prevention Policy
          Alaska Department of Environmental Conservation
All Media
The Alaska DEC and Pollution Prevention Policy Council (PPPC) require all notice of violation (NOV)
letters to: (1) recommend implementation of pollution prevention and recycling strategies to correct
violations and prevent violations in the future, (2) refer the facility to the DEC'S nonregulatory Pollution
Prevention Office for technical assistance, (3) request a description of written pollution prevention
plans, and (4) request information on the steps the facility takes to correct violations using pollution
prevention strategies.

This approach creates a positive relationship between the pollution prevention program and the
facility and has encouraged facilities to rethink waste management and materials use practices. The
NOV led one company to complete a chemical use audit, which reduced the number of chemicals
used at the facility from 400 to 153, and to begin recycling wastewater back into the process rather
than discharging it.
          Grumman Corporation Pollution Prevention SEP
          EPA Region 4
    RCRA
A 1993 consent decree with Grumman to correct violations associated with the ground disposal of
used methylene chloride from stripping operations allowed a reduction of $1 million of a $2.5 million
civil penalty for pollution prevention projects. The key pollution prevention projects included:

&  Replacement of methylene chloride stripper with an alternative acid-based or other
   environmentally acceptable stripper ($209,940; 100% credit)

S  A process change at the wastewater treatment plant for filtering and recycling wastewater
   discharges ($220,000; 80% credit)

H  Downsizing of a large trichioroethylene (TCE)-based vapor degreasing unit, reduction in exposed
   surface area of TCE, and installation of a carbon absorption vapor recovery system ($350,000;
   100% credit).
          Boeing SEP
          EPA Region 3
    RCRA
The attorney for Boeing Helicopter located in Ridley, Pennsylvania, proposed an innovative pollution
prevention SEP as part of a RCRA consent agreement in 1992. The agreement required Boeing to
pay a cash penalty of $800,000, and either: (1) make an additional $350,000 cash penalty payment,
or (2) develop and manage a small business pollution prevention education and assistance program
for "the RCRA regulated community" in the Delaware Valley. Boeing retained the Institute for
Cooperation in Environmental Management (ICEM), a regional nonprofit organization based in
Philadelphia, to develop and implement the program. The agreement required that a specific program
plan be prepared, and numerous certifications were required as the program got underway.

                                                                                (continued)
                                                                                     ES-17

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                                                                       Executive Summary
                                Table ES-3 (continued)
          Klein Bicycle Incorporated SEP
          Washington Department of Ecology
                                                                             RCRA
Klein Bicycle, Inc., in Seattle, Washington, proposed an innovative pollution prevention SEP as part of
a settlement with the Washington Department of Ecology that required Klein to pay $40,000 in cash
and carry out $100,000 worth of innovative pollution prevention actions. In addition Klein is required to
pay $50,000 in cash to "a party, program, or project that benefits water quality in Lewis County or the
State of Washington." The DOE agreed to suspend $50,000 of the penalty provided that Klein
remains in compliance.
          Eastman Kodak SEP
          EPA Region 2
                                                                             RCRA
A settlement with The Eastman Kodak Company in Rochester, New York, required a reduced cash
penalty of $8 million to $5 million contingent on the completion of six separate pollution prevention
SEPs (at a cost to Kodak of $12 million beyond the cost of the penalty). The SEPs reduce the
generation of hazardous waste and air and water pollutants and include the following projects and
costs to Kodak:
a
m
m
Trichloroethylene substitution
Chlorofluorocarbon elimination
Toluene substitution/naphtha recycling
Chemical substitution/toxicity reduction
Methanol elimination
Formaldehyde elimination
    Total
Project Cost
   $788,000
  $5,173,000
   $372,000
  $3,100,000
  $1,916,000
   $720.000

 $12,069,000
           Universal-Fuller Company
           Ohio Environmental Protection Agency
                                                                             RCRA
 Universal-Fuller Company, an industrial laundry and cleaning facility, was a large quantity generator
 of still bottoms from the use of Stoddard solvents in their dry cleaning process. Ohio EPA encouraged
 Universal-Fuller to pursue pollution prevention and recycling solutions proposed by the company to
 correct RCRA violations. The company installed a secondary still that reduced the amount of ignitable
 still bottoms from 9,377 gal/yr to 5,782 gal/yr—below the small quantity generator (SQG) threshold of
 100 kg/mo. Payback on the company's $197,000 investment was over 22 years, based on disposal
 costs savings of about $2,000/yr, raw materials savings of $3,000/yr. The company received a
 $10,600 penalty mitigation for the project and was required to complete the terms of the settlement
 within 210 days. The agreement led to reduced status to SQG.

                                                                               (continued)
                                                                                     ES-18

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                                                                       Executive Summary
                                Table ES-3 (continued)
          Bleached Kraft Pulp Mill
                                                                                Water
Bleached Kraft Pulp Mill (BKPM), a manufacturer of bleached kraft pulp, entered into a consent
decree with EPA and a citizen's group to study a range of effluent treatment systems and in-plant
process changes to bring the mill into compliance. BKPM proposed a pollution prevention solution—
changing to a hydrogen peroxide and oxygen bleaching process that eliminated elemental chlorine
and chlorine dioxide from the pulp bleaching process, and recycled wastewater back into the
production process. The pollution prevention project also saves on worker safety training and safety
equipment purchases, expensive corrosion-resistant plastic, and paint films.
          Ketchikan Pulp Company
          EPA Region 10
        Air,
       Water
The Ketchikan Pulp Company, located on Ward Cove in Alaska, agreed to pay $3.1 million in civil
penalties and up to $6 million more to: (1) conduct an independent facility-wide multimedia audit to
find ways to ensure full compliance and prevent pollution, (2) eliminate direct discharges from its
water treatment plant, (3) develop a mill operations and maintenance program designed to minimize
pollution, and (4) conduct a pollution prevention study modeled after EPA protocols that emphasizes
the prevention of toxic emissions.
          Bristol-Myers Squibb Company SEP
          New York Department of Environmental Conservation
Multimedia
The New York DEC entered into a multimedia enforcement order and a Memorandum of
Understanding (MOU) with Bristol-Myers Squibb Company, in Onondaga County, which required that
the company

B  Hire an independent consultant, approved by DEC, to complete a compliance audit of its facility.
B  Implement a DEC-approvable air pollution control plan.
S  Perform a remedial site assessment and ground water monitoring study.
S  Implement a toxic chemical reduction plan that will achieve a 50% reduction of the 8,722,488
    pounds of toxic releases from the facility by the year 2000.
H  Develop an approvable emergency response program to train and equip local emergency
    response teams.
8  Develop an approvable accident prevention planning program.
B  Develop an approvable community awareness program that includes a community advisory
    group.
H  Fund two full-time, onsite environmental monitors.
                                                                               (continued)
                                                                                     ES-19

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                                                                        Executive Summary
                                Table ES-3 (continued)
          Anitec Image
          New York Department of Environmental Conservation
Multimedia
In 1991, Anitec Image, a Binghamton manufacturer of photographic films, papers, and chemicals for
the graphic arts industry and a subsidiary of International Paper, entered into two consent orders to
correct contaminated ground water seepage into nearby homes and reduce high levels of silver
affecting the quality of the local stream and Chenango River.

The first consent order, to correct immediate problems, required Anitec to complete an ambient air
monitoring plan, perform a soil vapor survey, submit a hazardous waste release report, and provide a
written report on actions taken to eliminate the potential for releases of hazardous substances. A
second consent order required Anitec to complete several pollution prevention and other projects
addressing ambient and fugitive air emissions, ground-water contamination, and hazardous waste
generation, such as the substitution of less toxic alternatives for hazardous chemicals, and closed-
loop reclamation. Anitec is actively promoting the adoption of various programs at other divisions of
International Paper and is participating in NY DEC'S Multimedia Pollution Prevention program.
                                                                                      ES-20

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Section 1.0
Pollution Prevention  Basics
1.1   What Is Pollution Prevention?

"Pollution prevention" has a legal definition and a practical definition. The legal definition,
contained in the Pollution Prevention Act of 1990, includes any practice that

      (i) reduces the amount of any hazardous substance, pollutant or contaminant
      entering any waste stream or otherwise released into the environment (including
      fugitive emissions) prior to recycling, treatment, or disposal; and

      (ii) reduces the hazards to public health and the environment associated with the
      release of such substances, pollutants or contaminants ....

      The term includes equipment or technology modifications, process or procedure
      modifications, reformulation or redesign of products, substitution of raw
      materials, and improvements in housekeeping, maintenance, training, or inventory
      control.1

The practical definition could be stated as: changing the way things are made in order to reduce
waste generation. To illustrate, several categories of pollution prevention measures (which are
not mutually exclusive) are listed below. These activities reduce the volume and toxicity of
pollutants and waste generated during the manufacturing process and may diminish the toxicity
of the end product prior to recycling, treatment, and disposal.

a  Changes in product design. Design changes may include changes in composition of the raw
   materials and/or the end product to reduce pollutants generated during the manufacturing
   process and to reduce the environmental impact during or after product life. Examples
   include redesigning paint to eliminate heavy metals and redesigning inks to use a water base
   instead of a solvent base.

m  Technology/process modifications. Technology and process changes may range from minor
   adjustments in the design and efficiency of operations (e.g., adding a lid or adjusting the
'Pollution Prevention Act of 1990 § 6603 (5)(A).
                                                                                   1-1

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Pollution Prevention Basics
Section 1.0
   temperature on a solvent degreasing tank to reduce emissions) to expensive or complicated
   modifications (e.g., replacing a solvent-based cleaning process with an aqueous-based or dry-
   abrasive cleaning system).

•  Input/material changes. Input/material changes involve replacing hazardous chemicals or
   other materials with less toxic alternatives that are equivalent in performance (e.g., replacing
   chlorine bleaching with ozone bleaching).

a  In-process recycling and reuse. Recycling and reuse as a closed-loop, integral part of the
   production process constitutes source reduction under the U.S. Environmental Protection
   Agency's (EPA's) definition. Such closed-loop systems could involve recycling and reuse of
   metals, solvents, coatings, or any other materials that would otherwise leave the production
   system as emissions, discharges, or wastes.

•  Operation and maintenance improvements. Examples include better materials management
   and inventory control, housekeeping, and preventive maintenance. Materials management/
   inventory control involves efficient management of inventory to reduce product losses due to
   product expiration and overstocking. Examples may include establishing a "hazardous
   materials pharmacy," restricting access to supply areas, maintaining accurate inventory
   records, and using "just-in-time" delivery to avoid inventory buildup and expiration. Good
   housekeeping practices involve keeping the facility clean and organized to reduce the poten-
   tial for spills and the release of chemicals, ensuring that hazardous wastes and materials are
   not exposed to workers or released to the environment, and preventing nonhazardous
   materials from becoming hazardous due to commingling. Preventive maintenance involves
   maintaining equipment in good working order to prevent releases and spills due to malfunc-
   tion and to extend the equipment's useful life (e.g., installing lifetime valve gaskets to avoid
   leaks).

Other process improvement concepts, such as total  quality management, yield improvement, and
process reengineering, can improve efficiency and result in pollution prevention.

"Waste minimization," defined in the Hazardous and Solid Waste Amendments to the Resource
Conservation and Recovery Act (RCRA) of 1984,2 is closely related to pollution prevention
except that the term includes environmentally sound recycling in addition to source reduction and
closed-loop recycling. A recycled material is a secondary material "that is used, reused, or
reclaimed" according to EPA regulations. Waste minimization has been used incorrectly by some
to include volume reduction techniques (e.g., compaction), which do little to affect the hazardous
qualities  of waste; combustion for energy recovery  and for destruction; chemical treatment; and
disposal. Waste minimization does not include activities that closely resemble conventional
242U.S.C.A. § 6902(a)(6), (b).
                                                                                      1-2

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Pollution Prevention Basics
                               Section 1.0
waste management activities.3 For the purposes of this handbook, the term "pollution prevention"
is used unless specifically referring to RCRA and waste minimization.

1.2   What Are the Benefits of Pollution Prevention in Permitting and
       Compliance?

Pollution prevention solutions not only improve the environment but also often provide cost
savings to businesses. Some perceive that there are barriers to exploring these solutions during
the permitting and compliance process (e.g., permit writers or inspectors are not allowed to ask
questions about production processes; the schedules associated with permitting and compliance
are so  constrained that there is no time to explore potentially cost-effective pollution prevention
solutions). In fact, however, making the extra effort to explore pollution prevention during
permitting, inspection, and enforcement activities often has productive results (see box).
           Benefits of Pollution Prevention in the Permitting and Compliance Process
               Benefits to Industry
  M  Reduces the amount of pollution generated and
     the cost of handling, treating, and disposing of
     wastes.
  •  Reduces the demand for raw materials and the
     environmental impacts associated with taking
     raw materials from the environment.
  H  Encourages better communication and working
     relationships between government agencies and
     companies.
  ffi  Improves corporate image with customers and
     the community.
  H  Improves ability to remain in compliance.

  8  Reduces health risks to employees and worker
     compensation costs.
  •  Reduces risk of future environmental liability.

  S  Reduces conflict between environmental and
     economic goals.
   Benefits to Government Agencies

Focuses the source of the pollution and
encourages a balanced, whole-facility approach
to environmental compliance rather than isolated
specific media releases and regulations.

Encourages better communication and working
relationships between government agencies and
companies.

Reduces administrative costs associated with
permitting and compliance.

Encourages a more cooperative, less litigious
approach to industry.

Encourages development and implementation of
innovative technologies.

Government agencies may be able to reduce
oversight and reduce their resource burden.
 3U.S. EPA, Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program: Interim
 Final Guidance, p. 7-8.
                                                                                           1-3

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Pollution Prevention Basics
Section 1.0
1.3   Is Pollution Prevention Required?

In 1993, EPA formally endorsed pollution prevention as a guiding principle for all EPA
programs to encourage sustainable development while continuing the Agency's mission to
protect human health and the environment:

       Pollution never created avoids the need for expensive investments in waste
       management or cleanup.

       [W]e must encourage pollution prevention as a means of compliance through our
       permitting, inspection, and enforcement programs, relying on the first-hand
       experience of regions and states in this area.

       The new focus on pollution prevention will require a significant change in the way
       EPA carries out its responsibilities and allocates resources .... If we are to
       succeed, we must continually renew our commitment by questioning established
       practices, working cooperatively across program and agency boundaries, and not
       hesitating to acknowledge shortcomings as well as success stories.

       The mainstream activities at EPA, such as regulatory development, permitting,
       inspections, and enforcement, must reflect our commitment to reduce pollution at
       the source, and minimize the cross-media transfer of waste.4

EPA's policy builds on the momentum of several states that began in the late 1980s. Since 1985,
several dozen states have enacted laws that encourage or require pollution prevention
activities—16 states mandate pollution prevention planning by certain groups of companies to
encourage the identification of more cost-effective environmental solutions.

This handbook summarizes state and EPA Regional pollution prevention approaches within the
permitting, inspection, and enforcement process. There are  still a variety of obstacles to
overcome, however. For example, some government managers and staff assume permit writers
and inspectors need to become experts on production processes and pollution prevention
technology in order to promote pollution prevention during their regulatory activities. In most
cases, this is not true. Instead, permitting and inspection staff need to understand the basic
concepts of pollution prevention and the production processes that generate waste. It is more
important to encourage companies to explore pollution prevention options, providing contacts for
assistance and to consider pollution prevention changes during the permit and compliance
process.
*EPA Pollution Prevention Policy Statement: New Directions for Environmental Protection, June 15, 1993.
                                                                                      1-4

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Section 2.0
PoSSution  Prevention in the Permitting Process
2.1    What Do I Need to Know?

7s pollution prevention required in permits?

       The Clean Air Act (CAA), Clean Water Act (CWA), and RCRA encourage reducing the
       generation of pollution at the source (i.e., pollution prevention) rather than releasing it to
       the environment. For example, a primary goal of the CAA is to "encourage or otherwise
       promote reasonable federal, state, and local governmental actions, consistent with the
       provisions of this chapter, for pollution prevention." The CAA also authorizes EPA to set
       maximum achievable industrial emissions standards based on pollution prevention and/or
       control methods. RCRA's goals place highest priority on preventing the generation of
       hazardous waste and lowest priority on treating and disposing of waste. Similarly, the
       CWA seeks to eliminate discharges of toxic pollutants. Storm water regulations specifi-
       cally require a pollution prevention plan, while publicly owned treatment works
                         States with Pollution Prevention Strategies

 States that require pollution prevention facility planning through legislation or regulation:
     Arizona
     California
     Georgia
     Maine
Massachusetts
Minnesota
Mississippi
New Jersey
New York
North Carolina
Oregon
Pennsylvania
Tennessee
Texas
Vermont
Washington
 States that encourage pollution prevention facility planning:
     In Connecticut, Delaware, Florida, Illinois, Indiana, and Iowa, facility planning is voluntary. In Illinois, for
     example, facility planning is linked to regulatory incentives such as expedited handling of permits.

     Louisiana had a one-time waste minimization planning requirement. There is no current facility planning
     requirement for facilities in Louisiana.

     Ohio has a pollution prevention facility planning requirement that applies specifically to owners and
     operators of Class I injection well facilities. If the injection well is located within a manufacturing facility, the
     planning requirement applies to the entire facility. Ohio also requires RCRA-permitted facilities to submit
     hazardous waste minimization plans.
                                                                                      2-1

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Pollution Prevention in the Permitting Process
Section 2.0
       (POTWs) can take action to reduce contaminants in sludge, protect receiving waters, and
       protect their own plant and workers.

       Sixteen states require facilities to conduct pollution prevention planning to identify cost-
       effective solutions that reduce generation, which can feed into the permit process. Several
       other states encourage pollution prevention planning. In most cases, state planning laws
       and regulations do not link pollution prevention planning directly to permit processes.
       However, several states and EPA Regions have adopted a policy of considering or
       requiring a review of the pollution prevention plan during the permitting process to
       encourage the installation of cost-effective technologies that reduce the amount of end-of-
       pipe controls necessary for compliance. These provisions tend to provide incentives and
       flexibility for pollution prevention options. This handbook cites many examples where
       permit writers have used this latitude to promote pollution prevention in the permitting
       process.

 Why is it a good idea,  to promote pollution prevention  during the
 permitting process?

       Many companies rely on end-of-pipe treatment to achieve compliance because EPA
       regulations have historically based environmental standards on end-of-pipe treatment
       technology. Now, many companies would rather reduce the amount of pollution they
       generate than spend money expanding single-media, end-of-pipe pollution controls.
       Focusing on prevention alternatives at the front end of the permitting process can often
       help companies make cost-effective decisions that may reduce or eliminate the need for a
       permit and inspection oversight. Having specific permit requirements and costs in hand at
       the beginning can help corporate environmental managers sell cost-effective prevention
       technologies to corporate decision  makers. Once money has been sunk into more end-of-
       pipe equipment, pollution prevention is less likely to be funded. Reducing costs and
       improving compliance are crucial pieces of this approach. Environmental agencies benefit
       from better environmental performance over the long term.

       Some of the strategies EPA Region, state, and local agencies have used to promote
       pollution prevention in the permitting process include prepermitting interviews and
       information distribution, permit avoidance through pollution prevention, permit
       flexibility, pollution  prevention planning, explicit pollution prevention permit conditions,
       and incentives. These are discussed in Section 2.2.

 What types of facilities provide the best opportunities for pollution
 prevention during the permitting process?

       Facilities that generate or manage air emissions, direct or indirect wastewater discharges,
       storm water, and/or hazardous waste may be ideal places to integrate pollution prevention
       into the permitting process. Although identifying options on a site-by-site basis is the only
                                                                                     2-2

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PoHuVion Prevention in the Permitting Process
Section 2.0
       way to know for sure, there may be some situations where pollution prevention is an
       effective choice:

       B  Facilities that exceed a regulatory cutoff by a small amount may be able to reduce
          their regulatory status through pollution prevention. For example, a facility that
          generates more than 100 kg of RCRA hazardous waste per month might be able to
          reduce its status to a conditionally exempt hazardous waste generator using pollution
          prevention.

       m  Companies may be able to eliminate the need for certain permits by implementing
          pollution prevention technologies (e.g., eliminating surface water discharge to avoid
          National Pollutant Discharge Elimination Standard [NPDES] permitting; qualifying
          as a synthetic minor designation to avoid Title V permitting).

       M  Facilities experiencing frequent compliance problems with their current control
          technologies may be better off installing pollution prevention technology rather than
          new pollution control technology.

       m  Facilities that meet emission requirements by shifting pollutants to wastewater
          effluents or solid waste shipments may be better off changing their production process
          than paying for air, water, and/or hazardous waste controls.

       B  POTWs subject to tight limits in their NPDES permits might benefit by promoting
          pollution prevention at industrial dischargers.

       Commercial waste treatment facilities (e.g., commercial hazardous waste treatment,
       storage, and disposal  and recovery [TSDR] facilities, cement kilns, and lightweight
       aggregate kilns) have little control over the generation of waste they receive and therefore
       are less amenable to pollution prevention strategies. Some of these facilities work with
       their customers to exclude highly toxic constituents from wastes generated.

 What is the permit writer's role in promoting pollution prevention
 approaches? Does a permit writer need to be an expert in a company's
 production processes?

       There are various roles a permit writer can assume, ranging from providing the company
       with sources of basic pollution prevention information, which does not require in-depth
       knowledge of the company's manufacturing processes, to meeting regularly with the
       company to develop a pollution prevention analysis that determines key permit
       parameters. A permit writer can point the company to the state technical assistance
       organization, distribute basic pollution prevention documents, or help identify specific
       sources of pollution and strategies for their prevention. Regardless of the permit writer's
                                                                                    2-3

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Pollution Prevention in the Permitting Process
Section 2.0
       expertise, the most important role is to use the permit process to encourage a cost-
       effective reduction in pollutants generated by the company.

       The permit writer's role also depends on whether the permitting agency is organized on a
       media or multimedia basis and on the permit writer's knowledge and interest in
       promoting pollution prevention.

What is required in pollution prevention planning?

       Section 2.2 provides a variety of examples of pollution prevention planning. In some
       cases, the permitting agency works cooperatively with the state pollution prevention
       office. In those states where pollution prevention planning is required, the process
       generally includes the following basic elements:

       m  A statement of the company's pollution prevention goals and management's
          commitment to the process of implementing pollution prevention.

       m  Characterization of the pollutants released and the hazardous wastes released or
          generated by the facility.

       H  A description of the operations or processes that result in generation of pollutants or
          environmental releases.

       9  An assessment of the technical and economic feasibility of alternative, less polluting
          inputs, processes, and operating practices.

       3  A plan for implementation of those alternatives found to be technically and
          economically feasible.

 How do I prepare to discuss pollution prevention with a company?

       The permit writer should look at the company's pollution prevention plan or an example
       of one from a similar facility. The writer should also have a basic understanding of which
       hazardous wastes and toxic chemicals the facility releases and which pollution prevention
       approaches should be considered. Consult the following resources to obtain this
       information:

       B  State-required or sample pollution prevention plan. As discussed at the beginning of
           Section 2.1, 16 states require facilities to prepare a pollution prevention plan. These
           plans often must provide information on the facility's waste sources and source
           reduction goals and accomplishments. Most of the 16 states require the plan to be
           kept on file at the facility, and a few states require plans or a summary of the plan to
           be made publicly available. If the state does not require pollution prevention plans,
                                                                                      2-4

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Pottution Prevention in the Permitting Process
                               Section 2.0
           ask a state that does for some
           examples of plans to use as point
           of discussion with the facility.

           Biennial Report System (BRS).
           The BRS contains waste-stream-
           specific hazardous waste genera-
           tion and management data, and
           some information on recycling and
           source reduction, for large-
           quantity hazardous waste gen-
           erators (greater than 1,000 kg per
           month generated) and hazardous
           waste TSDR facilities. Data are
           provided for the most recent and
           preceding reporting years. BRS
           reports are available from
           information management staffs in
           EPA Regions and states. The data
           may lag by 2 to 4 years.

           Toxic Release Inventory (TRI).
           The TRI report contains specific
           toxic chemical release and transfer
           information from manufacturing facilities in the United States. It contains information
           on the manufacture, processing, use, and recycling of listed toxic chemicals, including
           amounts of chemicals released to all environmental media. Data are available on the
           Internet at www.epa.gov and www.rtk.net.

           Case studies, technical pollution prevention brochures, fact sheets, and technical
           assistance. Over 200 technical assistance offices operating in state offices,
           universities, and nonprofit organizations provide case studies, fact sheets, technical
           brochures, phone consultations, and some onsite assistance.  Computer-based
           pollution prevention information systems are available through the Internet. For
           example, EPA's Enviro$en$e (located at http://es.epa.gov) provides keyword
           searching for hundreds of files. In addition, some industry associations are developing
           their own sector-specific pollution prevention technical databases.
 Questions to Answer before Meeting
          with a Company

Does the state require a pollution prevention
plan? Has a plan been prepared? If so, obtain
copy from facility.
If no pollution prevention plan has been prepared
at this facility, can I get an example to use as a
point of discussion with the facility? Call a state
that requires them.
How much hazardous waste does the facility
generate and manage? What types of production
processes generate the waste? Get the Biennial
Report System data.
What toxic chemicals does the facility release?
Get Toxic Release Inventory data.
Is there any free technical assistance available?
Is it confidential? Call the state technical
assistance contact.
Are there any pollution prevention case studies or
technical brochures available for similar facilities?
Look into Enviro$en$e or other pollution
prevention databases. Call the state technical
assistance contact.
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Pollution Prevention in the Permitting Process
                      Section 2.0
When in the permitting process should pollution prevention be discussed?

       The permitting process can offer many opportunities to introduce pollution prevention.
       The best results are likely if discussions begin early in the process and continue through
       subsequent steps. Some generic steps that may be applicable in a variety of permitting
       processes are discussed below.

       m  Prepermit facility analysis. The CAA Title V permit process requires a compliance
           analysis of all of the facility's air requirements. This generally requires an analysis of
           air sources, emissions potential of the sources, and operational scenarios that may
           affect emissions. Some companies take this opportunity to do a whole-facility,
           multimedia compliance audit in order to identify areas in need of correction. These
           audits may include chemical usage studies, emissions inventories,  stack or emission
           point testing, process-specific and facility-wide mass balance calculations, or other
           data-gathering activities. The compliance analysis could be limited to an end-of-pipe
           analysis, or it could be used to explore pollution prevention options. For example, a
           company could explore process modifications that reduce emissions below the cutoff
           for becoming a synthetic minor—or process changes that could completely eliminate
           a source.

        m  Preapplication meetings and permit scoping sessions. Preapplication meetings
           provide an early opportunity to discuss pollution prevention concepts and whether the
           facility would like to consider pollution prevention options. This is a good time to
           discuss expected outcomes, ground rules, time frames, and resources and guidance
           that may be necessary to complete the job. The permit writer can point the applicant
           to consultants, trade associations, trade journals, the Internet, and state technical
           assistance programs for help identifying
           pollution prevention opportunities.
           Permit application. Some states require
           companies to investigate pollution prevention
           or draft pollution prevention plans and
           worksheets as part of the permit application.
           The plan or worksheet provides the structure
           for the permit writer and applicant to identify
           pollution prevention opportunities and follow
           up any feasible alternatives.

           Draft permit review. The permit writer and
           company can continue to discuss pollution
           prevention opportunities while preparing the
           draft permit.
   When to Discuss Pollution
           Prevention

M  Prepermit facility analysis
B  Preapplication meetings and permit
   scoping sessions
B  Permit application

H  Draft permit writing

B  Public comment

B  Final permit issuance

H  Permit renewal

•  Permit modification for process
   expansion or increased capacity
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Pollution Prevention In the Permitting Process
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       m  Public comment. Where public comment on a draft permit occurs, the company
          and/or permit writer can provide pollution prevention information at a public hearing
          or through public notice. They also can direct commenters to information resources.

       S  Final permit issuance. Some government agencies require companies to explore
          pollution prevention alternatives as a permit condition.

       m  Permit renewal. The permit renewal process provides equally beneficial opportunities
          for companies to investigate pollution prevention alternatives in their manufacturing
          process as methods for meeting permit requirements.

       m  Permit modifications. When a company requests a permit modification (e.g., to
          increase production or significantly modify its operations), consider opportunities to
          promote pollution prevention approaches as the most cost-effective means to
          accommodate both production goals and emission limit requirements.

