.. . .
Office of Pollution" Prevention and Toxics
Mail Code 7409 '
' .'",. Unted States
, . . -. i Protection Ag
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EPA, states, and municipalities have
made significant progress over the last
20 years in improving the quality of
the environment through continuous investment in
the nation's wastewater treatment infrastructure and
implementation of the Clean Water Act. Today how-
ever, the nation faces increased challenges including
municipal growth, newly regulated pollutants, a.nd
more stringent effluent limits. EPA encourages
municipalities to meet these challenges through pol-
lution prevention practices as the preferred
approach to augment traditional treatment and con-
trol of wastewaters, and avoid or defer the expan-
sion of a Publicly Owned Treatment Works (POTW).
As the federal government's role in funding
municipal wastewater treatment declines, there is
both the need and the opportunity to adopt pollu-
tion prevention measures to meet the expanding
demands and to prepare for new federal and state
requirements. Thus, a primary goal of EPA is to
encourage and support states and
municipalities in developing pollution
prevention programs.
To this end, the Office of Pollution
Prevention and Toxics funded a pilot
program in FY 1991 to demonstrate
how municipalities can benefit from
pollution prevention. EPA awarded
grants of up to $100,000 to five states
to demonstrate how a municipal POTW,
through its pretreatment program and
its facility operations, can promote
source reduction activities to industrial
and business dischargers. Activities
funded under this grant include:
Outreach and technical assistance to industrial
dischargers;
a Energy audits of specific POTWs; and
Establishment of water conservation programs
in the community. .
This brochure presents case studies of the five pro-
jects carried out under the grant program. The case
studies outline the goals and strategies employed by
each of the grant recipients. In addition, they high-
light program accomplishments and resolution of
problems encountered by recipients, where possible.
For further information about any of the projects,
please contact the project director listed at the end
of each case study.
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INTRODUCTION
The Massachusetts Office of
Technical Assistance (OTA) used EPA
grant funding to conduct its "Critical
Parameters Project". This pilot program
assisted two POTWs reduce key pollu-
tants that constitute "critical parame-
ters" through pollution prevention
assistance. Critical parameters are:
(1) those pollutants for which loadings
to the POTW are approaching or
exceeding 85 percent capacity, necessi-
tating capital expenditures to enlarge
the system, and/or (2) those pollutant
concentrations which, if exceeded, can
prohibit the marketing of the sludge or
cause the POTW to be in violation of
its own NPDES permit. The project
included an analytical sampling pro-
gram of POTW influent to document
pollutant reductions. The two projects
targeted a different source of pollution in POTWs:
Industry Toxic Effluent Reduction:
Warren Wastewater Treatment Plant;
Household/Small Business Hazardous Waste
Reduction: Worcester Upper; and
Blackstone Pollution Abatement District.
Originally, OTA planned to conduct a third project
in Springfield that would target non-point source
pollution received by the POTW. OTA cancelled this
project as the project team had difficulty locating a
suitable sampling point and State sludge classifica-
tion regulations changed, which altered the parame-
ters of the project.
COALS
Industry Toxic Effluent Reduction
Massachusetts has many rural communities, each
with a distinct identity and character. Most have
fragile economies unusually dependant upon a sin-
I
gle industrial facility. Warren, with a
population of 4,500, is such a town. The
Warren Project sought to reduce, through
pollution prevention practices, the tox-
icity of the effluent from a textile plant,
the major industrial discharger. The
plant normally contributes 40 to 60
percent of the Warren POTW influent.
Therefore, any reduction in the waste's
toxicity would make a major contribu-
tion to the town's pollution prevention
efforts. In 1991 the POTW failed to
meet two consecutive quarterly tests for
toxicity. Without reductions in the tox-
icity of its effluent, the POTW faced
costly regulatory measures in the future.
Household/Small Business Hazardous
Waste Reduction
The Worcester Project sought to reduce
loadings of several metals generated by
households and small businesses that are very small
quantity generators (VSQGs) in influent to the treat-
ment works. The POTW targeted copper, cadmium,
nickel, and zinc for reduction. The treatment plant
feared that a new NPDES permit might contain
stringent discharge limits for these metals. While
Worcester's pretreatment program controls the met-
als discharged by industries to the district, little had
been done in Massachusetts to reduce household
and VSQG releases. Studies in other parts of the
country (i.e., Seattle and San Francisco) have revealed
that small (i.e., household and VSQG) discharges
can significantly affect POTW influent and effluent.
STRATEGY
Industry Toxic Effluent Reduction
The project team developed a team approach to
evaluate and reduce levels of toxins in effluent from
the textile plant. Before carrying out the technical
work of the project, the project team sought the
support of the town, the POTW, and the manage-
ment and employees of the textile plant.
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The team believed that this support was paramount
to the success of the project. The team planned to
achieve its goals through three activities:
8 Develop and implement a textile plant efflu-
ent sampling program to establish baseline
levels, detect load reductions as they occur,
and identify the type of toxicity affecting the
plant (e.g., metal organics, surfactants).
a Develop a systemic approach to evaluating
pollution prevention opportunities at the
plant.
ซ Implement the easiest pollution prevention
measures first.
Household/Small Business Hazardous
Waste Reduction
The Worcester Project used a two-part approach to
reducing household and VSQG hazardous waste
loadings. First, the project team established a tem-
porary collection site for waste oil, antifreeze, and
photographic waste to provide a safe means for
households and VSQGs to dispose of the wastes.
Second, the project publicized the recycling center
and educated the public about clean water issues to
increase participation in the collection program and
reduce releases of other pollutants.
To attract VSQGs and households to the center,
familiarize them with the POTW, and educate them
on the total impact of all wastes on the POTW,
Worcester offered limited collection of used oil,
antifreeze, and photographic wastes. The project
team planned to measure and document the reduc-
tions in the concentrations of the metals in the
treatment plant influent.
Industrial Toxic Effluent Reduction
At the outset, the project team held meetings with
plant employees and management to encourage
support for the project. The project team explained
the importance of reducing the toxidty of the effluent
of the plant, both for the POTW and for the plant.
Iri addition, the project team emphasized that the
activities the employees perform every day in their
wprk caipi influence the quality of the influent and
effluent of the POTW. The team also explained the
costs to the plant of pretreatment or other end-of-
pipe regulatory requirements the plant would have
tti enact If the POTW continued to fail effluent toxi-
city tests. With this knowledge of pollution costs,
regulatory requirements, and the potential costs to
the significant industrial user (the textile plant), the
plant's employees and management became sup-
porters of the project. Throughout the project, man-
agement (especially middle managers from the dye
house and the finishing room) and employees vol-
unteered ideas and information they felt would be
helpful and provided data and information request-
ed by the project team.
