ONGOING EFFORTS BY STATE
REGULATORY AGENCIES TO INTEGRATE
        POLLUTION PREVENTION
         INTO THEIR ACTIVITIES
                    for:
            Pollution Prevention Division
        Office of Pollution Prevention and Toxics
         U.S. Environmental Protection Agency
        Work Assignment Manager: Lena Hann
              Kerr & Associates, Inc.
             2634 Wild Cherry Place
               Reston, VA 22091

              In partial fulfillment of
          Industrial Economics Corporation's
     Work Assignment #132, Contract #68-W1 -0009

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                          TABLE OF CONTENTS


Introduction	1

Program Elements	,....:	2

Chart: Multimedia and Pollution Prevention Activities by State
 Regulatory Agencies	6

Regulatory Integration Activities, Region I	7
      Explanatory Notes	,	7
           CONNECTICUT	7
           MAINE	7
           MASSACHUSETTS.	.	8
           NEW HAMPSHIRE	9
           RHODE ISLAND	.	9
           VERMONT	10
      CONTACTS	10

Regulatory Integration Activities, Region II	13
      Explanatory Notes	13
           NEW JERSEY	13
           NEW YORK	14
      CONTACTS	15

Regulatory Integration Activities, Region III	16
      Explanatory Notes	16
           DELAWARE	.16
           MARYLAND	16
           PENNSYLVANIA	17
           VIRGINIA	17
      CONTACTS....	I	....18

Regulatory Integration Activities, Region IV	20
      Explanatory Notes	20
           FLORIDA	20
           GEORGIA	21
           KENTUCKY	....21
           NORTH CAROLINA	22
           MISSISSIPPI	23
      CONTACTS	24

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Regulatory Integration Activities, Region V	...„.	26
      •Explanatory Notes	             26
            ILLINOIS	;	       "26
            INDIANA	     27
            MICHIGAN	    28
            MINNESOTA	             29
            OHIO	    30
            WISCONSIN	:	    31,
      CONTACTS	33

Regulatory Integration Activities, Region VI	......35
      Explanatory Notes	 35
            LOUISIANA	35
            OKLAHOMA	 35
            TEXAS	.	  35
      CONTACTS	37

Regulatory Integration Activities, Region VII	...........39
      Explanatory Notes	39
            IOWA	39
            KANSAS	39
            NEBRASKA	40
      CONTACTS	41

Regulatory Integration Activities, Region VIII......	43
      Explanatory Notes	43
            COLORADO	43
            NORTH DAKOTA	43
            SOUTH DAKOTA	44
            UTAH	44
            WYOMING	45
      CONTACTS	46

Regulatory Integration Activities, Region IX	.48
      Explanatory Notes	.........48
            ARIZONA	.48
            CALIFORNIA	49
            HAWAII	52
      CONTACTS	52

Regulatory Integration Activities, Region X	54
      Explanatory Notes	.54
            ALASKA	54
            IDAHO	:	..:	55
            OREGON	55
            WASHINGTON	56
      CONTACTS	58
                                       n

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Introduction


       As  pollution  prevention  has  become  an  increasingly important  part  of  state
environmental programs, the scope and diversity of these programs has increased.  When the
National Roundtable of State Pollution  Prevention Programs first  formed,  the  few state
pollution prevention programs were largely non-regulatory technical assistance programs.

       While the vast  majority of state  pollution prevention  initiatives  remain focused on
providing non-regulatory assistance to industry, the range of methods utilized by the states has
grown enormously. The changes have included both a growth in the scope and sophistication
of the non-regulatory programs, and an increasing effort in many states  to modify regulatory
programs to incorporate pollution prevention approaches.

        Many states are increasingly looking for opportunities to  improve the environmental
protection provided by their regulatory programs beyond that afforded by the traditional media-
specific end-of-pipe programs. Some have decided that integration  of pollution prevention1
into their regulatory programs  may both augment current regulatory strategies and support
non-regulatory initiatives.

       Innovation  and  experimentation   are  frequent  elements of  regulatory  integration
initiatives. States have  used pilots to test new approaches. Program designs have often been
context-specific for unique state or local conditions.  They have included  a range of activities
affecting the issuance  of environmental  permits, compliance inspections and enforcement
actions. In some cases, states have also  taken organizational measures, ranging from training
of regulatory personnel to functional reorganization within the state  agency,  to more fully
promote implementation of pollution prevention approaches.

       In order to  facilitate sharing of what is being learned from these  pilot projects and
experimental approaches, the Board of Directors of the  National Roundtable agreed it would
be useful to develop a summary of current state regulatory integration activities. The purpose
of this report is to provide  a general perspective on the  approaches being  used, a very brief
picture of the projects being undertaken in individual states, and a list of appropriate people to
contact for  in-depth information  or for updates.  Much  of the information in the  report on
individual state programs was provided to the Board by Roundtable members.

       The  focus of this  report is specifically  on integration of pollution prevention  into
regulatory operations; it is not  meant to be a comprehensive picture  of any state's pollution
prevention activities.   Incentives,  programs, peer match,  grants, technical assistance,  and
other voluntary pollution prevention efforts fall outside the scope of this project
1      Former EPA Deputy Administrator Henry Habicht, in a memorandum to EPA staff (May
28, 1992),  defined "pollution prevention" as being "source reduction" as defined under the
Pollution Prevention Act, which includes any practice which reduces release of pollutants  prior
to recycling, treatment, or disposal. A few state programs, however, also include at least some
recycling within the scope of their pollution prevention programs.

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 Program Elements

       What activities  contribute to  integration  of pollution prevention into regulatory
 programs?   Approaches  are  evolving, and vary widely from  state, to state.  The areas
 summarized in the matrix and within individual state summaries reflect a wide range of current
 projects and directions.


 Legislation

       Facility Planning

       At least twenty states now require or promote pollution prevention planning for some of
 the facilities subject  to environmental regulation.  In  most (but not  all) cases, planning
 requirements are specifically established under state statute.

       Other Pollution Prevention Legislation

       Beyond facility planning requirements, pollution prevention legislation, in some states,
 promotes multimedia coordination, mandates integration of databases to promote multimedia
 pollution prevention, requires pollution prevention training for regulatory personnel, or requires
 a  state regulatory agency to  make  pollution  prevention technical  assistance referrals  for
 facilities found to be out of compliance.  This category includes legislation involving integration
 of pollution prevention into state regulatory programs.  For  the purposes of this report, this
 category does  not include  authorizing legislation  for  non-regulatory technical  assistance,
 economic incentives or financial support for pollution prevention.


 Permitting

       Multimedia

       A few states are exploring the possibility of writing permits which cover more than one
medium at once.  By asking permit writers from more than one program to review a proposed
permit, or by asking the firm to consider its overall process with all of its impacts, the  state
may reduce cross-media transfers and assist in ascertaining additional pollution prevention
opportunities.

       Pollution Prevention

       Whether or not permits  are multimedia in scope,  prevention approaches may be  used
in  the permitting process.  For  example, states  may require firms to  develop pollution
prevention plans for processes as part of the permit application package.  As  permit writers
become more sophisticated in their understanding of manufacturing processes, they can foster
a dialogue with applicants about prevention alternatives.

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 Inspections

       Multimedia

       A few states have  explored the possibility of multimedia inspections.  These may
 involve single-media inspectors trained to evaluate a facility with respect to all media concerns,
 teams of inspectors with all the media specializations, inspectors with in-depth knowledge of ail
 aspects of a particular  industry, or some combination of these  approaches.   Objectives of
 multimedia inspections  might be  potential pollution prevention gains  from  evaluating  all
 aspects of a facility simultaneously, or efficient use of agency resources.

       Pollution Prevention

       This includes at least two types of activity: inspectors providing some form of pollution
 prevention technology  transfer, and  inspectors making referrals  to  technical assistance
 programs, either during  the  inspection or in follow-up. Such pollution prevention inspection
 activities are sometimes done by individual media programs, and sometimes as part of a
 multimedia inspection effort  In some cases  inspectors  hand out brochures  for the state's
 technical assistance program, discuss the content of a site's waste minimization plan, or look
 over facility pollution prevention plans.  Or, with a notice of noncompliance, officials may make
 a stronger referral to technical assistance or consulting services or even suggest developing
 specific pollution prevention'options.


 Enforcement

       Multimedia

       In some cases, settlements may involve multimedia requirements: Such requirements
 are most likely where the enforcement action is based on multimedia inspections.

       Pollution Prevention

       Several states are using enforcement actions to encourage companies to use pollution
 prevention  to  come into compliance. The  primary goal is  always  to  bring the firm into
 compliance. Both officials and regulated entities are finding that pollution prevention can be an
 effective long-term strategy, less likely to be inadequate in a few years, and less likely to cause
 cross-media transfers, than are traditional abatement approaches. Settlements may include
 either  particular pollution prevention measures or  specify the  development of a waste-
 reduction plan.


 Data Integration

       A few states have made data integration a goal; such data may be used to support
either pollution prevention technical assistance efforts and/or regulatory targeting,  in addition
to uses of data for targeting technical assistance (which is beyond the scope  of this paper),
data on chemical use, emissions or discharges, and compliance can be overlaid  to gain a more
accurate picture of a facility's operations and to identify  any  gaps.   Historically,  trie use  of

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 separate databases tracking different information (perhaps even using different names for the
 same -facility) has made it  harder for people from different programs to coordinate  their
 activities with respect to a firm or site. Integration may take the form of development of a new
 database which incorporates or cross-references older compliance databases.  Some states
 are now making innovative use of existing data to improve their overall program operations.

