United States
         Environmental Protection
Office of Pollution
Prevention and Toxics
Spring 1996
          Pollution Prevention
          Incentives for States (PPIS)
          Grant Program
          Assessment Study
In • »
                     AA Recycled/Recyclable
                     C7 Printed on paper that contains at least 20 percent postconsumer fiber.

Table  of Contents
CHAPTER I:  Introduction
          A.  Background on PPIS Grant Program	6
          B.  Purpose and Scope of Report 	7
          C.  Methodology and Data Sources	8
          C.I Limitations	9
          D.  Outline of Report	9

CHAPTER II:  Allocation of PPIS Grant Awards
          A.  Organizations Funded	11
          B.  Types of Programs Funded	12
          C.  Distribution of Grant Funding by EPA Region and State	14

CHAPTER III:  Summary of PPIS Grant Activities
          A.  Targeted Groups	18
          B.  Range of Activities Conducted	18
          B.I Education and Outreach	19
          B.2 Data Collection and  Research	20
          B.3 Infrastructure	21
          B.4 Technical Assistance  and Technical Training	23
           ,5 Pilot Programs and Demonstration Projects	24
          B.6 Awards and Recognition	25
          B.7 Regulatory Integration	25

CHAPTER IV:  Measurement and Evaluation
          A.  Monitoring and Evaluating EPA Media Program Grants	29
          B.  State Strategies to Measure Effectiveness	30
          B.I Overall Evaluation	31
          B.2 Evaluation of Specific Services	32
          B.3 Measures of Activity  Level	33
          C.  Improving Future Measurement Efforts	34

                  Table of Contents  • 1

CHAPTER V:  Case Studies

           A. Summary of Findings	38

           A.1 Building a Pollution Prevention Infrastructure	38

           A.2 Implementing Innovative Approaches to Pollution Prevention	40

           A.3 Establishing and Expanding Pollution Prevention Programs	40

           A.4 Providing Resources for Technical Assistance and Training	41

           A.5 Fostering Information Sharing and Communication	41

           A.6 Conclusion	42

           B. Case Studies	43

           B.I Delaware	43

              Overview	43

              Activities Funded by PPIS Grants	45

              Analysis of PPIS Impact	49

              Program Future	50

           B.2 New Hampshire	52

              Overview	52

              Activities Funded by PPIS Grants	54

              Analysis of PPIS Impact	58

              Program Future	59

             3 New Jersey	61

              Overview	61

              Activities Funded by PPIS Grants	63

              Analysis of PPIS Impact	66

              Program Future	67

           B.4 North Carolina	68

              Overview	68

              Activities Funded by PPIS Grants	70

              Analysis of PPIS Impact	71

              Program Future	72

           B.5 South  Dakota	73

              Overview	73

              Activities Funded by PPIS Grants	74

              Analysis of PPIS Impact	77

              Program Future	78

                     Table of Contents • 2

          A.  Ranked Distribution of Total Funding by State	82
          B.  Funding Breakdown by State	84
          C.  Funding Breakdown by Grant	89
          D.  Groups Targeted by PPIS Grantees	96
          E.  List of Contacts	98
                   Table of Contents

              Chapter  I
          As an initial step in EPA's long-term strategy to evaluate the
          Pollution Prevention Incentives for States (PPIS)1 grant
          program, this report documents the full range of activities
          funded by the PPIS grant program during the first five years.
          All of the information presented in this report is based solely
on interviews or materials prepared by the grantees themselves. This report
does not attempt to compare or rate state programs, nor is the study
designed to evaluate the effectiveness of specific activities funded by the
grant. This report represents an accounting of how grantees used EPA
funds to stimulate and enhance pollution prevention awareness and initia-
tives throughout the country.
   In 1994, the General Accounting Office (GAO) studied 107 state pro-
grams that were funded, in part, by PPIS funds to assess how well these
programs are implementing the federal pollution prevention strategy.2
While it is not EPA's formal response to the GAO study, this report does
attempt to answer similar questions to those raised by GAO, such as:
  Are states using PPIS  funding to support activities that promote pollu-
  tion prevention?
  How are states combining regulatory and voluntary approaches towards
  pollution prevention?
  Do PPIS grants support the establishment of sustainable pollution pre-
  vention programs at the state level?
   The conclusions from this report and GAO's report may differ given
the different people interviewed. While the GAO report surveyed contacts
from state programs from a list provided by the National Pollution
Prevention Roundtable,  this study draws on material obtained from the
grant recipients themselves. Furthermore, the GAO report failed to link
the different activities at the pollution prevention programs to specific
funding sources. For example, states may provide recycling assistance, but
         Introduction  • 5