To establish baseline toxicity concentrations and
track changes, the project team sampled effluent
from the textile plant and influent and effluent
from the POTW. Sample analysis determined that
while the textile plant was not the sole source of
toxic contaminants, it was a large source that caused
the POTW-effluent to exceed toxins concentration
"standards. Sample analysis and a literature review
pinpointed the two most significant toxins in the
plant effluent: toxic surfactants and salt. The pro-
ject team resolved these issues as follows:
Surfactants: With the help of the management
and employees of the textile plant, the project
team compiled a list of surfactants (cleaning
agents) used at the plant. The project team
researched dyes used in conjunction with lower
amounts of the toxic surfactants and researched
alternative dyeing methods. One company had
developed several dyes that could be used with
a non-toxic surfactant and would soon produce
several more. The textile plant agreed to switch
to the non-toxic surfactants after depleting its.
current stock of surfactants.
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Salt: The project team found several ways to
reduce salt effluent from the textile plant with-
out reducing the quality of the textiles pro-
duced. The plant may reduce the use of salt
with the current dyes or through revising dye
batch formulations. As with surfactants, the
project team researched new low-salt dyes, and
found dyes that would result in a 30 to 70 per-
cent reduction in salt use. Also, the project
team continues to study ways to reclaim salt
from textile plant wastewaters.
The project team and the textile plant employees
continue to evaluate technologies and substitutes to
reduce the toxic effluent from the plant. Working
together, they study the economic feasibility and
product performance of each alternative. Progress is
ongoing as the project team continues to evaluate
the effectiveness of the pollution prevention activities.
Moreover, the interest in pursuing and the willing-
ness to implement pollution prevention has contin-
ued to grow for all participants.
Toxidty at the POTW appears to have been reduced
while production levels at the textile plant have
increased steadily since the beginning of the project.
In order to ensure that the toxicity remains abated
after the project concludes, OTA is developing com-
puter software tracking and electronic systems that
will allow both parties to input respective data ele-
ments and generate graphs that will chart produc-
tion, POTW loadings, and toxicity data over time.
Household/Small Business Hazardous
Waste Reduction
The temporary recycling center opened in the FaU
of 1992 and served as an education center in addi-
tion to a collection point for antifreeze, used oil,
and photographic wastes. An educational poster
board presented information, and Massachusetts
Office of Technology Assistance staff members dis-
cussed recycling and POTW pollution issues with
recycling center users. To ensure use of the center,
the project planned an extensive publicity effort.
The public education program and the recycling
center participation publicity worked in tandem.
To advertise the recycling center, the project team
placed advertisements in newspapers, on radio, and
on local cable television. The project team made
presentations about POTW pollution issues to civic
groups and sponsored topic-specific workshops for
the general public. The general presentations
focused on the problems pollution causes POTWs
and introduced the concept of pollution prevention
versus pollution control. The project team also
made presentations to a wide range of civic groups,
ranging from the local chapter of the Appalachian
Mountain Club to the local Rotary Club. In addi-
tion, the project team presented two topic-specific
workshops, "Household Product Dangers," and
"Green Tips for Weekend Mechanics," which
instructed participants how to reduce toxic releases
during specific activities. To learn which aspects of
the public education programs were most valuable
so as to improve the effectiveness of its education
efforts, the project team surveyed participants in the
educational activities and the recycling center users.
The project team also developed a curriculum for
primary grade students that explores (through lec-
tures and hands-on activities) how pollutants harm
the operation of a POTW. The project team collected
portions of existing curricula and included or modi-
fied them to best present information on POTWs.
The curriculum consists of six lessons supported by
handouts, presentation boards, and brief slide
shows. As part of this curriculum, the project team
created a cartoon character named "Roddy the
Rotifer" to bring alive for students the importance
of the biological processes upon which POTWs
depend. The curriculum includes activities such as
writing a cookbook of non-toxic household cleaners
and holding a mock pollution prevention project
grant application writing competition. The project
team planned to donate a curriculum copy to up to
100 schools.
Over nine months, the project created several
innovative lessons for the curriculum and collected
over 1400 gallons of waste at the collection site
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from 150 users. The team measured four pounds of
the targeted metals in the 1400 gallons of waste.
While these four pounds of metals were diverted
from the POTW, the concentrations of the metals in
the influent of the POTW did not change during the
duration of the project. Although the project did
not meet its overall goal of reducing influent con-
centrations, it did accomplish several important
intermediate goals that will help limit influent con-
centrations in the future and thus help it to meet
future, more strict permit requirements for effluent.
The public education project reduced toxic releases
and laid the groundwork for further educational
activities. A survey of the users of the recycling cen-
ter yielded a 65 percent response rate. The data
show that: (1) half of the users knew nothing about
wastewater treatment before using the center; (2) 71
percent understood the POTW better after using the
center; (3) 60 percent wanted more information
about the POTW; (4) 41 percent wanted a tour of
the POTW; (5) 36 percent tried one or more of the
source reduction suggestions from the center; and
(6) all respondents wanted the service continued.
Although difficult to quantify, the many newspaper
articles arid ads, radio advertisements, and other
outreach efforts raised the awareness of thousands
of people of the problems water pollution causes
POTWs.,In,addition, the publicity about the POTW's
efforts to implement low-cost, non-regulatory solu-
tions to pollution problems will help to create ongo-
ing goodwill between the community and the POTW.
PROBLEMS ANP RESOLUTION
Household/Small Business Hazardous Waste
Reduction
In addition to some common operational prob-
lems, the Worcester Project encountered two prob-
lems. Through flexible planning and an understand-
ing of the project area, the project team resolved
_one.of-these.problems.and.approached the project
goals through alternative means.
(1) Low Turnout at Workshops: The workshops
offered to the general public suffered from
lower-than-expected turnout. The project
team surmised that the evening scheduling of
the workshops and limited publicity con-
tributed to the low turnout. To reach a wider
audience, the team scripted, contracted, and
filmed a one-half hour educational and instruc-
tional video that explains the effect of water
pollution on the POTW. The video offers more
detailed information, such as specific steps
households can take to reduce pollutant releases.
The team televised the video on a popular
local-access cable channel.