        Facility-based databases represent a shift  in the way that environmental  regulators
 think about regulated entities. Rather than a plant looking only like a set of stacks to an air
 quality inspector, or only a wastewater outfall to a water permit writer, or only a generation and
 storage area to a hazardous waste inspector, the plant becomes an entire facility which exists
 to make one or more  products and  happens to produce one  or more byproduct or waste
 streams incidental to making that primary product.  By at least cross-referencing the various
 data elements associated with a given facility, regulators make it easier to see the big picture
 at a plant, and reduce  the likelihood that a pollution prevention opportunity (or a stream that
 should be reported) will be overlooked. Facility-based data management also supports efforts
 to prevent cross-media transfers resulting from new  regulations or enforcement actions.


 Organization


        Training

        Several states  have begun  offering training  to  regulatory  personnel  on pollution
 prevention.   EPA  HQ  and  Regions have assisted  some  states in  providing training to
 inspectors or permit writers.  Training may focus on a particular industry and its processes, or
 may more generally discuss pollution prevention thinking and how regulatory personnel can
•'begin to use ft.

        Multimedia Workgroups

        Short of (or instead  of)  restructuring, some  agencies have established multimedia
 workgroup processes to identify opportunities and clarify goals and objectives for multimedia
 and pollution prevention approaches to meeting agency regulatory objectives.

        Integration Strategy

        Som« agencies  have developed, often as a result of workgroup efforts, strategies for
 integrating pollution prevention into their regulatory  business.  The development of a strategy
 may preceda or follow pilot projects (in permitting, inspection, or enforcement) or training
 programs.

        Reorganization

        In order to support these   new  approaches  some  agencies have undergone
 restructuring, elevating the pollution prevention group or encouraging media programs to work
 more closely together.   In  some cases, an agency might restructure functionally; for example,
 all permit-writers might  report to a single senior manager for permitting, rather than being
 organized by media.

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ORGANIZATION OF THE REPORT


      The report is arranged in the following format

o     a chart summarizing, in the form of a matrix, the regulatory integration activities of the
      states;

o     explanatory information about particular state programs (organized by EPA Region);
      and

o     lists of contacts for state programs (by Region).

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Regulatory Integration Activities, Region I


Explanatory Notes


CONNECTICUT

Legislation

General pollution  prevention policy  and philosophy  were established by  P.A.  91-376;
manufacturers may be required to use pollution prevention as the primary means of coming
into compliance with state regulations.

Permitting

DEP has been exploring permit conditions which promote pollution prevention.

Organization

A workgroup with representation from various media programs has recently been constituted,
and  some  internal pollution  prevention training has  been conducted.  DEP  has been
developing  improved  management practices for  hazardous waste, and making regulatory
efforts to reduce packaging and toxic constituents in packaging.  The Department's annual
strategic plan sets pollution prevention goals.


MAINE

Legislation

The 1992 Amendments to the Reduction of Toxics Use, Waste and  Release Act establishes
the Office of Pollution Prevention within the  Department of Environmental Protection.  The
Office is to review Department programs and make recommendations to the Commissioner on
the integration of pollution prevention into its programs.  In addition, the Office ensures that
Department rules,  programs,  and  activities  are  consistent with and  are  not barriers to
prevention goals.

Organization

Maine has located an Office of Pollution Prevention (OPP) within the DEP to administer the
state's TUR Law and its Small Business Assistance (CAAA) Program, and to facilitate
Industry/DEP Pollution Prevention Teams in Total Quality Environmental Management (TQEM)
projects.  The TUR staff  (4) works with  companies  to help meet state mandated reduction
goals for hazardous waste, toxic release and use. TQEM Teams are underway at about 35

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 companies.  More companies are, waiting to get in as resources become available.  Cross
 training' of all DEP compliance -arid technical  staff is helping to identify opportunities  for
 pollution prevention use in many areas of the program.


 MASSACHUSETTS

 Permitting                           •  .   /                .      .,    '

 A few multimedia  permits have been issued by DEP throughout the state. The state-wide
 permit coordinator is Deborah Gallagher (617-292-5572).  Bill Lamkin is the director of the
 Source Reduction  Permit Project (SRPP) based in the Northeast Regional Office in Wobum.
 The project will include evaluation of several different models for permitting facilities.

 Inspection

 It is now standard  practice, for all regions statewide, for compliance inspections to be facility-
 wide inspections including all relevant media inspections plus screening for unregistered waste
 streams in all regulated media.  By organizing  the  inspection report by production  unit,
 inspectors  find it  easier to  articulate source reduction opportunities they have identified.
 Inspectors  provide  some  technology transfer  during  inspections  and  in follow-up
 correspondence, and they make referrals to the Office of Technical Assistance (OTA) and the
 Toxics Use Reduction Institute (TURIJ.  In addition, multimedia workgroups composed of DEP
 and EPA middle managers and senior field staff have been established to develop a facility-
 wide inspection protocol and new EPA reporting criteria.

 Enforcement

 It is now routine statewide for enforcement actions to cite violations within more than one
 program if such violations are found. Ordinarily these take the form of administrative actions.
 DEP has also negotiated some multimedia consent orders.  All enforcement routinely includes
 referrals to OTA and TURI. Where inspectors have noticed pollution prevention opportunities,
 they make  suggestions in the NONs* cover letters.  In some cases, DEP has required toxics
 use reduction planning or has mitigated penalties if firms take actions which reduce toxics use.

 Data Integration

The Massachusetts Facility Master File (FMF) cross-references all kinds of facility data cross-
 media.  TUR  reporting information is included as a subset of this database.  After October 1,
 1993, the FMF wiJI  be used to track and report compliance and enforcement accomplishment
data. In addition, DEP has integrated permit data on a system which develops timelines and
tracks statutory deadlines.

Organization

DEP's  Source Reduction Policy Task Force, with representation  from each of the media
programs, was formed in 19S7 to explore and develop source reduction options  Since that
time, several  ongoing advisory  committees have been established  to provide input from
stakeholders  outside  the  Department.   In February 1993, the Department reorganized the

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Bureau of Waste Prevention in order to support the facility-wide approach and to facilitate
integrating a prevention bias throughout industrial regulatory activities. The new organization
includes an Office of Program Integration and adopts functional (i.e., compliance/enforcement,
permitting) supervisory roles in addition to the media-based expertise and supervision. The
Office will write three-year workplans on how to implement toxics use reduction and integrate
cross-media approaches for compliance and enforcement, permitting,  regulations and policy,
training, outreach,  program planning, EPA accomplishment reporting and facility  reporting.
Also, within the Bureau of Waste Prevention,  the Department maintains a TUR program to
oversee implementation of TUR reporting and planning requirements.
NEW HAMPSHIRE

Organization

A multi-media task force with representation from each division has been meeting regularly
since June 1992.  The group also includes invited participants from state-level OSHA, public
health, and the NH Business and Industry Association.  The Assistant Commissioner attends
the monthly meetings.  The group has  drafted and adopted  a statement of purpose  and
objectives, and  has also drafted a pollution prevention definition, which was adopted as DES
policy. Currently, the Task Force is drafting a pollution prevention strategy for the Department,
and is working on a project to incorporate pollution prevention into DES compliance activities.

The Task Force has also  developed a list of potential regulatory barriers and  is working  with
EPA Region I on  media grant flexibility.  DES is also closely associated with the Northeast
States Pollution Prevention Roundtable.

In order to select candidate firms for pollution prevention outreach or possible multimedia
projects, the group is in  the process of gathering targeting information from each of the
program offices and is currently considering ways to consolidate these approaches (some use
GIS-based data; others use information  on generation and releases).  DES has two very
limited multimedia databases in place; one for enforcement purposes, and the other a  pilot
program for tracking waste generation, releases, and reductions.
RHODE ISLAND

Organization

DEM has expanded its nonregulatory technical assistance program with a PPIS grant intended
to demonstrate and evaluate the relative effect of regulatory, policy, and in-plant technical
assistance  initiatives on source reduction practices in Rhode Island's textile industry.  The
grant is supporting state efforts to  expand  and incorporate statewide pollution prevention
approaches into  regulatory policy  making  and enforcement actions  by  state and  local
authorities.

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VERMONT

Inspections

Some  RCRA  inspectors have  been  transferring  technical  information about  pollution
prevention  during the inspection process.   A multimedia  training for inspectors will  be
scheduled soon.  DEC has developed a multimedia inspection checklist, and is developing a
multimedia inspection pilot program.

Enforcement

DEC has allowed SEPs and used planning requirements in enforcement actions.

Organization

The  Vermont DEC'S multimedia  pollution prevention workgroup has drafted a charter and
defined terms for internal use. The workgroup is surveying each division which has regulatory
responsibility to discover what types of flexibility its regulations currently have, in  order to
understand what would  be  required to undertake a whole-facility permitting  or inspection
program. The  survey, beyond gathering information, is intended to stimulate dialogue about
what the Department can do to promote pollution prevention through its regulatory actions.