this activity is not necessarily fund-
ed with PPIS funds. This report
only looks at the PPIS-funded por-
tion of state programs to answer
the above-mentioned questions.
   The remainder of this chapter
presents background information
on the PPIS grant program,
describes the purpose and scope of
the study, recounts the methodolo-
gy and data sources used, identifies
study limitations, and overviews
the contents of the remainder of
the report.
      Background on
      PPIS Grant
   EPA established the PPIS grant
program with the philosophy that
states should play a primary role in
encouraging industry, small and
medium-sized businesses, local gov-
ernments, and the public to shift
priorities from pollution control to
pollution prevention. Because
states have more direct contact
with generators and hence are more
aware of their needs and problems,
EPA believes that state-based envi-
ronmental programs can make a
unique contribution to the national
effort to promote source reduction.
   At the outset of the program in
1989, EPA established several
goals, including:
  Empowering states to build a pol-
  lution prevention infrastructure;
• Learning from and building
  upon innovative means of imple-
  menting pollution prevention at
  both state and facility levels;
• Providing resources for pollution
  prevention technical assistance
  and training;
• Supporting states in establishing
  and expanding pollution preven-
  tion programs; and
• Fostering federal and state informa-
  tion-sharing and communication.
   From these broad goals, EPA
developed specific criteria to  evalu-
ate grant proposals received from
states. According to these criteria,
state grant proposals should:
  Target areas for risk reduction
  and integrate these areas in the
  state's overall pollution preven-
  tion goals and strategies;
• Identify multimedia opportunities;
  Leverage pollution prevention
  activities of other pollution pre-
  vention programs or organiza-
  tions in the state;
  Identify measures of success;
• Identify a plan for dissemination
  of results; and
  Identify plans for funding the
  pollution prevention program
  over time.
   The PPIS grant program  has
evolved to meet changing needs
and priorities. The initial grants
awarded in 1989 funded state pro-
grams to  implement source reduc-
tion and  recycling programs. After
the passage of the 1990 Pollution
Prevention Act, EPA changed the
name of the program from the
Source Reduction and Recycling
Technical Assistance (SRRTA) pro-
gram to the Pollution Prevention
Incentives for States (PPIS) pro-
gram. The new name reflects EPA's
increased emphasis on pollution
   In 1992, EPA began encourag-
ing states to build upon and
expand their existing pollution pre-
vention programs. To receive addi-
tional funds under PPIS, states
would need to show EPA that they
were either:
• Integrating pollution prevention
  into state regulatory programs; or
  Establishing a statewide pollution
  prevention  infrastructure involv-
  ing all levels of state government,
  including promoting interagency
  pollution prevention initiatives
  with state departments of agricul-
  ture, transportation, energy, com-
  merce, and development, and
  defining the roles of county and
  municipal governments.
   As most states have now devel-
oped basic pollution prevention
programs, EPA has shifted respon-
sibility for implementing the grant
program from EPA Headquarters
to the EPA Regions. This shift
gives Regions flexibility to focus
resources on local priorities. Some
regional priorities include:
• Nonindustrial sectors. To build
  a strong pollution prevention
  infrastructure, some Regions
  encourage applicants to establish
  partnerships with state agencies
  in nonindustrial sectors such as
  agriculture, energy, health, and
  Indoor air quality.  Because
  people spend as much as 90
  percent of  their time indoors,
  some Regions encourage states
  to demonstrate solutions to
  indoor  air quality problems in
  both industrial and nonindus-
  trial settings.
  Environmental justice.
  Preventing pollution in low-
  income and minority neighbor-
  hoods is a priority  for several
  EPA Regions. These Regions

  give extra weight to grant
  proposals that plan to integrate
  pollution prevention and
  environmental justice.

   As the PPIS grant program
matures, EPA will place increasing
emphasis on evaluation—determin-
ing which program components
might be most effective in achieving
pollution prevention, and establish-
ing measures of program effective-
ness. This report represents a first
step in measuring pollution preven-
tion progress by documenting grant-
funded pollution prevention activi-
ties underway in the  states. Over the
next few years, EPA will continue to
measure  and evaluate program effec-
tiveness.  Specifically,  EPA plans to
offer technical assistance to the
states in pollution prevention mea-
surement and narrow PPIS award
criteria to fund the development of
measurement methodologies in fis-
cal year (FY) 1996. As EPA awards
these grants, the Agency will devel-
op criteria to assess the success of
different measurement methodolo-
gies. EPA will then use these criteria
to evaluate the impact of the PPIS
grant program in preventing pollu-
tion nationwide.
   Measuring program effectiveness
and pollution prevention progress
has been a persistent problem for
state pollution prevention programs.
Finite resources, the inherent diffi-
culty in developing measurement
methodologies, and limited data
have constrained the ability of the
states to measure progress. For a
more in-depth look at the ways EPA
traditionally evaluates program effec-
tiveness and the difficulties in mea-
suring pollution prevention, please
see Chapter IV on Measurement.
B.  Purpose  and
     Scope of Report

