2 A Look at MEPPS

  3 Integrating P2 into
     State Environment
I- „

  4 Indiana

  5 Pennsylvania


 ~ 7 NPPR's Roadmap
    for the Future

  8 State Officials
 J  Associations Want
 -  In on P2

    P4 Pilot Project


- tj Requiem for ConnTAP
 12 Calendar
United States
Environmental Protection
                                                       Office of Pollution
                                                       Prevention and Toxics
                                                       Washington, DC 20460
                                                                              September-October 1997
                                                                                  ERA 742-N-97-004
 Partnering with  the States
William H. Sanders, III
Director, EPA Office of Pollution
Prevention and Toxics

     Across the country, from corporate
     boardrooms to individual house
     holds, great strides have been made
in pollution prevention over the past seven
years since the nation's Pollution Preven-
tion Act was signed. Pollution Prevention
(P2) concepts now permeate all aspects of
our society, and new ideas for source
reduction are being explored and applied
to deal with the expanding complexity of
the environmental problems we face. State
pollution prevention programs represent a
great deal of this progress.
                                                                For almost a
                                                              decade now, EPA
                                                              has been providing
                                                              grants to states to
                                                              support their P2
                                                              efforts. The
                                                              Pollution Preven-
                                                              tion Incentives for
                                                              States (PPIS)
                                                              program provided
                                                              early seed funding
                                                              to help get state
                                                              P2 programs off
                                                              the ground. Innovative approaches and
                                                              demonstration projects showing the
                                                                              William H. Sanders, III
                                                                                    Continued on page 2
                         Pollution Prevention and Beyond
                         Linda Rimer
                         Assistant Secretary for the Environ-
                         ment, North Carolina Department of
                         Environment, Health, and Natural

                              The subject of pollution prevention
                              can be introduced this way: If we
                              don't change our direction, we may
                         end up where we are headed. For a long
                         time we recognized we were headed in the
                         wrong direction in our relationship with
                         our environment. Over the last decade,
                         however, we have risen to the occasion and
                         learned how to emphasize pollution
                         prevention over treatment and disposal.
                           North Carolina has a long and aggres-
                         sive history of promoting pollution
                         prevention. We opened the doors of the
                                     first state-run
                                     pollution preven-
                                     tion program in
                                     the nation in 1983.
                                     This office is still
                                     going strong today.
                                     We have helped
                                     thousands of
                                     public and private
                                     sector organiza-
                                     tions rethink their
                                     pollution problems  Linda Rimer
                                     in terms of pre-
                                       However, we have only begun to meet
                                     our challenges in improving environmen-
                                     tal quality. Addressing current waste
                                     management problems through P2 is only
                                                           Continued on page 2

2 Pollution Prevention News
                  September-October 1997

                             Pollution Prevention

                             and  Beyond
                             Continued from page 1
                             the first step. Pollution prevention can be
                             the building block upon which other bricks
                             must be laid to build a sustainable struc-
                             ture. Or to use another metaphor, pollu-
                             tion prevention aims only at the fourth
                             outer ring of our target. What are the
                             three inner rings?
                                The third inner ring of the target is life
                             cycle analysis, or product stewardship in a
                             manufacturing operation. Not only should
                             an organization look to prevent waste on
                             site, but it must also consider the environ-
                             mental implications of its choices from
                             cradle to grave. This consideration could
                             or should include everything from the
                             environmental impacts of extracting raw
                             materials from the earth to product use
                             and final disposal.
                                The second inner ring on our target is
                             clean technology. Pollution prevention
                             tends to function within the parameters of
                             existing operations. But even if we elimi-
                             nate all pollution associated with a
                             process, life cycle analysis tells us that
                             there still  may be environmental impacts
                             both up- and downstream of the opera-
                             tions. If manufacturers and communities
                             are going to truly minimize the environ-
                             mental impacts of their activities, they
                             must explore cleaner technologies.
                                The bull's eye for which we are aiming
                             is sustainability. Sustainability involves a
                             commitment to long-term economic
                             development as it guides us to the best,
                             holistic environmental solution.
                             Sustainability helps organizations balance
                             their needs with those of the community,
                             environment, and even future generations.
                             Like life-cycle analysis and clean technol-
                             ogy, sustainability goes far beyond the
                             impacts of the single organization. It
                             guides an  organization to make not just a
                             zero impact on the environment, but to
                             make a positive impact.
                                These four rings of the target are
                             fundamental to our future as the world
experiences continuing stresses from a
wide range of environmental issues. In
North Carolina, we are trying to move
toward sustainability. A range of efforts is
underway, from setting long-range envi-
ronmental goals to exploring environmen-
tal management systems. The target is
clear; now our aim must be true.
with  the States
Continued from page 1
advantages and opportunities of protecting
the environment through source reduction
began spreading across the nation largely
through university-based and other
technical assistance activities.
   State P2 programs have increasingly
become institutionalized within their state
environmental protection departments.
This represents a critical complement to
the early P2 assistance programs. Today,
Texas and Indiana are just two examples
of P2 programs that have grown signifi-
cantly in partnership with their state
waste, air and water programs. I applaud
this increasing effort by states to integrate
P2 into their core media environmental
programs. The continued success of state
P2 programs is dependent on their ability
to develop partnerships with their regula-
tory programs, and to help those programs
adopt source reduction techniques to solve
environmental problems.
   As we move into the 21st century, the
practices of the past will be insufficient to
deal  with the complex environmental
issues of our future. State programs, like
environmental programs at all levels of
government and in all sectors of society,
must endeavor to prevent more pollution
at the source if we are to sustain our
economic development and preserve
precious natural resources. EPA is commit-
ted to helping our P2 partners in the
states in this vital mission.