How can multimedia pollution prevention be considered during the
permitting process?

       Multimedia pollution prevention means looking at pollutants generated by all processes
       in the facility. Many facilities are pursuing multimedia pollution prevention outside the
       permit process. Incorporating multimedia pollution prevention in the permitting process
       requires coordinating permit schedules for all of the facility's permits. While only a few
       states are exploring multimedia permits, some steps are listed below that can move
       single-media permitting toward multimedia evaluation and analysis.

       S  Share information informally with permit writers who work with the facility for other
          media to determine if there are common sources of problems that can be dealt with
          simultaneously.

       B  Develop regular working groups of permit writers and/or industry environmental
          managers from various media.

       m  Make use of resources  such as facility pollution prevention plans, and make contact
          with any staff reviewing such plans.

       m  Use the screening ideas listed earlier in this section to identify candidate facilities that
          may benefit from a multimedia approach.

       m  Initiate agency-industry discussions about the benefits  of multimedia permitting and
          the opportunities that could be pursued.
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       Drawbacks/Disincentives

       Agencies engaged in multimedia permitting and pollution prevention have experienced
       some hurdles that must be crossed.

       &  The initial time investment by companies and agencies can add to the overall schedule
          for permitting. This initial effort gets easier for agencies as they acclimate to a new
          way of doing business. In addition, multimedia permitting may offer considerable
          time and resource savings over the long term compared to the multitudes of resource-
          nibbling permit actions that are otherwise required.

       m  The differences between individual agency and company management structures can
          limit the degree to which a multimedia permit process can be initiated and/or
          accelerated.

       a  Companies may not willingly undertake changes if failure risks regulatory penalties.

2.2   Examples of Approaches

EPA and states have relied on end-of-pipe treatment technology as the basis for setting facility
specific permit limits for many years—and tremendous progress has been made using this
approach. More recently, however, some permitting agencies have worked with companies to
find ways to meet or exceed compliance requirements by reducing the volume and toxicity of
waste that is generated, rather than building bigger more expensive treatment technologies.
Identifying pollution prevention solutions at the front end of the permitting process often requires
the permitting agency and the company to refocus their emphasis, i.e., some "out-of-the-box"
thinking, which in many cases has paid off for both sides. Companies find a cheaper, cleaner,
smarter compliance solution, and government agencies can report improved environmental
performance.

This section describes 33 EPA Region, state, and local agency examples of how pollution
prevention was considered in air, water, pretreatment, storm water, and hazardous waste
permitting situations. Contact names are provided.

These examples cover a variety of strategies:

m  Prepermitting interviews and information distribution
a  Permit avoidance prevention
m  Pollution prevention preapproval
m  Pollution prevention planning
 m  Explicit pollution prevention conditions in permits
 a  Permit process incentives
 a  Whole-facility permits.
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2.2.1  Prepermitting Interviews and Information Distribution
              Examples of Prepermitting Interviews and Information Distribution
Permitting agencies have used a variety of approaches for providing pollution prevention
information to permit applicants early in the permitting process. These range from resource-
intensive, prepermitting conferences for particular companies or industry sectors to less costly
but less targeted distribution of information packages. Examples of the latter include self-audit
questionnaires that direct the applicant to sources of assistance, general fact sheets and brochures,
industry-specific pollution prevention "care packages," or lists of technical information sources.
Prepermitting conferences provide a focused opportunity to discuss pollution prevention options
specific to the operation of the individual facility. Regardless of the mechanism chosen, the early
introduction of pollution prevention is important.
           Permit Application Worksheet and Prepermitting Review
           Massachusetts Department of Environmental Protection
    Air
The Massachusetts DEP uses a voluntary pollution prevention worksheet in the Title V permit
application process. The worksheet helps the applicant provide information that helps permit
writers determine which pollution prevention opportunities should be considered. The following
are examples of the type of questions asked on the permit worksheet:

1.  Input substitution is the use of nontoxic or less toxic raw materials in place of more toxic
    ones. Examples: no/low flow solvent coatings, clean fuels, aqueous cleaners, etc. Is input
    substitution a technique that could be employed at your facility? Yes? No? If yes, on which
    emission point?

2.  Production unit redesign or modification  is the altering of a process to eliminate the use of or
    to utilize a lesser quantity of toxic materials. Examples: coating equipment that improves
    transfer efficiencies, countercurrent rinses, etc. Is production unit redesign or modification a
    technique that can be employed at your facility? Yes? No? Briefly describe.

3.  Improved operation and maintenance includes improving housekeeping, system adjustments,
    process control equipment, etc., and/or providing training to improve efficiency. Examples:
    leak detection and repair, mixing protocols, maintenance logs and schedules for process,
    purchasing and inventory controls, production scheduling, operator training, etc. Would
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Pollution Prevention in the Permitting Process
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   improved operation and maintenance procedures be beneficial to your facility in order to
   minimize waste generation? Yes? No? Briefly describe.

4. "Total cost assessment" attempts to more fully account for less tangible, longer-term, and
   indirect costs associated with a project alternative. Examples: pollution-related liability,
   company image, regulatory compliance costs, and other costs typically grouped into
   overhead. Can total cost assessment economic analysis be used to evaluate processes at your
   facility in order to incorporate pollution prevention alternatives? Yes? No? Briefly describe.

The worksheet also encourages the permit applicant to contact the permit writer and the Office of
Technical Assistance.

Three factors are reducing the effectiveness of the worksheet: the Massachusetts DEP is short on
funding for outreach, the newly implemented Title V program has had effected a low initial
response rate, and Massachusetts' guaranteed permit timeline hinders the integration of
innovative pollution prevention technology because of the increased analysis and approval times
necessary for complex permits.

Contacts:  Keith Anderson
            Central Regional Office
            Massachusetts Department of Environmental Protection
            508-792-7692

            Bill Lampkin
            Pollution Prevention/Multimedia Pilot Project
            Northeast Regional Office
            Massachusetts Department of Environmental Protection
             617-932-7657
 Some agencies have used the compliance inspection process as an opportunity to work with
 companies to identify cheaper, smarter, cleaner compliance solutions in cases where end-of-pipe
 treatment approaches may be experiencing compliance problems. The approaches in this section
 require some "out-of-the-box" thinking, but in many cases have paid off for both sides—
 companies find a cheaper, cleaner, smarter compliance solution, and government agencies can
 report improved environmental performance.
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PoNution Prevention in the Permitting Process
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          Advertisement in Cover Letter Accompanying Permit
          Ohio Environmental Protection Agency
    Air
When Ohio EPA issues an air permit, they include a cover letter urging the permittee to
investigate pollution prevention and energy conservation. Promoting pollution prevention as a
way to protect the environment and save money, the letter offers the company the assistance of
Ohio EPA's Office of Pollution Prevention.

Contact:    Andrea Futrell
             Office of Pollution Prevention
             Ohio Environmental Protection Agency
             614-644-3469
          Advertisement in Permit Application
          Michigan Department of Environmental Quality
 Water
The Michigan DEQ's Surface Water Quality Division has amended its NPDES permit
applications to include the following pollution prevention statement:

                        Preventing Pollution Is the Best Solution

       The Michigan Department of Environmental Quality (DEQ) encourages you to
       consider pollution prevention alternatives. In some cases, pollution prevention
       may allow you to avoid the need to discharge pollutants that would otherwise
       require permit limitations—or even avoid the need for permits altogether!
       Pollution prevention can:

       a  Save money
       a  Reduce waste
       S  Aid permit compliance
       B  Protect our environment
       m  Reduce liability

       The DEQ is helping Michigan's industries save money, reduce waste, and protect
       our environment through pollution prevention. DEQ staff can provide pollution
       prevention assistance through telephone consultations, technical workshops and
       seminars, and informational publications. They can also put you directly in touch
       with local support networks and national pollution prevention resources. For more
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Pollution Prevention in the Permitting Process
   Section 2.0
      information, contact the Michigan Department of Environmental Quality,
      Environmental Assistance Division at 1-800-662-9278 or visit our homepage at
      http:///www.deq.state.mi.us.

Contact:   Carrie Monosmith
           Pollution Prevention Section, Environmental Assistance Division
           Michigan Department of Environmental Quality
           517-373-0604
        Information Packages for Permit Applicants
        Connecticut Department of Environmental Programs
All Media
The Connecticut DEP includes pollution prevention information with the materials sent to all
companies that apply for permits. This material includes information on the activities and
services of the Connecticut DEP's Office of Pollution Prevention as well as information on
industry-specific technical options for pollution prevention.

Contact:   Mary Sherwin
            Office of Pollution Prevention
            Connecticut Department of Environmental Programs
            203-424-3297

2.2.2  Permit Avoidance through Pollution Prevention
                Examples of Permit Avoidance through Pollution Prevention
        Best Management Practices for Vehicle and Equipment           Water
        Wash Water Discharges                                        	
        Washington Department of Ecology

 The Washington DOE requires permits for vehicle washing activities that result in discharges to
 the ground or sanitary sewer. To reduce this source of discharge, the Washington DOE developed
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Pollution Prevention in the Permitting Process
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a best management practices manual that focuses on preventive approaches. In most cases,
companies that install pollution prevention-based best management practices are able to
eliminate their discharge permit.
Contact:   Bill Moore
            Washington Department of Ecology
            360-407-6444
        Avoiding NPDES Discharge Permits through Pollution            Water
        Prevention                                                        	
        Washington Department of Ecology
The Water Quality Program in Washington's DOE has had great success in helping companies
use pollution prevention to reach zero discharge and eliminate their NPDES permits. The
Washington DOE promotes pollution prevention by requiring the following language in NPDES
permits:

       The Permittee shall provide a report on all wastewater discharges that at minimum
       includes:

       A complete inventory of all waste streams

       Daily average and maximum flow rates for each waste stream

       A detailed investigation into the options available for reduction, recirculation, reuse, or
       elimination

       Selection of a preferred option

       A schedule for implementation of the preferred option....

The report must show whether reaching zero discharge through pollution prevention is feasible.
Final inspections during dry weather result in cancellation of NPDES permits for companies that
have achieved zero surface water discharge. Reductions as large as 4,000,000 gpd to zero
discharge have resulted using this approach.
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Pollution Prevention in the Permitting Process
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Contacts: PamElardo
           Water Quality Program
           Washington Department of Ecology
           206-649-7000

2.2.3  Pollution Prevention Preapproval—Avoidance of Permit Modifications
                      Examples of Pollution Prevention Preapproval—
                           Avoidance of Permit Modifications
                                  8
        Incorporating Preapproval of Pollution Prevention-Based
        Changes Using a General Permit Condition
        Massachusetts Department of Environmental Protection
The following general provision in Massachusetts DEP air permits preapproves pollution
prevention changes and eliminates the need for a permit modification:

       XYZ company can implement formulation changes, equipment changes, and/or
       relocation of equipment that reduce air emissions in order to achieve the goals of
       toxic use reduction, volatile organic compound (VOC) reduction, or waste mini-
       mization without requiring a modification to this approval. Any modification or
       new equipment installation that increases emissions greater than 1 ton per year
       shall comply with the applicable requirements of regulation 310 [Code of
       Massachusetts Regulations (CMR)] 7.00 (sections 7.02, 7.03, etc.). Any other
       modifications (such as moving equipment, changing solvents, or changing exhaust
       configurations) shall be noted on the emission statement forms as required by
       regulation 310 CMR 7.12.... These modifications cannot violate the conditions
       of this facility-wide approval, such as the VOC emission restrictions contained
       herein.
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Pollution Prevention in the Permitting Process
Section 2.O
Contact:   Rich Bizzozero
            Office of Technical Assistance for Toxics Use Reduction
            Massachusetts Department of Environmental Protection
            617-727-3260
        Title V Permit Containing Preapproved Changes
        Oregon Department of Environmental Quality
    Air
Oregon's air regulations contain no de minimis exemption from Minor New Source Review. For
Intel, this meant that any physical or operational change affecting its VOC emissions, no matter
how small, could subject it to time-consuming and, as a result, costly review. Oregon DEQ
issued Intel a permit containing regulatory incentives that promote pollution prevention as the
preferred means of reducing emissions. This incentive is attractive to Intel, which must develop
new products rapidly in order to compete in dyamic market conditions.

One condition of the Intel permit preapproves the company to make certain process changes
affecting VOC emissions without triggering Minor New Source Review as long as Intel meets all
applicable requirements including a federally enforced VOC emissions cap. In order to qualify
for this preapproval, (1) Intel cannot alter or add to its control technology requirements; (2) the
maximum capacity of the plant to emit VOC can not exceed 8.0 tons in any one week;  (3) any
emissions increases occurring from the change must be offset by reductions made through
pollution prevention; and (4) Intel must meet monitoring requirements and all other requirements
specified in the permit.

Contacts: DaveDelarco
            EPA Region 10
            206-553-4978

            Marianne Fitzgerald
            Oregon Department of Environmental Quality
            503-229-5850
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Pollution Prevention in the Permitting Process
Section 2.0
        Permit Flexibility
        New Jersey Department of Environmental Protection
    Air
In 1990, Schering-Plough Corp., a pharmaceutical research and manufacturing firm that had 85
air permits, volunteered for New Jersey's facility-wide permit program to have greater flexibility
to make production changes and reduce the paperwork involved in such changes. Previously,
each time Schering changed a process to add a piece of control equipment or changed the
existing process floor plan, a preconstruction review and permit modification was required.
Schering required 10 to 15 permit modifications each year, and each modification took 3 months
to 1 year to complete.

The New Jersey DEP agreed to allow flexibility for certain changes under Schering's facility-
wide permit without the preconstruction review. The agency proposed revised regulations in
December 1992 to accommodate this approach. The regulatory change that allows preapproved
pollution prevention changes is as follows:

       For a change to be considered an amendment under these new provisions, it must
       not increase the permitted concentration or rate of emission of any air contaminant
       for the production process or the entire facility. The change also cannot cause an
       increase in the generation of nonproduct output... per unit of production or
       increase the concentration or effluent limitation of any pollutant to waters of the
       state. Nonproduct output includes all outputs from a production process or source
       at a facility that are not intended to be sold as product... and is measured prior to
       treatment, out-of-process recycling or release to the environment....

       The change must also be incorporated in and be consistent with a Pollution
       Prevention Plan Modification or a Pollution Prevention Assessment.5


Contact:   Jeanne Herb
            Office of Pollution Prevention
            New Jersey Department of Environmental Protection
            609-777-0518
 5New Jersey Register, December 7,1992; 24 NJR 4323.
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Pollution Prevention in the Permitting Process
Section 2.0
          Flexible VOC Emissions Cap Permit
          Minnesota Pollution Control Agency
    Air
The 3M plant in St. Paul, Minnesota, is an industrial and consumer tape manufacturing facility.
The product requires frequent equipment changes, equipment modifications, and other
operational changes to accommodate new products and respond to customer needs. The facility's
ability to respond quickly was hindered by the traditional permit modification process.

After negotiations with 3M, the Minnesota PCA, and EPA, a flexible emissions cap permit was
granted in March of 1993.6 The flexible permit has three key features:

H  A facility-wide VOC emissions cap locked in at 3M's previously voluntary VOC reduction
    level

E  Improved monitoring and recordkeeping at the facility to ensure that VOC emissions do not
    exceed the cap

S  Elimination of the need to use the permit amendment process required for most operational
    and equipment changes.

The flexible permit offers benefits to 3M, the Minnesota PCA, and the environment. First, 3M
does not have to endure the lengthy and resource-intensive permit amendment process. For both
3M and the Minnesota PCA, the permit reduces staff resources that would normally be devoted
to permit modifications. The recordkeeping and monitoring requirements simplify enforcement
for the Minnesota PCA by providing detailed emissions information and ensuring compliance.
Finally, the environment benefits through now-mandatory VOC reductions and the indirect
incentive for pollution prevention via the emissions cap and allowing pollution prevention
implementation without permit modification.

Both 3M and the Minnesota PCA have found the permit workable and applicable to other
facilities. An interested facility must be willing and able to devote substantial resources to
developing the permit. Also, the trust required to award operational flexibility to a facility
demands that the facility have a good compliance record.
 6Although pollution prevention was not a driver for the flexible emissions cap permit, the cap provides an incentive
 for reducing pollution while allowing implementation of pollution prevention changes to the manufacturing process
 without permit modification.
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Pollution Prevention in the Permitting Process
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Contact:   Peggy Bartz
            Air Quality Division
            Minnesota Pollution Control Agency
            612-297-8113
          Using Pollution Prevention to Change Status from Major
          Source to Synthetic Minor
          U.S. Environmental Protection Agency
    Air
Facilities seeking to avoid a Title V permit have the option of applying for status as a synthetic
minor. A synthetic minor is any facility that would otherwise qualify as a major source, except
that the owner/operator voluntarily reduces emissions by one of the following methods:

m  Restricting the hours or methods of operation

m  Using pollution prevention measures to restrict the type or amount of polluting material
    stored, combusted, or processed

a  Accepting more stringent requirements on their pollution control devices.

EPA has seen the number of major air sources drop from 40,000 to 25,000 nationwide and a
concomitant increase in the number of synthetic minors.

2.2.4  Pollution Prevention  Planning
E
xamples of Pollution Prevention Planning
12

17


13

18


14

19


15

20


16

21


 Permitting agencies are using pollution prevention plans in a variety of ways to encourage cost-
 effective alternatives to end-of-pipe treatment, ranging from cooperative approaches with
 companies to mandatory approaches.
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Pollution Prevention in the Permitting Process
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         Title V Permits Requiring Development of Pollution
         Prevention Plan (two examples)
         Oregon Department of Environmental Quality
Example 1: The Oregon DEQ issued Intel a Title V permit that requires development of a
pollution prevention plan after the permit becomes effective. The permit lists several elements
that must be described in the plan:

M  Performance goals and objectives to conform to emissions limits through pollution
    prevention.

m  Partnership agreements with materials suppliers to reduce hazardous air pollutant (HAPs) and
    VOCs from raw materials/products.

m  Partnership agreements with the equipment vendor to reduce HAP and VOC emissions to the
    extent possible by integrating pollution prevention into equipment design.

S  Data collection necessary for the evaluation of pollution prevention effectiveness.

H  An employee training program to promote pollution prevention at the facility.

B  A statement of commitment to pollution prevention.

Contacts:  DaveDelarco
            EPA Region 10
            206-553-4978

            Marianne Fitzgerald
            Oregon Department of Environmental Quality
            503-229-5850

Example 2: The Oregon DEQ issued Composite Technologies, Inc., an air contaminant
discharge permit that requires subsequent development and eventual implementation of a
pollution prevention plan. The permit requires Composite to develop and submit a pollution
prevention plan to the Oregon DEQ within a certain time period after the  permit's issuance. The
plan must include the following:

M  A summary of ways in which the permittee could modify its process, raw materials, or final
    product so as to reduce the quantity and or toxicity of VOCs and HAPs emitted by the
    facility.
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Pollution Prevention in the Permitting Process
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H  An analysis of the feasibility and effect of implementing such process, material, and product
   changes at the facility. Emission reductions shall be verified using several specified formulas.

a  A comprehensive analysis of the ability to use vapor-suppressed resins and gel coats and a
   proposal for using these materials. The plan also must specify the proposed percentage of
   parts (based on square footage) that will be cast using vapor-suppressed resin and gel coats.

S  A list of other pollution prevention techniques that the permittee has or will implement and
   an implementation schedule.

The permit also stipulates that immediately after approval of the pollution prevention plan,
Composite must begin implementation. In addition, within 6 months of approval of the plan,
Composite must submit a report detailing the plan's accomplishments, including any emission
reductions and calculations supporting the reductions. Similar reports must be submitted to the
Oregon DEQ semiannually.

Contact:   Gary L. Andes
            Air Quality Program
            Oregon Department of Environmental Quality
            503-378-8240 ext. 234
          Pollution Prevention Plan as Part of the Permit Application
          Process
          New Jersey Department of Environmental Protection
    Air
As described earlier, Schering-Plough Corporation received a facility-wide, pollution prevention
permit as part of New Jersey's facility-wide permit program. Although New Jersey state law
required Schering to develop a pollution prevention plan as part of the facility-wide permit
process, the plan itself was not itself included in the facility-wide permit.

There are two major parts of the required pollution prevention plan. Part I includes facility- and
process-level materials accounting of the amounts of each hazardous substance used,
manufactured, stored, or incorporated in products at the facility, as well as the amounts recycled
or released to any environmental medium. Hazardous substances that are not incorporated in
products, either primary or secondary, are referred to as nonproduct output (NPO). The process-
level information must identify of the facility's processes, including any grouping of processes,
that meet the criteria for common elements permitted under the regulations. For each hazardous
substance, Part I also must include cost data on its use, generation of NPO, and release and
management. Part IB of the plan, due 1 year after submission of the original plan, requires
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PoHvrtion Prevention in the Permitting Process
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information on actual increases or reductions in NPO for the facility as well as for targeted
production processes. Part n of the plan includes a detailed economic and technical feasibility
analysis of the opportunities for reducing NPO per unit of output for the facility as a whole and
for targeted production processes. The outcome of Part II is the reporting of 5-year goals for
reducing the use and NPO of targeted hazardous substances.

The 5-year goals identified by Schering as part of the pollution prevention plan were not
enforceable requirements and are not used as a basis to ratchet down  emission limits in the
outyears of the facility-wide permit. The pollution prevention goals and approaches were,
however, considered in detail during the negotiations to develop the facility-wide permit. The
New Jersey DEP is relying on the financial and technical benefits of pollution prevention
opportunities identified in the facility's pollution prevention plan to influence emissions
reductions.
In fact, the pollution prevention plan was a major factor in initiating two major pollution
prevention breakthroughs. Schering eliminated the use of 1,1,1-trichloroethane as a solvent by
changing to equipment that uses an aqueous-based cleaner. Schering also is eliminating 70
tons/year of freon NPO through good housekeeping, product transfer piping upgrades, and the
installation of a $700,000 in-process freon recycling system. Schering expects to save $300,000
per year in raw material and waste disposal costs.
 Contact:   Jeanne Herb
            Office of Pollution Prevention
            New Jersey Department of Environmental Protection
            609-777-0518
          Granting POTWs the Authority to Require Their Significant      Water
          Industrial Users (SIUs) to Develop and Implement Waste       	
          Reduction Plans
          North Carolina Department of Environment, Health, and
          Natural Resources

 North Carolina made two changes to its administrative code to incorporate pollution prevention
 into pretreatment programs. The first change requires SIUs to summarize their activities to
 minimize pollutant loadings in industrial waste surveys and permit applications. This forces SIUs
 to analyze their pollution prevention activities and serves as a motivator for increased pollution
 prevention activity. The second change gave POTWs the authority to require their SIUs to
 develop a waste reduction plan and implement waste reduction techniques and technologies. This
 allows individual POTWs the discretion to require pollution prevention planning by their SIUs.
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Some North Carolina POTWs have instituted mandatory pollution prevention planning, and
others have left the planning voluntary while offering to conduct free pollution prevention audits.

The North Caroling DEHNR chose the voluntary pollution prevention plan approach. Instead of
requiring a pollution prevention plan from SIUs, the North Carolina DEHNR conducts a
pollution prevention assessment of willing SIUs. If technical pollution prevention questions are
uncovered by the audit, North Carolina DEHNR's pollution prevention technical assistance
program is brought in to provide technical assistance. North Carolina staff believe the incentive
of cost reduction, combined with the free technical assistance and required reporting of pollution
prevention progress, has led to increased pollution prevention implementation at SIUs. Most of
the success has been with large companies, while pollution prevention in smaller businesses has
only been somewhat successful.

The Charlotte-Mecklenburg Utility Department requires its SIUs to submit a waste reduction
plan within 6 months of the issuance of the SIU's permit. The North Carolina DEHNR conducts
pollution prevention assessments upon request, or the SIU can hire a private consultant to aid in
the drafting of the waste reduction plan. The program has been very successful, with some of the
SIUs reducing their waste to the point where a pretreatment permit is no longer needed. In
addition, three SIUs used their waste minimization experience to successfully apply for $2,000
grants from a state small business advisory board to develop new pollution prevention
technology. North Carolina DEHNR was inundated with SIU requests for pollution prevention
assessments.

Contacts:  Jane Pieczynski or Linda McSwain-Randall
            Winston-Salem Industrial Waste Control
            910-765-0134

            Jackie Townsend
            Charlotte-Mecklenburg Utility Department
            704-391-5100

            Lindsay L. Mize
            Division of Pollution Prevention and Environmental Assessment
            North Carolina Department of Environment, Health, and Natural Resources
            919-715-6500
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Pollution Prevention in the Permitting Process
Section 2.0
         Permit Allowing Termination with Implementation of Best       Water
         Management Practices                                        	
         Washington Department of Ecology

The Washington Department of Ecology (DOE) developed a general NPDES permit for dairy
farming operations that requires development and compliance with a waste management plan.
The plan must be developed and implemented by the dairy farm and is enforceable by the
Washington DOE. The permit, however, can be terminated if both of the following are submitted
to the Washington DOE:

B A copy of the current animal waste management plan

• A statement signed by the owner that (1) all facilities and best management practices have
   been installed and have been in operation for not less than 36 months and (2) there has not
   been a violation of permit conditions for the past 36 consecutive months.

The Washington DOE will respond to the request for termination by conducting a site inspection
and a review of the permit file. A written determination either terminating coverage under the
general permit or denying the request will be sent to the permittee. This termination clause
provides the incentive for the dairy farm to implement best management practices, including
pollution prevention measures, and rewards the permittee for this responsible behavior.

Contact:   Bill Moore
            Washington Department of Ecology
            360-407-6444
          Model Wastewater and Storm Water Permit Language
          Washington Department of Ecology
 Water
 This model permit requires the permittee to develop and implement a best management practices/
 pollution prevention (BMP3) plan for wastewater and storm water discharges within 6 months of
 the effective date of the permit. The permittee must develop a summary of the BMP3 plan and an
 annual implementation progress report, which must be kept at the facility and made available to
 the Washington DOE upon request. In addition to the BMP3 plan, the permittee must conduct a
 waste minimization assessment (WMA) to determine actions that can be taken to reduce waste
 loadings and chemical losses to all wastewater and storm water. The WMA must be implemented
 as soon as is practical after development.
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Pollution Prevention in the Permitting Process
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The permit cites the authority for requiring the BMP3 plan and WMA. The permittee must
develop and implement a plan for utilizing practices incorporating pollution prevention
measures. References to be considered in developing the plan are listed. The following sections
of the permit provide a description of the BMP3 plan, including requirements, signature
authority, and management responsibilities.

       Best Management Practices/Pollution Prevention Plan

       The Permittee shall develop and implement a BMP3 plan for the facility which is the
       source of wastewater and storm water discharges covered by this permit. The plan shall
       be directed toward reducing those pollutants of concern which discharge to surface waters
       and shall be prepared in accordance with good engineering and good housekeeping
       practices. For the purposes of this permit, pollutants of concern shall be limited to toxic
       pollutants ... known to the discharger. The plan shall address all activities which could
       or do contribute these pollutants to the surface water discharge, including process,
       treatment, and ancillary activities.

       Signatory Authority and Management Responsibilities

       The BMP3 plan shall be signed ... and reviewed by the plant engineering staff and plant
       manager....

       The BMP3 plan shall contain a written statement from corporate or plant management
       indicating management's commitment to the goals of the BMP3 program. Such
       statements shall be publicized or made known to all facility employees. Management
       shall also provide training for the individuals responsible for implementing the BMP3
       plan.