(2) Limited Use of Recycling Center: The recycling
center received little use from VSQGs and
moderate use from homeowners. Three factors
may have limited its use. First, small businesses
may have been dissuaded from using the recy-
cling center because they would have to identi-
fy themselves to the State as VSQGs to use the
center. Some may have feared future regulation
as VSQGs. Second, local environmental and
civic organizations did not provide as much
support for the project as originally planned.
Several organizations had initially agreed to
help with the project, but provided only limited
- -. help due to the short time deadlines of the pro- .-
ject and.their own pre-existing priorities and
projects. Third, the center received less publicity
than originally planned due to staff time
limitations. '...-.
Industry Toxic Effluent Reduction
Preliminary analysis of the data indicates that
when the textile plant switched to a more degrad-
able product it may have caused a new loading
problem for the POTW as biological units at the
POTW could only partially digest the product's car-
bon chains. The project team believes that the prob-
lem might be easily remedied if the POTW adds
additional biological reactors during periods of peak
production at the textile plant. This type of loading,.,,
problem may be resolved by simply establishing and
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-rf/
(l.yปH
maintaining a line of communication between the
POTW and the company.
RESULTS AND PRODUCTS
Industry Toxic Effluent Reduction
i
Toxicity at the POTW appears to have been
reduced while production levels at the textile
company have increased steadily since the begin-
ning of the project. Tools to aid in continued
cooperation at the conclusion of this project are
being developed.
Continued success in toxicity reduction will
depend on maintaining the data elements estab-
lished and by expanding them when new products
are introduced at the textile company. These activi-
ties will allow both parties to observe trends, noting
toxicity changes as they occur. The project team will
develop a computerized system to electronically link
the databases held at each facility in order to rou-
tinely track the data and review the trends.
The textile company should be commended for its
efforts. Both management and employees have been .
extremely helpful throughout the project. Moreover,
the textile company has actively pursued pollution
prevention beyond those measures addressed
through this project.
Finally, OTA is developing a model to expand the
Warren project. The model is being designed to help
small POTWs meet the increasing challenges of new
NPDES permit restrictions when they are imposed.
OTA's module will allow POTWs to use the microtox
unit on a lend-lease basis to conduct toxicity trials
at their plants. POTWs could use the toxicity infor-
mation to establish working relationships aimed at
problem solving with their industrial users.
Pollution prevention approaches and OTA technical
resources would be the first step in this process.
Program elements and the logistics of the proposed
model are in the early stages of development.
Household/Small Business Hazardous
Waste Reduction
A complete information packet on initiating a
consumer-targeted educational program about
POTWs and pollution prevention will be available
to all POTWs as a result of this study. Some packets
will be distributed throughout the Blackstone
Watershed while others will be available upon
request. The packet will consist of (1) a video; (2) a
permit application template for POTWs to use in
establishing waste collection centers; (3) a consumer
guide about POTWs, toxics and pollution preven-
tion recipes; (4) the children's curriculum; and (5) a
publicity poster. These materials will help POTWs
establish broad based consumer programs without
having to allocate scarce resources (time and
money) to this effort. Already, OTA has received
numerous requests for these materials.
AVAILABLE MATERIALS
Educational video
Sample curriculum materials
, ป "H^Ome Improvements" consumer manual
and brochure
e Recycling Center Permit Application
FOR MORE INFORMATION CONTACT
Paul Richard
Massachusetts Office of Technical Assistance
(617) 727-3260
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The Minnesota Office of Waste
Management (OWM) oversees State
programs designed to conserve
resources and prevent pollution. Its
programs encourage waste reduction,
recycling of reusable materials, recov-
ery of resources from waste, and treat-
ment of waste to reduce risks. In 1984,
the State established the Minnesota
Technical Assistance Program (MnTAP)
to provide non-regulatory assistance to
Minnesota industry in pollution pre-
vention and waste management.
MnTAP services include on-site and
telephone consultation, educational
and technical resources, and a student
intern program.
Since 1969, the Metropolitan Waste
Control Commission (MWCC) has managed the
wastewater of the Twin Cities metropolitan area.
MWCC owns and operates nine wastewater treat-
ment plants and over 300 miles of interceptor sew-
-ers and treats 275 million gallons of wastewater per
day. MWCC's Metro Plant is the largest treatment
plant in the State of Minnesota and treats approxi-
mately 220 million gallons of wastewater per day.
GOALS
Minnesota hoped to accomplish the following
three goals with the EPA grant:
1) To establish programs and activities that promote
source pollution prevention at the State's largest
POTW;
2) To reduce the level of pollutants and wastewaters
discharged to the wastewater treatment system; and
-~3)_To-seek ways to-benefit-from multi-media pollu-
tion prevention activities.
Minnesota adopted a six-pronged
approach to reach the above goals:
1) Training. The State planned to
train MWCC pretreatment program
staff, MWCC staff committee mem-
bers, other Minnesota POTW staff,
Minnesota Pollution Control
Agency (MPCA) industrial waste-
water staff, representatives from
metro county hazardous waste pro-
grams, and interested industrial
users of sewage treatment plant
systems on multi-media pollution
prevention techniques. The pro-
posed training would be in the form
of the following three workshops:
Workshop I: Presentation of background
information and introduction to
pollution prevention concepts.
Workshop II: Discussion of how to integrate
pollution prevention techniques
into inspections, identification of"
- * opportunities to prevent pollution,-
....... _-. and use of case studies to reinforce
the program's objectives.
Workshop III: A forum for industrial users and
POTW staff to share ideas and
experiences on pollution
prevention.
To supplement the workshops, the .State planned
to provide tours of successful industry pollution pre-
vention programs.
2) Technical Assistance. After attending the above
workshops, MWCC staff planned to provide
on-site technical assistance to industry in
Minneapolis/St. Paul. MWCC staff members
- would promote pollution-prevention to-indu^ .
stry. and identify opportunities to prevent
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pollution during routine inspections. In addition,
MWCC staff would refer industry to MnTAP or
other contacts, where appropriate.
3) Regulatory Integration. The State and MWCC.
proposed to organize a staff committee to help
integrate pollution prevention into MWCC pro-
grams. The staff committee would provide
guidance for MWCC in achieving program
objectives and would generally oversee the
grant project.
4) Measuring Success. The State and MWCC
planned to develop methods of quantifying
changes In the level of pollution resulting from
the pollution prevention efforts.