CONTACTS

Connecticut
Dick Barlow or Mary Sherwin
Connecticut Department of Environmental Protection
Waste Management Bureau
165 Capitol Avenue
Hartford, Connecticut 06106
203-566-8476 (Dick); 203-566-5217 (Mary)
203-566-4924 FAX

Rita Lomasney*
Connecticut Technical Assistance Program
900 Asylum Avenue, Suite 360
Hartford, Connecticut 06105
203-241-0777
203-241-2017 FAX
                                        10

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Maine
Ron Dyer, Michael Kuhns, or Ann Pistell
Office of Pollution Prevention
Department of Environmental Protection
State House Station #17
Augusta, ME 04333
207-287-2651
207-287-7826 FAX

Massachusetts
Suzi Peck or Lee Dillard
Toxic Use Reduction Act Implementation Team
Bureau of Waste Prevention
Massachusetts Department of Environmental Protection
1 Winter St., 7th Floor
Boston, MA 02018
617-556-1075; 617-292-5953
617-556-1049 FAX

New Hampshire    ^
Stephanie D'Agostino, Vince Perelli, or Paul Lockwood
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03302-0095
603-271-3503
603-271-2867 or 271-2456 FAX

Rhode Island
Rich Enander
Rhode Island Department of Environmental Management
Office of Environmental Coordination
Hazardous Waste Reduction Section
83 Park St
Providence, Rl 02903-1037
401-277-3434
401-277-2591 FAX

Vermont
Doug Kievet-Kylar or Gary Gulka
Pollution Prevention Division
Vermont Department of Environmental Conservation
103 South Main St.
Waterbury, VT 05671-0401
802-241-3888
802-244-5141 FAX
                                       11

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EPA Region I     .
Abby Swaine or Mark Mahoney  •  .
EPA
JFK Federal Building
One Congress Street
Boston, MA  02203
617-565-4523 (Abby); 617-565-1155 (Mark)
617-565-3346 FAX

*RoundtabIe Board Member
                                     12

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 Regulatory Integration Activities, Region II


 Explanatory Notes


 NEW JERSEY

 Legislation

 The 1991  Pollution Prevention  Act requires facilitiy-wide pollution prevention  planning for
 roughly 800 companies. The planning requirement includes three components:  (1) pollution
 prevention plans, (2) plan summaries, and (3) annual reports. The Act also requires that the
 DEPE issue 10-15 facility-wide permits.

 Permitting

 As a  pre-pilot  of the whole-facility permitting and  other requirements of the Act, Steve
 Anderson has been working with three companies to develop whole-facility pollution prevention
 plans and draft whole-facility permits to go with them.  Permit teams will work on the additional
 whole-facility permits as firms volunteer to participate.

 Inspections

 Under the County Environmental Health Act, DEPE has delegated minor air source inspections
 to certified local health agencies. These inspectors have been cross-trained to notice violations
 of hazardous waste and water regulations.

 Enforcement

 DEPE  has begun coordinating enforcement actions  across media, within the Facility Wide
 Enforcement Division,  and is developing a  policy paper  on pollution prevention  and
 enforcement.

 Data Integration

 DEPE's Office of Pollution Prevention is in the process of coordinating with the Right-to-Know
 division (which tracks throughput data as part of NJ EPCRA submissions) to identify their joint
 computer needs, which will include tracking the annual report data generated under the facility
 planning law. Contact Shelley Heame at (609) 777-0518 for more information.

Organization

DEPE has reorganized functionally, so that (for example) all permitting programs report to  one
senior manager, as do all enforcement programs.  Multimedia workgroups include the permit
                                        13

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teams which will work with the ten to fifteen facilities identified for the whole-facility permit
project.  Permit-writers and inspectors have participated in pollution prevention training.


NEW YORK

Legislation

In addition to New York's facility planning law, which addresses hazardous waste generation,
DEC plans to use its statutory authority under the Environmental Conservation Law to require
facility planning for  air and water releases.  Their draft regulations were reviewed at public
hearings held in September 1993.

Permitting

As of April 1, 1993, DEC'S nine regions designated five to nine facilities (for a total of forty-
nine) to  be  targeted for whole-facility permits, inspections, and enforcement actions.  The
targeted  facilities  represent more than 10% of the 400 facilities which generate over 95% of
the total  hazardous  waste generation and toxic air and water releases within New York.  The
targeting criteria will include TRI and hazardous waste generation data, as well as location of
sensitive receptors, public concern, ongoing enforcement, and other factors.

Inspections

For the forty-nine facilities designated above, multimedia teams are designing and coordinating
comprehensive, in-depth inspections.  In addition, DEC is developing training for inspectors so
that they are broadly, schooled in the other media for which they have not previously been
responsible.  The first training agenda should be out into the field within a few months; more
in-depth  material  will be delivered next year.  Inspectors will be acquainted with pollution
prevention planning requirements  so  that they can review the facility plans stored on-site as
part of their inspections.

Enforcement

Enforcement orders are  comprehensive  multi-media documents which  promote pollution
prevention.  Cross-media coordination already occurs.

Data Integration

DEC is designing (internally) a Corporate  Data Model which will allow inspectors and permit
writers to pull  up  comprehensive information  on facilities.   They intend to include GIS
information in the system if they find it feasible to do so.

Organization

As of January 1993, DEC abolished the pollution prevention unit within the hazardous waste
division and established a pollution prevention unit which reports to the Deputy Commissioner
responsible  for all  media divisions.   The Commissioner  issued a  memorandum providing
                                          14

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guidance for multimedia coordination in each regional office and establishing the headquarters'
pollution prevention  unit ("Organization  and Delegation Memorandum ,#92-13  - Policy:
Pollution Reduction and Integrated Facility Management")- A second memo ("Organization
and Delegation memorandum #92-24 - Organization: Pollution Prevention Initiative") attached
a mission and goals statement for the group, workplan, and information on their culture change
project.
CONTACTS

New Jersey
Jeanne Herb, Director
New Jersey Office of Pollution Prevention
New Jersey Department of Environmental Protection and Energy
CN-402
401 E. State St.
Trenton, NJ 08625
609-777-0518
609-777-1330 FAX

New York
Bill Eberie or John lannotti
Pollution Prevention Unit
New York State Department of Environmental Conservation
50 Wolf Road
Albany, NY 12233
518-457-7267 (John); 518-457-2480 (Bill)
518-457-2570 FAX

EPA Region II
Janet Sapadin
USEPA
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
212-264-1925
212-264-9695 FAX

Roundtable Board Member
Kevin Gashlin
Technical Assistance Program
NJ Institute of Technology
323 Martin Luther King Blvd., ATC Bldg.
Newark, NJ 07102
201-596-5864
201-596-6367 FAX
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Regulatory Integration Activities, Region III


Explanatory Notes



DELAWARE

Permitting

Delaware DNREC is exploring multimedia permitting:  it will produce a multimedia permit which
has a pollution prevention focus by the close of 1994, for a facility that is a "major" source for
at least two media programs.

Inspections

DNREC has been conducting some multimedia  inspections since 1988.  These have been
conducted when concerns arise at a facility with respect to more than one media.  They are
also triggered  by timing - when permits in more than one medium are up for renewal, or when
new facilities require several individual permits.

Organization

DNREC has formed a task force under a PPIS grant designed  to support integration and
institutionalization of pollution prevention into media specific regulatory programs.  The entire
department has received pollution prevention training.  (Rather than a headquarters/regional
structure, DNREC has  a main office in Dover and two satellite field offices.)


MARYLAND

Enforcement

MDE has supported some multi-media compliance settlements; MDE's efforts have involved
teams from all media  offices.  There have also been  settlements with pollution  prevention
elements,  under which fines  have  been mitigated for  installation of pollution  prevention
technologies or adoption of pollution prevention measures.

Organization

Genera] pollution prevention training  for MDE staff began in the summer of 1993.  MDE has a
Pollution Prevention Coordinator.
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PENNSYLVANIA

Permitting

Currently, DER is developing a plan for a pilot multi-media project. The Department is looking
at New Jersey's program as possible model.  Generators seeking permits for waste  disposal
facilities,  or disposing  of  solid or hazardous, waste in off-site TSDFs, are required,  by
regulation, to have pollution prevention facility plans.

Inspections

DER has conducted 6 multimedia inspections.  There is also a pilot program in each regulatory
office to evaluate the possibility  of  more  multimedia inspections  and the potential for
incorporating pollution prevention options into the programs.

Organization

A Source Reduction Section was created in the fall of 1992; one of its roles is to discuss with
the media offices potential pollution prevention  options for regulations  currently  under
development. An agency task force made up of all the programs is currently working on this.

Pollution prevention training was completed in October 1993. About 200 people at the various
regional offices were trained. In addition,  DER has institutionalized a pollution  prevention
component within the training academy for new field staff.
VIRGINIA

Legislation

The  1993 General Assembly passed  a bill which establishes  pollution prevention  as the
environmental strategy of choice for the Commonwealth.  The law also codifies the existing
pollution prevention technical assistance program, the Waste Reduction Assistance Program.
The legislation resulted from a legislative study committee convened in 1992 representing the
legislative and executive branches of government as well as  industry and public interest
groups. The 1993 General Assembly authorized the study committee  to continue its  work
through 1993, and additional legislative initiatives could be developed.