       BMP3 Plan Requirements

       a.  Name and description of facility, a site map illustrating the location of the facility and
           adjacent receiving waters, and other maps, plot plans, or drawings, as necessary

       b.  Overall objectives (both short-term and long-term) and scope of the plan, specific
           reduction goals for pollutants, anticipated dates of achievement of reduction, and a
           description of means for achieving each reduction goal

       c.  A description of procedures relative to spill prevention, control, and countermeasures
           and a description of measures employed to prevent storm water contamination
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Pollution Prevention in the Permitting Process
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       d.  A description of practices involving preventative maintenance, housekeeping, record-
          keeping, inspections, and plant security

       e.  The description of a waste minimization assessment performed in accordance with the
          conditions outlined ..., results of the assessment, and a schedule for implementation
          of specific waste reduction practices.7

In addition to the BMP3 plan, the permit stipulates that the WMA must consist of a plant water
balance, material and risk assessments, pollutant reduction methods, and a storm water
evaluation. The plant water balance is used to determine opportunities for water  conservation,
water reuse/recycling, and leak detection. The WMA's material and risk assessment should
include identification of the types and quantities or materials used and their effect on human and
ecological health. Regarding the pollutant reduction methods, the permit mandates that the WMA
reduce pollutant discharges in wastewater streams using process-related source reduction
measures, housekeeping changes, recycling, and treatment. Finally, the permit stipulates that the
WMA should evaluate the following potential sources of storm water contamination:

m  Loading, unloading, and transfer areas for dry bulk materials or liquids
a  Outdoor storage of raw materials or products
m  Outdoor manufacturing or processing activities
m  Dust or particulate generating processes
m  Onsite waste and/or sludge disposal practices.

Contact:   Bill Moore
            Washington Department of Ecology
            360-407-6444
          Submission of Waste Minimization Plans as a RCRA Permit
          Requirement
          EPA Regions 2, 5, and 7
          Ohio Environmental Protection Agency
          Arizona Department of Environmental Quality
 RCRA
 7Washington Department of Ecology, Examples of Pollution Prevention in Permits (Spring 1995) (assembled by
 Ross & Associates Environmental Consulting, Ltd. for Pollution Prevention Training).
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Pollution Prevention in the Permitting Process
Section 2.0
EPA Regions 2, 5, and 7 and Ohio require permitted hazardous waste management facilities to
complete pollution prevention plans (also referred to as waste minimization plans or hazardous
waste reduction plans) as a condition of their RCRA permit:

       the permittee [must certify that it] has a program in place to reduce the volume
       and toxicity of hazardous waste that he generates to the degree determined by the
       permittee to be economically practicable	[40 CFR 264.73(b)(9)]

This is known as the "program in place" requirement.

The criteria for completing plans are contained in EPA's Waste Minimization Opportunity
Assessment Manual (EPA/625/7-88/003, July 1988) and the similar Ohio planning guide.

Region 2 builds a working relationship between federal and state programs. New York's
planning requirement applies specifically to the largest generators, as well as to treatment,
storage, and disposal facilities (TSDFs) that generate waste. New Jersey's requirement applies to
priority facilities that generate hazardous substances. A RCRA permittee can submit the plan
prepared for New York to meet Region 2's permit requirement; the same is true, with only minor
modifications, for the New Jersey plans. Since 1991, only one facility challenged this  process,
but it later withdrew its challenge after a Regional permit writer visited the facility to discuss the
types of waste minimization alternatives to be considered and the purpose and benefits of the
process.

Ohio uses an expanded interpretation of the RCRA "program in place" language as the basis for
requiring development and submission of plans by TSDFs. It does, however, have a statutory
requirement for pollution prevention plans for facilities using deep well injection to dispose of
hazardous wastes. In addition, Ohio EPA's Office of Pollution Prevention (OPP) provides
technical assistance to facilities in developing and writing plans.  OPP also assists inspectors in
reviewing plans.

Arizona adopted a permit module developed by Region 9 that requires waste minimization
planning in RCRA permits developed by Region 9. In addition to certifying that the facility has a
waste minimization program in place, the module bases this requirement on RCRA omnibus
authority. The module, which has been included in all recent hazardous waste permits in Arizona,
also requires implementation of the plan.

EPA Region 7 includes the waste minimization model language in the general facility conditions
module of the permit. The permit requires the permittee to submit an annual certification and
report that documents compliance with the waste minimization program in-place certification.
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Pollution Prevention in the Permitting Process
                           Section 2.0
Contacts: Michael Poetzsch
           Hazardous Waste Facilities Branch
           Region 2
           212-637-4147

           Anthony Sasson
           Office of Pollution Prevention
           Ohio Environmental Protection Agency
           614-644-2810

           Hak Cho
           RCRA Permitting Branch
           EPA Region 5
           Indiana Section
           312-886-0988
Donna Twickler
RCRA Permitting Branch
EPA Region 5
312-886-6184

Alan Wehmeyer
Pollution Prevention
EPA Region 7
913-551-7315

Gail Bliss
RCRA Waste Minimization
Arizona Department of Environmental
Quality
602-207-4212
          Require Written Description of Plans to Reduce Pollution
          North Carolina Department of Environment, Health, and
          Natural Resources
                          RCRA,
                        Air, Water
North Carolina's 1989 Hazardous Waste Management Act requires all water or air quality permit
holders or applicants to submit a written description of current and projected plans to reduce the
discharge of waste and pollutants or to reduce the emissions of air contaminants through source
reduction or recycling. Detailed facility planning requirements are not specified in the statute.
The written description is not part of the permit application and does not serve as the basis for
denial of a permit or permit modification. Hazardous waste generators and operators of
hazardous waste treatment facilities that treat waste on site are required to submit a written
description of any program to minimize or reduce the volume and quantity or toxicity of such
waste at the time of the payment of the annual fee. Waste generation fees are adjusted to
encourage waste reduction.

Contacts:  William L. Meyer
            Division of Solid Waste Management
            919-733-4996

            Gary Hunt
            Office of Waste Reduction
            919-571-4100
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Pollution Prevention in the Permitting Process
Section 2.0
         Require/Encourage Commercial TSDFs to Work with            RCRA
         Generators to Reduce Waste                                   	
         California Department of Toxic Substances Control

California uses the authority provided in its Health and Safety Code, Title 22 to require its two
commercial TSDFs to work with their generators to reduce waste. The California DTSC and
Kettleman negotiated a permit that requires the Kettleman Hills Facility to provide "a detailed
description of any programs the permittee may have to assist generators of hazardous waste in
reducing the volume or quantity and toxicity of wastes they produce." The permit also requires
Kettleman to report the names of customers who have used or received pollution prevention
information from Kettleman, those who have a waste minimization program in place, and known
results of their programs. Waste Management, Inc., which manages Kettleman, operates a waste
minimization consulting service to assist its customers in waste reduction/pollution prevention
evaluations.

Contact:  William Veile
            California Department of Toxic Substances Control
            916-255-3545
         Coordination of TSDF Permit Provisions and State Waste       RCRA
         Minimization Facility Planning Requirements                   	
         California Department of Toxic Substances Control

Under California's Hazardous Waste Source Reduction and Management Review Act, permittees
generating RCRA or California hazardous wastes in excess of specified limits are required to
develop waste minimization plans. California permits contain language that requires generators
to have a program in place to reduce waste. California usually does not include expanded waste
minimization conditions in the permits. In the case of onsite TSDFs, permit writers are directed
to review facility plans for completeness and to ensure consistency with the permit application. In
addition, permit writers can incorporate the facility's voluntary efforts into the permit. While
time and resources to review the plans are limited, and resource constraints sometimes prevent
such evaluations, there are specific cases where the analysis has led to additional permit
requirements.
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Pollution Prevention in the Permitting Process
Section 2.0
Contact:   Alan Ingham
           HQ Pollution Prevention
           California Department of Toxic Substances Control
           916-322-3670
         Include Pollution Prevention Incentives in the MACT rule
         for Hazardous Waste Incinerators, Cement Kilns, and
         Lightweight Aggregate Kilns
         U.S. Environmental Protection Agency
RCRA,
  Air
EPA included pollution prevention incentives in EPA's Clean Air Act maximum achievable
control technology (MACT) standards for hazardous waste incinerators, cement kilns, and
lightweight aggregate kilns. One incentive allows EPA to grant facilities a 1-year extension (on a
case by case basis) to the 3-year compliance period if needed to install pollution prevention
measures to achieve MACT standards. The second incentive invites facilities to propose projects
in cases where the installation of pollution prevention measures will surpass MACT standards,
but other regulatory flexibility is needed to complete the changes. Those proposals are handled
under EPA's Project XL voluntary initiative.

2.2.5  Explicit Pollution Prevention Conditions in Permits
Examples of Exf
>licit Pollution Prevention Conditions in Permits
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         Temporary Increase in Emissions in Exchange for Long-
         Term Pollution Prevention
         Massachusetts Department of Environmental Protection
    Air
The Massachusetts DEP agreed to a temporary increase in a company's VOC emissions to allow
for expanded production in exchange for a permit condition that will lead to greater long-term
reductions in facility-wide emissions. The company also agreed to an enforceable pollution
                                                                                2-29

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Pollution Prevention in the Permitting Process
Section 2.0
prevention implementation schedule with completion dates and project goals. The permit
language reads as follows:

       ABC Corporation will implement the following schedule of modifications/installations to
       reduce VOC and [halogenated organic compound] HOC emissions from the facility to the
       original VOC and HOC emission caps by December 1, 1996.

       1.  By the end of August 1995, a nonchemical leak detection system will be installed,
          which will reduce the HOC emissions by approximately 3,000 pounds per month.

       2.  By the end of August 1995, introduce a nitrogen replacement for the freon flushing in
          select coating operations, which will reduce HOC emissions by approximately 110
          pounds per month.

       3.  By the end of December 1995, alcohol flushing stations with integral recycling will be
          installed, which will reduce HOC emissions by approximately 600 pounds per month.

       4.  By the end of March 1996, a filtration system to capture and control VOC emis-
          sions. .. will be installed, which will reduce VOC emissions by approximately 1,000
          pounds per month.

       5.  By the end of December 1996, eliminate distillation with the elimination of freon use,
          which will reduce HOC emissions by approximately 490 pounds per month.

Contact:   Rich Bizzozero
            Office of Technical Assistance for Toxics Use Reduction
            Massachusetts Department of Environmental Protection
            617-727-3827
          Pollution Prevention Implementation in Exchange for
          Reduced Monitoring and Recordkeeping
          North Carolina Department of Environment, Health, and
          Natural Resources
    Air
 North Carolina reasonably achievable control technology (RACT) rules allow use of a low-VOC
 emission "compliant coating" as an alternative to a permit-prescribed, numerical daily emission
 limit. Consequently, a company's required recordkeeping is reduced from a daily calculation of
 emissions to merely certifying use of a compliant low-VOC emission coating. In addition to
 greatly reduced monitoring and recordkeeping, the company that uses the low-emission coating
                                                                                 2-30

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Pollution Prevention in the Permitting Process
Section 2.0
does not have to worry about violating a permit-required emission limit, and resource demands
on the permit agency are reduced.

Contact:   Peter Lloyd
            North Carolina Department of Environment, Health, and Natural Resources
            919-715-6238
          Permit Requires Evaluation of Substitute Material for BACT
          Standard Determination
          Massachusetts Department of Environmental Protection
The Massachusetts DEP issued Dow Jones & Company a permit that requires technical
evaluation of a specific material that potentially could be used as a pollution prevention process
substitute that meets the facility's "best available control technology" (BACT) standard. The
permit states:

       Dow Jones & Company shall test Ecolo 4.08 (or chemical equivalent) to determine
       whether it is a suitable replacement for the existing blanket wash and/or cleaning
       solution. Dow Jones & Company shall submit a written report on the performance
       of the cleaning solution tested within 60 days  after the issue date of the
       conditional approval. The report shall address the following questions:

       m Can the solution be used to clean the equipment? Explain.
       fi Level of effort necessary to clean equipment compared to existing solutions.
       S Quantity of solution needed to clean equipment compared to existing solutions.
       m The cost of trial cleaning solutions compared to existing solutions.

Contact:  Rich Bizzozero
            Office of Technical Assistance for Toxics Use Reduction
            Massachusetts Department of Environmental Protection
            617-727-3827
 Ecolo 4.0 is a low-VOC cleaning solution.
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Pollution Prevention in the Permitting Process
Section 2.0
          Guidance for Incorporating Pollution Prevention into
          Permits
          Massachusetts Office of Technical Assistance
    Air
The Massachusetts Office of Technical Assistance prepared training materials to guide permit
writers in incorporating pollution prevention in permits. The guidance lists the domains in which
pollution prevention conditions may be instituted in permits. The following pollution prevention
measures may be considered for incorporation:

a   Fugitive emission reduction
a   Process modification if proposed by applicant
81   Material and product substitutions if proposed by applicant
a   Preventive and corrective maintenance
a   Routine equipment inspections
a   Proper material handling and storage procedures
B   Loss prevention practices
B   Employee training programs
a   Material tracking and inventory control
Si   Improved documentation
a   Environmental audits.

The following is an example of loss prevention language from a Massachusetts Department of
Environmental Protection permit:

       All open holding tanks, mixing tanks, and kettles shall be covered with lids except
       to add ingredients, take samples, or perform maintenance. The lid of each such
       tank shall extend 0.5 inch beyond the outer rim of the tank and maintain contact
       with 90% of the tank's rim circumference.

The following is an example of process and material substitution permit language from another
Massachusetts DEP permit:

       ABC Printing shall continue to investigate the feasibility of implementing
       alternative technologies or reformulated raw material inputs including, but not
       limited to, inks, fountain solutions, and cleaning solutions which  will lead to the
       decrease of overall emissions to the environment.... The facility shall seek
       assistance from outside sources such as ink and solvent suppliers, vendors, or the
       Office of Technical Assistance.... ABC Printing company personnel shall record
       any information supplied to them relative to reducing overall emissions and
       pollution prevention techniques. This information as well as any progress toward
       decreasing overall emissions to the environment shall be recorded in an
       Environmental Logbook.
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Pollution Prevention in the Permitting Process
Section 2.0
Contact:   Rich Bizzozero
            Office of Technical Assistance for Toxics Use Reduction
            Massachusetts Department of Environmental Protection
            617-727-3827
         Three-Tier Storm Water Permit System Using Less              Water
         Recordkeeping, Monitoring, and Inspections as Incentives    	
          Wisconsin Department of Natural Resources

Wisconsin's storm water regulations prescribe a three-tier system of permits as an incentive for
pollution prevention. Tier one consists of heavy manufacturing such as petroleum refining and
chemicals, while tier two is for light manufacturing like electronics and tobacco products. Tier
three is reserved for facilities that do not discharge contaminated storm water. By reducing storm
water pollution through pollution prevention methods, a company can move through the tier
system. The Wisconsin DNR provides a checklist for companies that are attempting to move
between tiers. Companies that move to a new tier using pollution prevention are rewarded with
reduced recordkeeping, monitoring, and inspections. Permit fees are also reduced.

Contact:   Anna Sundberg
            Bureau of Watershed Management
            Wisconsin Department of Natural Resources
            608-264-8535
          Pollution Prevention Requirements in Significant Industrial     Water
          User Permits                                                   	
          Palo Alto Water Quality Control Plant

In 1993, the Palo Alto WQCP began exploring pollution prevention approaches with six metal
finishing and circuit board facilities that discharge to its system. The effort resulted in a set of
pollution prevention measures called "Reasonable Control Measures" (RCMs) that are widely
applicable, generally feasible for all operations, have a simple payback period of 5 years or less,
and meet safety and product quality criteria. The RCMs are incorporated into pretreatment
permits for metal finishers. Metal finishers have a choice of two permitting options:
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Pollution Prevention in the Permitting Process
Section 2.0
B  Concentration limit option. The metal finisher must install each of the RCMs and meet an
   annual average copper concentration limit of 0.4 mg/1 of wastewater discharge.

B  Mass limit option. A metal finisher can request a pollution prevention assessment (completed
   by the Palo Alto WQCP) to set facility-specific annual copper discharge mass limits that
   must be met using pollution prevention measures identified in the pollution prevention
   assessment.

Contact:   Tom Barren
            Pollution Prevention Consultant
            510-283-8121
          Require Licenses/Permits for Generators with Pollution         RCRA
          Prevention Provisions                                          	
          Broward County and Dade County, Florida

The Broward County Department of Natural Resource Protection developed a set of pollution
prevention-based best management practices (BMPs) in partnership with the marine industry in
the area. These consensus BMPs are incorporated into the licenses of all regulated marine
facilities in the county.

The Dade County Department of Environmental Resources Management requires annual
operating permits for all polluters, including all generators of hazardous waste (LQGs, SQGs, or
CESQGs). Where a single business releases pollution to more than one medium, the Dade
County DERM is working to coordinate issuance of all the media permits in a single, multiple-
source annual operating permit. Industry-specific multimedia pollution prevention BMPs are
being included as attachments to permits. The BMPs are not enforceable but are
recommendations to the businesses. BMPs have been developed for vehicle maintenance
operations, boat builders, and paint and body shops.

Contacts: KayGervasi
            Pollution Prevention Program
            Broward County Department of Natural Resource Protection
            305-519-1257

            Ted James
            Associated Marine Technologies, Inc.
            305-926-030
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Pollution Prevention in the Permitting Process
Section 2.0
            Nichole Hefty
            Dade County Department of Environmental Resources Management
            305-372-6825

2.2.6  Pollution Prevention through Permit Process Incentives
             Examples of Pollution Prevention through Permit Process Incentives
                                              30
Some states base permit fees on the amount of pollutant generated, creating a built-in incentive
for pollution prevention. Others promise expedited permit review for facilities that implement
pollution prevention. Still other states will waive the preconstruction permit requirement for
facilities that plan to use pollution prevention techniques.
  29    Pollution Prevention Commitment in Exchange for
  	'   Expedited Permit
          Michigan Department of Environmental Quality
    Air
Michigan's Clean Corporate Citizen program grants permit-process incentives to companies that
commit to identify pollution prevention options; establish pollution prevention goals; report on
accomplishments; participate in information and technical exchange programs; and maintain an
environmental management system, which includes an identification of environmental impacts,
self-initiated compliance audits, public participation, a strong and clear statement of the
company's commitment to environmental excellence, and environmental training for employees.
Companies must also demonstrate consistent compliance with all applicable environmental
requirements.

Permit process incentives include (1) approval to begin construction of a facility or process while
the air use construction permit is under review; (2) a decision on the company's permit applica-
tion within 30 days of receiving the complete application; and (3) eligibility for a facility-wide
emissions cap, which allows installation of process changes without applying for permit modi-
fication if the emissions stay below the established cap. A facility-wide emission cap permit
requires the  facility to conduct monitoring and recordkeeping to verify that the cap is being met.
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Pollution Prevention in the Permitting Process
Section 2.0
Contact:   Wendy Fitzner
            Environmental Assistance Division
            Michigan Department of Environmental Quality
            1-800-662-9278
          Use of Permit Fees as an Incentive
          Washington Department of Ecology
    Air
The Washington DOE reduces permit fees and/or reporting requirements for facilities undergoing
new source review, general registration, or operating permit applications. Fees are based on
emissions, and fee reductions are tied to pollution prevention.
Contact:   Stu Clark
            Air Division
            Washington Department of Ecology
            360-407-6873

2.2.7  Pollution Prevention through Whole-Facility Permits
               Examples of Pollution Prevention through Whole-Facility Permits
 Whole-facility permits encourage companies and permitting agencies to deal with all pollutant
 sources simultaneously rather than as isolated permit requirements on various permit schedules.
 This approach has the potential to reduce the generation of pollutants from a variety of sources
 without shifting pollution from one media to another, which sometimes happens in media-
 specific end-of-pipe control situations (e.g., air pollutants removed by wet scrubbers become
 wastewater, which may be treated to produce a hazardous sludge). Only a few states have tried
 this approach.
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Pollution Prevention in the Permitting Process
Section 2.0
          Multimedia Pollution Prevention Permitting Pilot Project        RCRA
          New Jersey Department of Environmental Protection           	

The New Jersey Pollution Prevention Act of 1991 (NJPPA) requires facilities covered by the
Toxic Release Inventory provisions of Section 313 of the federal Emergency Planning and
Community Right-to-Know Act (EPCRA) to prepare pollution prevention plans that must be
revised every 5 years, pollution prevention plan summaries, and annual pollution prevention plan
progress reports. Summaries and progress reports are public documents.

The NJPPA includes provisions for a multimedia, whole-facility permitting pilot project, under
which  18 facilities that volunteer for the program are eligible to receive a single, whole-facility
permit rather than individual media-specific permits. The environmental benefits and cost
savings to facilities were anticipated to outweigh the complexity of embarking on this approach.
The foundation for a whole-facility permits is the multimedia pollution prevention plan.

The NJPPA gives the state the authority to require more stringent emission or effluent levels
based on pollution prevention strategies contained in a plan. Rather than mandating pollution
prevention solutions, however, the New Jersey Department of Environmental Protection decided
to rely on cost savings, improved compliance incentives, and public pressure in the case that the
facility does not implement pollution prevention solutions. As a result, facilities make individual
decisions regarding selection of pollution prevention opportunities to achieve permit limits.

A team of pollution prevention experts and permit-writers visited facilities frequently,
encouraged frequent  discussions that explored tradeoffs between pollution prevention solutions
and permitting requirements, and provided technical assistance.

The Schering Corporation facility  in Kenilworth received the program's first draft facility-wide
permit in September  1994. The batch-operation pharmaceutical manufacturer generated and
shipped large quantities of RCRA hazardous waste to offsite  management facilities. Schering had
permits for its two surface water discharge points and held 85 air permits. Development of the
draft Schering permit took 3 years. The Schering whole-facility permit resulted in substantial
reductions in generation of hazardous waste and in emissions of unregulated fugitive air
emissions.
 Contact:   Jeanne Herb
            Office of Pollution Prevention
            New Jersey Department of Environmental Protection
            609-777-0518
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Pollution Prevention in the Permitting Process
Section 2.0
          Multimedia Permitting Pilot Project
          Delaware Department of Natural Resources and
          Environmental Control
RCRA
The Delaware DNREC and the DuPont Company jointly developed a model approach for
incorporating pollution prevention into a multimedia permit. The model produced a process
strategy, a multimedia permit application, and permit format. A medium-sized metal fabricator,
which is covered by Toxic Release Inventory reporting requirements, Title V air requirements,
storm water requirements, and RCRA hazardous waste generator requirements, agreed to
participate as a pilot facility and, working with the state-industry team, submitted its multimedia
permit application in May 1995.

The team completed a pollution prevention assessment and multimedia inspections; identified
opportunities for reduced or consolidated reporting; and developed a one-page permit summary
that describes all of the facility's emission limits, reporting requirements and dates, and
monitoring requirements. The pilot project did not result in the issuance of a multimedia permit,
but it did accomplish its goals of multimedia coordination and identification of an opportunity to
potentially eliminate the facility's main air emission. The pilot facility continues its excellent
working relationship with the Delaware DNREC's regulatory programs. In fact, the facility was
the first in the state to submit its Title V application.

Front-end pollution prevention assessments  are currently being used in other permitting programs
at the Delaware DNREC. The cross-media and pollution prevention training provided to DNREC
staff continues to be used in permitting and compliance activities and in interaction with facilities
and the public.

Contact:   Andrea Kreiner
            Pollution Prevention Program
            Delaware Department of Natural Resources and Environmental  Control
            302-739-3822
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Section 3.0
Promoting Pollution Prevention through
Inspection Activities
States and EPA Regional offices have developed a variety of approaches to promote pollution
prevention solutions to reduce compliance problems. This section answers questions about how
to include pollution prevention in the inspection and compliance assistance process and discusses
examples of approaches used by states and EPA Regions.

3.1   What Do I Need to Know?

What is the inspector's role in promoting pollution prevention?

      The traditional role of compliance inspectors has been to assess facility compliance with
      environmental laws and regulations. While this role seems clear, it brings with it an
      unavoidable practical tension—because inspectors are so versed in compliance
      requirements, they are also ideally positioned to explain how facilities can return to
      compliance. Facilities often misconstrue compliance assistance information as a
      compliance requirement. In cases where the outcome has not resulted in full compliance,
      inspectors find themselves at risk.

      To overcome this dilemma, many states and EPA have embarked on compliance
      assistance programs. EPA Office of Compliance believes compliance assistance and
      enforcement of regulations are crucial and can be accomplished without breaching
      enforcement responsibilities. Many states
      and EPA provide compliance assistance as a
      supplement to the inspection process.
      Some of the most commonly noted roles for
      inspectors include the following:

      S  To provide handouts and fact sheets on
         pollution prevention success stories from
         similar companies, how to access
   Roles for Inspectors Promoting
        Pollution Prevention

•  Provide technical information.
S  Ask pollution prevention questions and
   discuss questions or ideas.
B  Provide access to follow-up.
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                                                Pollution Prevention Solutions vs. Legal
                                                Requirements: How to Avoid Confusion

                                                 Present pollution prevention discussions in a way
                                                 that avoids misinterpreting options and ideas as
                                                 compliance requirements.
                                                 Be aware of agency policy concerning inspectors
                                                 roles in compliance and pollution prevention
                                                 assistance.
         telephone- and computer-based
         pollution prevention technical
         assistance, industry and regulatory
         contacts, emerging trends in
         technology, and training and
         educational opportunities.

      H  To ask pollution prevention
         questions about processes or
         sources of waste. Inspectors also
         discuss questions and ideas and help the company expand its understanding of the
         potential benefits of pollution prevention.

      m  To establish contact with pollution prevention experts, permit writers, and inspectors
         from other media to help the facility focus on possible multimedia pollution
         prevention approaches.

      Inspectors should try to avoid misinterpretation of options, suggestions, and ideas by
      clarifying the separate natures of determining compliance and discussing pollution
      prevention information that could help the facility return to compliance. Some of the
      approaches to this include the following:

      9  Be aware of department policy on the procedures for making pollution prevention
         suggestions to prevent misunderstandings.

      m  Present information in a way that clearly separates compliance determinations from
         pollution prevention and compliance assistance.

When in the inspection processshould pollution prevention be discussed?

      m  Entrance or preliminary meeting. Ask  questions about the facility's awareness of
          pollution prevention alternatives and any past accomplishments.

      m During inspection. Ask to see where waste originates in the facility's processes and
          ask if pollution prevention alternatives,  such as material substitutions, process
          changes, or improved operating practices, have been considered to reduce waste
          generation. If the state requires the development of a pollution prevention plan,
          review the facility's goals and accomplishments in implementing the plan. At RCRA
          facilities,  ask the facility to describe the elements of its waste minimization program
          in place. Provide the facility with information on pollution prevention.
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                                                   When to Discuss Pollution Prevention

                                                H  During entrance or preliminary meetings.

                                                U  During inspections.
                                                S  After inspections.
       S  After inspection. Make note of
          pollution prevention strategies or
          options identified during the
          inspection. Provide names of
          pollution prevention technical
          assistance contacts, and attach
          pollution prevention information
          to the inspection report.

How do I prepare for an inspection
where I want to explore or promote
pollution prevention options?

       Although inspectors do not have to
       become experts on production
       processes to promote pollution
       prevention opportunities, some state
       and EPA inspectors have elected to
       build their technical expertise in
       particular industry-sector operations
       and processes by attending pollution
       prevention training courses. On the
       other hand, it takes very little
       production process expertise to refer
       the facility to pollution prevention
       technical assistance staff or
       distributing fact sheets or other
       process-specific technical materials.

       Certain information should be
       obtained before beginning a
       compliance inspection. Ask to see the
       sources of significant waste streams,
       the reasons for using materials or                    _----—~~-—---^^
       methods of operation that lead to
       generation of pollutants (particularly for any resulting in compliance problems), and the
       availability and feasibility of less polluting processes or material alternatives. As in the
       permitting process, there are several information sources that can be reviewed before or
       after visiting the facility. In addition to the sources listed in Section 2.1, the following
       sources are useful when preparing for inspections:

       8 Process-flow diagrams and operating records. Facilities interested in full-scale
           pollution prevention assessments may have other facility records that provide
                                                 Questions to Answer before an Inspection

                                                 I   How much hazardous waste does the facility
                                                    generate and manage? What types of production
                                                    processes generate the waste? Get Biennial
                                                    Report System data. Ask for process flow
                                                    diagrams.
                                                 I   What toxic chemicals does the facility release?
                                                    Get Toxic Release Inventory (TRI) data.
                                                 1   What types of releases/discharges does the
                                                    facility have? Where has it had problems meeting
                                                    limits for these releases/discharges? Review
                                                    permits and past inspection reports for all media
                                                    programs.
                                                 I   Has a state-required pollution prevention plan
                                                    been prepared? Is the plan, a plan summary, or
                                                    an annual progress report available? Check with
                                                    the agency pollution prevention staff.
                                                 I   Are there  any pollution prevention case studies or
                                                    technical brochures available for similar facilities?
                                                    Look into  Enviro$en$e or other pollution
                                                    prevention databases. Call the state pollution
                                                    prevention staff.
                                                 1   Is there any free technical assistance available?
                                                    Is it confidential? Call the state pollution
                                                    prevention staff.
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Promoting Pollution Prevention through Inspection Activities
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          information about material use and generation of pollutants. These records include
          process-flow diagrams, material safety data sheets, purchasing records, production
          logs, vendor information, production specifications, product-to-raw material data,
          equipment lists, facility layout information, rejected product records, or expired stock
          records.

       m  Permit and inspection files. Permits and inspection files may identify releases and
          processes that are amenable to pollution prevention alternatives.