3 Pollution Prevention News
                                                                                          September-October 1997
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Performance P2: A  Look  at NEPPS
by Ken Zarker, Office of
Pollution Prevention and Recycling,
Texas Natural Resources and
Conservation Commission

     Pollution prevention professionals
     across the country are actively
     working to incorporate pollution
prevention into EPA's National Environ-
mental Performance Partnerships System
(NEPPS) to link core environmental
performance measures and program
outcomes with measurable environmental
indicators. Many P2 practitioners are
interested in the NEPPS process, since it
gives state and local governments and
tribes more flexibility to promote multime-
dia P2 integration based on their own
environmental priorities.

What is NEPPS?
NEPPS was established as part of an
effort to reform EPA policy and practices
related to oversight of state programs. The
two elements of the NEPPS are:
(l)Performance Partnership Agreements
   (PPAs), strategic documents that
   typically identify mutually established
   agency-wide priorities, core regulatory
   activities, and program-based perfor-
   mance measures.
(2)Performance Partnership Grants
   (PPGs), the delivery mechanism for this
   new approach. PPGs tie resources to
   activities, and allow states to target
   resources to their highest priorities by
   combining two or more grants into a
   single, more flexible grant.
As of June 1997, 40 states have signed
PPGs for FY97. Currently EPA program
managers are working with state environ-
mental commissioners through the Envi-
ronmental Council of States to develop core
performance measures for FY98, including
integrating pollution prevention measures.
To promote integration, efforts are being
focused on increasing the visibility and
credibility of P2 programs. These include:
establishing P2 as an agency-wide priority
in the Pollution Prevention Act; funding
pilot P2 projects to demonstrate environ-
mental results; providing technical P2
training for agency staff; encouraging
media program to invest in P2 staff; and
establishing performance measures that
focus on environmental results.

Pilot Projects
Several states have initiated pilot projects
that could be funded through the PPA/PPG
^ Oregon VOC Amnesty Project: If the
   state finds a facility operating illegally
   without a permit, it will waive the
   applicable fines. The facility must apply
   for a permit during the amnesty period
   and receive advice on how to avoid or
   decrease regulatory requirements
   through P2. Oregon estimates that it
   has reduced VOC emissions by 20-30
   tons as a result of the project.
^ Pollution Prevention in Permitting
   Project (P4): This pilot project in four
   states will demonstrate how operating
   flexibility and P2 can be integrated into
   air permits. [See page 9 below]
^- Texas Emissions Inventory Data Project:
   Texas is using the air emissions inventory
   to identify facilities at or near regulatory
   thresholds. The state will approach these
   facilities with P2 technical assistance to
   help them drop emissions significantly
   below regulatory thresholds.