Organization

As of  April  1,  1993, Virginia  has reorganized  its  environmental  regulatory  and planning
agencies into a  single multimedia agency, the Department of Environmental Quality.  One of
the primary goals of the new agency is pollution prevention. Work completed over the past
three years to promote  pollution prevention (including staff training for approximately 300
employees) among the then-separate media agencies will continue within DEQ. The pollution
prevention program, formerly part of the Department of Waste Management, will be  located
within the Division of Policy, Budget and Administration, but will have dose ties to staff within
the Division of Operations. WRAP will be working to institute a pollution prevention network of
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 DEQ staff at both the headquarters and the seven regional offices within the next few months
 that will have regular communication to facilitate/promote pollution prevention integration within
 the agency and  its clients.   The network will  eventually extend to other state agencies
 responsible for pollution prevention initiatives, such as the Chesapeake Bay Local Assistant
 Department and the Department of Conservation and Recreation, as well as regional and local
 government agencies. Other activities planned for DEQ include training for inspectors permit
 writers and enforcement/compliance staff (although there are already enforcement settlements
 that include pollution prevention).
 CONTACTS

 Delaware
 Philip Cherry* or Andrea Farrell
 Delaware Department of Natural Resource's and Environmental Control (DE DNREC)
 P.O. Box 1401
 89 Kings Highway
 Dover, DE  19903
 302-739-6400
 302-739-5060 FAX

 District of Columbia
 Nick Kauffman
 Hazardous Waste Management Branch
 DC Gov't Env. Reg. Admin.
 2100 Martin Luther King Ave, SE
 Suite 203
 Washington, DC 20020
 202-404-1167
 202-404-1141 FAX

 Maryland
 Mitch McCalmon
 Pollution Prevention Coordinator
 Maryland Department of the Environment
2500 Broening Highway
 Baltimore, MD 21224
410-631-4122
410-631-3936 FAX
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 Pennsylvania
 Meredith Hill
 Asst. to Deputy Secretary
 Office of Air & Waste Mgmt.
 Pennsylvania Department of Environmental Resources
 P.O. Box 2063
 Harrisburg, Pa  17105-2063
 717-787-7382
 717-783-8965 FAX

 Virginia
 Sharon K. Baxter, Pollution Prevention Manager
 David Timberline, Pollution Prevention Outreach Liaison
 Department of Environmental Quality
 11th Floor, Monroe Bldg.
 101 North 14th St.
 Richmond, VA  23219
 804-371-8712 (Sharon); 804-371-8713 (David)
 804-371-0193 FAX

 West Virginia
 Randy Huffman
 Pollution Prevention and Open Dump Program
 Waste Management Section
 WV Dept. of Commerce, Labor, & Env'l Resources
 1356 Hansford Street
 Charleston, WV 25301
 304-558-7763
 304-558-0256 FAX

 EPA Region III
 Lorraine Urbiet
 USEPA
 841 Chestnut Building
 Philadelphia, PA 19107
215-597-8327
215-597-7906 FAX

'Roundtable Board Member
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Regulatory Integration Activities, Region IV

Explanatory Notes
FLORIDA

Permitting

While not systematic, some successful efforts have been initiated to build pollution prevention
requirements into individual air, water, and hazardous waste permits.  Air permits for the
combustion of solid waste will require a control standard that can meet with source segregation
(or separation at the facility) for heavy metals for waste to energy facilities.  Some individual
hazardous waste permits  have included  closed-loop metals recycling and  water reuse
requirements to reduce the volume of wastewater (and contaminants) discharged.

Inspections

In some districts, inspectors give regular referrals to the technical assistance  staff.  Joint
multimedia inspections have been proposed for the Tampa district, but have not yet occurred.
Some inspectors, hand out pollution prevention brochures. In addition, under a joint agreement
with the Florida Department of Environmental Regulation (DER), the Dade County Department
of Environmental Resources Management (DERM) is providing pollution prevention training for
all DERM inspectors - including all media programs.

Enforcement

Pollution prevention options or credits have been incorporated into some enforcement actions
on solid waste and hazardous waste; none for air yet; in water,  there has been interest in
several of the districts.  A Pollution Prevention Credit program (similar to the federal SEP) may
be applicable during enforcement  actions for facilities participating in the 33/50 program.
Under the Dade County DERM program (above), pollution prevention audit requirements can
be incorporated into consent agreements.

Organization

Pollution prevention training has been provided for media specific program and enforcement
personnel. Training  was provided under the RITTA program for inspectors, but  the turnover
rate for inspectors is extremely high, so additional training is needed.

Under a cooperative agreement (above) between Florida DER and the Dade County DERM, all
inspectors are being provided pollution prevention training.
                                        20

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GEORGIA

Legislation

Georgia has a facility planning law focused on hazardous waste reduction.  Pending legislation
would establish an Office of Pollution Prevention Assistance to provide more formal support to
pollution prevention efforts within media programs, as well as technical assistance outreach to
businesses/facilities.

Permitting

Pollution prevention has been incorporated into permits, although not on a multimedia basis.

Inspections

During hazardous waste inspections, inspectors check to see  whether the hazardous waste
reduction facility plans, required under Georgia legislation, are in place. Inspectors also ask to
see if the  company has a pollution  prevention policy statement.  A  pollution prevention
checklist is available for inspections, but again mostly for RCRA inspectors.

Enforcement

Each  program office  has done SEPs for pollution prevention,  although not necessarily
multimedia.

Data  Integration

There is a  data  management system which has been designed to integrate data formats,
although it is not as yet widely used for pollution prevention.

Organization

The Pollution Prevention Strategy Task Force, working with an outside  advisory committee,
has  written a final strategy for integration of pollution prevention into the state's media
regulatory programs.  It builds  on current organizational structure whereby, for each media
office, a single compliance officer (per facility) is responsible for permit writing, inspections,
and enforcement - a structure which facilitates building pollution prevention into the regulatory
framework.  The strategy calls for pollution prevention training of the compliance officers, and
has recommendations for looking at things in a multimedia context The first steps, however,
might be within the individual program offices.
KENTUCKY

Inspections

Regulatory officials within the Kentucky Department of Environmental Protection designed and
conducted a pilot multimedia inspection  project, with at least one  multimedia  inspection
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conducted by each of ten state regional offices. Inspectors participating in regional multimedia
pilot inspection projects promoted pollution prevention as the preferred compliance strategy
during their on-site work and in resulting notifications.

Enforcement

Kentucky DEP officials have included requirements for pollution prevention  planning  in
enforcement settlements with a few large facilities, and  are considering including such
provisions more routinely.

Organization

All of the single media programs participated in the pilot coordination efforts.  Each region
participated  in the design of the project they conducted; the  possibility for future pollution
prevention enforcement settlements and additional training  is considered in strategic plans.
Kentucky DEP conducted pollution prevention training for regulatory personnel, followed by in-
house discussions as needed to complete the projects.  The training focused primarily on
pollution prevention contextual issues rather than specific technologies.


NORTH CAROLINA

Legislation

North Carolina's legislation  requires submission of any waste reduction plans as  part of the
permit application.  However, the  reduction plan is not considered part of the permit application
and does not serve as the basis for the denial of a permit or permit modification.

Permitting

All water quality and air quality permit holders,  or applicants for a new  permit or permit
modification, must submit to the department a written description  of current and projected
plans to reduce the  discharge  of waste  and pollutants or to reduce the emission of air
contaminants under such a permit by source reduction or recycling. The written  description
shall accompany the payment of the annual permit fee or the application for new or modified
permit  Hazardous waste generation and operators of hazardous  waste treatment facilities
which treat waste onsite are required to submit to the department 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.

Inspections

The Department has  provided training to all environmental field staff on pollution prevention
and  they have additionally provided training to  pretreatment coordinators  on  pollution
prevention to be used in their local compliance efforts.
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 Data Integration

 North Carolina's Department of Environment, Health, and Natural Resources has developed a
 database which contains emissions and waste reduction  data  from  a variety of sources to
 facilitate waste reduction assessment by the  North Carolina Pollution Prevention  Program.
 The objective of this project is to integrate multi-media environmental release data into other
 state-wide waste reduction  efforts including technical assistance, training, grants research
 and demonstrated efforts of hazardous waste reduction.

 The database contains information from the following five individual databases:

              1.     SARA 313 Toxics Release Inventory;
              2.     North Carolina State Annual Report on Hazardous Waste Generation;
              3.     Airs Facility Subsystem Air Quality data;
              4.     National PoHutant Discharge Elimination System data;
              5.     North Carolina Pretreatment data.

 Currently, this database is used by North Carolina's Office of Waste Reduction to determine
 various multi-media waste releases by industries in preparation for site visits and  technical
 assistance. Ongoing projects utilizing this data include using the data to assist industries in
 waste  reduction plans, and evaluating the toxicologies! factors versus the  risk factors of
 various chemicals in me database  and directing  technical assistance  efforts  towards  the
 reduction of those chemicals. This database will also be used as  a basis for targeting problem
 sectors (e.g.,  SICs, geographic regions,  company  sizes), and allocating funding, resources,
 and technical assistance.
MISSISSIPPI

Data Integration

A TRI database currently being developed for the state by the technical assistance program
will be provided to the regulatory program to assist in developing andVor targeting regulatory
activities.