Where should I look for pollution prevention opportunities?

       During the course of the inspection, the inspector should discuss operating procedures,
       materials usage, and technologies that are involved in waste generation and alternatives
       considered to reduce waste.

       a  Operation and maintenance improvements. Operation and maintenance
          improvements can prevent air and water pollution and reduce the generation of waste.
          Examples include inventory control to reduce waste resulting from overstocking or
          out-of-stock materials, preventive maintenance to reduce spills or leaks to air and
          water, and improved housekeeping and materials management.

       m  Technology changes. Technology changes range from minor adjustments in the
          design and efficiency of equipment to the installation of new technology. Pollutant
          reductions can result from inexpensive changes or from major capital outlays.

       a  Input/material changes. Input/material changes involve replacing hazardous
          chemicals  with other less toxic      _	
          chemical alternatives that are
          equivalent in performance.
          Examples of material substitution
          include replacement of solvent
          degreasers with aqueous cleaning
          systems or replacement of
          chlorinated bleaches with non-
          chlorinated bleaches in paper
          manufacturing processes.
           Product redesign. Changes made
           to the composition of the end
           product to cause less environ-
           mental impact and/or to increase
           product life usually require careful
           attention. Many companies,
 How to Identify Pollution Prevention
           Opportunities

Ask if the facility has a pollution prevention plan
or a waste minimization program and if the facility
has implemented any pollution prevention or
recycling techniques.
Ask to talk to the facility's pollution prevention
coordinator.
Ask about the sources of waste generation and
materials used in the facility's processes.
Identify releases to the environment, which media
they affect, and how much pollution results from
each.
Ask if line workers have suggested ways to
reduce waste.
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Promoting Pollution Prevention through Inspection Activities
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          however, have been successful with this approach. Examples include redesigning
          paints to eliminate heavy metal pigments and redesigning inks to use a water base
          instead of a solvent base.

       M  Recycling opportunities. Examine opportunities to recycle wastes in a closed-loop
          manner in the same process, in onsite recycling/recovery processes, as raw materials
          into other onsite production processes, at offsite commercial recovery facilities, or as
          raw materials into other offsite production processes. Waste exchanges provide
          opportunities to identify potential markets for materials that are wastes for one
          industry but usable raw materials for another.

3.2   Examples of Approaches

Some agencies have used the compliance inspection process as an opportunity to work with
companies to identify cheaper, smarter, cleaner compliance solutions in cases where end-of-pipe
treatment approaches may be experiencing compliance problems. The approaches in this section
require some "out-of-the-box" thinking, but in many cases have paid off for both sides—
companies find a cheaper, cleaner, smarter compliance solution, and government agencies can
report improved environmental performance.

This section provides 21 approaches for incorporating pollution prevention in the inspection
process. The examples are divided into eight categories:

S  Distribution  of literature
m  Review program-in-place certifications
m  Joint inspections with pollution prevention staff
M  Providing technical information and recommendations during inspection
@  Referral to state technical assistance
H  Multimedia inspections
a  Linking compliance assistance to inspection
3  Recognition  programs.

3.2.1  Distribution of Pollution Prevention Literature
                  Examples of Distribution of Pollution Prevention Literature
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Distributing fact sheets and brochures on pollution prevention provides initial access to pollution
prevention strategies and information and has been used successfully in many states and EPA
Regions. Several examples are discussed below.
          Distribution of Fact Sheets and Brochures
          Alaska Department of Environmental Conservation
All Media
Alaska's inspectors are required to distribute pollution prevention fact sheets and brochures and
to discuss the benefits of pollution prevention during opening or exit meetings with facilities.
They do not, however, make pollution prevention recommendations or decisions for the facility.
Alaska's Pollution Prevention Policy Council's goal is to use the inspection function to make a
case for pollution prevention without compromising compliance goals and without significant
increase to inspector workloads.9

Contact:   David Wigglesworth
            Alaska Department of Environmental Conservation
            907-269-7500
          Pollution Prevention Survey during Inspection
          Connecticut Department of Environmental Protection
All Media
In addition to distributing a booklet on pollution prevention options and fact sheets for specific
industries, inspectors conduct a facility pollution prevention survey. Some of the survey's
pollution prevention questions are as follows:

S  Has the facility ever made process changes specifically to reduce waste generation or
    emissions to any media?

B  Has the facility ever considered substituting nontoxic materials as inputs for products that are
    currently made with hazardous substances?

m  Has the facility ever determined how much it costs to manage its wastes?
'Memorandum, Interim Steps for Incorporating Pollution Prevention Into Department Functions, Mead Treadwell,
Deputy Commissioner Chair, Pollution Prevention Policy Council, March 4, 1994.
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Promoting Pollution Prevention through Inspection Activities
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B  Does the facility or company have a written, formal pollution prevention policy or waste
   minimization policy?

B  Does the facility or company have a pollution prevention coordinator?

m  Can a copy of company policy be made available at this time?


Contact:   Mary Sherwin
            Office of Pollution Prevention
            Connecticut Department of Environmental Protection
            203-424-3297

3.2.2  Review of RCRA Waste Minimization Program-in-Place Certifications
                     Examples of Review of RCRA Waste Minimization
                             Program-in-Place Certifications
Several agencies explore the extent to which facilities have developed a waste minimization
program as required in all RCRA permits. This approach works most successfully if the state has
other complementary pollution prevention authority.


   oc  I  Audit Program to Evaluate Waste Minimization Programs       RCRA
  L^5*-1  in Place                                                         	
          EPA Region 2

EPA Region 2 requires completion of a hazardous waste reduction plan (which builds on pollu-
tion plans required in New York and New Jersey) with each RCRA permit application. To deter-
mine if waste minimization efforts are in place, Region 2 completes audits at large quantity
generators that handle ozone-depleting chemicals and generators that send hazardous waste to
boilers and industrial furnaces. The audit team uses a waste minimization checklist developed by
the Region. Most of the facilities audited under this program do not have permit-required pollu-
tion prevention planning. At RCRA permitted facilities, inspectors check waste minimization
certifications and whether a hazardous waste reduction plan is available. The audit is followed by
a compliance assistance phase that provides information on new technologies, pollution preven-
tion training, computer clearinghouses, organizational contacts, and some onsite assistance.
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Promoting Pollution Prevention through Inspection Activities
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Contact:   Ray Basso
            Hazardous Waste Facilities Branch
            EPA Region 2
            212-637-4109
          Pollution Prevention Program Review of Facility      RCRA  EPCRA
          Waste Minimization Plans	
          Mississippi Technical Assistance Program

Mississippi's Multimedia Pollution Prevention Act of 1990 requires hazardous waste generators
and TRI-reporting facilities to develop a waste minimization plan and to file annual progress
reports. To implement these requirements, Mississippi's Technical Assistance Program
(MISSTAP) for pollution prevention works with companies to (1) ensure that facilities meet the
pollution prevention planning and reporting requirements of the act and (2) provide pollution
prevention technical assistance to companies to achieve that goal. MISSTAP has targeted large
quantity generators and major TRI facilities from among the 700 facilities in the state's database
for the first round of site visits.

Pollution prevention inspectors take the following steps to work with companies: (1) call in
advance to schedule a meeting with the appropriate facility personnel, (2) review copies of the
facility's annual hazardous waste and TRI reports, and (3) review the company's annual waste
minimization report. The inspector then visits the facility, reviews the waste minimization plan,
and discusses the merits or efficiencies of the plan with the facility personnel. After the site visit,
the inspector sends the facility a letter either approving the plan or identifying deficiencies and
specifying a date by which the plan should be revised. Follow-up visits are usually not feasible
due to time constraints. Issues are typically resolved through an exchange of letters.

The 1990 law mandates waste minimization planning by hazardous waste generators and TRI
facilities. It does not require facilities to meet the state goal of 25% hazardous (and nonhaz-
ardous) waste reduction. Some facilities are revisited to encourage implementation of waste
minimization plans and meet their waste minimization goals. MISSTAP is developing an
incentives program that targets large TRI-chemical releasers for voluntary waste reductions.

Contact:  James Hardage
            Office of Pollution Control
            Mississippi Technical Assistance Program
            601-961-5321
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3.2.3  Joint Inspections by Compliance and Pollution Prevention Staff
                       Examples of Joint Inspections by Compliance
                              and Pollution Prevention Staff
Joint inspections provide the facility with alternative pollution prevention strategies by
combining the inspector's expertise and knowledge of regulations and processes with pollution
prevention staff's expertise. The strategies recommended may avoid violations and, in some
circumstances, minimize production costs or costs associated with waste disposal. Joint
inspections promote information sharing among staff and minimize multiple trips.

Some agencies believe these two activities should not be jointly conducted to avoid the potential
for a diminished perception of the compliance role. Agencies that do conduct these activities
jointly make clear the different roles of compliance and technical assistance. Examples of joint
inspections and pollution prevention technical assistance are discussed below.
          Joint Inspections Process
          Washington Department of Ecology
RCRA
Washington reorganized its Toxics Reduction Program and Hazardous Waste Compliance
Program in 1994 to, among other things, facilitate a joint inspection program. One of the
purposes/goals of the reorganization was to minimize multiple visits to a single facility and
eliminate the mixed messages each inspector was sending to the facility. In addition,
management hoped that a combined program would promote information sharing among staff
and minimize administrative and logistical problems. To pilot this approach, the Southwest
Regional Office in Washington has conducted joint inspections with toxic reduction engineers
and RCRA inspectors. Before proceeding with the inspection, the staff clarify their roles as either
a compliance inspector or as a staff person who will offer pollution prevention technical
assistance. While conducting a technical assistance visit, the inspector cannot use information
gathered for enforcement purposes unless a substantial threat to public health and the
environment is observed.
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Promoting Pollution Prevention through Inspection Activities
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Contact:   Tom Eaton
            Hazardous Waste and Toxics Reduction Program
            Washington Department of Ecology
            360-407-6086
          Hazardous Waste/Pollution Prevention Joint Inspections-
          Assistance Project
          Delaware Department of Natural Resources and
          Environmental Control
    RCRA
DNREC's Hazardous Waste and Pollution Prevention Programs experimented with three
successful approaches to integrate pollution prevention assistance into compliance inspections.
The approaches included: (1) joint site visits including hazardous waste inspection and pollution
prevention staff; (2) inspector-only visits with inspectors referring facilities to the pollution
prevention program; and (3) inspector-only visits with inspectors conducting a compliance
inspection and providing pollution prevention assistance.

During the first phase of the project in 1995, seven facilities were scheduled for site visits. Of the
seven facilities, three were targeted for a joint visit. Survey feedback indicated that this approach
was viewed positively by the facilities. Three facilities received pollution prevention referrals.
An inspector conducted a compliance inspection and provided pollution prevention assistance at
the last facility, which resulted in a referral to the pollution prevention program for additional
assistance. Based on industry's reaction, eight additional joint visits were conducted in FY1996.

Contact:   Andrea Kreiner
            Pollution Prevention Program
            Delaware Department of Natural Resources and Environmental Control
            302-739-3822
          Joint RCRA/Pollution Prevention Inspections
          Ohio Environmental Protection Agency
All Media
Ohio EPA pollution prevention staff maintain a nonregulatory role by providing pollution
prevention information and technical assistance to inspectors and facilities. Pollution prevention
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    Section 3.0
staff occasionally accompany hazardous waste inspectors on informational visits.

Contact:   Tony Sasson
            Office of Pollution Prevention
            Ohio Environmental Protection Agency
            614-644-3469

3.2.4  Providing Pollution Prevention Technical Information and
       Recommendations during Inspections
              Examples of Providing Pollution Prevention Technical Information
                        and Recommendations during Inspections
Inspectors in several states provide companies with pollution prevention information or refer
them to pollution prevention technical information staff without diminishing their compliance
role. As noted previously, it is crucial for inspectors to be aware of agency policy and to present
pollution prevention information in a way that avoids misinterpretation. Examples of approaches
are discussed below.
          Compliance Inspectors' Varying Activities
          Ohio Environmental Protection Agency
All Media
Ohio EPA inspectors are encouraged to promote pollution prevention solutions during
inspections. Some inspectors distribute pollution prevention literature and/or refer facilities to
Ohio's pollution prevention technical assistance staff. Some examine facility operations and
suggest pollution prevention opportunities and/or include information on pollution prevention in
inspection follow-up letters.

In one case, an inspector worked with a metal finishing company to modify operating processes
to achieve zero discharge.
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    Section 3.0
Contact:   Tony Sasson
            Office of Pollution Prevention
            Ohio Environmental Protection Agency
            614-644-3469
          Hazardous Waste Management Division Inspectors
          San Diego County, California
    RCRA
In San Diego County, California, inspectors look for obvious pollution prevention opportunities;
however, time constraints prevent more detailed reviews. As a follow-up, the Hazardous
Materials Management Division distributes customer service evaluation forms to facilities to
determined whether the inspector discussed pollution prevention with the business
representative. Eighty percent of surveyed facilities responded that pollution prevention
information had been presented.

Contact:   Linda Giannelli Pratt
            Environmental Health Pollution Prevention Program
            San Diego County, California
            619-338-2215
          Public Health Services Inspections
          Orange County, California
All Media
Orange County encourages its inspectors to suggest pollution prevention opportunities that may
improve compliance to plant managers and to alleviate as much as possible the perception of
"black hat" compliance visits. Where compliance problems require more immediate attention,
inspector may schedule a second visit to explore pollution prevention opportunities. All county
inspectors receive pollution prevention training and a yearly refresher course. At a minimum,
inspectors distribute pollution prevention information or refer the business to the pollution
prevention staff for follow-up. The level of detail covered depends on the inspector's expertise in
pollution prevention and the business' production processes. Inspectors avoid presenting
information in a way that could be misinterpreted as requiring a specific pollution prevention
approach. Inspectors also review state source reduction plans as input into their inspections.
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Success at Innovation Industries, a manufacturer of fiberglass components located in Anaheim,
illustrates Orange County's approach. While asking a series of questions during a routine
inspection, an inspector identified several strategies the company could consider to substitute raw
materials and reuse or modify its waste. The company had been allowing its unused gelcoat
cleaning material to dry, which was a potential fire hazard and inappropriate waste treatment
under the Wright-Polanco-Lampert Hazardous Waste Treatment Permit Reform Act of 1992. The
company eliminated the use of acetone as a cleaning solvent by substituting styrene into its
gelcoat process and by switching to a batch mixing process, which avoids waste.

The substitution of styrene and the process modification eliminated air and RCRA permit
requirements, resulting in a savings of approximately $3,000 per year in raw material costs and a
savings of hundreds of dollars in state and local air and RCRA permit fees. Reduced air
emissions also provide a safer work environment for the company's employees.

Contact:   Pearl Hoftiezer
            Supervising Hazardous Waste Specialist
            Orange County, California
            714-667-3629
Media
          Viewing Companies as Clients
          Delaware Department of Natural Resources and
          Environmental Control
 Delaware's inspection policy focuses on regulated companies as clients, not as adversaries.
 Inspectors' primary goal is to educate businesses and to protect the environment. As a small
 state, Delaware has very few large industries, which allows inspectors to visit them annually.
 During the compliance visit, inspectors ask general pollution prevention questions and distribute
 available pollution prevention brochures.

 Inspections of small businesses are tailored to address the needs and concerns of the company.
 During the routine compliance visit, the inspector informs the business owner of any compliance
 problems, and recommends pollution prevention and/or other strategies to resolve the problem,
 including, if possible, strategies to save money. If an inspector issues a notice of violation
 (NOV), the business has 30 days to comply. Most businesses are eager to cooperate in order to
 avoid fines. As a result, few fines are levied.

 For example, an auto dealership in Dover was approaching the upper limit of its small quantity
 generator classification (300 gallons of hazardous waste solvents per month). The inspector
 pointed out that the solvents used in the parts washer and to clean paint guns were being changed
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Promoting Pollution Prevention through Inspection Activities
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too often. The inspector suggested purchasing special paint gun cleaning unit and changing
solvent in the parts washer less frequently. The dealer reduced waste generation by
90%—enough to be reclassified as a conditionally exempt small quantity generator (less than 25
gallons of hazardous waste per month). As a result, 275 fewer gallons of solvent were purchased
per month, and the dealer saved permit and waste disposal fees.

Compliance inspectors distribute industry-specific pollution prevention handouts compiled by the
Delaware Hazardous Waste Management Branch. If, however, inspectors encounter a question or
issue that exceeds their level of expertise, they will refer the business owner to Delaware's
pollution prevention staff.

Two brochures, "Delaware's Hazardous Waste Regulations" and "Managing Automotive
Maintenance and Repair Waste" are in comic book format and successfully provide information
on hazardous waste regulations, waste streams, proper management practices, and pollution
prevention techniques.

The state's hazardous waste, air, and pollution prevention programs have jointly sponsored
evening workshops for autobody shops. The workshops focus on the clean air and hazardous
waste management requirements and pollution prevention techniques. The state also developed a
program to teach pollution prevention practices and hazardous waste requirements to students in
autobody maintenance vocational schools.

Contact:   Bruce Cole
            Delaware Department of Natural Resources and Environmental Control
            302-739-3689

3.2.5  Referral to State Pollution Prevention Technical Assistance and/or
       Successful Companies
                     Examples of Referral to State Pollution Prevention
                    Technical Assistance and/or Successful Companies
                                      44
Inspectors in several states refer facilities to state pollution prevention technical assistance
offices for help in waste reduction and compliance.
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          Mississippi's Technical Assistance Program (MISSTAP)
          [Agency Name]
All Media
Under the Mississippi Multimedia Pollution Prevention Act, inspectors often refer facilities that
receive a notice of violation to the state's Pollution Prevention Division or to MISSTAP for
assistance in returning to compliance or as part of penalty negotiations.

The Pollution Prevention Division assists facilities in the preparation of waste minimization
plans. MISSTAP, a nonregulatory technical assistance program located at Mississippi State
University (funded by the Pollution Prevention Division) conducts onsite waste minimization
audits, literature searches, and locates information on waste exchanges. Although in some
instances waste minimization audits may help ameliorate regulatory violations through
implementation of sound waste management practices, they are not specifically designed to
address violations or potential violations. MISSTAP also provides pollution prevention education
and training to local communities.

Contact:   James Hardage
            Office of Pollution Control
            [Agency Name]
            601-961-5321
          Permanent Pollution Prevention Program
          Tennessee Natural Resources and Conservation
          Commission
All Media
TNRCC's Permanent Pollution Prevention Program works with regional inspectors to better
understand the "nuts and bolts" of pollution prevention and to identify companies that could
benefit from pollution prevention technical assistance. These companies are invited to training
seminars and offered site assistance. The training focuses on an eight-step process to create
pollution prevention teams, encourage management support, and train staff to conduct
multimedia pollution prevention assessments. The pollution prevention staff develop pollution
prevention materials that inspectors can provide to facilities during inspections.

Contact:   Kathy Ferland
            Pollution Prevention Conservation Section
            Tennessee Natural Resources and Conservation Commission
            512-239-3177
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3.2.6  Multimedia Inspections
                           Examples of Multimedia Inspections
Multimedia inspections can increase the opportunity for reducing overall pollution generation
and cross-media transfers of pollution. Only a few states and EPA Regions are pursuing this
approach since most are organized by media. Multimedia cross training of inspectors has been a
key ingredient in agencies that have tried this approach.
   A g    Comprehensive Reorganization/Conversion of All
  	'   Inspections to Multimedia Basis                             	
          Massachusetts Department of Environmental Protection

Massachusetts is comprised of mostly small businesses. The Massachusetts DEP developed a
statewide, pollution prevention-based approach to compliance and enforcement called Waste
Prevention Facility-wide Inspections to Reduce Sources of Toxics (FIRST). All environmental
inspections are pollution prevention-based, multimedia, and facility-wide, with a strong
emphasis on source reduction and toxic use reduction to achieve compliance.

The Waste Prevention FIRST program  achieves several goals:

m  Fosters whole-facility, process-oriented inspections. Inspectors consider the facility as a
    whole unit rather than as a set of discrete media release points. They look for sources of
    waste in the manufacturing process in addition to waste management measures. This provides
    the opportunity to identify pollution prevention measures that can reduce pollution
    generation, management, and release to several media and to avoid cross-media transfer.

9  Promotes pollution prevention over pollution control solutions. Two changes have occurred
    as the result of training inspection and enforcement personnel in a multimedia pollution
    prevention approach. Compliance personnel are now more likely to suggest a pollution
    prevention approach to return to compliance than pollution control alone. Inspectors also are
    more likely to incorporate specific pollution prevention recommendations in enforcement
    documents. As a result, companies  are more likely to contact Massachusetts' Office of
    Technical Assistance for help.

m  Efficiencies from the multimedia approach. Over the long term, the multimedia approach
    appears to result in greater efficiency in compliance efforts. Analysis of the Massachusetts
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Promoting Pollution Prevention through Inspection Activities
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   DEP's initial effort (known as the Blackstone project) indicates that, although there were no
   significant cost-saving efficiencies achieved during the pilot, more environmental protection
   was achieved at the same cost.

Hi  Clear definition of compliance roles in protocol. Massachusetts clarified the inspectors' role
   in compliance and technical assistances through a draft protocol, which defines these roles
   more precisely.

U" h; . •   •..,_,    •  '               -•:-
Contact:   Lee Dillard
            Massachusetts Department of Environmental Protection
            508-792-7692
          Multimedia Pollution Prevention-Based Inspections of
          Largest Generators
          New York Department of Environmental Control
All Media
The New York DEC's multimedia pollution prevention program focuses on the 400 facilities
responsible for 95% of New York's waste and/or TRI releases. Under this program, each of the
DEC's nine regions forms teams that conduct multimedia inspections at about 10% of each
region's facilities per year. The New York DEC uses TRI and hazardous waste generation data,
applicability of the state's pollution prevention facility planning requirements, location of
sensitive receptors, public concern, ongoing enforcement, compliance records, and other factors
to determine which facilities to inspect first. Plans are to cover as many of the 400 facilities as
possible by the year 2000.

The New York DEC cross-trains its inspectors in multimedia regulatory and pollution prevention
planning requirements so that they can encourage the use of pollution prevention solutions
identified in facility hazardous waste reduction plans to solve compliance problems. Notwith-
standing the state's emphasis on pollution prevention, the primary focus of inspections remains
compliance oriented. New York has many large facilities with complex permitting and
compliance issues, which slows the ability of inspectors to incorporate pollution prevention fully
into the inspection process.
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Contact:   Bill Eberle
            Pollution Prevention Unit
            New York Department of Environmental Control
            518-457-6072
          Multimedia Inspection and Permitting Action Team
          Vermont Department of Environmental Control
All Media
Having placed top priority on industrial facilities that have compliance problems, the Vermont
DEC completes multimedia inspections that focus on pollution prevention solutions at these
facilities. Inspectors and program experts are cross-trained in each other's requirements and
practices. Pairs of inspectors and program experts are assigned to inspection teams by a
coordinator from the Pollution Prevention Division. The teams conduct multimedia inspections,
which are then reviewed by the team leader and a pollution prevention expert to determine
whether potential pollution prevention opportunities should be reported to the facility. An
excerpt from Vermont's draft coordination policy, "Coordination of Inspection Procedures on the
Potential Criteria for Selecting Facilities for Vermont's Multimedia Inspections," follows:

       A screening process will be used by the external coordinator to determine if a
       facility is a candidate for a multiprogram inspection. The development of this
       screening process is one of the first tasks of the coordinators.

       Factors to consider during the screening process may include:

       1.   Consideration of EPA mandates for each program

       2.   Focus on sectors (metal platers, paper, dairy, service stations, etc.) where
           program crossover exists

       3.   Consideration of individual program priorities (priorities are often dictated by
           new regulations, compliance records, time constraints, etc.)

       4.   Potential for cross-program conflicts

       5.   Potential for public health/environmental risks

       6.   Focus on facilities  that have the most program crossover

       7.   Types of program inspections—short versus intensive major inspections
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Promoting Pollution Prevention through Inspection Activities
    Section 3.0
       8.   Announced versus unannounced inspection needs

       9.   Enforcement-related issues (only the investigating program should go on an
           inspection that has a high potential for future enforcement)

       10.  Range of technical assistance efforts versus inspections.

Contact:   Paul Van Hollebeke
            Pollution Prevention Program
            Vermont Department of Environmental Control
            802-241-3629

3.2.7  Compliance Assistance Linked to inspections and Pollution Prevention
                       Examples of Compliance Assistance Linked to
                           Inspections and Pollution Prevention
Some states separate compliance inspections from compliance assistance. Compliance assistance
inspections provide facilities with an opportunity to have a thorough review of its operations to
identify potential problems without fear that the inspection will result in a notice of violation
and/or penalty. In addition, facilities may have the opportunity to correct problems before an
NOV is issued. When linked to pollution prevention, compliance assistance inspections can help
facilities identify sources of waste affecting noncompliance, as well as raw  materials, operating
methods, housekeeping practices, and administrative practices that could be modified to reduce
pollution and improve compliance.
          Sector-Focused Compliance Assistance and Pollution
          Prevention Inspections
          Washington Department of Ecology
All Media
The Washington DOE has initiated compliance assistance inspections for selected industry
sectors involving medium and small facilities. The goal of these campaigns are as follows:

a  Education. To help the Washington DOE and local governments understand the complexities
    of day-to-day management of hazardous wastes.
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Promoting Pollution Prevention through Inspection Activities
Section 3.0
B  Compliance. To help industry understand and voluntarily comply with hazardous waste
   requirements.

B  Pollution prevention. To promote waste reduction and recycling as a compliance and
   environmental quality tool.

The program emphasizes brief onsite visits that identify basic pollution prevention opportunities
and disseminate easy-to-read pollution prevention educational materials targeted to particular
industry specialties.

The first campaign, "Shop Sweep" focused on the automotive industry. The Washington DOE
proposed forming a joint partnership with key automotive trade associations that would provide
fair and efficient compliance assistance in exchange for increased industry compliance and
cooperation. Automotive associations and individual businesses contributed valuable input to the
development and cost of educational booklets, and they advertised the campaign through
association newsletters. A follow-up evaluation of 5% of the participating auto shops revealed
that 82% tried, and an additional 15% were planning, to implement  at least one compliance
assistance recommendation. Overall, 61% of recommendations had  been implemented, and an
additional 25% were planned.

The "Snapshots" campaign focused on the printing industry. A workgroup of 10 to 12 govern-
ment and industry representatives spent a year developing user-friendly compliance and pollution
prevention materials for screen printers, lithographic printers, and photo processors. The
materials addressed how waste is generated, compliance requirements, and pollution prevention
strategies. Washington DOE staff conducted 1-day training sessions required for all site
inspectors. About 1,000 field visits were completed.

Washington DOE focused its third campaign on dry cleaners and is  also working with vocational
schools to teach auto mechanic and other trade students how to properly manage waste and spot
prevention possibilities.

Inspectors make their compliance assistance role clear to shop managers during facility visits in
order to avoid misinterpretation of pollution prevention suggestions as compliance requirements.


Contact:   Tom Eaton
            Washington Department of Ecology
            360-407-6086
                                                                                     3-20

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Promoting Pollution Prevention through Inspection Activities
    Section 3.0
         Multimedia Compliance Assistance Program
         City of Santa Rosa, California
All Media
Santa Rosa's compliance incentive program provides small businesses with technical assistance,
multimedia regulatory streamlining, and pollution prevention information, as well as public
recognition and awareness (see Section 3.2.8). Initial inspections take up to 3 hours and involve
educating shop employees on compliance requirements and pollution prevention opportunities.
Reinspections of certified shops take much less time.