5) Coordination. MWCC planned to coordinate
its efforts with other programs in Minnesota by:
(1) meeting quarterly with other pollution pre-
vention programs in the state; (2) continuing to
participate on OWM's Pollution Prevention Task
Force; (3) participating at OWM's annual Pollution
Prevention Conference; and (4) developing fact
sheets and other materials for use by other POTWs.
|^ 6) Advisory Group. The State and MWCC proposed
j to solicit industry and public input both by
forming an advisory group which would serve in
an advisory capacity for the grant project and
MWCC's pollution prevention efforts.
PROGRAM ACCOMPLISHMENTS
Pollution Prevention Workshop #1
On April 29, 1992, the first of three workshops
was held by OWM and MWCC. Speakers described
pollution prevention and its importance as an alter-
native to end-of-pipe treatment. They also intro-
duced waste minimization techniques for various ,
industries.
Pollution Prevention Workshop #2
On October 13,1992, OWM and MWCC srW
sored a second workshop. The purpose of this work-
shop was to: (1) provide information on how to
integrate pollution prevention into inspections; (2)
identify pollution prevention opportunities; (3) pro-
mote the pollution prevention approach; and (4)
discuss case studies. Concurrent sessions were held
for a variety of industrial processes so that pollution
prevention could be discussed specific to each indi-
vidual industry.
Pollution Prevention Workshop #3
The State decided to integrate the third workshop
with the Minnesota statewide Pollution Prevention
Conference because the combination of the two
events was more efficient and provided an opportu-
nity to reach a larger audience. The Conference/
Workshop was held on June 17, 1993 and was spon-
sored by OWM, MWCC, MnTAP, and the Minnesota
Chamber of Commerce. The purpose of the confer-
ence was to promote pollution prevention to all
industrial users. There were eight different topic
areas with six sessions for each topic area. The eight
topic areas were: (1) Pollution Prevention Basics;
(2) Industry/Process Specific I; (3) Industry/Process
Specific II; (4) Wastewater Pollution Prevention;
(5) Solid Waste Source Reduction; (6) Pollution
Prevention Community Partnerships; (7) Pollution
Prevention Case Studies; and (8) Pollution
Prevention Initiatives.
Pollution Prevention Survey
To obtain information regarding industrial pollu-
tion prevention activities, success stories, and input
on ways to provide further assistance to industries,
MWCC conducted a pollution prevention survey
among permitted industrial users. MWCC mailed
the survey to over 650 permitted industrial users
and received a 65 percent response rate. The results
of the survey have been compiled and will serve to
guide MWCC's future pollution prevention efforts
and initiatives.
Pollution Prevention Advisory Committee
In August, 1992 MWCC established the Pollution
Prevention Advisory Committee (PPAC). The com-
BvfcjS
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mittee, comprised of sixteen representatives of
MWCC, OWM, and various industries, citizen groups
and communities, serves in an advisory capacity for
the grant project and MWCC's pollution prevention
efforts. PPAC meetings were held once every two
months during the term of the grant program. The
topics discussed included MWCC's pollution prevention
program, the pollution prevention survey, integra-
tion of pollution prevention into MWCC's pretreat-
ment program, and the grant program in general.
Staff Training
MWCC Staff have attended several local work-
shops and conferences on pollution prevention as
part of staff training. Some of the topics discussed
included pollution prevention in electroplating/metal
finishing operations and vehicle maintenance. The
Waste Reduction Institute for Training Applications
and Research conducted a one-day training session
for MWCC's pretreatment staff on pollution preven-
tion opportunities in electroplating and metal fin-
ishing operations on April 20,.1993.
Industrial Pollution Prevention Participation
Program (I4P)
Initiated in November of 1992, this program, is,
intended to promote, in a voluntary and non-regu-
latory manner, pollution prevention among the per-
mitted industrial users; The program encourages
industries to reduce pollution of wastewater without
transferring pollutants from one medium to another
(i.e., from water to air).
AVAILABLE MATERIALS
Minnesota has made the following materials
available:
A brochure describing the Minnesota
Technical Assistance Program;
A brochure summarizing the topics of discus-
sion at.ฑhe. 3rd,annual Minnesota Conference,
on Pollution Prevention;
ซ A booklet summarizing a model pollution
prevention plan including examples of pre-
ventative activities;
ซ A! fact sheet describing the MWCC;
ซ A fact sheet describing the Industrial Waste
Division of the Quality Control Department
of MWCC. The fact sheet outlines how the
division controls and monitors discharges to
the sewer system to insure compliance with
local and federal regulations;
A, fact sheet defining pollution prevention
and outlining its use as an environmental
protection tool;
9 A:fact sheet explaining the Minnesota Toxic
Pollution Prevention Act;
"Managing and Reducing Dental Waste", a
brochure on preventing pollution at dental
dinics; and
ซ A brochure on household pollution
prevention.
FOR. MORE .INFORMATION CONTACT
Kevin j. McDonald
Minnesota. Office of Waste Management
(612) 649-5744
Navneet K. Tiku
Metropolitan Waste Control Commission
(612) 772-7016
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,*ซ /'"
-It
INTRODUCTION
The New Mexico Environment
Department (NMED) initiated a num-
ber of pollution prevention efforts in
conjunction with EPA Region 6 prior
to the award of the EPA grant. These
efforts focused on a pilot program
Improving Municipal Performance by
Addressing Capacity (IMPAC). IMPAC,
developed during 1989-90, is a compli-
ance maintenance program that helps
POTWs meet federal Clean Water Act
provisions. IMPAC is intended to assist
municipalities in their efforts to identify
and address performance-limiting fac-
tors that have been found to adversely
impact the ability of POTWs to effec-
tively treat municipal wastewater and
produce a compliant effluent.
NMED transferred $70,000 of the
$100,000 awarded by EPA to the City of
Albuquerque. Albuquerque is a large city (approxi-
mately 500,000 residents) that has a growing eco-
nomic base. The State chose Albuquerque, in part,
because Albuquerque had already established a pro-
gram to pretreat potentially hazardous pollutants
prior to introduction to the POTW. Because industri-
al pretreatment programs often result in transfer of
pollutants to other media rather than elimination,
Albuquerque used the grant to emphasize pollution
prevention. The POTW strongly encouraged pollu-
tion prevention as it feared more stringent discharge
requirements on both its effluent and sludge and
was interested in composting and distributing
wastewater sludge for beneficial use.