Organization

This upcoming year,  the  Waste  Reduction technical assistance program  will  be doing 4
enforcement training programs for the regulatory staff to make them aware of what pollution
prevention is and how to get out-of-compliance facilities in touch with technical assistance.
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 CONTACTS      :

 Alabama
 Dan Cooper or Gary Ellis
 Alabama Dept of Environmental Management
 1751 Congressman William L. Dickinson Drive
 Montgomery, AL 36130
 205-260-2782 (Gary); 205-260-2783 (Dan)
 205-260-2795 FAX

 Florida
 Janeth Campbell*
 Director
 Pollution Prevention-Waste Reduction Assistance Program (P2-WRAP)
 Florida Department of Environmental Protection
 2600 Blair Stone Road
 Tallahassee, FL  32399-2400
 904-488-0300
 904-922-4939 FAX

 Georgia
 Bob Donaghue
 Assistant Division Director for Pollution Prevention
 David Word
 Hazardous Waste Authority
. Georgia DNR/EPD
 4244 International Parkway, Suite 104
 Atlanta, GA 30354
 404-651-5120 (Bob); 404-656-4713 (David)
 404-651-5778 FAX

 Kentucky
 Russ Bamett or Hannah Helm
 Kentucky Department for Environmental Protection
 18 Reilly Road
 Frankfort, KY 40601
 502-564-2150
 502-564-4245 FAX

 Mississippi
 Tom Whitten or Chris Bowen
 Mississippi Comprehensive Waste Reduction/Waste Minimization Program
 Mississippi Department of Environmental Quality
 P.O. Box 10385
 Jackson, MS  39289-0385
 601-961-5241
 601-354-6612 FAX
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North Carolina
Gary Hunt
North Carolina Office of Waste Reduction
Mail-  P.O. Box 27687
            Raleigh, NC 27611
Street- 3825 Barrett Drive
            Raleigh, NC 27609
919-571-4100
919-571-4135 FAX

South Carolina
Bob Burgess, Jeff deBossonet, or Ray Guerrin
South Carolina Department of Health and Environmental Control
Center for Waste Minimization
2600 Bull St.
Columbia, SC 29201
803-734-4715
803-734-5199 FAX

Tennessee
Angle Pitcock
Pollution Prevention/Environmental Awareness Division
Department of Environment and Conservation
14th floor, L&C Tower
Nashville, TN 37243-0454
615-532-0736
615-532-0231  FAX

 EPA Region IV
 Carol Monell
 Environmental Protection Agency
 345 Courtland Street, N.E.
 Atlanta, GA 30365
 404-347-7109
 404-347-1043 FAX

 •Roundtable Board Member
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Regulatory Integration Activities, Region V

Explanatory Notes
ILLINOIS

Legislation

Pollution prevention  is well established  in  Illinois statutes as  the preferred  means  of
environmental protection; facility planning is considered a key aspect of implementing pollution
prevention solutions to these environmental problems. Facilities pollution prevention planning
is generally voluntary in  Illinois.  Pollution  prevention will be suggested  in  enforcement
settlements, in circumstances for which it is appropriate.
                *                                                                -
The Pollution Prevention initiative is well founded in two key statutes of the State of Illinois, the
Toxic Pollution Prevention Act of 1989 (TPPA) and the Illinois Pollution Prevention Act of 1992
(IPPA).  Copies are available from the Illinois EPA.

Permitting

Multimedia  coordination has" been in effect for several years; expedited multimedia review of
pollution prevention  proposals  and settlements involving pollution prevention  is  in the
implementation phase.   Some pollution prevention  projects have been implemented.  All
permits  issued for hazardous waste generators include as a condition:  "All  permittees shall
certify at least annually that the permittee has a program in place  to reduce the volume and
toxicity of hazardous waste that he/she generates to the degree determined by the permittee
to be economically practicable and the proposed method of treatment, storage, or disposal is
that practicable method currently available tot he permittee which minimized  the present and
future threat to human health and the environment..."

Inspections

Coordinated inspections have been carried out by Illinois EPA inspectors for several years;
planning for multimedia  inspections  for  pollution  prevention  possibilities  is  in the
implementation  phase.   Planning  for  multimedia, on-site  assistance  inspections  has
progressed and pilot projects are scheduled.

Enforcement

Multimedia enforcement actions and settlement agreements have been operational for several
years; planning for multimedia  inspections  for pollution  prevention possibilities is in the
implementation phase.

Planning for expedited multimedia review of settlements involving pollution prevention is in the
implementation phase; some projects involving pollution prevention have been incorporated
into enforcement settlement agreements.
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Data Integration

Some SARA and RCRA data are utilized to prioritize and initiate contacts with companies;
much additional coordination and use of data is planned for the near future.

Organization

All Agency technical staff have had an initial training session; planning for a 5-element training
program for staff is well underway.
                                                       t
Multimedia inspection  and permitting  coordination has  been operational for several years;
planning for expedited multimedia review of pollution prevention proposals and settlements
involving  pollution prevention is in the implementation phase  of development.  A Pollution
Prevention  Manual  for Field  and  Permit  staff  is being  developed which describes the
integration of pollution prevention into media programs.

No reorganization is being considered nor is reorganization anticipated to accomplish the full
implementation of pollution prevention into Agency programs.
INDIANA

Legislation

House Enrolled Act No. 1412, enacted by the General Assembly (1993) of the State of Indiana
orders that pollution prevention may  not be mandated by document,  manual, policy or rules
which would  require businesses to  practice pollution  prevention or by means of  permit
conditions, enforcement actions, or  other departmental actions.  This does not apply to
authority granted under federal law.  Notwithstanding, the Department of Environmental
Management  shall  present  pollution prevention  as an  option to  businesses in  permit
conditions, enforcement actions, or other departmental actions.

Organization

In May of 1993,  the Indiana  Department of Environmental Management (IDEM), decided to
embark on a comprehensive pollution prevention training program for staff. A $100,000 grant
to the Environmental Management Institute through  Indiana University  funded the project
According to the grant agreement, the project should have begun on June 1,  1992 and  ended
two years later on May 30, 1994. However, the agreement was not formally  approved  by the
State until June 18, and notice was not provided to the Institute until June 30, 1992.  Despite
the delay, the Environmental Management Institute committed to complying  with the original
schedule.

This training was designed by the Environmental Management Institute to assist IDEM staff to
encourage the regulated community to make the shift from pollution control and treatment to
pollution  prevention, to incorporate prevention concepts into management decisions, and to
ensure consistent prevention applications in multimedia environmental programs.

IDEM appointed  a  Pollution Prevention Training Workgroup with representatives from each
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 office  directly affected to guide the program.  This group meets  on a bi-monthly basis to
 determine training needs, provide guidance to the three phases of this program, and to discuss
 cross-media issues.  The initial phase of the training program consisted of a survey by the
 Environmental  Management Institute of similar  programs  in  other states, followed by
 development and implementation of actual training sessions.

 The project accomplishments to date include:           .

       •      Development of the "Pollution Prevention:  Indiana's  Choice for Environmental
              Protection," coursebook;

       •      Phase I (awareness) training for a total of 617 staff (470 technical and 147 non-
              technical) was completed in April 1993;

       •      Continued course refinement to meet present and future needs;

       •      Excellent evaluation response rates and overall ranking by staff;

       •      Compilation of ideas from staff oh various aspects of pollution prevention;

       •      Planning for continued Phase II  (technical-industrial) and Phase III (function-
              specific) pollution prevention training.
     1           i *'

 MICHIGAN

•Permitting

 Michigan is planning on evaluating permits issued in the future to determine whether pollution
 prevention activities can be incorporated into facility specific requirements. This evaluation will
 be taking place throughout all media programs.                 -   ,

 Inspections

 In the hazardous waste program, inspectors are currently evaluating a generator's pollution
 prevention program during the inspection and are making appropriate referrals to the technical
 assistance program.  Plans  are being made to move this type of activity into other media
 programs.

 Enforcement

 Settlement of enforcement actions routinely includes discussion of a  pollution prevention offset
 to penalties in the solid and  hazardous waste programs.  Plans are underway to  incorporate
 pollution prevention settlements into the other media programs. There is also a concerted
 effort to undertake multimedia enforcement cases in the state. While the driving force for this
 consolidation of efforts has not been pollution prevention, it is planned that promoting pollution
 prevention settlements in the individual media programs will change the focus  of the
 multimedia enforcement activities to pollution prevention as well.
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 Organfzation

 Grant money has been requested to undertake focused multimedia training for all  DNR
 inspectors, permit writers, and enforcement specialists.

 Planning is underway to convene a multimedia workgroup to discuss integration of pollution
 prevention into all media programs.

 It is  expected that  an integration  strategy will be  the  final  output from the multimedia
 workgroup.
MINNESOTA

Legislation

Under the 1990 Toxic Pollution Prevention Act, all TRI reporters are required to prepare plans
for eliminating or reducing the generation or release of toxic pollutants.  The 1993 legislature
expanded the types of facilities required to plan pollution prevention and report progress. The
Minnesota Pollution Control Agency (MPCA) reviews annual progress reports, and may review
facility plans under certain circumstances.

Inspections

The Minnesota Pollution Control Agency (MPCA) has conducted a pilot multimedia inspection
and enforcement project, known as the Lake Superior Partnership (LSP), with EPA support
Teams of inspectors from the MPCA media programs and from the Western Lake Superior
Sanitary  District (which has responsibility  for wastewater and  solid  waste management in
Dulutfi and its suburbs) have jointly conducted a series of multimedia  inspections for a range
of facilities which discharge to the District  With the end of federal funding  for the project, it
has been scaled  down  to six major-facility (permits in more than two media programs)
inspections each year, utilizing regional inspection staff.