The program was originally targeted at the area's 275 vehicle maintenance facilities, which were
discharging organic solvents into Santa Rosa's publicly owned wastewater treatment plant
(POTW), causing violations of state air toxic standards and hazardous buildups of noxious fumes
in sewer trunk lines. Efforts to begin solving the POTW problem revealed that regulations from
the eight Sonoma County agencies responsible for environmental compliance were unclear and
often conflicting, and there appeared to be little communication between regulatory agencies to
ameliorate the problem. For example, some shop owners found that evaporation methods to
remove toxics from wastewater discharges violated air requirements, but they were unaware of
alternatives.

In response to this problem, the eight Sonoma County agencies responsible for air, water,
hazardous waste and environmental health formed the Sonoma Environmental Quality Assurance
Committee (SEQAC). The SEQAC reduced the 48 pages of agency inspection checklists to eight
pages. It also produced compliance assistance and pollution prevention best management
practices information for vehicle shops. Agency inspectors notify each other when violations are
identified, which allows a coordinated enforcement effort.
 Contact:   Martin Grimsrud
            City of Santa Rosa, California
            707-524-5294
          Contract with the Small Business Development Center's        RCRA
          Business Environmental Program                             	
          Nevada Department of Environmental Protection

 The Nevada DEP uses RCRA 3011 state grant money to contract for compliance and waste
 minimization assistance with the University of Nevada-Reno's Small Business Development
 Center's Business Environmental Program (BEP). The BEP is now the largest provider of
                                                                                  3-21

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Promoting Pollution Prevention through Inspection Activities
                                   Section 3.0
environmental assistance to over 2,500 businesses in Nevada. The Nevada DEP RCRA
inspectors distribute BEP brochures during inspections and refer noncompliant facilities to the
BEP. BEP staff meet with Nevada DEP inspectors and enforcement personnel in a monthly
"regulatory forum" to discuss regulatory issues, ensure consistent interpretation of regulations,
and develop pollution prevention fact sheets.

Services provided by the BEP include:

&  Response to toll-free hotline inquiries
M  Training seminars (25 completed and over 10,000 business representatives trained)
9  Onsite consultations and reports.

As a direct result of BEP's assistance (1995 survey):

•  89% of clients indicated they improved their compliance
B  61 % stated they reduced their waste generation.

All BEP assistance and onsite consultations are confidential. The Nevada DEP has awarded BEP
additional contracts to provide air and solid waste assistance.


Contact:   Kevin Dinck
            Business Environmental Program
            Small Business Development Center
            University of Nevada-Reno
            702-784-1717

3.2.8  Participation/Reward/Sticker Programs
                    Examples of Participation/Reward/Sticker Programs
                                  52
53
Some state and local governments provide public recognition to companies in compliance with
environmental regulations. One of the most popular forms of recognition is environmental
stickers or emblems to display at the facility. This kind of visible recognition is particularly
valued by retailers who deal directly with the public.
                                                                                   3-22

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Promoting Pollution Prevention through Inspection Activities
Section 3.0
          Progressively Increased Awards for Actions Beyond      LI*-,***!*. .<-
          Compliance                                               Hazardous
          Seattle-King County Local Hazardous Waste                 Waste
          Management Program

The Seattle-King County Local Hazardous Waste Management Program developed its "Enviro
Stars" sticker program to encourage beyond-compliance and pollution prevention efforts.
Businesses receive a 2- to 5-star rating according to the following criteria:

       2 stars: The facility is in compliance.

       3 stars: The facility implemented at least half of the waste reduction opportunities
       identified during the onsite assessment.

       4 stars: The facility implemented all waste reduction opportunities identified during the
       assessment.

       5 stars: The facility operates at the 4-star level and demonstrates a record of progress in
       solid waste recycling and surface water best management practices. This category is also
       called Green Works and includes logos for letterhead and window stickers.

Contact:   Shirli Axelrod
            City of Seattle Solid Waste
            710 2nd Avenue, Suite 505
            Seattle, WA 98104
            206-684-7804
            206-684-8529 (Fax)
         Association of Bay Area Governments (ABAG) Award       A n tuiafti*
         Sticker Program                                             A" MeOIB
         San Francisco Bay Area, California

The ABAG operates a sticker program that recognizes top environmental performers. Built on
successful local models, the program covers four of the nine Bay Area counties. The program
encourages multimedia training of inspectors who work with companies and make referrals to
pollution prevention experts where potential violations are spotted. The program is founded on
the principle of "education before litigation:" when a violation is found, a grace period is
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Promoting Pollution Prevention through Inspection Activities
    Section 3.0
provided for returning to compliance. During the grace period, inspectors help companies return
to compliance.

Each county in the San Francisco Bay Area forms an interagency committee of representatives
from the air, water, hazardous waste/materials, solid waste, pollution prevention, and energy and
water conservation agencies. For selected industry sectors, a lead agency is identified to
coordinate inspector cross-training, audit activities, and the streamlining of inspection procedures
and checklists.

Businesses are requested to complete a self-audit streamlined checklist, which is reviewed by
inspectors. The program rewards two levels of performance. Level I recognition requires a
demonstration of basic pollution prevention effort. Level n recognizes more advanced pollution
prevention achievements. Response has been positive; some businesses have called the
regulatory agencies to request an inspection after completing the checklist rather than waiting for
county inspections.

Contact:  Jennifer Krebs
            Association of Bay Area Governments
            P.O. Box 2050
            Oakland, CA 94604-2050
            510-464-7977
            510-464-7970 (Fax)
          "Sonoma Green Business" Stickers
          City of Santa Rosa, California
All Media
Santa Rosa issues "Sonoma Green Business" stickers to shops that participate in the city's
compliance incentive program. The county advertises the program to encourage consumers to
support facilities displaying the green business emblem. Violations at facilities that have
previously been issued a Sonoma Green Business sticker could result in loss of sticker. Once a
sticker is confiscated, a company must demonstrate 6 months of compliance before the sticker is
reissued.

Contact:   Martin Grimsrud
            City of Santa Rosa, California
            707-524-5294
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Section 4.0
Incorporating  Pollution Prevention into
Enforcement Activities
EPA and some states use pollution prevention as an important tool in negotiating injunctive relief
and/or as a tool in negotiating supplemental environmental projects to offset civil penalties.
Pollution prevention-based injunctive relief requires a facility to use pollution prevention
methods to reach legally required compliance levels. Pollution prevention remedies must be
sufficient to cure the violation and technically and economically feasible for the facility.
Supplemental environmental projects (SEPs) are "environmentally beneficial projects which a
defendant/respondent agrees to undertake in settlement of an enforcement action, but which the
defendant/respondent is not otherwise legally required to perform." SEPs are an innovative
settlement approach that often result in mitigating a portion of a civil penalty in exchange for a
legally enforceable commitment from the company to undertake a specific project that goes
"beyond compliance."

Companies in violation may be open to funding preventive measures that could return them to
compliance, offset penalties, reduce pollution generation, reduce the likelihood of future
compliance problems, and possibly eliminate a public relations liability. The role of pollution
prevention in the enforcement process depends on the specific characteristics of the violation and
EPA and/or state enforcement policies.10 EPA and state enforcement offices have adopted a
variety of approaches, some of which are described in Section 4.2.
 10EPA's handbook, Encouraging the Use of Pollution Prevention in Enforcement Settlements (EPA-300-R-95-005),
 describes EPA's policy framework for folding pollution prevention into the enforcement arena and provides
 examples of how EPA Regions have approached this new initiative. This handbook provides additional examples of
 successful enforcement approaches developed by EPA Regions and states.


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Incorporating Pollution Prevention into Enforcement Activities
                                 Section 4.0
4.1    What Do I Need to Know?

What is the enforcement official's role in promoting pollution prevention?
       States and EPA enforcement officials
       incorporate pollution prevention in
       several ways. Common roles are
       summarized below.
 Roles for Enforcement Officers Promoting
           Pollution Prevention

I  Inform companies of the availability and benefits
   of pollution prevention.
i  Discuss pollution prevention options at the facility
   with compliance inspectors and technical
   assistance personnel.
1  Communicate a willingness to work with the
   facility in developing pollution prevention options.
i  Provide reasonable flexibility in negotiating
   injunctive relief and SEPs.
       m  Enforcement staff can inform
           companies of the possibility to
           include pollution prevention
           measures in injunctive relief or
           SEP settlements. Information can
           include, for example, SEP policy
           documents, pollution prevention
           brochures, or access to pollution
           prevention clearinghouses or
           technical assistance sources.11

       n  Enforcement staff can talk to inspectors or compliance assistance staff who have
           visited the site to assess whether there may be pollution prevention opportunities
           and/or whether the company is a good candidate for such an approach.

       a  During negotiations, enforcement staff can discuss the priority that the agency places
           on the pollution prevention as a tool in compliance settlements. EPA's SEP policy
           allows greater penalty mitigation for pollution prevention SEPs compared to other
           types of SEPs.12 Other benefits of pollution prevention, such as long-term compliance
           and potential permit elimination, should also be emphasized.

       m  Flexibility in penalty mitigation and compliance scheduling can be used as incentives
           for implementing pollution prevention and achieving long-term compliance.
 nAn enforcement official should ensure that a facility does not interpret pollution prevention suggestions as legal
 requirements (see Section 3.1).

 nPolicy on the Use of Supplemental Environmental Projects in EPA Enforcement Settlements (March 19, 1996)
 (Enviro$en$e at http://es.inel.gov/comply/oeca/policy.html). Some states, however, have developed other SEP
 policy.
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Incorporating Pollution Prevention into Enforcement Activities
                                                                        Section 4.0
How do I prepare for an evaluation where I want to explore or promote
pollution prevention?

       Having a technical understanding of manufacturing processes and facility operations is
       often an asset in regulatory compliance situations and in assessing pollution prevention
       opportunities. It is not essential, however, for enforcement staff to be experts on
       manufacturing processes or pollution prevention methods to leverage pollution
       prevention in a settlement. In many states, enforcement staff can turn to pollution
       prevention technical assistance experts for general information about opportunities in
       similar facilities or that particular facility. In many cases, the need to return to compliance
       may motivate the facility to investigate pollution prevention possibilities without
       requiring agency technical assistance.

       Preparing to discuss pollution prevention during enforcement activities is very similar to
       that for the permit process and inspections. Readers should refer to Sections 2.1 and 3.1
       for information sources.

 When in the enforcement process should pollution prevention be
 discussed?
                                                 When to Discuss Pollution Prevention

                                              •  During initial correspondence with the company
                                              B  Early in and throughout settlement negotiations
Some states integrate pollution pre-
vention into enforcement actions by
including pollution prevention infor-
mation in the notice of violation. In
addition to identifying problems
identified/observed during an
inspection, such NOVs suggest that the facility consider utilizing pollution prevention
strategies to resolve present and future violations.13 NOVs may also refer facilities to state
or local technical assistance programs for help in developing pollution prevention
measures that may be considered in injunctive relief or SEPs. Most agencies have found
that the earlier the concept of pollution prevention is raised, the greater the likelihood that
pollution prevention measures will be adopted.

Some states and EPA Regions discuss  pollution prevention measures during settlement
negotiations.
 13When suggesting pollution prevention options, the NOV should ensure that facilities do not regard the suggestions
 as legal requirements (see Section 3.1).
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Incorporating Pollution Prevention into Enforcement Activities
                              Section 4.0
What are important factors to consider when negotiating pollution
prevention measures for injunctive relief?

       Pollution prevention-based injunctive relief requires a facility to use pollution prevention
       methods to reach legally required compliance levels. Pollution prevention remedies must
       be sufficient to cure the violation and technically and economically feasible for the
       facility. It is important to consider the complexity of the pollution prevention measures
       (e.g., some may involve major changes in production processes or raw materials to
       eliminate or reduce chemicals causing compliance problems) and the amount of time the
       approach will require. Although design, testing, and implementation of new processes
       may take extra time, chemical releases may be reduced or eliminated. The probability of
       success must therefore be a critical factor weighed along with the potential benefits of a
       pollution prevention approach.
 What are general guidelines for an
 SEP?
       EPA's policy lists seven categories of
       SEPs, one of which is a pollution
       prevention category.14 A pollution
       prevention SEP "reduces the genera-
       tion of pollution through...any practice
       which reduces the amount of any
       hazardous substance, pollutant or
       contaminant entering any waste
       stream or otherwise being released
    General Guidelines for SEPs

Demonstrate an adequate nexus with the
violation.
Advance at least one of the declared objectives
of the environmental statute violated.
Avoid agency involvement in management/
implementation of the SEP.
Include the type/scope of each project in the
settlement agreement.
Avoid projects that, by law, are required to be
completed by EPA.
    e six other SEP categories are:
       Public Health—Providing diagnostic, preventive, and remedial components of health care services to
       individuals whose health was damaged as a result of a violation.

       Pollution Reduction—Utilizing recycling, treatment, containment, or disposal techniques to reduce
       pollutants after generation.

       Environmental Restoration and Protection—Repair, restore, or improve the ecosystem or geographic
       location affected by the violation; go beyond repair to enhance the environment in the vicinity of the
       violating facility.
       Assessments and Audits—(1) Pollution prevention assessments, (2) site assessments, (3) environmental
       management systems audits, and (4) compliance audits.

       Environmental Compliance Promotion—Require the facility to provide training for members of the
       regulated community to achieve or maintain compliance.

       Emergency Planning and Preparedness—Provide computer equipment, software, communications
       systems, and HAZMAT equipment to a state or local emergency planning or response office in support of
       the Emergency Planning  and Community Right-to-Know Act (EPCRA).
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Incorporating Pollution Prevention into Enforcement Activities
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       into the environment, prior to recycling, treatment, or disposal." Measures might include
       equipment and technology modifications, improved housekeeping and maintenance
       procedures, substitution of raw materials or redesign of products. Projects that conserve
       or protect existing resources, such as energy and water, are also considered pollution
       prevention.

       EPA's policy contains five guidelines for determining whether a SEP is appropriate. State
       guidelines may differ, and enforcement staff should consult their agency's written SEP
       policy.

       a  Legal nexus. EPA's SEP policy provides flexibility in the definition of nexus (i.e.,
          the connection between the violation and SEP's ability to correct the specific
          violation). For example, the nexus may be sufficient if the SEP occurs "in the same
          ecosystem or within the immediate geographic area. Such SEPs may have a sufficient
          nexus even if the SEP addresses a different pollutant in a different medium."

       B  Advance an  objective of the environmental statute violated. The SEP cannot be
          inconsistent  with any  of the existing federal, state or local environmental statutes and
          regulations.

       a  Avoid agency involvement in management/implementation of the SEP. Agency
          staff can not manage or administer the SEP on behalf of the facility. The agency,
          however, can provide oversight to ensure that the project is implemented pursuant to
          the settlement agreement and take legal recourse if the SEP is not adequately
          performed.

       a  Include the type/scope of each project in the settlement agreement. The settlement
          agreement must clearly identify the "what, where, and when" of the SEP. Settlements
          where the facility agrees to spend a specified amount of money on projects to be
          determined later are not acceptable as SEPs.

       m  Avoid projects that complete EPA mandated duties. A project may not complete
          activity that  EPA is required to complete, nor may a project be an expansion of an
          existing EPA program.

Furthermore, an SEP cannot include requirements that the violator must meet under federal,
state, or local regulations.

What incentives does pollution prevention provide in negotiating
injunctive relief and/or SEPs in settlement agreements?

       Several incentives can be considered in negotiating pollution prevention in injunctive
       relief and/or SEPs in settlement agreements:
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Incorporating Pollution Prevention into Enforcement Activities
                                                                         Section 4.0
                                                       Pollution Prevention Incentives

                                                     Direct environmental and health benefits

                                                     Facilitating settlement/reducing litigation

                                                     Minimize future liability

                                                     Provide economic incentives

                                                     Improve company image
m  Direct environment and health
   benefits. Pollution prevention
   measures can be used to reduce or
   eliminate specific wastes causing
   compliance problems. Achieving
   compliance through injunctive relief
   or going beyond compliance with an
   SEP offers potentially more health and
   environmental protection than an end-
   of-pipe solution. Since pollution
   prevention measures get at the source
   of pollution generation, this approach has a better chance of reducing or eliminating
   cross-media transfers of pollutants than single media regulation and end-of-pipe
   pollution control technology.

m  Potential shift in  corporate philosophy. Many companies indicate that cost-effective
   pollution prevention solutions are frequently preferable over end-of-pipe pollution
   controls, but that there are often barriers to using pollution prevention. These barriers
   can include lack of funds, no access to pollution prevention technical information, and
   deadlines in permits or inspections that do not allow extra time to consider pollution
   prevention. Companies that tackle these barriers often find cost-effective pollution
   prevention solutions. Creating the incentive for pollution prevention in the settlement
   process can affect corporate preferences for preventive solutions in a broad array of
   environmental areas.

m  Facilitating settlement. Facilities and agencies may find it more appealing to
   implement pollution prevention settlement solutions that reduce or eliminate waste
   streams, return the facility to compliance, and provide long-term environmental
   benefit than to pay penalties, continue to rely solely on end-of-pipe solutions, and/or
   enter into litigation.

m  Minimize potential for future violations. SEPs are designed to go beyond
   compliance, which encourages long- and short-term environmental benefits and
   reduces the potential for future violations.

M Provide economic incentives. Pollution prevention SEPs may reduce or avoid the
    costs of litigation, raw materials or production methods that may have been causing
    waste problems, and the costs of waste management and future liability. Going
    beyond compliance might also eliminate or  reduce permit requirements and
    associated administrative costs. Finally, pollution prevention may reduce worker
    exposure to pollutants and, thus, worker compensation costs.
                                                                                        4-6

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Incorporating Pollution Prevention into Enforcement Activities
                       Section 4.0
       m  Improve company image. Pollution prevention can demonstrate increased awareness
          and concern about the environment and can have a more positive impact on public
          perception and community relations than end-of-pipe control strategies alone.

How do I determine If a case Is a good candidate for pollution prevention
injunctive relief or an SEP?

       Not all cases are good candidates for pollution prevention injunctive relief or SEPs.
       Consider the following factors in making a determination:

       B  Compliance history. Does the facility's compliance history indicate repeat violations
          or a recalcitrant violator? A recalcitrant company could fail to complete a pollution
          prevention project, which would extend the period of violation.

       •  Penalty amount. The penalty amount may affect the feasibility and/or attractiveness
          of a pollution prevention settlement to a company. In the face of a large penalty, a
          cost-effective pollution prevention project that could offset a signficant amount of the
          penalty may be very attractive. If the facility faces a relatively small penalty, the
          pollution prevention project might be perceived as too expensive and not worth the
          effort.

       m  Interest in completing the project. A facility not fully committed to the project might
          delay or fail to complete implementation, resulting in further agency oversight and
          enforcement action and unrealized health and environmental benefits.

       m  Feasibility of pollution prevention. Pollution prevention measures can range from
          very simple changes in production processes to major redesign and replacement of
          equipment and raw materials. The technical complexity and risk of delays or
          performance shortfalls should be carefully assessed.
           Ability to implement project. The facility
           must have the ability to install and
           maintain pollution prevention measures.
           Financial resources and technological
           expertise must be evaluated to ensure the
           facility can follow through.
What Makes a Good Candidate
  for Injunctive Relief/SEP?

Compliance history
Penalty amount
Interest in completing the project
Feasibility of pollution prevention
Ability to implement project
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Incorporating Pollution Prevention into Enforcement Activities
                                 Section 4.0
What strategies will facilitate discussions of pollution prevention in
enforcement settlements?
       A variety of approaches are used by
       state and federal enforcement case
       officers to negotiate pollution
       prevention in settlements. The
       appropriateness of these approaches,
       of course, depends on individual
       agency enforcement policies.

       m Determine pollution prevention
          capability early in the process.
          Discuss pollution prevention
          opportunities as early as possible
          in the negotiation process. If
          pollution prevention knowledge is
         How to Facilitate Pollution
          Prevention Discussions

^  Determine pollution prevention capability early in
   the process
B  Encourage/assess cooperativeness
BS  Encourage facilities to develop pollution
   prevention proposals
ffl  Use agency and technical assistance staff to
   support initial discussions, provide company with
   contacts and information about innovative
   alternatives, and assess proposals
           limited, refer the facility to a state or local technical assistance office. Reassess the
           company's capability after consultations with the technical assistance office.

       a  Encourage cooperative environment. Encourage a nonadversarial process. As
           discussed in a previous section, assess the facility's past compliance history for repeat
           violations and/or recalcitrance, and the ability to pursue pollution prevention
           solutions.

       @  Encourage facilities to develop pollution prevention proposals. Encourage the
           facility to develop or acquire pollution prevention expertise to explore opportunities
           and develop a settlement proposal. A crucial first step is completing a pollution
           prevention audit or feasibility study.

       m  Provide company with contacts and information on pollution prevention. Use
           expertise of inspectors and technical assistance staff to support initial discussions and
           assess proposals. Provide the facility with contacts at other facilities and technical
           assistance offices that may have information on similar situations.

 4.2   Examples of Approaches

 Some agencies have used the enforcement process to provide a strong incentive for companies to
 identify cheaper, smarter, cleaner compliance solutions in cases where end-of-pipe treatement
 approaches are in violation of permit requirements. This approach may be beneficial for both
 sides—companies find a cheaper, cleaner, smarter compliance solution, and government agencies
 can report improved environmental performance.
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Incorporating Pollution Prevention into Enforcement Activities
Section 4.0
This section is divided into two parts: examples of pollution prevention SEPs and examples of
pollution prevention injunctive relief approaches.

4.2.1  Promotion of Pollution Prevention Supplemental Environmental Projects
                      Examples of Pollution Prevention Supplemental
                                 Environmental Projects


60
57


                                                  61
                                                      58
Enforcement actions provide the opportunity to leverage attention on pollution prevention
activities. In some cases, using pollution prevention SEPs in settlements has shortened the time
required to reach a settlement, reduced the penalty to the facility, improved environmental results
by going "beyond compliance," and/or reduced the likelihood of future violations.

These advantages are important. A reduction in the potential for future violations might free up
valuable agency resources for other pressing environmental problems.  From the company's
perspective, the potential for a reduction in the financial burden of the  penalty may provide an
incentive to look for and undertake pollution prevention measures that might not otherwise have
been recognized or considered. In some cases, reduction in the penalty may be a significant factor
in making the pollution prevention measure financially feasible or attractive for the facility. In
addition, the development of a pollution prevention SEP may be a significant factor in triggering
a recognition by facility management of the potential financial, environmental, and even
operating efficiency benefits that result from pollution prevention.

Some agencies have noted that SEP may require additional staff time at first to oversee
development and implementation. This additional resource expense, however, can be reflected in
penalty adjustments.
          North Carolina Pollution Prevention SEPs
                                                                        Hazardous
                                                                           Waste
North Carolina's Department of Environment, Health and Natural Resources' Division of Solid
Waste Management actively pursues SEPs in enforcement cases. At the beginning of an
enforcement action, the division suggests considering an SEP as the preferred route to a solution.
The facility can then conduct, either itself or with the assistance of the Office of Waste Reduction
technical assistance staff, a waste reduction audit. The audit can be included in the settlement
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Incorporating Pollution Prevention into Enforcement Activities
    Section 4.0
agreement; however, the penalty mitigation is based on actual implementation of pollution
prevention measures and not completion of the audit. Waste audits can constitute an SEP element
under EPA's SEP policy, without requiring implementation of pollution prevention measures.
EPA reasons that the facility will implement the audit recommendations because "many of the
implementation recommendations from these [audits] may constitute activities that are in the
[facility's] own economic interest."

Contact:   William L. Meyer
            Division of Solid Waste Management
            North Carolina Department of Environment, Health, and Natural Resources
            919-733-4996
          Ohio Pollution Prevention SEPs
All Media
The Ohio Environmental Protection Agency has developed guidance that encourages pollution
prevention during inspections and enforcement.15 The guidance encourages introducing pollution
prevention first in the inspection process to raise the awareness of the facility and then in the
negotiation process to encourage pollution prevention in the settlement process. Ohio inspectors
are trained to assess the potential for pollution prevention solutions and awareness at a facility.
They can either recommend specific projects for inclusion as an enforcement requirement or
consider projects recommended by the facility. Suggesting potential pollution prevention projects
at the inspection stage raises the likelihood that the facility may be willing to negotiate a
pollution prevention SEP.

Ohio's district offices assess which facilities are good candidates for undertaking pollution
prevention measures and make recommendations to Ohio EPA headquarters. Decisions are based
on facility interest, understanding, and resources to undertake a pollution prevention projects and
the availability of opportunities for similar facilities or processes in that industry sector. If the
facility is a good candidate, the opportunity to consider pollution prevention measures as a means
 of reducing a portion of the penalty is included in a letter to the facility, with the office's draft
 findings and draft settlement orders. In some cases, pollution prevention may be introduced after
 the letter is sent.

 The Ohio EPA considers several factors in determining the amount of penalty mitigation,
 including benefits to the public or environment at large, innovation, environmental justice, multi-
 15Pollution Prevention in Ohio Environmental Enforcement Settlements—Analysis and Update, Office of Pollution
 Prevention, Ohio EPA (September 1995).

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media impact, and pollution prevention. The Ohio EPA does not allow penalty mitigation if the
project would have been implemented in the normal course of the facility's business. Factors
used to make this determination include whether:

m  The project is not otherwise economically attractive (either because of long payback period or
   high capital cost).

H  The project carries considerable technical risk.

m  Implementation of the project would adversely affect immediate production concerns due to
   demands on time, money, and personnel or because it would require temporarily ceasing
   some operations.

m  Management is unresponsive to and or unaware of the benefits of pollution prevention.

Contact:   Anthony Sasson
            Ohio Environmental Protection Agency
            614-644-2810
          Florida Pollution Prevention SEPs
All Media
The Florida Pollution Prevention Act of 1991 provided the foundation for the Florida
Department of Environmental Protection (DEP) to consider pollution prevention in its
enforcement program. The Florida DEP included in its 1994 "Settlement Guidelines for Civil
Penalties" extensive guidance for incorporating pollution prevention in enforcement actions.
Under these guidelines, the Florida DEP outlines how pollution prevention projects can be used
to offset fines of eligible noncompliant companies. The following pollution prevention costs can
be used to offset penalties:

m  Preparing a pollution prevention plan
m  Designing, installing, and testing a specific pollution prevention project
a  Training employees to run the project
m  Initial capital investment needed to start up the project.

During the first 2 years of this program, the Florida DEP started or completed more than 30
pollution prevention SEPs. Pollution prevention coordinators in district offices work closely with
Florida DEP headquarters in Tallahassee on these projects. The six regional districts have tried
various approaches.
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Coordinators in the Southwest and Northeast districts, located in Tampa and Jacksonville, assist
facilities in preparing waste audits. This program was funded by an EPA grant to provide
technical assistance to local industries. In one case, the Southwest District levied a $200,000 fine
against a large fiberglass boat manufacturing company for violations associated with acetone
discharges. The company substituted propylene carbonate for acetone and installed solvent stills
to recover emissions at two of its facilities. In addition to correcting the acetone violation, the
manufacturer proposed an SEP to reduce its styrene emissions by substituting more efficient
spray guns. This change reduces estimated styrene emissions by 168,000 Ibs/year. The company
also elected to reduce the generation and disposal of waste adhesive putty by 7,230 gal/year by
replacing the existing hand-mix operation with an automated dispensing system. The automated
system allows the company to mix and dispense on an as-needed basis. The company is actively
sharing its knowledge with other companies in the industry and was featured as a success story in
a Florida DEP-funded video on pollution prevention in the fiberglass boat manufacturing
industry.

The Florida DEP's Central District develops educational materials to encourage companies to
incorporate pollution prevention into their  activities. Staff work with companies in its "industry
heroes" program to encourage other companies to consider pollution prevention methods.

In another example, the Florida DEP approached  an unpermitted boat manufacturing facility that
was violating air requirements with pollution prevention suggestions for coming into compliance
and an overview of the "industry hero" program. After seeing that other companies in the
industry used pollution prevention methods, the facility opted to substitute two nonhazardous
cleaning solutions for acetone as a pollution prevention credit to offset their penalty. The consent
agreement required using the substitute for a minimum of one year. This pollution prevention
effort resulted in an 80% reduction in air pollution emissions from the facility.
 Contacts:  Julie Abcarian
             Pollution Prevention Program
             Florida Department of Environmental Protection
             904-488-0300

             Fred Alverez
             Pollution Prevention
             Northeast District
             904-448-4320, ext. 373
Dick Burns
Pollution Prevention
Southwest District
813-744-6100, ext.321

Charles Collins
Pollution Prevention
Central District
407-894-7555
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Incorporating Pollution Prevention into Enforcement Activities
    Section 4.0
          EPA Region 1 Pollution Prevention SEPs
All Media
EPA Region 1 negotiated for the Massachusetts Highway Department (Mass Highway) to pay
$100,000 in fines and complete $5 million dollars in pollution prevention SEPs at 148 facilities
throughout the state. The SEPs involve a range of projects, including environmental justice,
community emergency planning, and pollution prevention. For example, one project involves
replacement of solvent chemicals and lead-based paint with less toxic alternatives.