COALS
New Mexico and the City of Albuquerque hoped
to accomplish the following objectives in this project:
1) Educational Outreach. Provide information on
hazardous waste management to industry;
2) Technical assistance. Help compa-
nies identify and evaluate site-spe-
cific opportunities for hazardous
waste minimization;
3) Identification and Targeting of
Specific Discharges for Waste
Reduction. Reduce wastes with
greatest detrimental impact on the
POTW's ability to comply with
NPDES permit requirements and
produce safe sludge; and
4) Evaluation of Regulatory
Alternatives. Establish indirect
inducements or direct requirements
to promote waste minimization (i.e.,
mass balance discharge limits or
more stringent local limits).
STRATEGY
NMED chose to implement its waste minimization
program through the established Albuquerque
Industrial Pretreatment Program.Through this pro-
gram, New Mexico focused on meeting waste mini-
mization and source reduction goals at the local
level, since 29 of the state's 50 largest industries are
either located in Albuquerque or utilize the city's
sewer system for disposal of their effluent.
Some of the services that the Albuquerque
Industrial Pretreatment Program planned to
perform include:
Monitoring of industries suspected of dis-
charging toxins or hazardous constituents to
the City's POTW;
Levying of surcharges and enforcement
actions to violators to induce industries to
reduce the amounts of toxic or hazardous
wastes they discharge into the POTW;
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e Technical assistance to industry on matters
relating to the pretreatment, minimization, or
elimination of toxic waste discharges;
9 Identification and elimination of toxins in
the wastewater received by the Albuquerque
POTW; and
Laboratory analyses performed to identify or
quantify the concentrations of toxic or haz-
ardous constituents in industrial wastewater
discharges.
New Mexico has accomplished numerous objec-
tives in educational outreach, technical assistan.ce,
and identification and targeting programs.
Educational Outreach
Albuquerque is currently developing a Self-
Assessment Manual to help general industry assess a
facility's waste generation and its potential waste
reduction opportunities. While the manual itself is
not industry-specific, there are industry-specific
worksheets being developed,to supplement -the -. -
manual. The Cityjs developing worksheets for pho- ^
toprocessors, jewelry manufacturers, and electro-
JpTaters/metals"finishefs. .
During 1993, the City of Albuquerque sponsored
five workshops:
1) Photo and Jewelry Industry Workshop. The
New Mexico Silver Users Association/City of
Albuquerque sponsored two nights of work-
shops on techniques for reducing the level of
silver in wastewater. The sponsors advertized
the workshop in a newsletter that reaches near-
ly 1,000 people in the photo and jewelry indus-
tries both large users of silver. At the work-
shop the City introduced the City's 5 PPM
.....Program..Under this voluntary-compliance.pro-,
gram, the City provides certificates to facilities
that reduce the content of silver in their waste-
water to 5 parts per million (ppm). The City
also asked participants to share information on
successful silver reduction/recycling techniques.
At the conference, one area jeweler spoke on
what his facility has done to achieve virtually
closed-loop recycling of most process metals
and recharge/reuse of its pickling solutions.
Approximately 50 people attended at least one
of the workshops.
2) Electroplating/Metals Finishing Industry
Workshop. Approximately 40 participants,
including close to 30 industry representatives,
attended this workshop sponsored by the City
of Albuquerque on May 28, 1993. This work-
shop covered methods of waste reduction and
ion exchange and similar processes.
3) Photographic Processing Silver Reduction
Workshop. Close to 30 percent of the facilities
contacted attended this workshop held on July
14, 1993. The information discussed at the
workshop included techniques for reducing
photographic wastes and the 5 PPM Program.
Three area silver recovery and equipment sup-
pliers made presentations. Waste Minimization
"staff discussed water conservation and the level
of fixer solution required to make on-site recov-
. . ,ery of silver economically viable at photopro-
cessing facilities. A representative of the
Albuquerque Hazardous Waste Program covered
.. current RCRA and DOTjregulations that affect
photographic wastes.
4) Radiator Repair Industry Workshop. This work-
shop/seminar, sponsored by the Albuquerque
Environmental Health Department, advised par-
ticipants of waste reduction opportunities in the
radiator repair industry.
5) Waste Reduction Workshop for the Printing
Industry. On November 30, 1993, a waste
reduction workshop for printers was held. The
.workshop, sponsored by.,the Albuquerque. Waste
Minimization Program, the Albuquerque Club
I'M.
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J5?
.TT!^.
ซฃ*ฃ
of Printing House Craftsmen, and the T-VI
Commercial Printing Program, provided partici-
pants with information on printing industry
regulations and pollution prevention tech-
niques (i.e., silver recovery). Workshop presen-
ters also discussed the handling of hazardous
waste and various air quality and stormwater
quality concerns.
Technical Assistance
The City launched the Industry Waste Reduction
Opportunities (Industry WROs) project by visiting
28 industrial sites. The objective of the program was
to identify and evaluate opportunities for pollution
prevention through reduced volume and toxicity of
industrial wastes. The majority of the visits were to
photo processing labs (7), jewelry manufacturers (6),
and electroplaters and metals finishers (5). At cer-
tain sites, the City took samples from the waste
streams to assess metal loadings in effluent dis-
charges. These site visits helped the City to identify
the present level of pollution prevention at facilities
around the city as well as explore areas for potential
waste reduction. The City found businesses with
successful product recovery systems willing to trans-
fer information on pollution prevention techniques
to similar area businesses.
Identification and Targeting
In January 1993, the City initiated an industrial
mapping project. Using the Albuquerque Geographic
Information System, the City located nearly 80 per-
cent of the City's metal finishing and photofinish-
ing industries. The map shows clusters of the priori-
ty industries in relation to sewer lines. The City
used the map to select specific manholes for domes-
tic and domestic/commercial sampling. The City is
also better able to manage field time by selecting
those industries of concern and visiting those indus-
tries within close proximity of each other.
Sampling and process data collected during the
ฃ5*7
site visits (described above) has helped the City bet-
ter target resources.
PROBLEMS AND RESOLUTION
Implementation of the project was delayed from
the proposed October 1, 1991 start date because of
prolonged contract negotiations between NMED
and two of the contractors (City of Albuquerque
and University of New Mexico) working on the pro-
ject. In addition, a .State-issued temporary freeze on:
any new expenditures of funds for professional ser-
vice agreements delayed the commencement of the
project. To enable the project to meet its objectives,
EPA extended the project and budget periods for
one year to September 30, 1994.