   This report marks the first time
that EPA has taken a comprehen-
sive look at state pollution preven-
tion activities funded by the PPIS
grant program. Given that the
states themselves have only just
begun to measure their progress,
the purpose of this report is to
identify what is happening in the
states right now. The next three
chapters of this report seek to
answer the following questions:
• How much money has EPA
  invested in state pollution pre-
  vention programs and how has
  this funding changed over time?
  What types of organizations have
  received funding and where are
  they located?
• Are the funded programs regula-
  tory or voluntary in nature?
  Redefining the  State/EPA Grant
  As part of the Agency's commitment to contin-
  ually improving government, EPA has estab-
  lished the Performance Partnership Grant
  (PPG) program. This program will enable
  states and tribes to combine funds from two or
  more categorical grants (including PPIS) into
  a multi-program grant or PPG. Benefits of
  PPGs include:
  • Increased flexibility. States and tribes will
    have the flexibility to address their highest
    environmental priorities across all media
    and to establish resource allocations based
    on those priorities, while  continuing to
    address core program commitments.
  • Improved environmental  performance.
    States and tribes can more effectively  link
    program activities with environmental goals
                   and program outcomes as well as develop
                   innovative pollution prevention, ecosystem,
                   and community-based strategies.
                •  Administrative savings. Recipients and
                   EPA can reduce administrative burdens
                   and costs by greatly reducing the numbers
                   of grant applications, budgets, workplans,
                   and reports.
                •  Strengthened partnerships. EPA will
                   develop partnerships with states and tribes
                   where both parties have the same environ-
                   mental and program goals and deploy their
                   unique resources and abilities to accom-
                   plish these goals.
                EPA will begin piloting the PPG program in

• What return did EPA receive on
  its investment (measured by
  what activities the grantees
• How many people were the
  grantees able to  reach?
• How are grantees currently eval-
  uating their programs?
• Are any grantees measuring actu-
  al reductions in  pollution?

   The final chapter—case studies
of five state pollution prevention
programs—examines the role of
PPIS funding in each of these
states and places PPIS funding in
the greater context of state pollu-
tion prevention activities. The
chapter also evaluates whether or
not EPA achieved, in each of these
states, the objectives  established at
the outset of the grant  program.

   This study does not attempt to
compare state programs or rank
states in any manner. Descriptions
of different programs are  provided
to illustrate alternative models of
implementing pollution prevention
programs. This report is not intend-
ed to rate  state programs, neither
does it evaluate the effectiveness of
specific activities (such  as a newslet-
ter, manual, or training session)
conducted under the grant. Rather,
EPA seeks to narrate  grant activities
as reported by the  grantees.

   The report covers SRRTA and
PPIS grants awarded from 1989
through 1993. Other EPA pollu-
tion prevention sector grants were
excluded,  such as the National
Industrial Competitiveness  through
Efficiency: Energy, Environment,
and Economics (NICE3);
Agriculture in Concert with the
Environment (ACE); Risk
Reduction through Pollution
Prevention (R2P2); Municipal
Water Pollution Prevention
(MWPP); and grants awarded
through EPAs media programs. In
addition, because grants awarded in
FY94 were in the early stages of
implementation during the data-
collection phase of this study, they
were not included.
Methodology and
Data Sources
   EPA employed the following
methodology to collect information
on PPIS-supported activities. For
Chapters II through TV, which exam-
ine PPIS-funded activities nation-
wide, EPA conducted comprehensive
interviews with each grant recipient.
These interviews enabled EPA to cat-
alogue the activities supported by the
grant, accomplishments, and barriers
to implementation. Where possible,
EPA collected quantitative measures
of activity level for each area of fund-
ing. For example, EPA collected data
on the number of audits conducted,
case studies developed, training ses-
sions held, and other parameters.
EPA also asked questions designed to
elicit information on the impact of
these activities. For example, if states
conduct waste audits for industrial
facilities, EPA asked if they track
whether or not the facilities actually
implement state-recommended pol-
lution prevention measures.
Furthermore, for those states that do
track whether or not the facilities
implement recommendations, EPA
also asked the states to describe the
fiscal and environmental impact of
implementing the recommendations,
as reported by the facilities. To deter-
mine why states might not conduct
such follow-through activities, EPA
asked states to describe the barriers to
facility followup. In addition to the
quantitative measures described
above, EPA asked grant recipients to
describe examples of successes they
had in implementing their grants.
The interviews also tracked the
industries or sectors (e.g., electroplat-
ing, agriculture, small businesses)
that different grant activities targeted.
   Before conducting the inter-
views, EPA reviewed all available
in-house information contained in
EPAs Pollution Prevention
Information Tracking System
(PPITS). This system contains data
from the grant application and
semiannual progress reports,
including award amount, activities
funded, and accomplishments.
EPA also reviewed, where available,
final reports and other documenta-
tion that grant recipients supplied.
   Five Regions participated in the
development of the case studies.
The pollution prevention coordina-
tor from each  of these Regions
selected a representative state from
their region. For each case-study
state, EPA reviewed in-house infor-
mation and conducted comprehen-
sive interviews to assess the impact
of PPIS grant funding. In these
interviews, EPA used a standard list
of questions to assess:
• The organizational structure  of
  each program;
• The current budget and sources
  of funding;
• Pollution prevention legislation
  and strategies in place;
                                              Introduction • 8