The General Electric Company was ordered to pay a $225,000 fine and expend at least $ 1.2
million on a pollution prevention SEP to replace an oil-based coolant with a water-based coolant
for its milling and lathing machine processes. The enforcement action arose from the company's
failure to obtain "prevention of significant deterioration" permits for one boiler and four test cells
used for jet engine testing.

A consent decree with CPF, Inc., a beverage bottler, ordered the company to pay $160,000 and
spend $99,625 on SEPs to enhance protection of the Nashua River watershed. The enforcement
action arose out of CPF's discharges of wastewater into a municipal sewer system (via discharges
into the Nashua River) in violation of pretreatment requirements. The SEPs include (1) an
$80,000 conservation land acquisition of 15 acres along the Nashua River for water quality and
habitat protection and public recreational use; (2) a $7,000 project to stop sediment erosion
plaguing a portion of the Squannacook River, a Nashua tributary;  and (3) a $12,625 bilingual
storm-sewer stenciling project to help prevent the dumping of wastes into public storm drains to
the Nashua River.

Contacts:  Amelia Katzen
            Regional Counsel's Office
            EPA Region 1
            617-565-1133
            Mark Mahoney
            Environmental. Stewardship Division
            EPA Region 1
            617-223-1155

            Steve Yee
            RCRA Enforcement
            EPA Region 1
            617-573-9644
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          EPA Region 2 Pollution Prevention SEPs
All Media
EPA Region 2 case officers suggest the opportunity for developing SEP projects to companies
early in the enforcement process. Region 2 has actively promoted SEPs since the early 1990s and
has negotiated numerous pollution prevention based SEPs.


Contact:   George Meyer
            Hazardous Waste Compliance Branch
            EPA Region 2
            212-637-4145
          EPA Region 4 Pollution Prevention SEPs
All Media
 EPA Region 4's strategic plan for pollution prevention in enforcement settlements emphasizes
 notifying facilities of the opportunity for a pollution prevention SEP project early in the
 settlement negotiation process. The office makes it clear that such actions, where feasible, would
 be advantageous both to the facility and the environment. Facilities are provided with
 information about state technical assistance programs and the Region 4 Waste Reduction
 Resource Center in North Carolina. Enforcement staff may make a substantial effort to guide the
 company toward pollution prevention possibilities, perhaps even providing the facility with
 contacts in other companies or regions that have successfully undertaken pollution prevention
 changes for similar processes. Enforcement staff, however, cannot go the additional step of
 suggesting specific pollution prevention projects in order to avoid leaving the Agency open to
 criticism regarding facility-specific proposals.


 Contact:  Shelia Hollimon
            Enforcement Planning and Analysis
            EPA Region 4
            404-347-3555, ext. 6776
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          EPA Region 5 Pollution Prevention SEPs
RCRA
In 1991, Region 5 developed guidance on including pollution prevention in RCRA enforcement
settlements. It details the process for negotiating pollution prevention SEPs in RCRA settlements
and provides worksheets for evaluating pollution prevention projects. The following language is
included in the administrative complaint to promote early consideration of pollution prevention
projects to mitigate penalties:

       Regardless of whether you choose to request a hearing within the 30-day time
       limit following service of this Complaint, you are extended an opportunity to
       request an informal settlement conference. Topics for discussion at the settlement
       conference may include the establishment of a compliance schedule or the
       mitigation of the proposed penalty in accordance with Agency guidance on
       pollution prevention and supplemental environmental projects.

In addition, the Region sends an SEP pamphlet to the facility. The RCRA Technical Assistance
Program evaluates the technical elements of SEP proposals.

Indiana Steel and Wire/G.K. Technologies negotiated a settlement that requires a $900,000
pollution prevention project to eliminate ammonia emissions by converting to alternative
chemicals in a zinc plating line bath. Failure to complete the project results in an additional
penalty payment of $225,000. In another enforcement action, an SEP proposal to reuse caustic
waste and sell used oil waste as supplemental fuel was rejected because the proposal was a sound
business practice that should have otherwise been conducted and because the company was a
chronic violator.

Contacts: Joseph Boyle
           RCRA Enforcement Branch
           EPA Region 5
           312-886-4434

           Eli Martinez
           Program Management Branch
           EPA Region 5
           312-886-4023
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   Section 4.0
4.2.2  Examples of Pollution Prevention Measures in Injunctive Relief
Examples c
f Pollution Prevention Measures in Injunctive Relief
62
67



63
68



64
69



65
70



66
71


EPA policy requires considering the technical and economic feasibility of pollution prevention
measures to correct violations (i.e., failure of a pollution prevention technology could require the
facility to incur additional time and costs to install traditional treatment and control technologies
in place of the failed pollution prevention technology). While it is not acceptable to allow
additional time to carry out a pollution prevention-based SEP that does not correct the violation,
EPA negotiators may be more flexible when pollution prevention is used to correct a violation
through injunctive releif. EPA's interim policy states:

       If a pollution prevention activity is presented as the means of correcting the
       violation,... the Agency settlement team has some additional flexibility in
       negotiating an implementation schedule, given that pollution prevention
       alternatives sometimes add an element of complexity to a facility-specific
       compliance strategy, especially if it involves new or innovative technology.

If a pollution prevention measure is selected  as part of the compliance strategy, two additional
components of the agreement are also necessary. First, there should be measurable interim steps
that can be evaluated to determine whether the project is on a successful compliance trajectory.
Second, the facility must agree to implement a more traditional fallback compliance technique if
the pollution prevention  strategy is unsuccessful in achieving compliance within the negotiated
time period.
           Enforcement/Pollution Prevention Policy
           Alaska Department of Environmental Conservation
All Media
 The Alaska DEC and Pollution Prevention Policy Council (PPPC) require all notice of violation
 letters to: (1) recommend implementation of pollution prevention and recycling strategies to
 correct violations and prevent violations in the future, (2) refer the facility to the DEC's non-
 regulatory Pollution Prevention Office for technical assistance, (3) request a description of
 written pollution prevention plans, and (4) request information on the steps the facility takes to
 correct violations using pollution prevention strategies.
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Incorporating Pollution Prevention into Enforcement Activities
Section 4.0
The Alaska DEC staff has found that this up-front pollution prevention language in the NOV
yields positive results. Among other things, it has encouraged facilities to rethink their waste
management and materials use practices. In one case, for example, issuance of an NOV prompted
one company to complete a chemical use audit. As a result of the audit, the facility reduced the
number of chemicals used from 400 to 153 and began recycling wastewater back into the process
rather than discharging it.

The dialogue regarding possible pollution prevention alternatives creates a positive relationship
that might not otherwise occur. Staff note, however, that the effectiveness of such an approach
requires that the inspector have a certain amount of pollution prevention knowledge and the
desire to encourage a facility to consider pollution prevention options. It also requires increased
communication and cooperation between the staffs of the media programs and the pollution
prevention program.

Contact:   David Wigglesworth
            Alaska Department of Environmental Conservation
            907-269-7500
          Grumman Corporation Pollution Prevention SEP
          EPA Region 4
RCRA
Grumman Corporation in St. Augustine, Florida, paints and strips aircraft. A 1991 RCRA action
was brought against Grumman for ground disposal of used methylene chloride from stripping
operations. Grumman entered  into a consent decree in 1993 that included a pollution prevention
SEP to reduce the generation of hazardous waste, water, and air pollutants. The settlement
allowed a reduction of $1 million of the $2.5 million civil penalty for the pollution prevention
projects.

The company suggested several pollution prevention projects as part of the settlement. Nine of
those proposed and seven alternative projects were included in the settlement. Strong
environmental benefits and a close nexus between the projects  and the violation resulted in
nearly 100% credit for most of the projects. Some of the most expensive projects were the
following:

•  Replacement of the methylene chloride stripper with an alternative acid-based or other
   environmentally acceptable stripper ($209,940;  100% credit).

m  A process change at the wastewater treatment plant for filtering and recycling wastewater
   discharges ($220,000; 80% credit).
                                                                                    4-17

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Incorporating Pollution Prevention into Enforcement Activities
Section 4.0
a  Downsizing of a large trichloroethylene (TCE)-based vapor degreasing unit, reduction in
   exposed surface area of TCE, and installation of a carbon absorption vapor recovery system
   ($350,000; 100% credit).

While the settlement allows for the substitution or addition of specified alternative projects to
meet total expenditure requirements, the projects are currently well within compliance of the
settlement agreement. Grumman has 2 years from the date of the consent decree to complete the
projects.

Contact:   Jewell Grubbs
            Enforcement and Compliance Branch
            EPA Region 4
            404-562-8579
          Boeing SEP
          EPA Region 3
 RCRA
 Boeing Helicopter of Ridley, Pennsylvania, entered into a consent agreement in 1992 to correct
 several RCRA recordkeeping violations. The agreement contained an innovative SEP that was
 introduced into the settlement process by Boeing's attorney. The agreement required Boeing to
 pay a cash penalty of $800,000 and either make an additional $350,000 cash penalty payment or
 develop and manage an education and assistance program for the RCRA-regulated community in
 the Delaware Valley. Boeing retained the Institute for Cooperation in Environmental
 Management (ICEM), a regional nonprofit organization based in Philadelphia, to develop and
 implement the program. The agreement required that a specific program plan be prepared, and
 numerous certifications were required as the program got underway.

 Businesses eligible for the onsite assistance had to be:

 9  A small business
 •  A generator of certain RCRA hazardous wastes
 •  Located in eastern Pennsylvania or Delaware.

 The program got underway in mid-1993. ICEM used direct mail advertising to thousands of
 companies, advertisements in newspapers in eastern Pennsylvania and Delaware, and follow-up
 calls to recruit clients—but received few inquiries and customers for the free service. EPA
 involvement (even though it was indirect) was the main disincentive because the agreement
 required all pollution prevention audit reports be submitted to EPA for review.
                                                                                    4-18

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Section 4.0
As of February 1995, 11 audit reports have been completed, submitted, and approved by EPA.
Feedback from the companies has been positive for the most part. All have said they would
recommend the service to others.

Contact:  Christopher Pilla
           Compliance and Enforcement Branch
           EPA Region 3
           215-566-3100
         Klein Bicycle Incorporated SEP
         Washington Department of Ecology
RCRA
Klein Bicycle, Inc., in Seattle, Washington, proposed an innovative pollution prevention SEP as
part of a settlement involving RCRA and other environmental violations. While the severity of
the violations might normally have precluded Klein's eligibility for a settlement, Klein
underwent management changes and developed a pollution prevention plan involving the
replacement of solvent parts cleaning with an aqueous system as well as a change to powder-
based coating. Working from a penalty of $242,000, including $88,000 for RCRA violations, the
Washington DOE agreed on an SEP that required Klein to pay $40,000 in cash to the DOE and
carry out $100,000 worth of innovative pollution prevention actions. In addition, Klein is
required to pay $50,000 in cash to "a party, program, or project that benefits water quality in
Lewis County or the State of Washington." The DOE agreed to suspend $50,000 of the penalty
provided that Klein remains in compliance.
Contact:  Tom Eaton
           Washington Department of Ecology
           360-407-6086
          Eastman Kodak SEP
          EPA Region 2
RCRA
On October 7, 1994, EPA and the U.S. Department of Justice (DOJ) announced a landmark
settlement of an enforcement case against The Eastman Kodak Company at its Kodak Park
                                                                                4-19

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Incorporating Pollution Prevention into Enforcement Activities
                           Section 4.0
Facility in Rochester, New York. Kodak Park is the largest manufacturing facility in the
Northeast, comprising 400 buildings on 2,200 acres and employing over 20,000 people. The
violations primarily involved RCRA violations (e.g., failure to properly characterize hazardous
waste streams, leaks in the underground sewer system, and operation of an unpermitted
incinerator). An $8 million cash penalty was reduced to $5 million contingent on the completion
of six separate pollution prevention SEPs (at a cost of $12 million to Kodak beyond the cost of
the penalty). As stated in the SEP portion of the settlement:

       Kodak ... agreed to implement comprehensive injunctive relief that will
       safeguard the Rochester community from the threat of unregulated releases of
       hazardous wastes, and ultimately will result in cleaner air and water	The SEPs
       approved under this settlement will provide additional environmental benefits, as
       they will result in an aggregate reduction of 2.3 million pounds of pollutants by
       the year 2001. Li addition to this large reduction, the toxicity of the remaining
       emissions will be substantially reduced through substitution of less toxic raw
       materials.

The SEPs reduce the generation of hazardous waste and air and water pollutants, and include the
following projects:
                                                 Project Cost
•  Trichloroethylene substitution
a  Chlorofluorocarbon elimination
m  Toluene substitution/naphtha recycling
a  Chemical substitution/toxicity reduction
a  Methanol elimination
a  Formaldehyde elimination

       Total
   $788,000
 $5,173,000
   $372,000
 $3,100,000
 $1,916,000
   $720,000

$12,069,000
 Contact:  George Meyer
            RCRA Compliance Branch
            EPA Region 2
            212-637-4144
          Universal-Fuller Company
          Ohio Environmental Protection Agency
                            RCRA
 Universal-Fuller Company, located in Cleveland, Ohio, is an industrial laundry and cleaning
 facility providing both water washing and dry cleaning services to its commercial customers in
                                                                                    4-20

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Incorporating Pollution Prevention into Enforcement Activities
Section 4.0
five states. The company uses Stoddard solvents to remove oils and greases from gloves,
coveralls, and other industrial garments, making it a large quantity generator of hazardous waste
(comprised primarily of Stoddard solvent still bottoms from the dry cleaning process). Other
environmental discharges include releases to air, the local POTW, and land.

The company was in violation of 40 CFR, Part 265, Subpart I hazardous waste storage
regulations, which require storage of ignitable or reactive wastes at least 50 feet from property
lines. Although moving the dry cleaning operations to a new location or buying adjacent property
may have solved the 50-foot issue, large amounts of hazardous waste would still be generated
from the process. Rather than pursue this route, Universal-Fuller sought pollution prevention and
recycling solutions that would reduce hazardous waste generation to small quantity generator
(less than 100 kg/month) status.

Ohio EPA provided the facility with information about pollution prevention for dry cleaners. The
company president discovered a secondary still, or "cooker," for still bottoms that could reduce
or eliminate the amount of ignitable still bottoms from 9,377 gallons per year to 5,782 gallons
per year. Seeing the potential for Universal-Fuller to be reclassified as a small quantity generator,
Ohio EPA encouraged Universal-Fuller to pursue the project.

The  secondary still reduced hazardous waste generation as follows:

H The still bottoms generated from the primary still are pumped directly into the secondary still,
   where they undergo a second vacuum distillation while being continuously stirred.

• Reclaimed solvent (about 25% of the primary still bottoms) is pumped directly into a storage
   tank where they can be reused in the dry cleaning process as is.

a The remaining oily residue from the secondary still is pumped directly into another storage
   tank. This residue has  a flash point of approximately 177 degrees and therefore is no longer
   considered an ignitable hazardous waste.

H The residual oil can be shipped offsite for energy recovery.16

The company received a $10,600 penalty mitigation for the project and was required to complete
the terms of the settlement within 210 days. The payback on the company's $197,000 investment
was over 22 years, based on disposal costs savings of about $2,000/year and raw materials
savings of $3,000/year. The agreement was met and the company was reclassified as a small
quantity generator.
 ^Pollution Prevention in Ohio Environmental Enforcement Settlements—Analysis and Update, Office of Pollution
 Prevention, Ohio EPA (September 1995).
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Incorporating Pollution Prevention into Enforcement Activities
     Section 4.0
Contact:   Anthony Sasson
            Ohio Environmental Protection Agency
            614-644-2810
          Bleached Kraft Pulp Mill17
          [please provide Agency]
     Water
Bleached Kraft Pulp Mill (BKPM) entered into a consent decree with EPA and a citizen's group
to come into compliance with chronic toxicity limits under the Clean Water Act and to minimize
potential impacts of effluent on recreational users. The decree required BKPM to study a range of
potential remedial measures, including effluent treatment systems and in-plant process changes,
and to propose measures that would bring the mill into compliance.

After studying alternatives, BKPM proposed a pollution prevention solution that eliminated
elemental chlorine and chlorine dioxide from the pulp bleaching process by changing to a
hydrogen peroxide and oxygen bleaching process. Bleach plant wastewater is recycled from the
sewer to an oxygen delignification system and ultimately to a black liquor recovery cycle.

The pollution prevention project benefits the company through savings in worker safety training
and safety equipment purchases, expensive corrosion-resistant plastic, and paint films.
Contact:   [please provide contact information.]
          Ketchikan Pulp Company
          EPA Region 10
Air, Water
On March 21, 1995, Ketchikan Pulp Company of Ketchikan, Alaska, agreed to pay $3.1 million
in civil penalties and up to $6 million more in cleanup of damage caused to Ward Cove as a
result of violations of effluent requirements under the Clean Water Act and emissions violations
under the Clean Air Act.
^Encouraging the Use of Pollution Prevention in Enforcement Settlements: A Handbook for EPA Regions,
Massachusetts Institute of Technology (May 1994).
                                                                                   4-22

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Incorporating Pollution Prevention into Enforcement Activities
      Section 4.0
To obtain injunctive relief, the company agreed to (1) conduct an independent facility-wide
multimedia audit to find ways to ensure full compliance arid prevent pollution, (2) eliminate
direct discharges from its water treatment plant, (3) develop a mill operations and maintenance
program designed to minimize pollution, and (4) conduct a pollution prevention study modeled
after EPA protocols that emphasizes the prevention of toxic discharges or emissions.


Contact:   Office of Water
            EPA Region 10
            206-553-0422
          Bristol-Myers Squibb Company SEP
          New York Department of Environmental
          Conservation
Multimedia
The New York DEC entered into a multimedia enforcement order and a Memorandum of
Understanding (MOU) with Bristol-Myers Squibb Company, in Onondaga County, which
required that the company:

•  Hire an independent consultant, approved by DEC, to complete a compliance audit of its
    facility.

H  Implement a DEC-approvable air pollution control plan.

a  Perform a remedial site assessment and ground water monitoring study.

m  Implement a toxic chemical reduction plan that will achieve a 50% reduction of total toxic
    releases at the facility by the year 2000.

m  Develop an approvable emergency response program to train and equip local emergency
    response teams.

a  Develop an approvable accident prevention planning program.

a  Develop an approvable community awareness program that includes a community advisory
    group.

M  Fund two full-time, onsite environmental monitors.
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Incorporating Pollution Prevention into Enforcement Activities
      Section 4.0
The 50% reduction is to be based on 1988 EPCRA Form R submission, which indicated a total
of 8,722,488 pounds of toxic releases. The plan requires Bristol-Myers Squibb to follow the
pollution prevention hierarchy in finding ways to achieve the reductions.

Contact:   Bill Eberle
            Pollution Prevention Unit
            New York Department of Environmental Conservation
            518-457-6072
          Anitec Image
          New York Department of Environmental
          Conservation
Multimedia
In 1991, Anitec Image, a Binghamton manufacturer of photographic films, papers, and chemicals
for the graphic arts industry and a subsidiary of International Paper, entered into two consent
orders to correct violations at its facility. The problems caused by the plant were determined by
the New York DEC to be multimedia in nature. For example, waste chemicals contaminating
ground water were seeping into nearby homes. Levels of methylene chloride inside three houses
neighboring the facility ranged from 97 to 900 ug/m3 (well above the state's recommended long-
term average ambient air level of 60 ug/m3). A small creek running through the property received
large amounts of industrial waste water containing high levels of silver and affected the  quality
of the Chenango River. During the 1980s, waste silver was mined from under one of the facility's
buildings. In one 3-month period, the ground water temperature was about 90°F at one location
on the main plant site, and the soil was reported to have a high flash point. Anitec was also the
second largest emitter of fugitive air releases of methylene chloride in New York State, based on
1990 Superfund Amendment and Reauthorization Act Title IE data.

The first consent order, to correct immediate problems, required Anitec to complete an ambient
air monitoring plan, perform a soil vapor survey, submit a hazardous waste release report, and
provide a written report on actions taken to eliminate the potential for releases of hazardous
substances. A second consent order, issued in 1992, addressed the nonemergency environmental
concerns at the facility. This order included requirements for Anitec to complete several
environmental projects addressing ambient and fugitive air emissions, ground water
contamination, and hazardous waste generation. Many of these projects incorporated pollution
prevention/waste minimization options. For example, Anitec was required to consider
substitution of less toxic alternatives for hazardous chemicals and closed-loop reclamation. In
addition, Anitec agreed to pay a $1.45 million civil penalty and other costs incurred by state
agencies in responding to and monitoring conditions at the facility.
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Incorporating Pollution Prevention into Enforcement Activities
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Anitec has realized substantial cost savings associated with the pollution prevention/waste
minimization activities that they were required implement; is actively promoting the adoption of
various programs at other divisions of International Paper, and is participating in the New York
DEC's Multimedia Pollution Prevention program.


Contact:   Bill Eberle
            Pollution Prevention Unit
            New York Department of Environmental Conservation
            518-457-6072
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Appendix A
Pollution Prevention Information  Resources
A.1   Electronic Resources

Academic Resource Centers

      The National Pollution Prevention Center (NPPC) for Higher Education
      http://www.umich.edu/~nppcpub/index.html

      The site provides educational material to universities, professionals, and the
      public. The NPPC actively collects, develops, and disseminates pollution
      prevention educational materials.

Affirmative Procurement

      Affirmative Procurement
      http://www.epa.gov/epaoswer/non-hw/procure.htm
      This website provides a list of guidelines and resources to assist federal, state, and local
      agencies and others in purchasing and using products containing recovered materials.
Bulletin Boards
      Enviro Equipment Consulting
      Bulletin Board Number: (703) 506-1025

      This bulletin board offers a variety of environmental topics with a focus on recycling and
      a clearinghouse for environmental equipment.


      EPA Alternative Treatment Technical Information Center (ATTIC) and
      Office of Research and Development (ORD)
      Bulletin Board Number: (513) 569-7610
                                                                        A-l

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Pollution Prevention Information Resources
Appendix A
      This bulletin board provides a database for environmental EPA documents and pollution
      prevention studies.

      EPA Cleanup Information (CLU-IN) Bulletin Board
      Bulletin Board Number: (301) 589-8366; modem settings are 7,N,1

      This bulletin board provides information on all aspects of hazardous waste, cleanup,
      legislation, publications, and permits.

      Massachusetts Office of Technical Assistance for Toxics Use Reduction
      Bulletin Board
      Bulletin Board Number: (617) 727-5621
      This bulletin board provides news about upcoming workshops, technical information, and
      industry case studies.
Design for the Environment

       Carnegie Mellon University Green Design Initiative Home Page
       http://www.ce.cmu.edu/GreenDesign/

       This site provides access to research, publication lists, and education programs in green
       design. The site also provides information on its partnerships.

       Pacific Northwest Laboratory's Design for Environment Page
       http://pprc.pnl.gov/pprc
       The Pacific Northwest Pollution Prevention Research Center (PPRC) is a nonprofit
       organization that works to protect public health, safety and the environment by supporting
       projects that result in pollution prevention and the elimination or reduction in toxics use.
       The database includes over 300 pollution prevention projects. The request for Proposals
       (RFP) Clearinghouse provides information about pollution prevention projects. The site
       offers search engines, up-to-date newsletters, pollution prevention conference schedules,
       and abstracts on pollution prevention research projects.

       UC Berkeley Center for Green Design and Manufacturing
       http://greenmfg.me.berkeley.edu/green/Home/Index.html

       Research, publications, contacts, and green design software are available at site.
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Appendix A
Energy Conservation Related Servers

      Climate Wise
      http://www.epa.gov/oppeinet/oppe/climwise/cwweb/index.htm

      This site provides information on EPA's Climate Wise program—a government-industry
      partnership that helps businesses improve energy efficiency and reduce greenhouse gas
      emissions.

      The U.S. Department of Energy's (DOE's) Energy Efficiency and
      Renewable Energy Network (EREN)
      http://www.eren.doe.gov/

      The website offers hundreds of pages of information from the office of Energy Efficiency
      and Renewable Energy. The online library of resources offers news and archives about
      conservation techniques and developments in the world of energy technology.

      DOE's Energy Information Administration
      http://www.eia.doe.gov/

      This site provides information on energy prices, consumption information, and
      forecasting for a variety of fuel groups.

      The Electric Power Research Institute (EPRI)
      http://www.epri.com/
      EPRI conducts research and development activities and pollution prevention initiatives
      for the electric utility industry.

Environment, Health, and Safety

      DOE's Safety & Health Technical Information Services
      http://tis.eh.doe.gov/
      The website provides accurate and current information regarding material safety data
      sheets (MSDSs), EPA Chemical Fact Sheets, and other topics related to materials, health,
      and safety.

      Environmental Indicators Website
      http://www.epa.gov//indicators/index.html
      This site provides information on a variety of data that provide a picture of the
      environmental status of a state, county or region within the United States using EPA data.
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      Indicators include air quality, water quality, hazardous waste management, use of toxic
      chemicals and pesticides. Information on frequently asked questions, environmental
      progress and indicator reports and links to EPA National Program offices, and other data
      sources are available through this site.

      Occupational Safety and Health Administration (OSHA)
      http://www.osha.gov/
      This website provides information on OSHA standards, programs and services,
      compliance assistance programs, and technical information. This site also contains links
      to other health and safety sites on the Internet.

      Vermont SIR! (Safety Information Resources on the Internet)
      http://hazard.com
      The website provides access to MSDSs, and a wide variety of occupational and
      environmental safety and health information.
General Pollution Prevention Information

       Agriculture Compliance Assistance Center (AgCenter)
       http://es.epa.gov/oeca/ag/aghmpg.html
       The AgCenter provides "one-stop shopping" for the agriculture community, including
       information on the latest pollution prevention technologies and EPA requirements.

       Automotive Service and Repair: Greenlink™
       http://www.ccar-greenlink.org
       This site offers access to environmental compliance information and pollution prevention
       information to those working in the automotive service, repair, and autobody industry.

       Bookmarks from the Vic Young Waste Reduction Resource Center
       http://es.epa.gov/links/vicyoung.html
       This site is a source of Internet bookmarks related to pollution prevention and
       environmental information (part of Enviro$en$e).

       Center for Neighborhood Technology
       http://www.cnt.org/Welcome.html
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Appendix A
       This site is designed to promote public policies, new resources, and accountability which
       supports sustainable, just, and vital urban communities.

       Central European Environmental Data Request Facility (CEDAR)
       http://www.cedar.univie.ac.at

       This site features environmental information about Central Europe, primarily a transition
       point to many other destinations and useful environmental information.

       Defense Environmental Network & Information Exchange (DENIX)
       http://denix.cecer.army.mil/denix/Public/public.html

       DENTX provides the general public with timely access to environmental legislative,
       compliance, restoration, cleanup, safety and occupational health, security, and the U.S.
       Department of Defense (DoD) guidance information. Information on DENIX is updated
       daily and can be accessed through the series of menus, the site map, or via the DENIX
       full-text search engine.

       Department of Energy (DOE) EPIC Home Page
       http://epic.er.doe.gov/epic

       The DOE EPIC home page provides a database search of DOE documents, pollution
       prevention regulations, Internet search engines, a pollution prevention calendar, pollution
       prevention software, environmental information sources, material exchange, material
       substitution, and recycling information.

       Earth Systems, Inc.
       http://earthsystems.org/Environment.html

       This site provides links to over 650 virtual library environmental sites. Industry
       associations, recycling projects, pollution prevention project reports and other
       environmental documents are also listed.

       EnviroLink
       http://www.envirolink.org/
       Envirolink is a grassroots nonprofit organization that unites hundreds of organizations
       and volunteers around the world and serves over 1.5 million people over 130 countries.