AVAILABLE MATERIALS
ซ Announcement flyer and agenda for electro-
platers workshop
Monthly progress reports
o Summary reports of inspections, waste assess-
ment, meetings, and analyses
ป Synopsis of the Printer's Waste Reduction
Workshop
FOR MORE INFORMATION CONTACT
Robert Hogrefe, PE
Wastewater Utility Division
City of Albuquerque
(505) 873-7030
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North Carolina's pretreatment and
pollution prevention programs have
worked together for a number of years
to train industrial dischargers and
POTW pretreatment coordinators on
approaches that dischargers can use to
reduce effluent pollutant loadings. The
EPA grant allowed North Carolina to
fully integrate pollution prevention
into the State Pretreatment Program.
GOALS
North Carolina hoped to accomplish
the following four goals with the EPA
grant:
1) Develop a framework at the state
level to oversee local pollution
prevention programs;
2) Establish pollution prevention programs at
POTWs;
3) Address specific pollution problems through
the.use of pollution prevention techniques; and
4)~ Transfer information to other states and locaL
pretreatment programs.
STRATEGY
North Carolina initiated a number of activities to
achieve the above goals. To accomplish the first
goal, North Carolina endeavored to integrate its
well-established pollution prevention program with
the existing State Pretreatment Program. One means
of integrating the two programs is the provision of
training in pollution prevention techniques.
To realize the second goal establishing local
pi pollution prevention prograrns-at4?OTWs - North
Carolina decided to pilot programs at two represen-
tative POTWs located in Winston-Salem
and Troy. Pretreatment programs in
North Carolina generally fall into one
of two categories: programs in large
municipalities or programs in small
towns. The needs of POTWs in larger
municipalities such as Winston-Salem
differ somewhat from the needs of
POTWs in smaller towns such as Troy.
For example, POTWs in large munici-
palities usually serve a large number of
significant industrial users (SIUs) and
generally have sufficient staff and labo-
ratory support to implement pollution
prevention programs with minimal
support from the State. Small towns,
however, usually serve fewer SIUs.
Because of their small size, the towns
generally face greater resource con-
straints and may depend more heavily
on staff support provided by the State.
; Small town POTWs typically serve a
wide variety of uncontrolled discharges including
light industrial facilities and commercial operations.
Thus, North Carolina determined that it would
establish one project at a large municipality and one
at a POTW serving a small town. To transfer lessons
learned from the pilot project, North Carolina has
awarded three, challenge grants to qualified POTWs
in other areas of the state.
To further the State's third goal addressing spe-
cific pollution problems through the use of pollution
prevention techniques North Carolina used an
additional criterion when evaluating potential pilot
program locations. The State selected pilot locations
that possessed an existing pollution problem that
could not be addressed through treatment.
To accomplish the fourth goal enabling other
states, local pretreatment programs, and industries
to benefit from this project the State resolved to
develop comprehensive guidance materials on devel-
oping POTW pollution prevention programs at the
state and local levels. In addition, the State planned
..to develop.guidance for.industries based upon the
specific pollution addressed in the pilot projects.
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i
r-fc''.:
*ป>,*""'
v
State Accomplishments
Set up a pilot project with the City of Winston-
Salem to establish a pollution prevention pro-
gram within the City's POTW Pretreatment
Program (535,000). Winston-Salem is a rela-
tively large city that has a population of
approximately 150,000. The city maintains a
well-established pretreatment program and
would like to reduce metal loads to maintain
compliance with NPDES permit and regain
capacity for future use.
Set up a pilot project with Town of Troy to
establish a pollution prevention program at
the Town's POTW ($15,000). Troy is a small
town and has a population of approximately
3,400. It has three SIUs and nine industries. Its
POTW encountered periodic compliance prob-
lems with NPDES effluent limits for cadmium,
lead, cyanide, and whole-effluent toxicity.
The Office of Waste Reduction conducted a
training seminar for the DEM Pretreatment
Program. Training included a half-day of
classroom instruction on pollution prevention
case studies and a half-day field training on
waste reduction audits.
The State trained Winston-Salem staff to con-
duct on-site industrial audits.
The State trained Troy POTW staff on sampling
procedures and pollution prevention audits.
The State offered challenge grants for POTWs
with pretreatment programs to develop pollu-
tion prevention programs (3 at $17,000 each).
The State included several items involving
pollution prevention in the recent revision of
the State's pretreatment regulations.
City of Winston-Salem Accomplishments
Received training from Pollution Prevention
Program Staff.
ซ Publicized the pollution prevention program
through newspapers and radio.
ซ Surveyed 620 industrial and commercial users
in 17 industrial categories on waste streams.
9 Completed an updated headworks analysis
ซ Used the waste stream survey and headworks
analysis to target specific industries or categories
of users for outreach and pollution prevention
audit. Sent 385 information packages to target-
ed businesses. ' :
ซ Performed 44 industrial audits.
e Established a pollution prevention library.
e Modified pretreatment permit applications
and the inspection checklist to include ques-
tions pertaining to waste reduction activities.
Established an awards program for industrial
users of POTWs.
9 Staff attended sessions on water conservation
and water transfers and participated in waste-
water schools.
* Incorporated pollution prevention into
ongoing City efforts, "Keep Winston-Salem ' '
Beautiful" and "Recycle Today!"
ซ Sponsored two seminars:
- "Business and the Environment"
- "Pollution Prevention Makes $ense"
Town of Troy Accomplishments
ซ Received training from Pollution Prevention \
Program Staff.
ซ Completed a long-term headworks monitor-
ing program for the Town that provides site-
specific pollutant concentrations, loads, and
treatment plant pollutant removal efficiencies.
ซ Conducted a Pollution Prevention Program ',
kick-off presentation for industrial users. ;
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e Conducted pollution prevention audits/
assessments for nine industrial users.
6 Initiated a baseline performance monitoring
program and investigated sewer line monitor-
ing to further identify potential sources of
toxicity.
e Inventoried Material Safety Data Sheets
(MSDS) from 6 industrial users into a
computer database.
0 Incorporated pollution prevention into ongo-
ing municipal efforts such as the Town
Utilities Department's Street Crew and trie
local Parks and Recreation Department.
3 Publicized the pollution prevention program
through newspapers and television.
e Reduced oil/grease discharges through personal
communication with oil/grease dischargers.
e Mailed out 129 questionnaires to businesses
to assess their pollution prevention potential.
ฎ Sent 14 pollution prevention packages as a
result of the returned questionnaires.
e Performed a specific conductivity scan and
additional toxicity monitoring to locate
" sources of aquatic toxicity.