Future Activities
Many environmental programs are working
on P2 outcome measures, (e.g., the number
of permits issued, the number of P2 site
visits, the number of inspections, etc.). While
this traditional "bean counting" is useful for
tracking program outcomes, there still
exists a great need to develop measures
that align program outcomes with environ-
mental results. For example, a performance-
based outcome measure could be counting
the number of permits avoided as a result of
P2 technical assistance activities.
   Future activities for continuing P2 and
NEPPS integration include expanding
public involvement in developing and
testing new core measures.
 A ten-state study, Practical
    Steps for Advancing P2
 through NEPPS, sponsored
   by the Pacific Northwest
  states and EPA Region 10,
      in affiliation with the
 National Pollution Preven-
  tion Roundtable, offers P2
    practitioners a guide to
 understanding the NEPPS
      process, strategies for
     integrating P2 into the
 NEPPS process, opportuni-
  ties for furthering regula-
      tory integration of P2
      through NEPPS, and
     performance measures
     currently contained in
several NEPPS agreements.
   To order, contact the Na-
    tional P2 Roundtable at
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4 Pollution Prevention News
                  September-October 1997
                             Pennsylvania  Strives
                             For Zero  Emissions
                                 Pennsylvania's governor, Tom Ridge,
                                 has set the following ambitious
                                 mission for the state's Department of
                             Environmental Protection (DEP): "We are
                             now encouraging individuals, local govern-
                             ments and businesses to strive for a 'zero
                             emissions' goal in their environmental
                             programs." Pennsylvania citizens, compa-
                             nies, and local governments have already
                             made significant progress in meeting this
                             goal. Twenty-five companies which re-
                             ceived Governor's Environmental Excel-
                             lence Awards in 1996 have eliminated 2.8
                             billion pounds of pollution—hazardous and
                             residual wastes, air pollution and waste-
                             water. While DEP recognizes these results,
                             it knows it must go further. In the words of
                             James Seif, Secretary of DEP, "[A] goal of
                             zero emissions requires businesses and
                             communities to make an honest commit-
                             ment to pollution  prevention at its source
                             through continuous improvement to their
                             methods of doing business."
                               Only companies aggressively pursuing
                             zero emissions goals qualify for the
                             Governor's Awards for Excellence. The St.
                             Mary's Pressed Metals firm, for example,
                             received an award for eliminating all
                             industrial wastewater discharges from its
                             Ridgeway facility. Armstrong World
                             Industries received an award for reducing
                             landfill waste by 91 percent, hazardous
                             waste by 73 percent, volatile organic
                             compound emissions by 70 percent, and
                             NOx emissions by 95 percent.

                             Letting P2 Sell Itself
                             Pennsylvania DEP believes that with the
                             proper information and cost accounting,
                             pollution prevention will sell itself to
                             corporate decision-makers without the
                             need for "regulatory flexibility." DEP  has
                             developed tools to help companies under-
                             stand environmental accounting and the
                             savings to be gained through P2. It
                             provides free computer software to sim-
plify the tasks of organizing and analyzing
cost data, calculating annual cash flow, and
measuring short and long term profitability.
DEP has reprinted and distributes EPA's
manual, An Introduction to Environmental
Accounting as a Business Management Tool.
   DEP helps its manufacturers make
money from their P2 successes. DEP staff
led a delegation of 28 Pennsylvania firms
to the world's largest international envi-
ronmental conference and trade show to
help sell successful environmental tech-
nologies, including P2 methods. The effort
matched one company with numerous
business opportunities in Latin American
and the Pacific Rim. DEP also publishes
$uccess $tories fact sheets which describe
successful P2 methods, waste stream/
chemical process reduction, P2 costs and
savings, and other benefits obtained by
companies that have reduced pollution or
reached zero emissions. One  fact sheet, for
example, details how GE Transportation
Systems, a manufacturer of diesel engines,
installed an aqueous cleaning system that
annually eliminates the emission of about
100 tons of volatile organic compounds and
the off-site disposal of 92,000 pounds of
waste. These reductions should save the
company $500,000 per year.
   DEP has integrated P2 into its overall
environmental program through the
Pollution Prevention and Site Visit
Program. The program offers suggestions
for prevention pollution after site visits by
air, water, waste and energy  experts.
Suggestions vary from site to site and may
include flow and process diagrams,
outlines of environmental management
systems, alternate disposal options,
preventive maintenance schedules,  and
financial analysis methods. DEP staff, for
example, helped the Sinter Metals firm of
Emporium, Pennsylvania develop a closed
loop wastewater system.