Another  multimedia/pollution prevention compliance  inspection has been initiated  in  the
Minnesota River Basin area, utilizing regional inspection staff.

Enforcement

During the  Lake Superior Partnership inspections, all enforcement actions, at least initially,
were coordinated among divisions. This coordination resulted in some  multi-program NOVs or
Letters of Warning. This wUI be continued, when appropriate, in the  Minnesota River Basin
project

Multi-program enforcement actions are routinely pursued by program staff, where  they  are
appropriate.  Enforcement instruments routinely include requirements to submit public versions
of pollution prevention plans.  Negotiants  are  encouraged to propose pollution prevention
projects as part of enforcement instruments.
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Data Integration               ,.;.'                                •

MPCA is developing a new multi-program integrated database called Project  Delta.   This
database will integrate all compliance data and has been funded by the state legislature.

Organization

In MPCA, a pollution prevention staff team meets twice each month to discuss multimedia
inspection and permitting possibilities. Some training of regulatory personnel, including  some
inspectors from each of the media programs, has been initiated within MPCA.
OHIO

Legislation

Legislation  passed in 1992 requires  underground injection facilities  to  prepare waste
minimization plans for industrial wastes generated at these facilities.

Permitting

Pollution prevention plans are required  for both hazardous waste TSDFs and underground
injection well permits.

Enforcement

Pollution prevention requirements have been incorporated in some environmental enforcement
cases.  Pollution prevention related conditions in settlements allow projects that reduce waste
and emissions beyond levels required through pollution regulations, and may include reduced
penalties where  a facility will develop a pollution prevention plan or install source reduction
processes. Waste minimization/pollution prevention provisions have  been  most used  in
settlements  involving hazardous waste, but have also  been used in  cases involving water
pollution (particularly under the pretreatment program) and air  pollution.   Ohio EPA has
developed  a tracking system, and  is  making an  effort to evaluate the results of such
settlements.

Organization

Pollution prevention training for Ohio EPA staff has focused on contextual issues, and on what
staff can do about prevention in their jobs now - for example, advocating that they promote
prevention or make referrals to technical  assistance.

Ohio EPA is in the process of developing a multimedia pollution prevention strategy, which is
intended to encompass the full range of agency activities.  An initial draft has already been
completed, and a final draft is expected later in the year.

The Governor announced the formation  of a Pollution Prevention Development Workgroup in
1991;  the  Workgroup has  the responsibility of  formulating  and  coordinating  pollution
                                         30

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 prevention activities involving both state government agencies and business.  Within Ohio
 EPA, all divisions have  been directed to work with the Office of Pollution Prevention  in
 developing agency pollution prevention strategy, and to designate responsible staff.
WISCONSIN

Legislation

Wisconsin's pollution prevention law does not mandate pollution prevention facility planning.  A
separate law requires waste reduction planning for medical waste.

Wisconsin's Pollution Prevention Law (1989 Wisconsin Act 325) establishes the framework for
its  Pollution Prevention  Program.  The law  establishes  a  basis  for  promoting  pollution
prevention, drawing on the strengths of three agencies.  The Wisconsin Department of Natural
Resources through its Office of Pollution Prevention coordinates DNR's activities with other
agencies and the public creating a focus for multimedia policy development, training staff, and
identifying  pollution  prevention reporting  and environmental  needs.   The University of
Wisconsin  Extension provides  education,  training,  and technical  assistance for  pollution
prevention.   The  Wisconsin  Department of Development provides waste reduction audit
grants.

Permitting

A pilot effort involving the development of a standard facility description that can be used by
individual permitting programs is being started.

Industrial  wastewater discharge  permits that have  permit  limits  for  toxics have  waste
minimization studies  incorporated into  their compliance  schedules.   Municipalities with
pretreatment programs submit annual reports which include a summary of pollution prevention
plans.   Many Wisconsin  TSD licenses  incorporate standard RCRA  waste minimization
certification language. Pollution prevention strategies are evaluated where feasible, during the
air permit review process.

Inspections

The Agency encourages multimedia inspections when appropriate.  Several of DNR's  district
offices have begun coordinating inspections for selected  facilities.  A  pilot effort in  DNR's
Southeast District is working to merge hazardous waste and pretreatment inspection forms for
multimedia  inspections.  Approximately 15  to  20%  of the inspections conducted  in SE
Wisconsin are multimedia.

Hazardous waste,  wastewater and other media program staff promote  pollution prevention
during inspections  by handing out publications and encouraging companies to make  use of
Wisconsin's pollution prevention technical assistance programs.  Hazardous waste inspection
forms include several questions on waste minimization.
                                         31

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 Enforcement                                                      .

 The DNR's Office of Environmental Enforcement services all media programs.  While most
 enforcement cases are' single media, multimedia enforcement cases have been undertaken at
 selected facilities.

 The hazardous waste management program developed guidance for inspection followup for
 hazardous waste minimization certification and inclusion of pollution prevention and recycling
 provision in enforcement settlements.  DNR's Southeast District's pilot effort for incorporating
 pollution prevention into enforcement conferences has been adopted in several other areas of
 the state.   The  attorney general included  pollution  prevention stipulations in 8  of  44
 enforcement cases in FY1993.

 Data Integration

 Over 10 years ago, the Department established a common facility identification code. The
 code is included in  all media databases and the Agency's data system can easily identify
 environmental quality permits that apply to a facility.  A pilot project builds on this capability
 and has  developed  an  integrated toxics  data report that includes information from TRI,
 hazardous waste, air, and waste water programs.  The pilot project is  evaluating options  for
 making these type of retrievals more readily available to agency staff.

 Organization

 Most DNR environmental qualify staff received basic awareness pollution prevention training in
 1991 or 1992. A full day pollution prevention training session was held for all air management
 staff in 1993.  Most hazardous waste  inspection staff have attended two or more  days of
' pollution prevention training or workshops in the past several years.

 DNR has  an inter-program  Pollution  Prevention Advisory Committee (PPAC) that  helps
 coordinate Agency pollution prevention activities.  In addition, cross-media work groups and
 technology teams are routinely set up to address cross media issues in the Agency.  Current
 groups include  a Pulp and  Paper Technology  Team  that is  participating  in  a Pollution
 Prevention Partnership project between the pulp and paper industry and the Wisconsin DNR; a
 small business committee;  and a group working on a pilot project to test the feasibility and
 value of coordinating individual regulatory programs' technical assistance, and permitting and
 compliance activities in Southeast Wisconsin.  DNR Environmental Administrators have regular
 retreats to encourage discussion of cross-program issues such as pollution prevention.

 In 1992, the Department developed a Pollution Prevention Implementation Plan that identifies
 activities that each program and regional office is undertaking to  promote pollution prevention
 and integrate it into its ongoing  regulatory program.   Pollution prevention and  toxics  waste
 reduction has been one of the DNR Secretary's strategic objectives in the past several years.
 The concept of waste reduction and pollution prevention have also been incorporated into the
 Division for Environmental Quality's Strategic Plan and in the strategic plans  of each  of the
 individual media programs.
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No reorganization is anticipated at this time.  The Office of Pollution Prevention serves a
coordinating function  for pollution  prevention  activities undertaken  by individual  media
program.
CONTACTS

Illinois
Keri Luly, Mike Hayes, or Thomas Wallin
Office of Pollution Prevention
Director's Office
Illinois Environmental Protection Agency
2200 Churchhill Road
P.O. Box 19276
Springfield, IL 62794-9276
217-524-1846 (Keri); 217-785-0833 (Mike); 217-782-8700 (Thomas)
217-524-4959 FAX

Indiana
Tom Neltner or Charles Sullivan
Office of Pollution Prevention and Technical Assistance
Indiana Department of Environmental Management
100 North Senate Avenue
P.O. Box6015
Indianapolis, IN 46206-6015
317-232-8172
317-232-8564 FAX

Michigan
Kimberiy Paksi
Michigan Office of Waste Reduction Services
P.O. Box 30004
Lansing, Ml 48909
517-373-1871
517-335-4729 FAX

Minnesota
EricKilberg
Minnesota Pollution Control Agency
520 Lafayette Road
StPaul, MN 55155
612-296-8643
612-297-8676  FAX
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Ohio
Tony Sasson or Mike Kelley
Office of Pollution Prevention
Ohio Environmental Protection Agency
P.O. Box 1049,1800 WaterMark Drive
Columbus, Ohio 43266-0149
614-644-3469
614-644-2329 FAX

Wisconsin
Ken Wiesner, Director of the Office Pollution Prevention
Lynn Persson*. Hazardous Waste Minimization Coordinator
Wisconsin Department of Natural Resources
Box7921,101 South Webster Street
Madison Wl  53707-7921
608-267-9700 (Ken) or 608-267-3763 (Lynn)
608-267-5231 (Ken) or 608-267-2768 (Lynn) FAX

EPA Region V
Cathy Allen
EPA
77 West Jackson Blvd.
Chicago, IL 60604-3507
312-886-2910
312-353-5374 FAX

*Roundtabie Board Member
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Regulatory Integration Activities, Region VI


Explanatory Notes


LOUISIANA

Enforcement

The  Department of Environmental  Quality is  developing a policy  (and model settlement
agreement) for supplemental environmental projects (SEPs) designed to promote incorporation
of waste reduction and  pollution prevention  into enforcement settlements.   Many of  the
guidelines on use of SEPs are based on EPA's SEP policy.