       EnviroLink Library
       http://www.envirolink.org/EnviroLink_Library/
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      This website offers links to environmental websites and EnviroNews, a sustainable
      business network, and other environmental information related to ecology.


      Enviro-net
      http://www.enviro-net.com/

      Enviro-net provides a directory of companies, calendars, associations, a classified section,
      and contacting and bid opportunities related to the environmental marketplace.


      Environmental Law Institute (ELI)
      http://www.eli.org/

      This site incorporates ELI publications, programs, law and policy documents related to
      environmental law.


      Enviro$en$e Home Page
      http://es.epa.gov/orBulletinBoardNumber: (703) 908-2092; 1200, 2400, 9600, 14400
      bps (8,1,N)
      This is the most comprehensive environmental website. Enviro$en$e provides search
      services, industry sector notebooks, links to DOE; EPA; DOD; federal, regional, and state
      agencies; academia; public interest groups; industry and trade associations; international
      resources; vendor information; material exchange and substitution libraries; pollution
      prevention information exchange programs; and other valuable pollution prevention
      resources. Information is constantly updated. An information brochure (PPIC order
      number A103) is available through the Pollution Prevention Information Clearinghouse
      (PPIC), phone: (202) 260-1023.

      Enviro$en$e—American Institute for Pollution Prevention (AIPP) Home
      Page
      http://es.epa.gov/aipp/index.html

      The AIPP promotes pollution prevention within industry and throughout society, in part
      by working through its member organizations. The website provides general pollution
      prevention information, AIPP meetings, membership organizations, pollution prevention
      resource materials, pollution prevention publications and pollution prevention project
      updates.
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       EPA Atmospheric Pollution Prevention Division
       http://www.epa.gov/appd.html

       This site provides information on the activities of EPA's Atmospheric Pollution
       Prevention Division. Information on the Energy Star Program, Green Lights Program,
       Methane Outreach Program, publications, and software tools are also located at this
       website.

       EPA Home Page
       http ://ww w.epa. gov/

       This website provides access to a large amount of information. Users may search for
       environmentally related information, public information centers, grants and financing,
       press releases, software, databases, and newsletters regarding EPA's policies, regulations,
       and assistance programs. The site provides information on EPA's information holdings
       including documents, Toxic Release Inventory (TRT), Resource  Conservation and
       Recovery Act (RCRA) and other environmental data.

       Fedworld
       http://www.fedworld.gov/

       This website provides a gateway to over 125 federal bulletin boards.

       Great Lakes Regional Environmental Information System
       http://epawww.ciesin.org/

       The Great Lakes Website is a regional directory and data access system developed by
       CIESIN with support from the EPA's Great Lakes Program, and the Great Lakes National
       Program Office. It provides directory information, online resources, documentation of
       EPA's activities in the Great Lakes Region, and a pollution prevention forum for
       pollution prevention technical assistance providers and pollution prevention vendor
       information.

       National Pollution Prevention Roundtable
       http://www.p2.org/
       The site provides information on the activities of the Natural Pollution Prevention
       Roundtable. The Roundtable provides a national forum for promoting the development,
       implementation, and evaluation of efforts to avoid, eliminate, or reduce pollution at the
       source. The site provides information on legislative briefings, upcoming conferences,
       publications, and access to Roundtable yellow pages, links to other state and local
       websites, and information regarding international activities.
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       Pacific NW Pollution Prevention Resource Center
       http://www.pprc.org/pprc

       This website includes an online database of pollution prevention research projects, an
       online pollution prevention request of proposals clearinghouse, pollution prevention
       technology reviews, the PPRC's newsletter, and other information for businesses in the
       Northwest.

       Pro-Act, A Base-Level Environmental Information Exchange Sponsored by
       HQ Air Force Center for Environmental Excellence (AFCEE)
       http://www.afcee.brooks.af.mil/pro_act/main/proact4.htm

       The site contains access to information that has been developed by Pro-Act staff in
       response to queries from Air Force personnel. While new queries cannot be requested, the
       answers to past queries regarding a myriad of environmental topics can be viewed.
       Access is provided to a technical inquiry section, Fact Sheets, and Cross Talk, a monthly
       newsletter produced by Pro-Act.

       Sources of Environmentally Responsible Wood Products, Rainforest
       Action Network (RAN)
       http://www.ran.org/ran/ran_campaigns/rain_wood/wood_con/

       Information on environmentally sound wood product alternatives is available at this site.

       Waste Minimization National Plan
       http://www.epa.gov/wastemin/
       The Waste Minimization National Plan (WMNP) website provides access to the WMNP
       and presents descriptions of available tools, programs, and plans; available to assist in
       reducing the presence of persistent, bioaccumulative, and toxic chemicals in hazardous
       waste. Access  to the Waste Minimization Prioritization Tool is also available at this site.
Life Cycle Analysis/Life Cycle Assessment (LCA)

       EcoDS (Environmentally Conscious Decision Support System)
       http://shogun.vuse.vanderbilt.edu/usjapan/ecods.htm
       EcoDS is a decision support tool for a cost-risk evaluation of environmentally conscious
       alternatives using streamlined LCA.
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       ECOSITE
       http://www.ecosite.co.uk/

       The website provides information on recent events in LCA, case studies, and
       downloadable copies of software.


       European Network for Strategic Life Cycle Assessment Research and
       Development
       http://www.leidenuniv.nl/interfac/cml/lcanet/hp22.htm

       A platform for LCA research and development.
Material Substitution


       EPA RTI's Solvent Alternatives Guide (SAGE)
       http:/clean.rti.org/

       This database includes a guide to help individuals find alternative solvent materials to
       hazardous solvents. Hazardous Solvent Substitution Data Systems, Solvent Handbook
       Database Systems, Department of Defense Technical Library, and the National Center for
       Manufacturing Science Alternatives Database links are available at Enviro$en$e.


       Environmental Stewardship—Pollution Prevention—Los Alamos National
       Laboratory (P3O)
       Material Substitution Resource List
       http://perseus.lanl.gov/NON-RESTRICTED/MATSUB_List.html

       This website provides information on material substitution alternatives and links to over
       26 material substitution-related sites on the Internet.
Printing
       Environmental Laser's Laser Toner Cartridge Remanufacturing
       Information
       http://www.toners.com/cgibin/var/toner/welcome.html

       This site describes a list of products and available locations.
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       Printer's National Environmental Assistance Center
       http://www.inhs.uiuc.edu/pneac/pneac.html

       The website documents the environmental impacts of the printing industry and offers
       technical assistance to the printing industry. The site has links to Enviro$en$e and other
       websites.

       Printing Industry of America
       http://www.printing.org/
       The web site provides information on technical assistance, education and publications,
       industry research, and upcoming legislation.
Recycling Information

       Environmental Stewardship—Recycling Programs—Los Alamos National
       Laboratory
       http://perseus.lanl.gov:80/PROJECTS/RECYCLE

       The Internet site documents the recycling programs at the Los Alamos National
       Laboratory. Recycled materials are listed along with links to other recycling information
       sites in the country.

       Global Recycling Network
       http://grn.com/gm/
       This site provides recycling-related information to buyers and sellers of recyclable
       commodities.

       King County Recycled Procurement Program
       http://www.metrokc.gov/oppis/recyclea.html
       The King County Recycled Procurement Program lists resources for buyers; information
       on construction and landscaping materials, office products, automotive products, product
       performance summaries, and other environmental links.
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       Recycler's World
       http://www.recycle.net

       The Recycler's World was established as a world trading site for information related to
       secondary and recyclable commodities, byproducts, and used and/or surplus items and
       materials.

Right to Know (RTK)


       RTK NET
       http://www.RTK.NET/

       RTK NET was established to empower citizen involvement in community and
       government decision making. This site provides free access to databases, text files, and
       other information on the environment, housing and sustainable development. In addition
       to information on upcoming conferences, newsletters, training sessions, and job
       opportunities, the site provides links to other related websites.
State Pollution Prevention Programs

       Alabama DEM
       http://www.adem.state.al.us/

       This site offers information on Alabama DEM contacts, organization structure, rules and
       regulations, daily ozone, and AQI and a calendar of events.


       California Environmental Protection Agency (Cal/EPA), Department of
       Toxic Substances Control
       http://www.calepa.ca.gov/dtsc/txpollpr.htm

       This site provides a list of publications for various processes and industries.

       Colorado Department of Public Health and Environment
       http://www.sni.net/light/p3/

       This site has information on the pollution prevention program's free, confidential onsite
       assessments; telephone consultations; industry-specific fact sheets and case studies;
       training programs and technical workshops; a resource library; presentations to trade and
       industrial organizations; program development and support for local governments and
       tribes; grants for entities involved in providing pollution prevention educational  and
       outreach activities; and technical assistance.
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       Connecticut Department of Environmental Protection, Pollution
       Prevention and Compliance Assurance
       http://dep.state.ct.us/Cmrsoffc/Initiatv/p2.htm

       This site provides technical assistance to state agencies and small businesses; and
       educational programs for the public, businesses, and institutions, financial assistance for
       small businesses, and evaluation of marketing strategies, incentives, and other forms of
       assistance for development of new technologies or products that support pollution
       prevention.

       Delaware DNREC
       http://www.dnrec.state.de.us/

       This site provides access to DNREC air, waste, water, and emergency services programs.
       Links to pollution prevention programs for businesses are available through this site.


       Florida Department of Environmental Protection (DEP)
       http://www.dep.state.fl.us/index.html

       This homepage provides access to the DEP mission statement, offices, employees, fact
       sheets, regulations, press releases, upcoming events, and the Pollution Prevention
       Resource Center.

       Georgia Department of Natural Resources, Pollution Prevention
       Assistance Division
       http://www.Georgianet.org/dnr/p2ad/

       The site provides a list of servers and pollution prevention assistance programs on
       national and regional levels. The Pollution Prevention Assistance Division has a variety
       of innovative technical assistance programs including, but not limited to, planning, an
       information center, workshops, on-site pollution prevention assessments, and training. It
       uses existing resources through innovative public-private partnerships with the university
       system; federal, state, and local government agencies; industry and trade associations; and
       non-profit organizations to enhance the spread of pollution prevention throughout the
       state.

       Illinois HWRIC
       http://www.hazard.uiuc.edu/wmrc

       This site provides access to the Illinois Waste Management and Research Center
       (WMRC),  a division of Illinois' nonregulatory environmental agency, the Department of
       Natural Resources. Through this site, the browser has access to news and information,
                                                                                   A-12

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                                                                           Appendix A
      WMRC's library/clearinghouse, and pollution prevention services. Information on
      requests for proposal is also available.


      Indiana Department of Environmental Management, Office of Pollution
      Prevention and Technical Assistance
      http://www.state.in.us/idem/

      This site includes information on source reduction plans for industries to prevent
      pollution, grant programs to encourage innovation in pollution reduction, statewide
      recycling efforts, and education and outreach efforts through workshops and seminars.

      Kentucky Pollution Prevention Center (KPPC)
      http://www.kppc.org

      KPPC's web site provides information and technical assistance to help Kentucky
      manufacturers voluntarily reduce hazardous waste; helps businesses all over the state
      increase profitability, save money, and reduce liability through cutting edge
      environmental management assistance; and conducts statewide training events, onsite
      industrial pollution prevention assessments, management seminars, and information
      services.


      Louisiana Department of Environmental Quality (DEQ) Home Page
      http://www.deq.state.la.us/

      This site provides background information on Louisiana DEQ's calendar of events, and
      information on air quality, solid and hazardous waste, and water resources. Information
      on rules and regulations and an address/phone list for DEQ office locations is also
      available.


      Maine DEQ, Pollution Prevention Program
      http://www.state.me.us/dep/p2home.htm

      In addition to providing general pollution prevention information on their website, the
      Maine DEQ lists pollution prevention resources available on the Internet. Technology
      transfers, pollution prevention equipment information, online networking, library
      information, document search, chemical data, regulatory, recycling, and environmental
      software links are listed in the server.


      Michigan DEQ, Environmental  Assistance Division
      http://www.deq.state.mi.us/ead/

      This website contains pollution prevention information provided by the Michigan EPA.
      Regional information regarding the Environmental Assistance Division is provided.
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Appendix A
       Program descriptions, contact names, bulletins, calendars, publications, fact sheets, and
       other Internet links to Environmental sites are listed.

       Minnesota Technical Assistance Program (MNTAP)
       http://www.umn.edu/mntap/

       The MNTAP site provides a list that contains fact sheets, reference lists, and case studies
       on various pollution prevention topics. The information is organized by industry and
       waste stream.

       Montana Department of Environmental Quality,  Planning, Prevention and
       Assistance Division, Pollution Prevention Bureau
       http://www.deq.mt.gov/ppa/index.htm

       This web site provides information on the Pollution Prevention Bureau's activities in
       pollution prevention education and compliance assistance to Montana's small businesses
       through environmental audits, workshops, rale development, permitting assistance,
       financial assistance, and communications. The Bureau researches, develops,
       demonstrates, and brings to the marketplace new technologies relating to energy
       efficiency, renewable energy, and renewable resources which utilize local resources,
       product streams, or waste streams that are particularly applicable to Montana's economy;
       and evaluates the economic effectiveness of pollution prevention activities.

       New Jersey Technical Assistance Program for Industrial Pollution
       Prevention (NJTAP)
       http://www.njit.edu/njtap
       This site contains information on NJTAP's functions: provides environmental
       opportunity assessments; functions as an information clearinghouse for literature and
       videotapes related to pollution prevention; delivers education and training; and adopts
       and develops novel pollution prevention technologies.

       New York Department of Environmental Conservation, Pollution
       Prevention Unit
       http://www.dec.state.ny.us/website/pollution/prevent.html

       The Pollution Prevention Unit provides technical and compliance assistance to help
       public and private interests. The Unit implements regulatory programs and encourages
       public and private interests to avoid generating pollutants and to reduce, reuse, and
       recycle waste materials to attain a 50 percent reduction in waste.
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                                                                          Appendix A
       North Carolina Waste Reduction Resource Center
       http://www.owr.ehnr.state.nc.us/wn-cl.htm

       The Center provides multimedia waste reduction support for the eight states of U.S. EPA
       Region 4 (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South
       Carolina, and Tennessee). In 1994, U.S. EPA Region 3 (Delaware, District of Columbia,
       Maryland, Pennsylvania, Virginia, and West Virginia) was added. See also: North
       Carolina Pollution Prevention Pays Program http://www.p2pays.org.


       Ohio EPA, Office of Pollution Prevention
       http://www.epa.ohio.gov/opp/oppmain.html

       This website lists the services provided by the Ohio EPA and provides an extensive list of
       resources available in researching pollution prevention opportunities.


       Oregon Department of Environmental Quality, Pollution Prevention
       Division
       http://www.deq.state.or.us/general/p2.htm

       In addition to the program description, the site contains a list of the program's fact sheets
       and a list of pollution prevention resources links.


       Pennsylvania Department of Environmental Protection, Office of Pollution
       Prevention and Compliance Assistance
       http://www.dep.state.pa.us/dep/deputate/pollprev/pollution_prevention.html
      This site provides information and publications on topics relating to pollution prevention,
      links to other Internet sites, technical assistance, and a Small Business Assistance
      Program.


      South Carolina Department of Health and Environmental Control
      (SCDHEC)
      http://www.state.sc.us/dhec/eqchome.htm

      The SCDHEC has a Center for Waste Minimization. The Center's activities are described
      in the state's web page. SCDHEC's Office of Solid Waste Reduction and Recycling has a
      web site discussing its education programs and projects for students,  teachers, and
      schools.


      South Dakota Department of Environment and Natural Resources
      http://www.state.sd.us/state/executive/denr/denr.html
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Appendix A
      The web site's training section lists courses related to pollution prevention that are made
      available through the State.

      Tennessee Department of Environment and Conservation (TDEC)
      http://www.state.tn.us/environment/
      Tennessee's Department of Environment and Conservation's web page contains a
      description of TDEC's Division of Pollution Prevention and Environmental Awareness. It
      also provides a link to the University of Tennessee's (UT) Center for Industrial Services.
      UT's site contains forms, publications, videos, newsletters, and other information related
      to waste reduction.

      Texas Natural Resources Conservation Commission (TNRCC)
      http://www.tnrcc.state.tx.us/
      The TNRCC website features regional pollution prevention activities, community
       initiatives and pollution prevention technology assistance.

       Vermont Agency of Natural Resources
       http://www.anr.state.vt.us/
       Vermont's Agency of Natural Resources' web page has a brief description of the
       recycling program's activities and links to publications.

       Virginia DEQ, Office of Pollution Prevention
       http://www.deq.state.va.us/opp/opp.html
       This site contains fact sheets, success stories, a newsletter, publications, p2 links, and a
       link to Businesses for the Bay.

       Washington Department of Ecology, Hazardous Waste, and Toxics
       Reduction Program
       http://www.wa.gov/ecology/hwtr/index.html
       This web page has information on state regulations, publications, workshops, training
       opportunities, and services pertaining to pollution prevention.
 Technical Associations, Technology Transfer, and Industry

        Air and Waste Management Association
        http://www.awma.org/
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                                                                           Appendix A
       This site provides industry publications, membership information, a buyer's guide,
       meeting dates, employment and educational resources, and links to other relevant sites.

       American Electroplating and Surface Finishing Industry Home Page
       http://www.finishing.com/ or BB Number (201) 838-0113

       The website features industry-specific information regarding pollution prevention
       technologies and environmental issues in the electroplating, surface finishing, and
       painting industries.

       The American National Standards Institute (ANSI)
       http://web.ansi.org/default.htm

       The website is designed to provide the Institute's members and customers with
       convenient access to information on the ANSI Federation and the latest national and
       international standards-related activities.

       The American Plastics Council (APC)
       http://www.plasticsresource.com/

       The website is organized and formatted to meet the needs of specific user groups. The
       APC sites provides both general and specific environmental information.

       The American Welding Society
       http://www.amweld.org/

       This site provides access to relevant news and journals, conferences, company directories,
       and welding technologies.

       CERES Global Knowledge Network (GKN)
       http://www.cerc. wvu.edu/ceres/ceres_index.html

       The primary mission of the CERES-GKN initiative is the creation of a loosely
       interconnected, globally distributed, and locally administered set of knowledge bases on
       environmentally sound product development processes to promote environmental
       sustainability.

       Envirobiz—International Environmental Information Network
       http://www.envirobiz.com/

       The site is sponsored by the International Environmental Information Network, and it
       provides information about various businesses, policies, environmental technologies,
       events, products, and environmental services. The site also has searchable databases.
                                                                                 A-17

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      EPA Center for Technology Transfer and Pollution Prevention (CT2P2)
      http://ingis.acn.purdue.edu:9999/cttpp/cttpp.html
      This site provides the tools necessary to transfer technical information about the
      environment and pollution prevention worldwide.

      Hazardous Technical Information Service (HTIS)
      http://www.dgsc.dla.mil/htis/htis.htm
      HTIS provides technical service to the DoD community concerning compliant
      management of hazardous materials and wastes. It is accessible to the general public as
      well.

      The Industrial Assessment Center Database and Pollution Prevention
       (under the Office of Industrial Productivity and Energy Assessment
       [OIPEA])
       http:/128.6.70.23/
       This site contains the abstracts of papers presented at the April 1995 EPA Office of
       R&D	Risk Reduction Engineering Laboratory's 21st Annual Research Symposium.

       International Cleaner Production Info Clearinghouse (ICPIC)
       http://www.fedworld.gov/
       The ICPIC site provides international resources on cleaner production techniques.

       Manufacturer's Information Net
       http://mfginfo.com/
       This Internet site provides company and product information from various manufacturing
       industries.

       The National Institute of Standards and Technology (NIST): Technology
       Services Information System (TESIS)
       http:/ts.nist.gov/
       NIST provides a wide variety of services and programs to help U.S. industry and trade,
       other government agencies, academia, and the general public to improve the quality,
       reduce the cost, and strengthen the competitiveness of their products to sustain economic
       growth. TESIS provides access to international, uniform practices such as Standard
       Research Materials, Standard Reference Data, and the Standards for Weights and
       Measures.
                              _______=,     _~_

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Pollution Prevention Information Resources
                                                                           Appendix A
       National Metal Finishing Resource Center (NMFRC)
       http://www.nmfrc.org/

       The NMFRC offers vendor directories, technical databases, conference information,
       compliance assistance, and information on on-going metalplating/finishing research.


       National Technology Transfer Center's Environmental Technology
       Gateway
       http://www.nttc.edu/environmental.html

       This site is an excellent source of links to other environmental information. It provides
       information on technology transfer, manufacturing industries, business assistance,
       conferences, programs, phone numbers, Pollution Prevention Yellow Pages, other general
       information and links to over 150 websites. Information includes links to various
       agencies (EPA, DOE, DoD, National Aeronautics and Space Administration [NASA],
       and others), federal laboratories, and white house information.

       NIST's Manufacturing Extension Program
       http://www.nist.gov/public_affairs/guide/

       The site provides hands-on technical assistance and the newest business practices to
       America's smaller manufacturers in an effort to improve their competitiveness.

       The Office of Industrial Productivity and Energy Assessment
       http://128.6.70.23/

       This site provides links to information from the Industrial Assessment Center
       headquartered at Rutgers University. Industrial assessments of small- and medium-sized
       businesses with respect to such issues as waste minimization and energy consumption are
       documented. The website is an excellent resource to find information about pollution
       prevention applications in the manufacturing industry.

       Pollution Prevention Yellow Pages
       http://www.p2.org/nppr_yps.html

       The Pollution Prevention Yellow Pages is linked to the Enviro$en$e website and
       provides pollution prevention information on state, local, and federal pollution prevention
       technical assistance programs.

       Project XL
       http://www.epa.gov/Project XL
                                                                                  A-19

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Appendix A
      Project XL is a national pilot program that tests innovative ways of achieving better and
      more cost-effective public health and environmental protection. Under Project XL,
      sponsors (private facilities, industry sectors, federal facilities, and communities) can
      implement innovative strategies that produce superior environmental performance,
      replace specific regulatory requirements, and promote greater accountability to
      stakeholders. The website provides information on the specific XL projects, legal and
      policy documents, EPA contacts and access to an XL Communities Home Page.

      UCLA Center for Clean Technology (CCT)
      http://cct.seas.ucla.edu/cct.pp.html

      The site provides information on pollution prevention research conducted at the CCT.
      Research and novel educational efforts focus on developing innovative technologies and
      improving the understanding of the flow of materials.

      United Nationals Environment  Program
      http://www.unep.or.jp/
      This site provides a survey of databases on environmentally sound technologies.

Total Quality Management/International Organization on Standardization (ISO)
14000

      DOE's Environmental Management Home Page
      http://www.em.doe.gov/
      The site provides waste management, environmental restoration, nuclear material, cross
      cutting, and other environmental management information.

       EPA Standards Network (ISO 14000)
      http://es.epa.gov/partners/iso/iso.html
      The website provides information on ISO Environmental Management Standards and
       their potential impact in the United States.

       Exploring ISO 14000
       http://www.mgmtl4k.com
       A primer to the ISO 14000, this site includes features such as frequently asked questions
       and full text articles. The site covers ISO 1400 in-depth and touches on ISO 9000 as well.
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      ISO: ISO Online
      http://www.iso.ch/infoe/whatsnew.html
      The ISO provides direct information on ISO 14000 and other international standards
      documentation.

      NIST's Global Standards Program (GSP)
      http://ts.nist.gov/ts/htdocs/210/216/216.htm
      NIST promotes the economic growth of U.S. industry by helping develop and apply
      technology. General ISO 14000 information is provided.
U.S. Environmental Protection Agency (EPA) Pollution Prevention Reports and
Documents
       EPA Pollution Prevention Information Clearinghouse (PPIC)
       http://www.epa.gov/oppintr/acctg
       Telephone: (202) 260-1023
Water
       The Water Environment Federation (WEF)
       http://www.wef.org/
       The WEF provides information on information searches, links, catalogs, events, missions,
       and other activities as they relate to water issues.

       Water Online
       http://www.wateronline.com/
       This site supplies information on water-related manufacturing markets, discussion
       forums, engineering technology, resource libraries, and associations.
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       Waterwiser
       http://www.waterwiser.org/
       Waterwiser provides information on water efficiency and conservation, books,
       conferences, and links to other water-related websites.
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A.2  EPA Voluntary Pollution Prevention/Waste Minimization/
      Programs

      33/50 Program
      Promotes reduction of toxic releases of 17 high priority chemicals.

      TSCA Assistance hotline
      (202) 554-1404
      Monday - Friday
      8:30 a.m. - 5:00 pm. EST

      33/50 Director, OPPTS
      U.S. EPA (7408)
      401 M Street, SW
      Washington, DC 20460
      (202) 260-6907 (202) 401-8142 (fax)
      AgSTAR
      Promotes reduction of methane emissions from manure management.

      U.S. EPA (6202J)
      401 M Street, SW
      Washington, DC 20460
      (202)564-9041
      (202) 565-2077 (fax)
      http://www.epa.gov/agstar
      Climate Wise
      Promotes reduction of industrial greenhouse gas emissions and energy costs through
      comprehensive pollution prevention and energy efficiency programs. This is an
      EPA/DOE partnership.

      Climate Wise, Director
      U.S. EPA (2126)
      401 M Street, SW
      Washington, DC 20460
      (202) 260-4407
      (202) 260-0512 (fax)
      http://www.epa.gov/climatewise
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       Climate Wise Technical Support
       (800) 459-WISE (9473)

       Coalbed Methane Outreach Program
       Promotes methane recovery at coal mines.

       U.S. EPA (6202J)
       401 M Street, SW
       Washington, DC 20460
       (202) 564-9468
       http://www.epa.gov/coalbed

       Common Sense Initiative (CSI)
       Reinvention of environmental regulations to achieve cleaner, cheaper, smarter results for
       six industry sectors; auto manufacturing; computers and electronics; iron and steel; metal
       finishing and plating; petroleum refining; and printing.

       U.S. EPA
       401 M Street, SW
       Washington, DC 20460
       (202) 260-7417
       (202) 401-2474 (fax)
       http://www .epa.gov/commonsense
       Design for the Environment (DfE)
       Promotes environmental considerations in product design.

       U.S. EPA (7406)
       401 M Street, SW
       Washington, DC 20460
       (202) 260-1678
       http://www.epa.gov/dfe
        Energy Star
        Promotes maximum energy efficiency; reduction of atmospheric pollution.

        U.S. EPA (7409)
        401 M Street, SW
        Washington, DC 20460
        Hotline: (202) 775-6650
        http://www.epa.gov/energystar
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       Energy Star Building
       Promotes maximum energy efficiency in commercial and industrial buildings.

       U.S. EPA (6202J)
       401 M Street, SW
       Washington, DC 20460

       Energy Star and Green Lights Program Hotline
       (202)775-6650
       (202) 775-6680 (fax)
       Fax-on-demand: (202) 564-9659
       http://www.epa.gov/appdstar/buildings/

       Energy Star Office Equipment
       Promotes manufacture of energy efficient products.

       U.S. EPA (7409)
       401 M Street, SW
       Washington, DC 20460
       Hotline: (202) 775-6650
       http://www.epa.gov/office

       Energy Star Residential Programs
       Promote energy efficiency through new home design and residential use of energy
       efficient products.

       U.S. EPA (7409)
       401 M Street, SW
       Washington, DC 20460
       Hotline: (202) 775-6650
       http://www.epa.gov/office

       Energy Star Transformer Program
       Promotes use of high efficiency distribution transformers by utilities and manufacturers.

       U.S. EPA (7409)
       401 M Street, SW
       Washington, DC 20460
       Hotline: (202) 775-6650
       http://www.epa.gov/appdstar/buildings/
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      Environmental Accounting
      Promotes business decision making based on identification of environmental costs.

      U.S. EPA (7409)
      401 M Street, SW
      Washington, DC 20460
      (202) 260-3844
      (202) 260-0178 (fax)

      Environmental Leadership Program (ELP)
      Recognizes facilities defined as environmental leaders and promotes environmental
      management systems.

      U.S. EPA (2221A)
      401 M Street, SW
      Washington, DC 20460
       (202) 564-5081 or (202) 564-5041
       (202) 564-0050 (fax)
       http://www.es.epa.gov/elp

       EPA Standards Network
       Coordinates Agency involvement in international standards development and provides
       public information.