5 Pollution Prevention News
                                             September-October 1997
Indiana Integrates  Pollution
Prevention  From  the  Start
   Indiana's Department of Environmental
   Management (IDEM) has set a high
   priority on integrating pollution preven-
tion into its overall environmental pro-
gram, including training its entire staff in
P2 methods and benefits. IDEM's Office of
Pollution Prevention and Technical
Assistance (OPPTA) has trained over 324
IDEM employees to incorporate P2 in all
agency-administered regulatory and
enforcement programs. New employees
receive P2 training before they receive
training for their own jobs. The half-day
training course includes a video presenta-
tion, problem solving, and discussion.
OPPTA has developed an additional 14
technical seminars on industry-specific
P2 methods.
   OPPTA also has integrated P2 recogni-
tion and training into IDEM's enforcement
program. The Department is considering
using its inspectors to encourage P2 at
individual sites. While conducting routine
compliance inspection's, inspectors may
distribute on-the-spot awards for plants
or companies which have voluntarily
reduced pollution. Other companies will
receive P2 training materials. IDEM
recognizes that inspectors will require
significant training in P2 methods  for the
facilities they visit, and must be provided
with quantifiable P2 performance mea-
sures for determining progress.
   OPPTA also integrates P2 into Indiana's
environmental program through regula-
tory review. Over the past few years, staff
have analyzed over 300 proposed rules and
policies for opportunities to encourage P2.
Through this analysis OPPTA attempts to
work with rule writers from all IDEM
programs to encourage P2. OPPTA is now
beginning to review existing rules for  P2
   OPPTA has awarded eight P2 Challenge
Grants totaling $196,790 to manufactur-
ers, universities and consultants to
encourage P2. For example, Altec Engi-
neering received $25,000 to reduce styrene
emissions at its fiberglass plant by 50
percent. Millennium Environmental
received over $25,000 to teach P2 to
municipal wastewater treatment opera-
tors. OPPTA views these grants as one of
the most practical methods for encourag-
ing P2 in the state.
  Finally, Indiana is one of approximately
40 states that have entered into National
Environmental Performance Partnerships
with EPA. (See related article on page 3.)
P2 is the first priority embodied in the
Performance Partnership Agreement
between IDEM and EPAKegion 5. The P2
goals and specific objectives embodied in
the Agreement, stated in measurable
performance indicators, indicate where
IDEM will be directing its P2 efforts. (See
box below for a partial listing of P2 goals
and objectives.)
  Sample of Goals & Objectives in Indiana's
  Performance Partnership Agreement

  Goal A-1: Use pollution prevention to reduce toxic
  chemicals in environmental waste from manufacturers.

  A.I.I: Ninety percent of companies required to meet maximum achiev-
     able control technology standards under the Clean Air Act will
     comply through P2.
  A. 1.2: Fifty percent of treatment works that have a potential or real
     impact on Publicly Owned Treatment Works (POTW's) will conduct
     P2 opportunity assessments for 25 percent of their significant
     industrial users before 1999.
  A.1.3: Reduce the amount of hazardous waste shipped from operations
     other than environmental cleanup sites by 10 percent before 2000.
     (May be modified to include cleanup wastes.)
  A.1.4: Use P2 to reduce the quantity of toxic chemicals in manufactur-
     ers' environmental waste by 20 percent before 2001.
  A. 1.5: Develop and implement a comprehensive quality assurance
     program for the annual reporting of toxic chemicals through the
     federal Toxic Release Inventory.
  A. 1.6: By 2000, 75 manufacturing facilities will implement P2 recom-
     mendations of the Clean Manufacturing Technology and Safe
     Materials Institute.

6 Pollution Prevention News
                                                                                      September-October 1997
                            Carrying the  Environmental
                            Accounting Torch in  ftfew Jersey
                            Melinda Dower, New Jersey Depart-
                            ment of Environmental Protection
                successful in leading some
       ew Jersey's Pollution Prevention
       Act of 1991 mandated pollution
       prevention planning for the
approximately 700 manufacturing firms in
New Jersey required to perform Toxics
            Release Inventory (TRI)
            reporting. The Act requires
            firms to list facility and
            process-level materials,
            provide accounting data, and
            develop goals for reducing
            nonproduct output and
            chemical use. In addition,
            firms must examine a
            variety of environmental
            costs associated with their
manufacturing processes.
   The New Jersey Department of Envi-
ronmental Protection views calculation of
environmental costs as  critical to the
widespread adoption of P2 principles.
Therefore, it has asked  New Jersey
manufacturers to estimate their costs in
the following categories:
>  Storage and handling, including safety
   and health compliance
^  Monitoring, tracking and reporting
^-  Treatment
^  Transportation and disposal
>•  Manifesting and labeling
^  Permit fees
K  Liability insurance, if applicable
Rather than prescribing a detailed report-
ing format, NJDEP tries to get production
managers to think about how much time
and money they spend on the above items.
NJDEP also points out to firms how
quantifying these costs  can lead to better
business decisions. Specifically, NJDEP
describes how better cost data lead to
better pricing decisions, raw material
savings, decreased production times, and
better product mix decisions.
Evaluation Conducted
NJDEP recently completed an in-depth
evaluation of the P2 planning program.
The evaluation covered 115 firms and
included on-site plan reviews, a question-
naire on the firm's operations and motiva-
tions, an analysis of P2 goals and TRI
data, and statistical analyses to determine
which planning elements led to greater
pollution reduction.
   Overall, the study found that planning
appears to be successful in leading some
facilities to identify new P2 opportunities
and in continuing to provide an impetus to
facilities already experienced in finding P2
opportunities. However, not all aspects of
planning were equally successful and not
all facilities benefited equally. Significant
findings of the evaluation include:
^- Savings realized by facilities outweigh
   the costs of P2 planning. Depending on
   the figures used to calculate average
   savings and costs, the savings to cost
   ratios range from 3:1 to 8:1.
> Facilities conducting detailed P2
   planning realized greater savings, and
   cost-effective P2 opportunities continue
   to be plentiful.
>• Most of the 115 participating facilities
   did not complete the required cost
   accounting, leaving NJDEP unable to
   conclude that cost accounting prevented
   more pollution. Currently, many firms,
   particularly smaller ones, simply do not
   have the time or inclination to estimate
   environmental costs.
We conclude that we must continue
developing educational materials, case
studies, and outreach efforts to convince
firms of the benefits of environmental
   For further information or for a copy of
the evaluation study, contact Melinda
Dower at 609-292-1122 or via e-mail at