Organization

Pollution prevention training is being provided for RCRA inspectors.


OKLAHOMA

Organization

The process of implementing an intra-agency pollution prevention training program for media-
specific inspectors and permitting staff has been initiated.   Further work to develop this
program is on-going.

The  Pollution  Prevention Workgroup is a multimedia workgroup, composed of members
working in the air, water,  and solid and hazardous waste programs. This workgroup  planned
and  presented the first statewide pollution prevention conference,  and has plans  for two
additional 1993 conferences. The workgroup also has been  very active in initiating pollution
prevention projects, such as the generation of state-specific pollution prevention literature and
the initiation of a statewide voluntary toxics reduction program - Target '98.

On July 1,1993 many of the state's environmental programs, including the pollution prevention
program, were consolidated under the Department of Environmental Quality.  The pollution
prevention program was placed into a non-regulatory setting as part of a highly visible,  service-
oriented division called the Customer Assistance Program.


TEXAS

Legislation

The Waste Reduction Policy Act of 1991  requires facility planning for both RCRA and TRI
reporters.
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Permitting

The Texas Water Commission (TWO) Has written permits, mostly in the RCRA program, which
incorporate pollution prevention requirements. While considering New Jersey-type multimedia
permitting, current pollution prevention permitting is single medium.

Inspections

Field operations use a checklist for RCRA inspections which includes some waste minimization
types of questions.  Beginning in January 1994, inspectors will verify that pollution prevention
plans are in place.  Inspectors will not be judging the adequacy of the plans, but will be looking
at whether actions are being started.

Enforcement

TWO incorporates pollution prevention  into settlements on a case-by-case basis.  Several
have  been written; most are multimedia focused.  Currently, TWC is developing Supplemental
Environmental Projects (SEPs) in  which  out-of-compliance facilities  perform  a  pollution
prevention project in leiu of an administrative penalty for violation.

Data Integration

TWC has developed a  data management system that would allow integrated use of TRI and
RCRA hazardous waste data elements; also trying to build in other media data links (air,
water).

Organization

TWC has  done  both  internal  and external training; internal  targeted to inspectors and
permitting staff; external targeted to certain industries.

The Waste Reduction Advisory Committee (including industry and academics) helped develop
an implementation strategy for the facility planning law.  One subcommittee of the WRAC is
the Annual Reporting Workgroup which focuses on annual pollution prevention reporting.

The 72nd legislature created an Office of Pollution Prevention in the Texas Water  Commission
(TWC) in order to give  pollution  prevention  high visibility.  This office reports to the Executive
Directors across all media programs. TWC and the Air Control Board have now merged into a
single agency  called  Texas Natural Resource Conservation Commission;  hope is that
reorganization will promote multimedia approach to pollution prevention.
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CONTACTS

Arkansas
Robert Finn or Alfred Drinkwater
Hazardous Waste Division
Arkansas Department of Pollution Prevention and Ecology
P.O. Box8913
Little Rock, Arkansas  72219-8913
501-570-2861 (Robert); 501-682-7325 (Alfred)
501-682-7341 FAX

Louisiana
Gary Johnson or Jim FrUoux
Louisiana DEQ
P.O. Box 82263
Baton Rouge, LA  70884
504-765-0720
504-765-0742 FAX

New Mexico
Alex Puglist or Dick Vackers
Municipal Water Pollution Prevention Program
Facility Operations Section, Surface Water Quality Bureau
New Mexico Environment Department
1190 St Francis Dr.
P.O. Box26110
Santa Fe,  NM 87502
505-827-2799
505-827-2836 FAX

Marilyn Brown
Solid Waste Bureau
New Mexico Environment Department
1190 St Francis Drive
Santa Fe, NM 87502
505-827-0197
505-827-2836 FAX

Oklahoma
Dianne Wiikins or Chad CUbum
Hazardous Waste Management Service-0205
Oklahoma State Department of Health
1000 NE 10th St
Oklahoma City, OK 73117-1299
405-271-5338
405-271-8425 FAX
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Texas
Ken Zarker or Patti Everitt*
Office of Pollution Prevention
Texas Water Commission (TWC)
P.O. Box 13087
Austin, TX 78711-3087
512-475-4580
512-475-4599 FAX

EPA Region VI
DtckWatkins
EPA
First Interstate Bank Tower at Fountain Place
1445 Ross Avenue 12th Floor Suite 1200
Dallas, TX 75202-2733
214-655-6580
214-655-2146 FAX
*Roundtable Board Member
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Regulatory Integration Activities, Region VII


Explanatory Notes



IOWA

Legislation

The Iowa legislature has passed voluntary facility planning legislation but has not funded the
program to implement it.

Permitting

Permit writers  have required waste  reduction planning as part of the application review
process.  Some permit writers and  inspectors have been trained on pollution prevention
principles.

Inspections

Inspectors provide  referrals to Iowa's technical  assistance programs  for large and small
businesses; they also encourage pollution prevention approaches, and where they are familiar
with the technologies, may suggest alternatives. They do not recommend particular solutions.

Organization

The state of Iowa has received  a grant  which  will fund  pollution  prevention training of
personnel working for the Environmental Protection Division.


KANSAS

Permitting

To date, KDHE has not issued any multimedia permits, but the department is exploring both
multimedia permitting and the incorporation of pollution  prevention provisions into  permits.
Language in the current  Kansas  hazardous waste, solid  waste and air quality  statutes
encourages pollution prevention.

Inspections

Inspectors make referrals  to  technical assistance programs.  They also promote pollution
prevention workshops.
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Data Integration                                                  .

KDHE is in the process of designing an integrated data management system that will allow it to
evaluate a facility with regard to all permits issued,  compliance status and any pending or
existing enforcement action.

Organization

KDHE recently designated one FTE to direct the Office of Pollution Prevention - outside the
media-specific regulatory programs. The primary goal of this office is to plan and coordinate
the statewide pollution  prevention program with emphasis directed toward incorporating
pollution  prevention  concepts  into  existing  regulatory activities  such  as  rule-making,
enforcement and the permitting process. A departmental pollution prevention task force and
an advisory task force will be formed to address issues and concerns that arise  with the
integration of pollution prevention activities into the  regulatory process.  KDHE employees
have been trained on pollution prevention under RITTA and PPIS.
NEBRASKA

Inspections

RCRA inspectors have assisted in providing waste minimization technical assistance.  The air
and water programs are exploring way* inspectors can promote  pollution prevention.   The
various inspection programs are currently doing coordinated multimedia  inspections.

'Data Integration

DEQ is assessing and coordinating data needs as it explores the value of an integrated data
management system which incorporates  or  accesses air, water, hazardous  waste,  and
TRI/Right-to-Know data.

Organization

DEQ is planning training for Compliance inspections.  Within the next 2-3 year timeframe, DEQ
will be developing video and other training materials, available to both staff and industry.

DEQ is also planning on putting together multimedia teams to spread the word about pollution
prevention in their respective programs.
                                          40

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CONTACTS

Iowa
Tom Blewett or Teresa Hay
Waste Management Authority Division
Iowa Dept. of Natural Resources
Wallace State Office Building
Des Moines, IA 50319
515-281-8941
515-281-8895 FAX

Kansas
Theresa Hodges
KS Dept of Health and Environment
Forbes Field
Building 740
Topeka, KS 66620-0001
913-296-6603
913-296-6247 FAX

Missouri
June Sullens
Waste Management Program (WMP)
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
314-751-3176 *
314-751-7869 FAX

Steve Mahfood or Tom Welch
Environmental Improvement and Energy Resources Authority (El ERA)
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
314-751-4919
314-635-3486 FAX

Nebraska
TeriSwarts
Hazardous Waste Section
Nebraska Department of Environmental Quality
120ON Street
The Atrium Building
Suite #400
Lincoln, NE 68509
402-471-4217
402-471-2909 FAX
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EPA Region VII
Steve Wurtz or Alan Wehmeyer
EPA
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7336
913-551-7063 FAX

Roundtable Board Member
Richard Yoder
Lincoln/Lancaster County Heallth Department
2200 St Mary's Avenue
Lincoln, Nebraska  68502
402-441-8145
402-441-8323 FAX

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 Regulatory Integration Activities, Region VIII


 Explanatory Notes



 COLORADO

 Legislation

 Under the 1992 state Pollution Prevention  Act, pollution prevention is  the  environmental
 management tool of first choice. The Pollution Prevention Advisory Board (created by the Act
 and appointed by the Governor) will determine how to implement this mandate.  The bill raises
 money from EPCRA reporters to support a public outreach and  technical assistance  grants
 program.

 Permitting

 The Colorado Department of Health has  had pollution prevention sections incorporated in
 some RCRA permits, and new permits are now required to have pollution prevention sections.
 At  the local  government level, requirements for pollution prevention planning have been
 incorporated into individual zoning permits.

 Inspections

 Some targeted multimedia inspections have been carried out.

 Enforcement

 A policy has been developed in the hazardous waste division allowing reduction of fines where
 expenditures are made to achieve compliance through pollution prevention initiatives.