  The activities accomplished with
  PPIS funding;
  The impact of PPIS funding on
  developing a self-sustaining
  program, integrating pollution pre-
  vention into the regulatory pro-
  gram, and evaluating success; and
  The future direction of the
C.1  Limitations

   The reader should keep in
mind some limitations when con-
sidering the findings presented in
this report. One limitation relates
to the type of data that EPA col-
lected. Not all states track the same
information. Some states have
much more detailed information,
on both the number of activities
supported and the impacts of these
activities on preventing pollution.
For example, one state might col-
lect detailed data on the number of
workshops sponsored, record the
exact number of attendees, and fol-
low-through to determine whether
or not the attendees actually imple-
mented any pollution prevention
actions as a result of the workshop.
Other grant recipients, however,
may track only the number of
workshops and a range of atten-
dees.  Implications of this situation
are twofold. First, the report might
underestimate the number of activ-
ities supported by PPIS funds.
Second, the report presents a quan-
titative measure as a range of activi-
ty because EPA does not have exact
numbers. Additional data limita-
tions include the following:
•  Four states representing six
   grants could not be interviewed
   for the study due to scheduling
•  Some progress reports  and final
   reports could not be obtained;
•  Some of the grants were still in
   progress  at the time  the study
   was concluded, and  thus all tasks
   were not completed.
D.   Outline of Report

   The remainder of this report
presents EPA's assessment of the
PPIS grant program, and it is
organized as follows:
  Chapter II provides an overview
  of the distribution of PPIS funds
  from 1989 to 1993. To frame
  the context of PPIS funding, the
  chapter also briefly examines
  other state pollution prevention
  funding sources, such as state
  general funds and hazardous
waste fees. The distribution of
grant funding across EPA
Regions, states, and organization
type is also described.
Chapter III identifies the types
of businesses and industry sec-
tors that the state programs tar-
get, and summarizes the activi-
ties that the PPIS program sup-
ports (e.g., workshops, demon-
stration projects, clearinghouses)
and the types of programs sup-
ported (e.g., voluntary, regulatory).
Chapter IV examines how
grantees measure the effective-
ness of their programs, including
the actions they take to follow
up on their program activities
(e.g., audits, training) to see if
facilities actually implement pol-
lution prevention measures. The
chapter also describes the barri-
ers and problems that grant
recipients face in conducting fol-
lowup activities.
Chapter V illustrates how the
PPIS grants supported pollution
prevention  activities in five states.
These in-depth case studies exam-
ine how the PPIS grants were
integrated into the states' pollu-
tion prevention programs and
highlight the effectiveness of the
grants in building infrastructure
and self-sustaining programs.
1 EPA initially called the grant program the Source Reduction and
 Recycling Technical Assistance (SRRTA) program. Throughout
 this report, PPIS refers to both PPIS and SRRTA grants.
                  2 General Accounting Office. 1994. Pollution prevention: EPA should
                   reexamine the objectives and sustainability of state programs.
                   GAO/PEMD-94-8. January.


            Chapter  II
                 Allocation of
                 PPIS  Grant
        Since the inception of the grant program in 1989, EPA has
        awarded approximately $24 million through 1993. Grant recipi-
        ents and other partners (e.g., local governments, industry) have
        supplied over $16 million in matching funds for a total funding
        amount of approximately $40 million.
   This chapter overviews the distribution of PPIS funds from 1989 to
1993 and is divided into the following sections:
• Organizations funded;
• Types of programs funded; and
• Distribution of grant funding by EPA Region and state.
A.   Organizations