7 Pollution Prevention News
                                               September-October 1997
Setting Out a Roadmap
for  Future P2  Efforts
Andrea Kreiner Farrell, Chair,
National Pollution Prevention

    First formed in 1985, the National
    Pollution Prevention Roundtable is
    the largest membership organization
in the United States dedicated solely to
avoiding, eliminating and reducing
pollution at the source.
   Over the past decade, members of the
National Pollution Prevention Roundtable
have achieved substantial results in
reducing pollution entering the nation's
air, land and water resources. The
Roundtable's core constituencies of state,
local and tribal government officials, have
long been the vanguard of innovative
environmental protection efforts and at
the forefront in developing comprehensive
pollution prevention programs.
   After years of "working in the trenches,"
public and private sector pollution preven-
tion programs can now document dramatic
reductions in waste and toxic substances
as a result of their efforts. Quantitative
evaluations across the country now
attest to the effectiveness of pro-
moting pollution prevention mea-
sures as the first line of attack in
achieving superior environmental
results.  These striking results
have been achieved by making efficient use
of minimal resources.
   While significant progress has been
achieved, several issues impede the
country's ability to truly achieve a preven-
tion-based national environmental protec-
tion framework:
>• Multi-media, prevention-based environ-
   mental protection approaches are not
   routinely considered and used by
   environmental media programs in
   federal, state or local government.
^ The current federal environmental
   framework is not designed to ad-
   equately foster pollution prevention,
   provide flexibility for innovation within
   industry and within  state and local
  governments. The current laws also do
  not send appropriate environmental
  cost signals to consumers and industry,
  resulting in an inefficient use of re-
  sources and pollution.
> Even with conventional and costly end-
  of-pipe control and treatment technolo-
  gies, the nation's air, land and water
  resources are still being impacted—often
  by small difficult to manage pollution
  from dispersed and persistent sources.
fr> Funding is a major problem. Preven-
  tion-based programs are competing for
  resources with traditional well-funded
  end-of-pipe environmental programs.

Roadmap for the Future
National, state,  and local environmental
policies and programs must incorporate a
prevention-first approach to environmen-
tal management and support innovation
during regulatory and non-regulatory
interactions with business, government
and local communities. A strong network
of state, local, NGO and other pollution
prevention service providers must be
          expanded and strengthened to
          support national efforts to
          reduce pollution. In addition the
          price of goods and services must
          reflect true environmental costs.
  Two key efforts on the part of Congress
and the Administration would help define
P2 as the cornerstone of our nation's
environmental policy:
1. Assess and strengthen the Pollution
Prevention Act (PEA) of 1990. PPA
needs to be amended to reflect the dra-
matic changes that have occurred in the
field of pollution prevention since 1990. It
is no surprise the PPA has been considered
to be fairly ineffective. The Act has a
limited mandate and competes with much
better funded, end-of-pipe environmental
statutes such as the Clean Air Act, the
Clean Water Act, and RCRA. This year a
mere $5 million is being made available
                          Continued on page B

8 Pollution Prevention News
                                                                                      September-October 1997
                            State  Officials' Associations
                            Keep  P2  Fires  Burning
                                 Despite good intentions and general
                                 acceptance of the benefits of pollu-
                                 tion prevention, the major associa-
                            tions representing state air and waste
                            officials are finding that getting their
                            members' attention for pollution preven-
                            tion is an uphill battle. EPA's Media
                            Association Pollution Prevention Forum
                            brings together state environmental
                            officials from air, water, and solid waste
                            programs, and has been a major driver in
                            helping state associations integrate
                            pollution prevention into their mandates.
                            Two associations' efforts follow.