 Organization

 The current program plan focuses on integrating pollution prevention into other regulatory
 programs  and building a multimedia  pollution prevention effort involving both  all  the media
 programs  within  the  Department of Health and relevant programs in other agencies.  An
 advisory board supports planning and implementation of pollution prevention initiatives.  Some
 pollution prevention training has been provided for regulatory staff,  particularly for POTW
 operators.


 NORTH DAKOTA

 Inspections

The Department  conducts multimedia inspections on an "as needed" basis; formal pollution
 prevention has not been the motivating factor.
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Enforcement

The. Department conducts formal ..multimedia enforcement actions on an "as needed" basis;
again, pollution prevention is not the primary motivator.

Organization

EPA Region  VIII  assisted in  training regulatory personnel on pollution  prevention.   The
Department recently conducted a multimedia inspection training session. The training was at
the orientation level and pollution prevention principles were not addressed perse.


SOUTH DAKOTA

Permitting

Possible pollution  prevention  approaches  and requirements are being  incorporated  (or
considered for incorporation) into existing permitting regulations.

Inspections

Pollution prevention approaches being informally included in inspection procedures.

Enforcement

Use of enforcement activities to encourage pollution prevention being explored.  Additional
pollution prevention awareness will be encouraged in future legislation.        ,

Organization

Training was  assisted by Region VIII.  integration strategy is in the works.  The goal of the
current  PPIS-funded project is to establish  a  statewide,  multimedia pollution  prevention
program which  identifies,  integrates and  expands existing  pollution prevention and related
state programs into a formal, coordinated, sustained statewide pollution prevention program.
UTAH

inspections

Part of the current internal planning effort at DEQ is consideration of promoting multimedia
inspections.

Enforcement

DEQ has had a few projects where pollution prevention, either single medium or multimedia,
has been part of the settlement agreement.
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Organization

DEQ is providing pollution prevention training to regulatory staff, either through coordinators or
consultants.

There is an internal DEQ roundtable, which includes representatives from each of the agency's
divisions, which is responsible for developing departmental pollution prevention goals.  DEQ
senior managers had a retreat in June of 1993 in which one of the major topics was the scope
of the pollution prevention effort.

DEQ  conducts  pre-design conferences for  businesses  considering location in Utah.  The
purpose of the conferences is to inform businesses about Utah environmental regulations.
The meetings are multi-media and include pollution prevention issues.
WYOMING

Permitting

Pollution prevention integration into permitting activities  is on  an informal basis, with the
support of the new pollution prevention program.

Inspections

Pollution prevention integration into inspections and related compliance activities is on  an
informal basis.

Enforcement

Integration of pollution prevention concepts and approaches into enforcement actions is on an
informal basis.

Organization

Personnel received pollution prevention training with Region VIII support.  Integration strategy
is currently under development.
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 CONTACTS

 Colorado
 John Wright
 Office of the Environment
 Colorado Department of Health
 4300 Cherry Creek Drive South
 Denver, CO 80222-1530
 303-692-3009
 303-782-4969 FAX

 Montana
 Dan Fraser
 Dept. of Health & Environmental Sciences
 RmA-206
 Cogswell Bldg.
 Helena, MT 59620
 406-444-2406
 406-444-1374 FAX

 North Dakota
 Jeffrey L. Burgess
 Environmental Health Section
 ND Dept of Health & Consolidated Laboratories
 1200 Missouri Ave. Rm 201
 Bismarck, ND 58502
 701-221-5150
 701-221-5200 FAX

 South Dakota
 Wayne Houtcooper
 Dept of Environmental & Natural Resources
 Joe Foss Bldg
 523 E Capitol
 Pierre, SD  57501-3181
 605-773-4216
 605-773-6035 FAX

 Utah
Sonja Wallace or Stephanie Bemkopf
 Dept of Environmental Quality
 168 N1950W
Salt Lake City, UT 84114-4810
801-536-4480
801-538-6016
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Wyoming
Pat Gallagher*
Solid Waste Management Program
Department of Environmental Quality
122 West 25th Street
Cheyenne, WY 82002
307-777-7752
307-777-5973 FAX

EPA Region VIII
Don Patton
999 18th Street Suite 500
Denver, CO 80202-2405
303-293-1456
303-293-1198 FAX

*Roundtable Board Member
                                     47

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Permitting        .

Pollution prevention requirements are being incorporated into a diverse array of state and local
permits. At the state level, the Department of Toxic Substances Control (DISC) has guidance
for permit writers for hazardous waste facilities instructing them to look at pollution prevention
facility planning documents (SB14) during the permitting process; if there are elements in the
plan which have not been implemented, an effort should be made  to include them as permit
requirements.  Similarly, some of the state's regional water quality  boards  have incorporated
waste minimization requirements into NPDES permits.  Because  of high concentrations of
heavy metals,  the San Francisco Bay Regional Water Quality Board identified target sources
for waste reduction and feasible waste minimization technologies and measures, and provided
estimates of the program's costs both to the POTWs in the San Francisco area and to targeted
sources.  The Board  has  issued permits to the  POTWs requiring  that the pilot waste
minimization programs:

       •     be tailored to address the targeted industrial sector(s),

       •     establish best management practices and waste minimization alternatives for
             the targeted industries, and

       •     require waste  minimization plans in response to industry violations and as a
             condition of permitting for new permit applicants.

In response to these requirements, three POTWs  (Palo Alto, San Jose/Santa Clara, and
Sunnyvale) identified specific sources of heavy  metal problems, and established discharge
requirements for permittees which included  specific pollution  prevention measures and/or
planning requirements.

In  another local  program,  the  Orange  County  Sanitation  Districts  established  waste
minimization requirements for permittees, including mass emission  rate and water flow limits.
Permittees must  develop plans to both conserve water and to  utilize waste minimization
approaches for reducing releases of pollutants to the sewers.

While specific pollution prevention requirements are  not stipulated in air permits, many of the
new air permit requirements are so stringent that they can only  be met by substitution or
product change, and many of the recommended emission reduction approaches  do involve
pollution prevention measures.

Inspections

A focus on pollution prevention opportunities has been incorporated into many state and local
programs.  DTSC inspectors have a checklist which includes pollution prevention elements,
including questions on whether the facility has a pollution prevention facility plan. In addition,
inspectors may recommend consideration  of specific  pollution prevention  options, either
verbally or in writing.

Many local health department and POTW inspectors have checklists which include pollution
prevention elements, and/or are trained either to include pollution prevention elements in the
                                         50

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 provide pollution prevention advice, or to supply the facility  with technical  brochures  or
 information. For example, the Los Angeles County Sanitation Districts has pollution prevention
 checklists for many of the types of facilities which  they inspect.  Similar activities are carried
 out by hazardous waste inspectors for the Alameda County Department of Environmental
 Health and the Los Angeles County Fire Department.

, Enforcement

 Pollution prevention elements  have been included both in  settlements of state hazardous
 waste  non-compliance  enforcement  actions  and  in  POTW  settlements  with  indirect
 dischargers. The largest single example is the 1988 consent agreement between DISC and
 Texaco; $3.95 million of the total $8.95 million penalty was to be used for a waste reduction
 audit, and for implementation of some of the measures identified as beneficial in the audit.

 Orange County Sanitation District provides an example of incorporation of pollution prevention
 requirements into enforcement actions by POTWs.  As part of the enforcement requirement, a
 company may be required to carry out a pollution prevention assessment, and then to carry out
 those actions which are shown to be economically feasible.

 Organization         -

 All of California's state regulatory  programs are now included under the umbrella of the
 recently-formed California EPA; the formation of this organization has superseded the previous
 multimedia state  agency roundtable.  The Office  of Pollution  Prevention and Technology
 Development in the Department of Toxic  Substances Control (DTSC - a regulatory agency
 which is part of California EPA) is responsible for enforcing requirements and reviewing plans
 under the  SB14  facility planning requirements. It has also worked to provide regulatory
 incentives for generators of incinerable hazardous wastes to voluntarily adopt waste reduction
 plans for those wastes (e.g., guarantees of expedited permit reviews).

 Multimedia pollution prevention training has been provided to many state and  local agency
 regulatory personnel. Some of this training was supported by  a federal grant, and coordinated
 through the Local Government Commission, a non-profit organization providing support for
 numerous intergovernmental efforts throughout the state.

 Below the  state level, DTSC has supported the development  of local pollution prevention
 efforts with a PPIS grant which has been used to establish  local roundtables to provide a role
 in  coordinating  and promoting  pollution prevention  efforts  involving the  various  local
 government agencies with  environmental responsibilities  within the  regions.  These  local
 efforts  include the whole  gamut of activities from education and technical assistance to
 permitting  and enforcement  The first of the local roundtables to be formed (in 1988) is now
 called the Southern California Pollution Prevention Committee,  and includes agencies from
 Santa Barbara through San Diego.  Two additional committees have also been established  -
 the Bay Area Hazardous Waste Reduction Committee, including agencies in the area of San
 Francisco, and the Central Valley Hazardous Waste Minimization Committee, which includes
 agencies in the area surrounding and including Sacramento.  A Consortium  of California
 Pollution  Prevention Committees  serves  both to coordinate the efforts of  the regional
 committees, and to link them to the California EPA.    .v
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