  Applicants eligible for PPIS
funding include:
• The 50 states;
• The District of Columbia;
  The U.S. Virgin Islands;
• The Commonwealth of Puerto
  Any territory or possession of
  the United States;
  Any agency or instrumentality of
  the states, including state univer-
  sities; and
• Federally recognized Indian tribes.
   Although local governments,
private universities, private non-
profits, private businesses, and
individuals are ineligible for PPIS
funding themselves, EPA strongly
encourages them to team up with
eligible applicants in developing
   Over the 5-year grant period,
PPIS funds were distributed to four
categories of recipients:
  State environmental/health
  agencies, such as state depart-
  ments of environmental quality
Allocation of PPIS Grant Awards  "11

  and protection and state health
  Other state agencies, such as
  state departments of education;
  Universities that manage
  research-oriented grants, work
  through extension programs, or
  operate their own technical assis-
  tance programs;
• Indian tribes, which include the
  Navajo EPA, the All Indian
  Pueblo Council, and many indi-
  vidual tribes; and
• Other nonstate groups or orga-
  nizations, such as the New
  England Waste Management
  Officials Association (NEW-
  MOA), the District of
  Columbia, and the American
   State environmental and  health
agencies received the most funding
by far (see Exhibit II-1); their 5-
year total reaches close to $18 mil-
lion, or 71 percent of all PPIS
funds. Universities received the sec-
ond greatest portion of grant
monies (approximately $3 million,
or 13 percent of total funds).
Other state agencies received 7
percent of total funding, and
Indian tribes and other nonstate
organizations (such as regional
organizations and territories)
received 3 and 6 percent of PPIS
grant funds, respectively.
   The distribution of PPIS  fund-
ing to these categories of recipients
fluctuated somewhat  over time.
State environmental and health
agencies, however, accounted for
the majority of all grant monies
issued each year.  In 1989, PPIS
grants were distributed almost
exclusively to state environmental
and health agencies with only one
exception: the New England Waste
Management Officials Association
received a $305,525 grant to devel-
op the Northeast States Pollution
Prevention Roundtable. Over time,
other organizations began to receive
more funding. For example, in
1990, university programs received
a substantial quantity of funding
and have continued to receive PPIS
monies every year since. Not until
1992 did Indian tribes begin to
receive funding to establish pollu-
tion  prevention programs. In 1993,
the amount of grant monies award-
ed to tribal organizations more than
doubled from the  previous year and
exceeded the funds issued to all
other nonstate groups. In addition,
the number of tribal organizations
receiving PPIS funds increased from
one tribe in 1992  to seven in 1993.
B.   Types  of
      Programs Funded

   As described in Chapter I, one
of the initial goals of the grant pro-
gram was to fund states to provide
technical assistance and outreach to
targeted industries on pollution
prevention. EPA designed the pro-
gram to concentrate early efforts on
publicizing pollution prevention,
believing that businesses would
reduce waste voluntarily once they
learned the benefits and cost sav-
ings  associated with pollution pre-
vention. Thus, voluntary programs
that  either provide their services
(e.g., technical assistance audits,
training, presentations) upon
request or offer them to industry
and the public on an elective basis
received the most funding. These
programs accounted for 62 percent
of PPIS funds awarded between
1989 and  1993.
   As state programs gained expe-
rience, they discovered that to
build successful programs they
 Exhibit 11-1
 Distribution of PPIS Funds, by Organization
             State Environmental/
             Health Agencies

             Other State Agencies


             Indian Tribes

                                    Allocation of PPIS Grant Awards • 12

would need to better educate their
own regulatory staff. By training
state regulatory staff, many states
believed that they could provide
pollution prevention incentives
through regulatory mechanisms.
Thus, many programs contained
both voluntary and  regulatory
elements. For example, the
Connecticut Department of
Environmental Protection (DEP)
used its 1991 PPIS grant to fund
several outreach activities, such as
making presentations to industry,
developing fact sheets, and training
permit writers in pollution preven-
tion. Over a quarter of PPIS funds
supported these combined
programs. Since most grantees
combined regulatory integration
projects with voluntary activities,
strictly regulatory programs
received only 4 percent of total
grant monies.
   PPIS monies also funded
research programs (4 percent). For
example, the Iowa Waste Reduction
 Exhibit 11-2
 Distribution of PPIS Funds, by Program Type


Center studied the impact of toxic
waste on stream life as part of a pro-
ject to identify and reduce toxic
industrial discharges to small waste-
water treatment systems. Exhibit II-
2 shows the distribution of PPIS
grants among various program types.
   From 1989 to 1993, funding
allocated for regulatory integration
 Exhibit 11-3
 Nature of PPIS Grants Over Time,  1989 Through 1993
              1989       1990        1991
   projects increased (see Exhibit II-
   3). In 1993, a total of $516,000
   was allocated for four regulatory
   projects (e.g., attempts by the
   Louisiana Department of
   Environmental Quality [DEQ]  to
   incorporate pollution prevention
   into inspections), while in 1989,
   only one grant of $300,000 was
   allocated for similar projects.
       Athough the 1993 allocation
   supporting regulatory integration
   initiatives is not substantially high-
   er than the 1989 award, the  1993
   grants were awarded to multiple
   projects across several states rather
   than to one program. The trend
   over the first five years suggests  a
   movement away from strictly vol-
   untary or technical assistance and
   outreach programs and toward
   increased regulatory integration.
   This trend continued throughout
   1994 and 1995: nearly 20 percent
   of PPIS grants awarded in each  of
   these years supported regulatory
   integration projects.