                            The Pollution Prevention/Sustainability
                            Committee of the State and Territorial Air
                            Pollution Program Administrators and the
                            Association of Local Air Pollution Control
                            Officials (STAPPA/ALAPCO) estimates
                            that approximately one-third of state and
                            local air programs nationwide are actively
                            involved in P2 activities. For the past
                            several years, however, state and local air
                            program staff time and effort have largely
                            been consumed by implementation of the
                            1990 Amendments to the Clean Air Act.
                            Still, members of the P2/Sustainability
                            Committee are determined to keep pollu-
                            tion prevention issues on the radar screens
 of their peers through regular monthly
 conference calls, panels at the semi-annual
 membership meetings and the compilation
 of regulatory integration success stories.
 The Committee believes that if air pro-
 gram staff can access P2 information at
 the locations they usually consult for
 permitting and enforcement activities,
 they will be more likely to recommend P2
 options to the sources they work with.

 The Association of State and Territorial
 Solid Waste Management Officials
 (ASTSWMO) also recognizes the need to
 promote P2, and facilitates information
 sharing through its Waste Programs
 Pollution Prevention Subcommittee. The
 Subcommittee's three task forces concen-
 trate on P2 implementation, technology
 transfer and training, and resources.
  The Subcommittee's mission is to
 integrate P2 into all waste management
 programs. Like STAPPA/ALAPCO,
ASTSWMO's Subcommittee is compiling a
 summary of P2 success stories. In addi-
tion, the Subcommittee is establishing a
network of state waste program P2
contacts, providing P2  information at
annual meetings, and preparing a concept
paper on whole facility management.
                            Future  P2
                            Continued from page 7
                            under Pollution Prevention Incentives for
                            States (PPIS), the only dedicated federal
                            funding set aside for state prevention
                            activities. This amounts to less than one
                            percent of federal grant funds to states for
                            environmental programs. P2 deserves a
                            larger percentage of funding.
                            2. Incorporate a prevention-first
                            approach, in EPA's ambitious National
                            Environmental Performance Partner-
                            ship System (NEPPS), EPA's innovative
                            version of block grants to the states. The
                            NEPPS program has tremendous potential
to leverage more resources and commit-
ment to P2 nationwide. It is important for
EPA to include strong prevention activities
and incentives into the agreements signed
by the state environmental agencies.
While we work on cross cutting strategies,
such as amending the PPA of 1990, we
must help make P2 a key component of the
existing system.
  The Roundtable will continue to be an
aggressive advocate for pollution preven-
tion and its practitioners and will continue
to raise the profile of prevention in the
national discussion of environmental

9 Pollution Prevention. News
                                              September-October 1997
P4  Pilot Project  Injects  Pollution
Prevention  into  Air  Permits
Dave Dellarco, EPA Region 10

     EPA developed the Pollution Preven-
     tion in Permitting Pilot (P4) Project
     in an effort to find an effective way
to promote pollution prevention within the
Clean Air Act. Another goal ,of the project
is to advance the Clinton Administration's
"reinvention" initiative for flexible,
facility-wide air permits.
  The P4 permits developed to date have
pioneered the introduction of pollution
prevention as an important tool in prepar-
ing flexible, streamlined, and environmen-
tally beneficial air permits. These permits
enhance operational flexibility through
tools such as advanced minor New Source
Review (NSR) and streamlined compliance
demonstration. They also show that
measurable pollution prevention progress
can generate unique opportunities for
providing sources with operational flexibil-
ity. For example, several P4 permits
include a mechanism for offsetting emis-
sions increases with emissions reductions
through P2.
   Because changes in existing control
technology can trigger minor NSR and Title
V permit modifications, it can be less costly
for a source, and less burdensome for a
source and permitting authority, to use P2
offsets rather than control technology
offsets. For example, EPA estimates that
Searle Pharmaceutical can earn up to $1
million for every day that it does not need
to wait for a permit to produce a new drug.
   In addition to creating greater flexibil-
ity, P4 permits also realize pollution
prevention gains through the use of
emissions caps. Annual facility-wide caps,
plant-wide applicability limits, and daily
stationary source caps all serve as incen-
tives for sources to engage in pollution
prevention. At a minimum, these caps
ensure environmental "neutrality" over
the course of the permit term. However, if
these caps remain fixed over time, the
permits will actually reduce pollution if
the source experiences economic growth.

States Reap Multiple Benefits
State permitting authorities that have
participated in P4 projects have already
realized numerous benefits. First, provid-
ing greater regulatory flexibility for a
source often results in less time and
paperwork for the permitting authorities.
Further, sources can become more satis-
fied with the permitting process and more
willing to comply with permit terms.
   Some state permitting authorities
credit P4 with an enhanced working
relationship with air pollution sources. For
example, Ray Bishop of the Oklahoma
Department of Environmental Quality
believes that his agency's reputation
among the regulated community has
improved substantially. Mr. Bishop and
other "P4 alumni" are looking forward to
applying lessons learned from their pilot
projects to additional sources in the future.
   Communicating such "lessons learned"
to all levels of government and making
pollution prevention a routine component
of Clean Air Act permitting are important
future goals of the P4 Project. To help
ensure a broad distribution of P4 experi-
ence and benefits, new P4 projects are
being developed in different EPA regions
across the country. In addition, several
sources which have already participated in
a P4 project have expressed interest in
transferring their knowledge to facilities
under different permitting authorities.
Educational materials and P4 training
workshops are being developed for both
permit writers and state and local air
program managers. These workshops, in
combination with continued pilot projects,
will help guarantee that an increasing
number of state and local permitting
authorities will experience the many
benefits of P4.