       U.S. EPA (7409)
       401 M Street, SW
       Washington, DC 20460
       (202) 260-3584
       Green Chemistry Program
       Promotes and recognizes breakthroughs in chemistry that accomplished pollution preven-
       tion cost effectively.

       U.S. EPA (7406)
       401 M Street, SW
       Washington, DC 20460
       (202) 260-2659
       http://www.epa.gov/dfe/greenchem/
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      Green Lights
      Increase use of energy-efficient lighting technologies.

      U.S. EPA (6202J)
      401 M Street, SW
      Washington, DC 20460
      (202) 564-9178
      http://www.epa.gov/energystar

      Green Lights and Energy Star Program Hotline
      (202) 775-6650
      (202) 775-6680 (fax)
      Fax-on-demand: (202) 564-9659
      http://www.epa.gov/appdstar/buildings/
      Indoor Environments Program
      Promotes reduction of risks from indoor air pollution.

      U.S. EPA (6607J)
      401 M Street, SW
      Washington, DC 20460
      (202) 564-9370
      (202) 565-2038 (fax)
      http://www.epa.gov/iaq

      Indoor Air Quality Information Clearinghouse

      (800) 438-4318 (in DC: (202) 484-1307)
      (202) 484-1510 (fax) [This number is subject to change 4/1/98.]
      Landfill Methane Outreach Program
      Promotes development of landfill gas-to-energy projects.

      U.S. EPA (6202J)
      401 M Street, SW
      Washington, DC 20460
      (202) 564-9768
      http://www.epa.gov/lmop
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      National Radon Hotline

      (800) SOS-RADON (767-7236)

      Natural Gas Star
      Reduces methane emissions from natural gas industry.

      U.S. EPA (6202J)
      401 M Street, SW
      Washington, DC 20460

       (202) 564-9793
       (202) 565-2077 (fax)
       http://www.epa.gov/gasstar
       Pesticide Environmental Stewardship Program (PESP)
       Promotes integrated pest management and reduction of pesticide risk in agriculture and
       nonagriculture settings.

       U.S. EPA (7501W)
       401 M Street, SW
       Washington, DC 20460
       (703) 308-8716
       http://www.pesp.org
       PESP Infoline: (800) 972-7717

       Project XL
       Promotes alternative regulatory approaches to achieve greater environmental benefits.

       U.S. EPA (3202M)
       401 M Street, SW
       Washington, DC 20460
       (202) 260-4297
       http://www.epa.gov/projectxl
        Ruminant Livestock Efficiency Program
        Promotes reduction of methane emissions from ruminant livestock.

        U.S. EPA (6202J)
        401M Street, SW
        Washington, DC 20460
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      (202) 564-9043
      (202) 565-2077 (fax)
      http://www.epa.gov/ruminant
      State and Local Climate Change Program
      Promotes reduction of greenhouse gas emissions through state and local decision makers.

      U.S. EPA (2122)
      401 M Street, SW
      Washington, DC 20460
      (202)260-4314
      (202) 260-0290 (fax)
      Fax-on-demand: (202) 260-2860
      http://www.epa.gov/globalwarming/
      Transportation Partners
      Pomotes reduction of carbon dioxide emissions from the transportation sector.

      U.S. EPA (2126)
      401 M Street, SW
      Washington, DC 20460
      (202) 260-5447
      http://www.epa.gov/tp
      U.S. Initiative on Joint Implementation
      Promotes international projects that reduce greenhouse gases.

      U.S. EPA (2122)
      401 M Street, SW
      Washington, DC 20460
      (202) 586-3358
      Voluntary Aluminum Industrial Partnership
      Promotes reduction of perfluorocarbon gas emissions from aluminum smelting.

      U.S. EPA (6202J)
      401 M Street, SW
      Washington, DC 20460
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      (202) 564-9044
      (202) 565-2083 (fax)
      http://www.epa.gov/appd.html

      Voluntary Standards Network
      Principal mechanism for developing and coordinating EPA policy and participation in
      voluntary standards, including the ISO 14000 series of environmental management
      standards.

      U.S. EPA (7409)
      401 M Street, SW
      Washington, DC 20460
       (202) 260-3584
       (202) 260-0178 (fax)
       http://www.epa.gov/opptintr/p2home/vns.
       Waste Minimization National Plan
       Promotes reduce persistent, bioaccumulative, and toxic chemicals in hazardous waste.

       U.S. EPA (5302W)
       401 M Street, SW
       Washington, DC 20460
       (703) 308-8402
       (703) 308-8433 (fax)
       http://www.epa.gov/wastemin

       Waste Wi$e
       Promotes reduction of solid waste generation by businesses through prevention, reuse,
       and recycling.

       WasteWi$e Program Director
       U.S. EPA (5306W)
       401 M Street, SW
       Washington, DC 20460
       http://www.epa.gov/wastewise

       WasteWi$e Hotline
       (800) EPA-WISE (372-9473)
       (703) 308-8686 (fax)
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      Water Alliances for Voluntary Efficiency (WAVE)
      Promote water efficiency in lodging industry.

      WAVE Program Director
      U.S. EPA (4204)
      401 M Street, SW
      Washington, DC 20460
      (202) 260-7288
      (202) 260-1827 (fax)
      http://www.epa.gov/owm/genwave
      http://www.epa.gov/partners
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A.3   Journals and Newsletters

       Alternative Fuels Data Center Update
       This free quarterly newsletter provides information on technical updates, federal
       legislation, ongoing alternative fuel projects and product and service offerings. This
       newsletter is available through the National Alternative Fuels Hotline at 1925 N. Lynn
       St., Suite 10809, Arlington, VA 22209. Information about the journal is also available
       through the Internet at http://www.afdc.nrel.gov and (800) 423-1363.


       Army Acquisition Pollution Prevention Newsletter

       This journal is intended for Commanders, Chiefs of Staff, Program Executive Officers,
       Program/Product/Project Managers, and Training Activities Commandants/Directors. It
       provides information and assistance on hazardous material management, material substi-
       tution, the "Greening Acquisition Process," and other environmental programs and
       pollution prevention activities initiated by the U.S. Army. Conferences and Training
       Workshops are listed in addition to workshop proceedings. The World Wide Web address
       is http://www.aappso.com/newsltr/newsltr.html. Write to U.S. Army Material Command,
       Attn: AMCRD-E (Mr. Garcia-Baco, Editor), 5001 Eisenhower Avenue, Alexandria, VA
       22333-0001, fax AAPPSO at (703) 617-5146, or e-mail lgarcia@hqamc.army.mil for
       questions or to receive a hard copy.


       Army Energy Information Exchange Newsletter
       This newsletter is designed to aid in the transfer of information on the valuable lessons
       learned from the U.S. Army's energy seminars. Information is published in the areas of
       hazardous material management, energy programs, heating systems, boiler plans, water
       management, new technology, research and development activities, and case studies at
       various Army installations. The information may be accessed via the Internet at http://
       es.epa.gov/new/contacts/newsltrs/armcnsrv/cnsrv-95.html. Points of contact are available
       for each individual program.
        CFC Ha/on News
        The newsletter is a quarterly publication by the Navy Shipboard Environmental
        Information Clearinghouse (SEIC). Conference highlights, safety tips, training material,
        pollution prevention information, new material, and technology information and points of
        contact are provided. The back issues of the CFC Halon News can be accessed via the
        Internet at http://es.epa.gov/new/contacts/newsltrs/halon/halon.html. The information is
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       geared primarily to the Navy branch of the DoD. The newsletter can be accessed through
       SEIC at http://home.navisoft.com/navyozone. SEIC will be moving to
       http://www.navseic.com. Please address comments/questions to (703) 416-1132, fax
       (703) 416-1178, or e-mail seic@thepentagon.com.
       Cleaner Production Newsletter

       The newsletter of the United Nations Environmental Programme (UNEP) IE/PAC
       network is dedicated to promoting cleaner production. UNEP is a global network of
       people active in the area of product development and the environment and promotes
       policies, research initiatives, education, and information exchange and works in
       cooperation with other organizations in the area. The publications are compiled from
       international sources and attempts to unite international efforts for cleaner production
       technologies and green management. Points of contact for each program are provided. To
       access the newsletter go to: http://es.epa.gov/new/contacts/newsltrs/ unep/unep-8.html.
       Closed Loop Newsletter

       The quarterly newsletter of the Iowa Waste Reduction Center (IWRC) presents
       publications regarding small business assistance programs, pollution prevention tools,
       waste management and recycling information, and Iowa waste reduction success stories.
       The newsletter is available through the Internet at http://www.iwrc.org, or by contacting
       the Iowa Waste Reduction Center, 75 Biology Research Complex, University of Northern
       Iowa, Cedar Falls, IA 50614-0185; (319) 273-2079.
       Conservation Update

       The purpose of the Conservation Update is to facilitate the transfer of current State
       Energy Conservation Programs' (SECP's) conservation program and technology
       information among the states and territories. It provides a short description of the
       programs and contact names for each state. For monthly issues, send submittals (by the
       10th of each month), with address corrections, and mailing list changes to: Conservation
       Update, Kentucky Division of Energy, 663 Teton Trail, Frankfort, KY 40601; (502) 564-
       7192, fax (502) 564-7484. Information can also be obtained through the Internet at
       http://www.eren.doe.gov/events/cu/cu_02_97.html.
       Cross Talk

       This newsletter is produced by PRO-ACT, a base-level pollution prevention resource
       sponsored by HQ Air Force Center for Environmental Excellence. The newsletter is
       available through the Internet address http://afcee.brooks.af.mil/pro-act/main/. PRO-ACT
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       provides Air Force guidance and directives, research tools and services, funding
       information, supply process information, training and conference information and other
       resources. Environmental, process, industrial, and logistics experts provide services and
       produce publications in this newsletter. Contact PRO-ACT at (800) 233-4356 or DSN
       240-4214 for additional information.
       Currents-Naval Environmental News, Pollution Prevention, and Compliance
       The Currents-Naval Environmental News, Pollution Prevention, and Compliance is
       published quarterly for the Naval Facilities Engineering Service Center. In this newsletter
       pollution prevention success stories, environmental regulatory news, EPA/USN
       partnership programs, material substitution programs, technical resources and waste
       minimization activities in the U.S. Navy are highlighted. For more information contact:
       Matt Waters, Naval Aviation Depot (7.2.4.S), Jacksonville, FL 32212-0016; (904) 542-
       2795.
       Du Pont Company—Newsletter
       This newsletter is published by the Du Pont Corporation. The success story offers very
       brief information on a 90 percent waste reduction achievement in 3 years in an
       automotive finishing plant. The Internet site
       http://es.epa.gov/new/contacts/newsltrs/dupont-d.html. provides information on the plant
       redesign.
       Electronic Green Journal
       This journal is published on an intermittent basis by the University of.Idaho Library. It is
       devoted to disseminating information concerning sources on international environmental
       topics including: assessment, conservation, development, disposal, education, hazards,
       pollution, resources, technology and treatment. The focus is to publish articles,
       bibliographies, reviews, and announcements for the educated generalist as well as the
       specialist. To subscribe, send an e-mail message to majordomo@uidaho.edu with the
       following included: subscribe egj Your_email_address.
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       EnviroNet

       The quarterly newsletter of the Project in Development and the Environment (PRIDE) is
       supported by the United States Agency for International Development (USAID's) Global
       Bureau Center for Environment, Office of Energy, Environment, and Technology. This
       newsletter presents various global pollution prevention, recycling, and waste
       minimization initiatives. Community-based waste minimization projects, small business
       programs, and industry programs in the manufacturing, municipal, household, and
       agriculture sectors are documented on an international level. Write to EnviroNet, c/o
       PRIDE, 2000 M Street, NW, Suite 200, Washington, DC 20036 to get on the mailing list.
       Environmental Protection

       This monthly magazine focuses on environmental management and problem-solving
       issues in all media and targets environmental professionals. It addresses a variety of
       environmental topics and contains sections on regulatory trends, news updates, and
       products and services. For additional information contact Environmental Protection at
       (254) 776-9000; http://www.eponline.com/; or Stevens Publishing, P.O. Box 2573,
       Waco, TX 76702-2573.
       Environmental Science and Technology

       This monthly publication contains information on a variety of environmental subjects
       including pollution prevention and waste minimization in air, water and waste. The
       publication is technically oriented and contains scientific and research papers,
       environmental news, and legislative updates from around the country. For general
       information,  businesses may call the toll-free number (800) 333-9511, or visit the
       magazine's website at http://pubs.acs.org/journals/esthag/index.html.
       Environmental Solutions

       This magazine provides a forum to discuss environmental management issues in a variety
       of media. In addition to articles on a variety of environmental topics, the magazine
       provides the reader with informational updates on the Federal Register, a conference and
       workshop calendar, and products and services that are available. Businesses interested in
       subscribing to this publication may contact (312) 553-8924. The magazine is also
       accessible via Internet: http://www.esonline.com/index.htm.
       EPA Clear Air Technology Center (CATC) Newsletter

       The CATC News is a quarterly publication of the U.S. EPA's Clear Air Technology
       Center. The CATC is an informal, easy-to-use, no-cost, technical assistance service for all
                                                                                  A-35

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       state and local air pollution control agency and EPA Regional office staff. For others,
       some services may be on a cost-reimbursable basis. The CATC offers quick access via
       the Internet and the CATC Hotline, and in-depth technical support through source-
       specific engineering assistance projects and technical guidance projects. The CATC can
       be contacted at (919) 541-5742 or http://www.epa.gov/ttn/catc/.
       EPA Office of Solid Waste and Emergency Response (OSWER) Reusable
       News
       This newsletter offers information on recycling case studies, market information, state
       programs, products, publications, and links to other organizations that support the efforts
       of the EPA. The publication is available online at http://es.epa.gov/epaoswer/non-
       hw/recycle/reuse.htm.
       FOCUS Waste Minimization Newsletter
       This newsletter is published by the North Carolina Division of Pollution Prevention and
       Environmental Assistance (DPPEA) and provides information on environmental
       regulatory policy changes, industry compliance strategies, case studies, waste reduction
       updates, small business resources, contacts, and other information regarding environ-
       mental issues. It also lists documents free of charge to North Carolina businesses. The
       website is http://www.owr.ehnr.state.nc.us/owr.focus.htm. If you would like additional
       information or would like to be added to the mailing list, please contact (800) 763-0136,
       (919) 715-6500 or (919) 715-6503; or e-mail nowaste@p2pays.org.
       From the Source
       From the Source is a quarterly newsletter from the Pollution Prevention Assistance
       Division (P2AD) of the Georgia Department of Natural Resources. The newsletter offers
       technology updates in the field of pollution prevention, assistance programs, general
       pollution prevention information, and a forum for environmentally related issues. The
       newsletter is available through the Internet: http://www.Georgianet.org/dnr/p2ad/. Send
       comments, suggestions, or questions and requests to be included on the mailing list to
       p2ad @ ix.netcom.com.
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       Green Tech Report (GTR)

       This newsletter is a publication of the California Environmental Technology Partnership
       (CETP). Each quarter the GTR looks to promote, develop, and market the state's $17
       billion environmental technology industry. A calendar of events, international programs,
       and state initiatives are designed to provide the environmental industry with valuable
       information. GTR welcomes information on new technologies and products from the
       CETP. The GTR is available through the Internet at http://es.epa.gov/new/contacts/
       newsltrs/GreenTechReport/greenrpt.html, or by contacting the Green Tech Report,
       Cal/EPA, 555 Capitol Mall, Suite 235, Sacramento, CA 95814; tel. (916) 324-9670, fax
       (916) 445-6401.
       HazTech Transfer

       HazTech Transfer is published quarterly. The newsletter is interested in research
       appropriate to the Great Plains-Rocky Mountain Hazardous Substance Research Center
       (HSRC), technology transfer and training activities, articles of opinion on hazardous
       material technology or policy, reviews of technical books related to HSRC research,
       technology transfer and training, senior management changes in EPA Regions 7 and 8
       and DOE, and other related information. The newsletter is available through the Internet
       at http://www.engg.ksu.edu/HSRC/HazTech. html; or by writing to the Great Plains-
       Rocky Mountain Hazardous Substance Research Center, EPA Regions 7 and 8, 113 Ward
       Hall, Kansas State University, Manhattan, KS 66506-2502.
       Hazardous Technical Information Services (HTIS)

       The HTIS is a service of the Defense Logistics Agency located at the Defense Supply
       Center Richmond (DSCR), Richmond VA. The goal of the HTIS is to assist the DoD
       community with Helpline Answer Service as well as with a Technical Bulletin
       concerning the compliant hazardous materials and wastes. The bulletin responds to
       environmental questions and offers links to other environmental bulletins. The Internet
       address is http://www.dgsc.dla.mil/htis/htis.htm. The HTIS can be reached via telephone
       (800) 848-HTIS, fax (804) 279-5168, e-mail: htis@dscr.dla.mil, or via mail at the
       Defense Supply Center Richmond, DSCR-VBC/HTIS, 8000 Jefferson Davis Highway,
       Richmond, VA 23297-5609.
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       Journal of Air and Waste Management Association
       This magazine is published monthly and features articles on waste minimization and
       pollution prevention related to air quality and the management of waste. In addition to
       articles on innovative air and waste management technologies and techniques, this
       publication discusses regulatory trends and provides information on conferences,
       workshops, and available products and services. For additional information call (412)
       232-3444. The journal can be found on the Air and Waste Management Association's
       (AWMA's) website at http:///www.awma.org.
       Lighting Answers
       Lighting Answers is published by the Lighting Research Center at the Rensselaer
       Polytechnic Institute. The publication is intended to complement the National Lighting
       Product Information Programs' (NLPIP's) publication, Specifier Reports. It provides
       information related to lighting and energy research programs conducted at the Lighting
       Research Center. For publication ordering information, contact the Lighting Research
       Center, Rensselaer Polytechnic Institute, Troy, NY 12180-3590; (518) 276-8717, fax
       (518) 276-2999. The publication is available through the Internet at: http://www.lrc.rpi.
       edu.
        Municipal Solid Waste Management
        This publication is a journal for municipal solid waste professionals. Published seven
        times a year, it contains articles related to waste management and discusses the latest
        technologies in solid waste management techniques and technologies. The subscription is
        free to those in the industry; $60/year for others. For more information, contact Forester
        Communications at (805) 681-1300.
        The Newsletter of the Northwest Policy Center—The Changing Northwest

        The Northwest Policy Center is a program designed to improve public strategies for
        maintaining a vital economy and a healthy environment in the states of the Northwest.
        The purpose of the Center is to inform and invigorate the efforts of those who shape
        public policy by carrying out policy research, designing and evaluating policy
        alternatives, and fostering a continuous exchange of information to those facing the
        economic and environmental challenges of the Northwest region. The Internet site
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       http://weber.ii. washington.edu/unpcweb/ provides on line access to the most up-to-date
       newsletter. Contact the Northwest Policy Center, 409 Parrington Hall, Box 353060,
       University of Washington, Seattle, WA 98195-3060; (206) 543-7900; fax (206) 616-5769
       for subscription information.
       On Tap—Drinking Water News for America's Small Communities
       On Tap is a free publication of the National Drinking Water Clearinghouse, sponsored by
       the Rural Development Administration. News and notes regarding drinking water are
       presented in the newsletter. EPA policies, RDA loans, microbiological treatment systems,
       analytical tests, task force meeting proceedings, and other drinking water resources are
       discussed. The website http://www.ndwc.wvu.edu provides more information. To receive
       a hardcopy or to submit material for publication, contact: The Editor, On Tap, NDWC,
       West Virginia University, P.O. Box 6064, Morgantown, WV 26506, or call (800) 624-
       8301.
       Pollution Prevention Advisor

       Articles in this pollution prevention DOE newsletter provide information on federal
       pollution prevention programs, new technology, information resources, award programs,
       cleaner technologies implementations, industry pollution prevention activities, waste
       management alternatives, environmental management resources, and links to other
       pollution prevention information. The newsletter can be accessed via Internet at
       http://www.thewebcorp.com/nmer/advisor.htm. Back issues can be ordered from
       McPherson Environmental Resources at (423) 543-5422.
       Pollution Prevention News

       The free newsletter published by the Pollution Prevention Office of the EPA contains
       information on updates, calendars, state program information, policy changes,
       international programs, resource links and contacts. It is available online at:
       http://www.epa.gov/ChemLibPPNX. To be added to the mailing list write to Pollution
       Prevention News, U.S. EPA (MC7409), 401 M Street SW, Washington, DC 20460, or
       fax (202) 260-2219, or e-mail Heikkinen.Ruth@epamail.epa.gov.
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       Pollution Prevention Northwest Newsletter
       Pollution Prevention Northwest is published bimonthly by the Pacific Northwest
       Pollution Prevention Research Center (PPRC). Information on permitting, pollution
       prevention in higher education, pollution prevention in other states and regions, pollution
       prevention resource links, online services, conference information, meeting schedules and
       general pollution prevention information is provided. To receive a free subscription,
       contact the PPRC, 1326 Fifth Ave., Suite 650, Seattle, WA 98101, USA; telephone (206)
       223-1151; fax (206) 223-1165. Online access and subscription is available through:
       http://www.pprc.org/pprc/.


       Pollution Prevention Opportunities Newsletter

       Pollution Prevention Opportunities is a publication of Arizona DEQ's Pollution
       Prevention Unit. The newsletter addresses various issues related to pollution prevention
       and provides a calendar of events. For more information or to be included on the mailing
       list, please contact ADEQ at (602) 207-4235 or fax at (602) 207-2302.
        Pollution Prevention Post
        This quarterly publication highlights federal legislation, EPA initiatives, Pollution
        Prevention Roundtable activities, and state and local pollution prevention program
        activities. This publication is available from the National Pollution Prevention
        Roundtable, 2000 P Street, NW, Suite 708, Washington, DC 20036; (202) 466-7272 (The
        Update is a supplement to the Pollution Prevention Post).
        Pollution Prevention Quarterly
        The newsletter provides information on pollution prevention news around the country.
        Partnership programs between industry members state pollution prevention offices are
        highlighted. The newsletter provides technical information and pollution prevention
        developments in addition to pollution prevention conference schedules and success
        stories to businesses seeking to cut costs. Enforcement, permitting, initiatives, training,
        volunteer programs, facility audits information and state news are updated on a regular
        basis. To be placed on the permanent mailing list, contact: The Pollution Prevention
        Program, Dade County DERM, 33 SW 2nd Ave., Miami, FL 33130-1540; or call (305)
        372-6798. The DERM website can be found at http://www.metro-dade.com/derm.
        Pollution Prevention Review
        This quarterly journal discusses source reduction and waste minimization, with an
        emphasis on technical and institutional issues encountered in industrial settings. For
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       additional information, contact John Wiley & Sons, 605 Third Avenue, New York, NY
       10158; (212) 850-6645.
       Pollution Prevention Virginia Newsletter

       The Virginia DEQ Office of Pollution Prevention's quarterly newsletter includes
       information on regional grant programs, pollution prevention initiatives, technical
       assistance programs, a conference calendar, and pollution prevention networking
       information. Through the Office of Pollution Prevention (OPP), Virginia businesses can
       receive onsite technical assistance or personalized research services. Access to a library
       full of helpful information and training services are also available. Contact the OPP at
       DEQ, P.O. Box 10009, Richmond, VA 23240-0009; telephone (800) 592-5482, or fax
       (804) 698-4346, for additional information on Virginia DEQ programs. The newsletter
       will be online soon at http://www.deq.state.va.us/opp/newslettr.html.
       Point Source

       The Point Source is a quarterly newsletter published by the University of Northern Iowa.
       This program focuses on applied research to reduce emissions of hazardous pollutants
       from small business sources. The website http://www.iwrc.org provides online service to
       the newsletter. For a hardcopy or additional information, contact: The Iowa Waste
       Reduction Center, 75  Biology Research Complex, University of Northern Iowa, Cedar
       Falls, IA 50614-0185; telephone (800) 422-3109.
       R2P2 Spider—An EPA Region 2 Pollution Prevention Biannual

       The newsletter provides information form the Region 2 office of the EPA. Pollution
       prevention opportunity assessments, news from the National Pollution Prevention
       Roundtable, pollution prevention grant summaries, industry initiatives, pollution
       prevention editorials and policy information are featured in the newsletter. The newsletter
       is available through the Internet at http://www.epa.gov/ region02/pollprev/p2page.htm. A
       hard copy may be requested by e-mailing the editor at sapadin.janet@epamail.epa.gov or
       by calling (212) 637-3584.
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       Reusable News
       This newsletter provides information on municipal solid waste issues. It is available
       through EPA's RCRA Information Center. U.S. EPA, 401 M Street SW (5305),
       Washington, DC 20460 or phone (800) 424-9346.
       Shop Talk
       Published by the Washington State Department of Ecology, this newsletter highlights
       regional waste reduction programs, industry-specific pollution prevention initiatives
       (manufacturing, printing, pulp and paper mills, aerospace, defense, medical electronics)
       and links to other pollution prevention resources. Write to the Washington State
       Department of Ecology, P.O. Box 47650, Hazardous Waste Mo, Olympia, WA 98504-
       8711, or call (360) 407-6752. Access the website at http://www.wa.gov/ecology.
       U.S. Agency for International Development (USAID) Environmental
       Pollution Prevention Project (EPS)
       The Environmental Pollution Prevention Project (EPS) is a 5-year project sponsored by
       the USAID to address urban and industrial pollution and environmental quality in
       developing countries. The newsletter on the Internet home page http://es.inel/new/ep3/
       ep3.html. provides documents, EPS News and case studies of various global industries
       (Batteries, Cattle Hide Tanning, Textile, Electroplating, Oil Extraction, Sheep Hide
       Tanning, Soap manufacturing). For comments or questions on EPS's service, e-mail
       lharmon @ habaco.com.
        U.S. DOE Building Energy Standards Program (BESP) Update

        The newsletter from the U.S. Department of Energy Building Energy Standards Program
        at Northwest Laboratory features information on DOE developments in the field of
        pollution prevention. Model Energy Code Compliance Materials, DOE funding support,
        calendars, studies, surveys, state incentive funding programs, conferences, workshops,
        meetings and other pollution prevention information related to the DOE are presented in
        the publication. The newest edition of the newsletter is available at the website address:
        http://es.inel/new/contacts/newsltrs/besp/bespv3-3.html.
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       Waste Age Magazine

       This magazine targets professionals in the waste industry. Issues related to recycling,
       energy and landfilling are addressed in this publication. Information on legislative
       updates, products and services are also provided. Waste Age is published monthly at a
       subscription rate of $55/yr through the National Solid Waste Management Association.
       For additional information, contact (800) 829-5411.
       The Waste Line

       The Waste Line is a publication of the KY Partners State Pollution Prevention Center and
       promotes pollution prevention awareness in the state of Kentucky. Partnership programs
       between manufacturing industries, pollution prevention education in KY, research
       opportunities, waste management, waste reduction programs and a list of current events
       are documented in the newsletter. The newsletter also provides a list of other newsletters
       related to pollution prevention and waste minimization. The newsletter is available by
       Internet (http://es.inel/new/contacts/ newsltrs/wstlinewst-line.html) or by contacting
       Marvin Fleishman, KY Partners (502) 852-6357; fax (502) 852-6355, or e-mail
       mOfleiOl @ ULKYVM.Louisville.edu.
       WDNR Waste»Less»News

       This newsletter is sponsored by the Wisconsin Department of Natural Resources
       Hazardous Waste Minimization Program. The publication offers regional information on
       pollution prevention and waste minimization activities in Wisconsin and the Great Lakes
       region. Many articles from regional Hazardous Waste Pollution Prevention offices are
       presented. This publication can be obtained by calling Karen Bridge at (608) 246-7990.
       World Waste

       This magazine targets businesses and professionals involved in or associated with waste
       management. In addition to articles on emerging regulatory trends in waste management,
       this magazine discusses waste management techniques and technologies and associated
       products and services. World Waste is published monthly by Intertec Publishing Corp.
       Subscription rates in the United States are $55/year. For subscriber information, contact
       (800) 556-2209.
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       The Xchange
       The Xchange is the official Environmental Program newsletter of the Naval Aviation
       Systems Team. The newsletter features information on life cycle management,
       compliance issues, upcoming events, pollution prevention programs and the technology
       depot. For more information about this newsletter contact Herman Vormhall at the Naval
       Air Station, Bldg. 404, Patuxant River, Patuxant, MD; (301) 757-2137;
       vormauh.ntrprs@navair.navy.mil.
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