0 Lowered the hydraulic loading to the POTW
through an infiltration/inflow investigation.
e Distributed solid waste recycling and com-
posting information as requested by the
general public.
Winston-Salem found that small businesses had
difficulty locating recyclers interested in collecting
smalXampunts pfjreusable materials they_generated.
Winston-Salem identified the following possible
solutions to this problem:
8 Identification of small business interested in
"piggy backing" on larger facilities' existing
collections points;
s Assistance to small businesses in neighbor-
hpod networking; and
8 Establishment of local collection points
throughout the City.
The following materials are available from the
Division of Environmental Management:
0 Waste stream questionnaires used in the sur-
vey are available to interested parties.
Winston-Salem developed one general ques-
tionnaire and 17 industry-specific question-
naires including automotive, battery, car
washers, and laboratories.
0 Agenda for workshops.
0 Aifinal report that documents the results of
the two pilot programs, describes"" integration' *
-"of pollution prevention into state water pro-
-- grams, describes-how North Carolina estab--
lished pollution prevention programs at other
POTWs, and identifies additional resources for
. --POTWs.
e The City of Winston-Salem's Pollution
Prevention Plan.
Julia E Storm
NC Department of Environment, Health and
Natural Resources Division of Environmental
Management
-x^-Shf -
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INTRODUCTION
Utah does not have legislation or reg-
ulations that require industry to devel-
r^- op waste minimization plans. Thus,
[9 IT the Utah project focused on how to
Incorporate waste minimization into
existing POTW pretreatment programs.
In particular, the State focused on one
POTW pretreatment program in Salt
Lake City. Salt Lake City is a moderate-
ly sized metropolitan city located in a"
semi-arid and rapid-growth region, typ-
ical of the southwest. The typical
industrial users are metal finishers.
GOALS
Project goals included reducing pollution through-
out Utah as well as in Salt Lake City. Specific goals
include:
Expand the scope of the State's POTW self-
audit program to include multi-media source
reduction, water conservation, and technical
assistance as a means for extending the useful
lifeofPOTWs;
Strengthen both Utah and Salt Lake City's
pollution prevention capacity;
Encourage industrial, commercial, and resi- -
dential users of Salt Lake City's POTW to
prevent pollution and minimize waste;
Address high-risk areas (based on health,
ecological, and POTW compliance factors);
Use the results of this pilot to transfer
knowledge gained to similar states and
municipalities; and
Or 3^ Support goals of the Pollution Prevention Act
^ of 1990.
STRATEGY
The City resolved to conduct the fol-
lowing activities to encourage industri-
al, commercial, and residential users of
Salt Lake City's POTW to prevent pollu-
tion and minimize waste:
Conduct assessments of waste
water being discharged into City
sewers; . , :
Promote water conservation;
Conduct waste minimization
assessments at select industrial
sites;
ฐ Establish stringent local limits
based on mass and technology;
Provide information, education,
and technical assistance;
* Target key industries that discharge to Salt
Lake City's POTW; and
Recognize industrial, users that implement
aggressive pollution prevention programs.
As part of this strategy, the State and City spon-
sored pollution prevention workshops for the City's
commercial and industrial users. As the majority of
industrial users in Utah are in the metal finishing:
industry, the State planned to focus at least one
workshop on this industry.
To reduce solvents released to the City's POTW,
Salt Lake City planned to develop a solvent reduc-
tion and reuse program at city-owned operations. To
further the same goal, the City sought to establish a
chemical clearinghouse.
Utah presented the results of this project at meet-
ings with industrial organizations and government
officials throughout the State and EPA Region VIII.
Ba
itt
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PROGRAM ACCOMPLISHMENTS
As part of its "Pollution Prevention Education
Initiative", Utah held workshops for the following
four groups:
(1) Pretreatment Coordinators. Representatives
from 14 of the 15 approved pretreatment pro-
grams, and several coordinators from
non-approved programs attended this three-day,
City/State-sponsored workshop. During the
first two days, the staff introduced pollution
prevention and discussed how coordinators can
incorporate pollution prevention into their
POTW pretreatment programs. Pretreatment
coordinators also learned how to conduct
pollution prevention assessments. On the third
day of the workshop, the group visited two Salt
Lake City industrial sites a metal finisher and
the City's fleet maintenance service. The partic-
ipants toured the facilities and discussed source
reduction opportunities for each facility's waste
stream. Participants also received hands-on
training on how to access pollution prevention
information on data bases and clearinghouses.
(2) Metal Finishers. This workshop focused on
metal finishing companies in Salt Lake City.
Metal finishers represent 17 of the'18 industrial
users that discharge to the POTW. the staff
presented pollution prevention case studies and
discussed applications of pollution prevention
techniques. The staff illustrated that pollution
prevention is a practical and cost-effective tool
for the metal finishing industry.
(3) General Industry. This workshop highlighted
the uses of pollution prevention techniques in a
wide range of industries. The presentations
highlighted six industries including: metal
finishing, food processing, aircraft production,
laundries, hospitals, and auto maintenance.
The workshop included information on waste
disposal and water conservation.
,(4) ..PretreatmentUpdate. Seminar. JUtah .held a
follow-up seminar to the first workshop for
pretreatment coordinators. The staff presented
success stories to the pretreatment coordinators
and distributed a survey to help the State assess
the benefits of the grant program.
Salt Lake City developed an awards program to
recognize and encourage implementation of innova-
tive pollution prevention programs. To keep the
awards program meaningful, the City determined
that the same company could not routinely win.
The City developed the following criteria to select
the award-winning programs:
B The program is designed to-decrease the
production of pollution;
Pollution prevention techniques do not result
in a media transfer of pollutants;
The company developed innovative changes
in processes that will decrease pollution and
may be transferred to other industries;
a The company substitutes chlorinated solvents
with cleaner alternatives, where applicable; and
e The company complies with State/City
regulations.
Through this grant project, Salt Lake City also
changed procurement policies at city-owned facili-
ties to eliminate chlorinated solvents. Salt Lake City
now gives priority to bids that utilize alternative,
non-chlorinated solvents.
Finally, Utah presented a summary of the project
results at two conferences held in the spring of 1993:
(1) Utah Water Pollution Control Association.
Given that many POTW managers attended
the annual meeting in April 1993, Utah/Salt
Lake City staff emphasized the importance of
management support for pollution prevention
programs, as well as the benefits to POTWs.