 10 Pollution Prevention News
                                                                                       September-October 1997
                             U.S.  Counties Make
                             Pollution  Prevent ion  Work
Thuriton County, WA staff helps a
local print shop outline pollution
prevention opportunities.
     The National Association of Counties
     (NACo), which represents the
     country's 3,000 county governments,
 is playing a role in advancing local P2
 efforts. As a national organization, NACo
 provides a link across  counties and between
             counties and national P2
               Counties are well posi-
             tioned to lead P2 efforts. In
             providing such services as
             garbage collection and
             disposal, drinking water
             purification, and sewage
             treatment, they are often
             the first point of contact
             between citizens and public
             health and environmental
             officials. This  same proxim-
             ity to residents and busi-
 nesses means that counties are well
 positioned to distribute P2 information
 and assistance. County workers such as
 fire inspectors, permitting and licensing
 officers, health officials, and zoning and
 planning board members have numerous
 opportunities to promote P2. Moreover, in
 their capacity as building owners and
 managers, fleet operators, and procure-
 ment agents, county governments can
 incorporate P2 into internal operations
 and provide the benefit of their experience
 to the community.
   With increased devolution of responsi-
 bility from the federal to the  state and
 local levels and greater regulatory flexibil-
 ity, counties have more opportunities to
 serve as leaders in the pollution preven-
 tion field. However, county officials need
 information and assistance — on how to
 staff and finance programs, and how to set
 priorities and measure progress.

Closing the Info  Gap
 NACo wants to help close this information
 gap. One of the best sources of information
 for counties is other counties. County
 officials benefit greatly from learning how
 their peers have resolved similar prob-
 lems. NACo has a variety of mechanisms
 for helping counties link with each other.
 These include two major and two minor
 conferences per year, regional seminars
 and trainings, vidoeconferences, state-
 level meetings, a bi-weekly newspaper
 with a circulation of 35,000, a quarterly
 environmental newsletter, a host of
 publications, and telephone referrals.
   To provide counties concrete examples
 of how pollution prevention can be put into
 practice, NACo published Preventing
 Pollution in our Cities and Counties: A
 Compendium of Case Studies, that has
 been disseminated to over 5,000 local
 governments and individuals. In conjunc-
 tion with the National Recycling Coalition,
 NACo co-wrote Making Source Reduc-
 tion and Reuse Work in Your Commu-
 nity: A Manual for Local Governments.
 We will soon be publishing County Case
 Studies: Flushing our Problems with
 Septic Tanks.
   NACo also has numerous forums for
 county leaders to meet with each other in
 small groups. For example, for our new
 Environmentally Preferable Purchasing
 Project, we have formed an advisory
 committee of local elected officials,
 environmental staff, and procurement
 officials, and established a series of
 county-based pilot projects. Through
 these pilots, participating counties can
 connect with other counties researching
 and testing environmentally preferred
 purchasing in eight areas: automobile
 and heavy equipment; cleaners; pesticides
 and lawn chemicals; office supplies;
 paints; construction and demolition;
 buildings design and energy efficiency,
 and printing. By "buddying" pilot commu-
nities with other local governments,
pioneers are given the support and
information they frequently lack when
beginning a new program. NACo is
developing a "starter kit" to help counties
nationwide embark on similar efforts.