                                    Allocation of PPIS Grant Awards  • 13

C.   Distribution of
      Grant Funding by

   Exhibit II-4 illustrates the total
PPIS funding by year. EPA funding
peaked in 1990, when over $7 mil-
lion in grant monies were awarded.
Funding was more moderate in
1991  (approximately $5 million), a
trend  that continued in 1993. This
gradual increase in funding over the
1989  level was, however, broken in
1992, when only $2,565,000 was
awarded. During 1992, EPA
reduced the PPIS grant funding to
support pollution  prevention in
other  targeted sectors in the states.
For example, EPA awarded
$450,000 to five states to support
pollution prevention at publicly
owned treatment works (POTWs).
   Just as the total amount of PPIS
dollars distributed each year has
increased, so has the total number
of grants awarded. In fact, the num-
ber of grants awarded annually has
increased substantially from  14 in
1989  to 52 in 1993. Within the
past five years,  EPA has awarded
grants to 124 organizations.
   At the outset of the program,
EPA funded fewer organizations
with larger grants (most were
approximately $300,000). As EPA
began funding more programs per
year, the amount of each grant
awarded decreased. Whereas the
majority of the early grants provided
seed money for nascent pollution
prevention programs, more recent
grants have helped states implement
special pollution prevention
 Exhibit 11-4
 Total PPIS Funding by Year


  •Z 6,000
  u 5,000
  | 4,000

  jj 3,000
  Q 2,000

                        1990       1991
   Exhibit II-5 depicts the
Regional distribution of PPIS
funds from 1989 through 1993.
With the exception of Region 1,
total grant funding by Region was
relatively equal. Most Regions
received between $1 and $3 mil-
lion in total grant funding. Region
1 received slightly more grant
funding than other states since
many of its states have been on the
forefront of the pollution preven-
tion movement. States in this
Region received several early grants
to test innovative ideas. This trend
continued over the years as EPA
continued to  fund  the expansion of
these programs.

   The distribution of grant fund-
ing in any particular year was less
balanced. An understanding of the
award process can explain dispari-
ties among the EPA Regions in any
given year. In the first four years of
the program,  EPA  Headquarters
distributed the grants through a
centralized, competitive process.
An expert review panel (consisting
of Headquarters and Regional
staff) evaluated all proposals. For
the 1993 grants, EPA decentralized
the grant award process and dele-
gated responsibility to each
Regional office to enable the
Regions to fund regional pollution
prevention priorities.

    EPA awarded some level of
PPIS funding to all 50 states over
the 5-year period under considera-
tion. Early leaders, such as New
York and New Jersey, received pro-
portionately more funding due to
their pioneering efforts developing
innovative pollution prevention
programs. New York and New
Jersey, as well as Rhode Island and
Massachusetts, were among the
first states in the country to
establish broad-based pollution
prevention programs.
Consequently, these states applied
for and received funding in the first
year of the PPIS program. These
states continued to build and
expand their pollution prevention
programs, thereby receiving addi-
                                    Allocation of PPIS Grant Awards • 14

  Exhibit 11-5
  Regional Distribution of PPIS Funds



     £   2,000

     jo   1,500

                                       11989  I	11990 I	11991 I	11992 I	11993
                                        3,000   3'065






                                                EPA Region
tion grant support in subsequent
years. Note that, in addition to
state environmental agencies, other
groups such as state universities,
Indian tribes, and other state gov-
ernment organizations received
funding in each of the states receiv-
ing the most funding. Exhibit 11-6
shows the five states that received
the most funding, accounting for
over 15 percent of total funding.
    In contrast, other states received
more limited funding from 1989 to
1993. For example, New Mexico
received $58,000 over the entire
5-year period. Similarly, Hawaii
received $185,000 in total funding
between 1989 and 1993. In addi-
tion to the reasons given above,
disparities in funding to individual
states may be attributed to several
factors, including:
  States' budgets could not meet
  the matching requirements nec-
  essary for a large PPIS grant,
                             particularly when the matching
                             requirement was raised by
                             Congress to 50 percent in 1992;
                             Some states are more industrial
                             than others, making pollution
                             prevention a more salient issue
                             and thus prompting requests for
                             large grants; and
                             The competitive award process
                             used by EPA before 1993 gave
                             an advantage to states who had
                           Exhibit II-
                begun their pollution prevention
                programs first.