These benefits include extending the useful
life of the plant by reducing loadings from
. commercial, industrial, andjdomestic users
and increasing regulatory compliance.
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(2) EPA Region VIII. Utah also presented the
results of their project at the annual EPA
Region VIII pretreatment coordinators meet-
ing in Jackson, Wyoming in May 1993. Many
of those attending the conference were unfa-
miliar with pollution prevention techniques
prior to the conference. Some pretreatment
coordinators mentioned, however, that they
were beginning to incorporate pollution pre-
vention into their pretreatment programs.
PROBLEMS AND RESOLUTION
Utah encountered several problems during the
implementation of its grant project including:
Ensuring attendance at workshops;
Making workshops specific enough to
inform industry;
Encouraging solvent recovery at city-owned
facilities; and
Establishing a chemical clearinghouse.
Utah had difficulty attracting a large audience to
some of its workshops. For example, Utah sent out
over 200 invitations for the general industry work-
shop and only 26 individuals representing 13 com-
panies attended. In contrast, 40 metal finishers rep-
resenting IS companies attended the first industry
workshop which was specific to the metal plating
industry. Since the metals industry is regulated by
the State, the staff attributed the high attendance to
the regulatory threat posed by the State and City.
Post-conference survey results indicate that partici-
pants, especially those of the general industry work-
shop, desired more industry-specific information
(i.e., case studies of how pollution prevention had
benefited a company similar to their own and
details of how the pollution prevention practice was
implemented).
3Sf 53..
Salt Lake City did not develop a solvent recovery
system for city-owned facilities as it had planned
initially. Upon further reflection, the City deter-
mined that eliminating solvents altogether would be
a preferable waste management alternative. To elim-
inate solvents, Salt Lake City now gives preference
to alternative, non-chlorinated solvents in the bid-
ding process.
The City encountered liability problems as it tried
- to establish a chemical clearinghouse. Rather than
operating a chemical clearinghouse, the City chose
to facilitate the exchange of chemicals and materials
and match users and producers.
SUCCESS
Salt Lake City staff distributed a questionnaire/skill
evaluation to help staff gauge the success of each
workshop. Overall, the results show that the work-
shops were successful.
Overall, pretreatment coordinators found their
workshop beneficial rating the workshop as a 4.4
on a 5.0 point scale. The pretreatment coordinators
also indicated that they wanted further training and
information on pollution prevention. The survey
results demonstrate that Utah/Salt Lake City success-
fully communicated the message about the benefits
of pollution prevention:
8 Only 3 percent of respondents felt that
increased regulation was needed to help
promote pollution prevention.
100 percent of the pretreatment coordina-
tors indicated that pollution prevention
provides economic payback and is cost
effective.
48 percent of the coordinators indicated
that reduced liability was another benefit of
pollution prevention.
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At the metal finishers workshop, the average rat-
ing on the usefulness of the program was 3.7 on a
5.0 point scale. The overall quality of the presenta-
tion was rated as 4.5 and most participants stated
that they would attend a follow-up workshop. Some
of the participants also requested vendor lists, more
references, examples of practical applications, and
specific information for their individual companies.
The participants seemed to be most interested in
hearing about innovative technologies that have the
potential to be implemented as pollution preven-
tion strategies.
The survey of pretreatment coordinators attending
the update seminar indicated that 80 percent of the
POTWs were incorporating pollution prevention
into their pretreatment programs and 45 percent
had at least one industrial user reporting success
with pollution prevention activities. Two POTWs
responded that they had noticeable reductions in
pollutants at their plant. Although five POTWs had
awards programs in place, only the one in Salt Lake
City included pollution prevention.
One-hundred percent of the attendees at the
Pretreatment Update Seminar responded that they
had benefitted from the training and would be
interested in-further programs. Particularly, the par-
ticipants were interested in learning.more about the.
printing, dry cleaning, laboratory, photo finishing,
food service, silk screening, and waste oil industries."
When asked what information had been the most
valuable, 38 percent of the pretreatment coordinators
indicated that specific case studies ahd examples
were the most useful information and 21 percent
felt that the session on how to communicate effec-
tively with industrial users was the most valuable.
ซ Workshop announcement flyers
Workshop agenda and detailed outline of
Pollution-Prevention Workshop for
Pretreatment Inspectors held June 2-4, 1992
Pollution Prevention Skill Evaluation
administered at the beginning and the con-
clusion of all workshops to help evaluate
the success of the workshops
Final report
Nathan Guinn
Utah Department of Environmental Quality
Division of Water Quality
(801) 538-6146
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CT, MA, ME, NH, RI, VT
NJ, NY, PR, VI
DC, DE, MD, PA, VA, WV
AL, FL, GA, KY,
US, NC, SC, TN
IL, IN, MI, MN, OH, WI
AR, LA, MM, OK, TX
IA, KS, MO, NE
CO, MX, ND, SD, UT, WY
AS, AZ, CA, CNMI,
GU, HI, NV, RP
AK, ID, OR, WA
L?fel
EPA REGIONAL CONTACTS
Region 1
Pollution Prevention Coordinator (PAS)
JFK Federal Building Room 2203
Boston, MA 02203
Region 2
Pollution Prevention Coordinator (2-PPIB-OPM)
26 Federkl Plaza
New York, NY 10278 "
Region 3
Pollution Prevention Coordinator (3ES43)
841 Chestnut Building
Philadelphia, PA 19107
Region 4
Pollution Prevention Coordinator
345 Couttland Street, NE
Atlanta, GA 30365
Region 5
Pollution Prevention Coordinator (ME-19J)
77 West Jackson Boulevard
Chicago,1 IL 60604-3590
Region 6
Pollution Prevention Coordinator (6M-PP)
1445 Ross Avenue - --- - -
12th Floor, Suite 1200
Dallas, TX 75202
Region 7
Pollution Prevention Coordinator
726 Minnesota Avenue
Kansas City, KS 66101
Region 8
Pollution Prevention Coordinator (8PM-SIPO)
999 18th Street, Suite 500
Denver, CO 80202-2405
Region 9
Pollution Prevention Coordinator (H-l-B)
75 Hawthorne Street
San Francisco, CA 94105
Region 10
Pollution Prevention Coordinator
1200 Sixth Avenue
Seattle, WA 98101
PHONE
(617) 565-1155
(212) 264-1925
(215) 597-0765
(404) 347-3555
X6779
(312) 353-4669
(214)665-6580 '
(913) 551-7315
(303) 293-1471
(415) 744-2190 :
(206) 553-4072
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