11 Pollution Prevention News
   September-October 1997
Requiem  for a  State TAP
     The decade-old ConnTAP — Connecti-
     cut Technical Assistance Program —
     closed its doors on July 1,  1997, a
victim of legislative budget cuts. Over the
years, ConnTAP answered thousands of
telephone hotline requests, issued match-
ing grants and loans, and published
reports, case studies, and fact sheets.
Perhaps its most visible effort was a Site
Visit Program that helped 150 Connecticut
companies identify ways of operating more
efficiently while reducing the amount of
hazardous emissions they generate.
   Operating with only five retired
engineers, the free Site Visit Program
targeted small and medium-sized busi-
nesses.  ConnTAP estimated that its
recommendations to businesses with
which it worked would result, if fully
implemented, in annual reductions of 115
million  gallons of wastewater, 3 million
pounds  of air emissions (volatile organic
compounds), and 11 million pounds of
hazardous waste. In follow-up  surveys,
ConnTAP's clients have indicated that
they have implemented about half of
ConnTAP's recommendations.
   Among ConnTAP's other efforts was a
Materials Exchange to provide  businesses
with an alternative to the disposal of
unwanted materials. The exchange
focused on materials that would otherwise
require  disposal as hazardous waste.
Listings of materials offered and materials
needed  were published in ConnTAP's
quarterly newsletter.
   According to Rita Lomasney, Hazardous
Waste Program Director, when  ConnTAP
started  out in 1987, "not many  people were
convinced that pollution prevention could
deliver  on its promise to simultaneously
reduce waste generation and costs."
Thousands of cases later, Lomasney
believes that "pollution prevention has
delivered on its promises, despite the fact
that it is has gotten harder, not easier, to
find ways to reduce waste. Early on, better
housekeeping and simple operating
modifications yielded remarkable results.
Now, however, companies are finding that
capital and technology are needed to
produce additional waste reductions."
  Lomasney noted that Connecticut's
manufacturing sector has been in decline
and that small and medium-sized compa-
nies are doubly burdened by limited
resources that make it difficult to
comply with regulations and stay
current with regulatory and
technology changes. "What's sad
is that Connecticut's manufactur-
ing companies need more, not
less, assistance. The fact that
ConnTAP was a nonregulatory
program enabled us to gain the trust of the
businesses we served and increased our
effectiveness. As of July 1, 1997, there is
no nonregulatory state agency able to
provide Connecticut companies with
environmental assistance."
   Dozens of Connecticut companies rose
to the defense of ConnTAP in the recent
legislative session, although to no avail.
Carol Violette of the Delta Rubber Com-
pany in Danielson, CT wrote, "Because of
ConnTAP's assistance, our company was
able to identify a number of practical and
economical ways of reducing and, in some
cases eliminating, waste generation at the
plant." Lomasney laments the fact that
funding was cut off despite ConnTAP's
record of achievements, and advises other
TAPs to investigate fee for service possi-
bilities to avoid a similar fate.
   ConnTAP's demise has elicited both
surprise and regret from counterparts in
state and federal programs. Lena Ferris,
who manages state pollution prevention
grants for EPA's Pollution Prevention
Division, commented, "We and the people
of Connecticut will certainly miss
ConnTAP's hard work and commitment to
pollution prevention in the coming years.
The unexpected precariousness of the
program's financing brings home to all of
us how important it is for technical
pollution prevention assistance programs
to be part of the mission of state environ-
mental agencies in order to ensure the
sustainability of these programs."
Editorial Staff:
Ernestine Jones-Lewis,
Wendy Campbell
Gilah Langner
Julie Saulnier
Free Hand Press, Layout

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 12 Pollution Prevention News
                                                                                             September-October 1997
 November 12-14

 Allanlo, GA

 December 8-10
 Providence, Rl

NPPR Fall Workgroup Conference
National Pollution Prevention
Tel: 202-466-3908
es.inel.gov/nppr Northern
GA Pollution Prevention/
Green Manufacturing Conference
for Industry and Business
NEPPS Performance Partnership

The Environment 2000 Institute:
Proactive Environmental Strategies
for Forward-Thinking Organizations
EPA Region 4
EPA Region!,

Government Institutes
EPA Region 4
Katrina Kipp

Jesus Ferro
Tel: 301-921-2345

  EPA's Office of Pollution Prevention and Toxics has awarded over $1
  million in grants to maintain four existing regional pollution prevention
  information centers and create five new centers. These regional centers
  will be coordinated as part of a national Pollution Prevention Informa-
  tion Network. The network will improve the quality, standardization,
  and accessibility of pollution prevention information, while avoiding du-
  plication of effort.
     The regional centers will supply and update information for training
  and operation manuals, case studies, and technical aids. Users are expected
  to include states, as well as businesses and other interested parties. Each
  regional center will establish an advisory committee of state representa-
  tives to ensure the relevance and accuracy of the information it provides.
  For further information, contact Beth Anderson, EPA, at tel: 202-260-2602;
  fax: 202-260-0178, or e-mail: Anderson.Beth@epamail.epa.gov.
                                                     P2 Information Center Web Sites

                                                     Waste Reduction Resource Center
                                                     (EPA Regions 3&4)
                                                     Great Lakes Regional Pollution
                                                     Prevention Center (EPA Region 5)
                                                     University of Texas at El Paso
                                                     (EPA Region 6) www.utep.edu/im3/p2/
                                                     Pacific Northwest Pollution
                                                     Prevention Resource Center
                                                     (EPA Region 10) pprc.pnl.gov/pprc/
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