                 Appendicies A-C show the dis-
              tribution of funding to each state
              by Region and include detailed
              breakdowns of annual funding
                            Top Five Recipients of Total Funding, 1989 Through 1993
Number of Grants
Total Funding
                            New York
                            New Jersey
                            Rhode Island
                                   Allocation of PPIS Grant Awards • 15

            Chapter  III
                   Summary  of
                   Grant Activities
          This chapter documents the wide range of pollution prevention
          activities implemented by PPIS grantees. In the time period of
          the study, PPIS grant monies funded nearly 5,000 assessments,
          more than 850 workshops, and the development of 370 pollu-
          tion prevention case studies. In addition, PPIS grantees' efforts
reached companies in 35 industry sectors, as well as many other groups.
Such a breadth of activities illustrates not only the efforts of grantees to
disseminate the pollution prevention message to a wide and varied audi-
ence, but also the aggressive role states have assumed at the forefront of
the pollution prevention movement. The diversity of projects implement-
ed also indicates that grantees addressed several different areas of need
within their particular states, thereby fulfilling the intent of the 1990
Pollution Prevention Act.
   According to the grantees interviewed for this study, PPIS grants also
helped businesses improve the environmental and economic effects of their
operations. In some cases, PPIS grantees's efforts achieved substantial cost
savings for businesses. For example:
  Businesses that received assistance from Kentucky Partners were able to
  save approximately $3 million annually by implementing pollution pre-
  vention measures;1
  Florida's Waste Reduction Assistance Program (WRAP) has saved busi-
  nesses $3.7 million;2
  Companies receiving technical assistance from Alabama's Waste
  Reduction and Technology Transfer (WRATT) program save an average
  of $160,000 each;3 and
  Iowa WRAP has helped businesses in Iowa save more than $1.5 million
   In terms of environmental benefits,  some PPIS grantees demonstrated
significant results. For example:
Summary of PPIS Grant Activities "17

  Tennessee showed a decrease in
  toxic releases of up to 42
• West Virginia experienced a
  53-percent decrease in toxic
  releases;6 and
  Rhode Islands PPIS program
  eliminated 3.4 million pounds of
  liquid waste and 20,000 pounds
  of solid waste.7
   This chapter describes in detail
the groups targeted and activities
A.   Targeted Groups

   The 1990 Pollution Prevention
Act required that all grants awarded
through the matching grant pro-
gram be targeted to the groups
most in need of pollution preven-
tion assistance. Overall, the
majority of PPIS grants have been
targeted to small and medium-sized
businesses and industries, on the
assumption that these organizations
often do not have the resources to
identify and evaluate pollution pre-
vention opportunities on their own.
From 1989 through 1993, PPIS
grants reached over 35 industry sec-
tors, as well as nonindustrial groups
such as universities, Indian tribes,
trade associations, and schools. The
industry sectors most commonly
targeted by PPIS grants include:
• Automotive;
• Printing;
• Dry cleaning;
• Metals manufacturing;
  Agriculture; and
• Painting.
   For a detailed breakdown of
groups targeted by PPIS grantees
see Appendix D.
   The grantees commented that
by focusing on high-priority indus-
try sectors, they can target their
efforts and resources effectively.
Many grantees believe that educat-
ing industry about stopping the
generation of waste at its source is
the key to pollution prevention.
The grantees also indicated that
targeting nonindustrial groups,
such as schools and environmental
groups can also be useful for dis-
seminating information and instill-
ing the pollution prevention ethic
in the general population. As
shown below, PPIS-funded activi-
ties from 1989 to  1994 attempted
to address a wide range of audi-
ences by implementing a diverse
mix of program activities.
B.   Range of

   This section describes the range
of activities conducted by PPIS
grant recipients.8 Categories of
activities include:
   Education and Outreach;
   Data Collection and Research;
•  Infrastructure;
   Technical Assistance and
   Technical Training;
   Pilot Programs and
   Demonstration Projects;
  Awards and Recognition; and
   Regulatory Integration.
   Exhibit  III-l shows the percent-
age of grant recipients implement-
ing each type of activity. The
remainder of this chapter describes
each activity in detail.
 Exhibit 111-1
 Summary of Activities
                                   Summary of PPIS Grant Activities  "18

B.1  Education and

   As shown in Exhibit III-l, near-
ly all programs dedicate some
resources to education and outreach
activities. These initiatives, designed
to heighten public awareness of pol-
lution prevention, are implemented
through a variety of projects, as
illustrated in Exhibit III-2.

   As shown in Exhibit III-2,
workshops and seminars are the
most frequently implemented form
of education and outreach activities,
conducted by 66 grantees (57 per-
cent). These workshops may edu-
cate participants on topics such as
conducting pollution prevention
audits, current hazardous waste reg-
ulations, and cost savings through
pollution prevention.
   Presentations are also an
extremely popular outreach activity,
conducted by 41 grantees (36 per-
cent). Presentations frequently tar-
get various industry sectors (see
Appendix D for a description of
industries targeted), state environ-
mental managers, and trade associa-
tions. Topics are similar to those of
PPIS-funded workshops and semi-
nars. The  prevalence of these activi-
ties is most likely attributable to the
fact that they are quick, easy ways
to directly disseminate pollution
prevention information to business-
es, industries, and the general
   Grantees also developed and
distributed a large quantity of
printed outreach materials such as
case studies and fact sheets. These
materials might document the pol-
lution prevention and  cost-savings
successes of companies, or provide
general suggestions for how facili-
ties can reduce hazardous waste at
its source. Grantees noted that out-
reach documents are relatively sim-
ple methods of sharing pollution
prevention information.
    Some grantees have placed par-
ticular emphasis on such education
and outreach areas as developing
targeted materials or sponsoring
teleconferences. For example, the
Virginia Department of
Environmental Quality's (DEQs)
Office of Pollution Prevention
(OPP) has taken a broad approach
to developing outreach materials
and tries to tailor each item for its
intended audience. OPP has pro-
duced two videos—one for medi-
um-sized lithographic printers and
one for manufacturers in Virginia—
which have been distributed to over
450 companies throughout the
 Exhibit II1
       state. In addition, OPP used PPIS
       funds for two large pollution pre-
       vention posters targeted to automo-
       tive industries and general industrial
       audiences. The program has distrib-
       uted over 10,000 posters to date.10
          The Montana State University
       Extension Service (MSUES) target-
       ed its 1992 and  1993 PPIS grants
       to the automotive and drycleaning
       industries. To educate these indus-
       tries about pollution prevention
       opportunities, MSUES has pro-
       duced a set of fact sheets, a video,
       and vendor and product lists target-
       ed to each industry. In addition, the
       grantee conducted two demonstra-
       tion assessments and held 22 work-
       shops (attended by a total of 443
       people) for the industries.11

          Two of the more innovative out-
       reach materials that MSUES devel-
       oped are self-assessment checklists
 Education and Outreach Summary
  Education and
  Outreach Activities
Number of
Number Developed
  With PPIS Funds
  Fact sheets
  Case studies
  Guidance materials/
  Public service
  Waste exchanges
                                    Summary of PPIS Grant Activities  "19

for drycleaners and automotive
workers. The checklists assist the
targeted groups in evaluating pollu-
tion prevention opportunities in
their facilities and provide helpful
hints for hazardous waste avoid-

   The Tennessee Department of
Environment and Conservation,
through the University of
Tennessee's Center for Industrial
Services, concentrated its PPIS out-
reach efforts through video telecon-
ferencing. The program developed
and produced three national tele-
conferences on the following pollu-
tion prevention topics: solvents
alternatives, painting challenges of
the 1990s, and promotion of land-
fill alternatives for solid waste.  Each
teleconference was downlinked by
at least 40 states,  thereby reaching
3,000 people per  event. According
to the grantee, the teleconferences
were very well received. Based  on
feedback from the attendees, the
Department of Health and
Environment believes that the  con-
ferences had a significant impact on
pollution prevention, not only in
the state but nationally as well.12

   Newsletters also are a popular
way for state pollution prevention
programs to disseminate informa-
tion to industry, other programs and
agencies, and other states.  Erie
County, for example, sends its
newsletter to both small and large
businesses in targeted industry
groups.  The county developed  its
mailing list from community
sources  including chamber of com-
merce directories, business indexes,
and standard "yellow pages." In
addition, the county used regulatory
databases to target larger businesses
and industries.13
   Frequently, newsletters feature
case studies of companies that have
benefitted from pollution prevention
program efforts, articles about perti-
nent regulations and legislation, and
notices of upcoming educational and
outreach events.  These newsletters
are generally free to interested parties
within the grantees' states and
offered either at no cost, or for a
nominal fee, to out-of-state sub-
scribers. Approximately 25 percent
of PPIS grant recipients published
newsletters, many with remarkably
high circulations.
   For example, Kentucky Partners,
Kentucky's state pollution preven-
tion center, published over 27 issues
of their newsletter, "The Waste-
Line," and distributed each issue to a
mailing list of approximately 7,000
people.14 Similarly, the Erie County
Department of Environment and
Planning distributed five industry-
specific and one general pollution
prevention newsletter to 4,500 peo-
ple quarterly.15 Finally, the New York
State Department of Environmental
Conservation's newsletter, published
twice yearly, is distributed to  a mail-
ing list of  8,000 people.16
B.2 Data Collection
      And Research

   PPIS supports a variety of data
collection and research initiatives to
evaluate the usefulness of current
pollution prevention methods and
to increase knowledge about new
pollution prevention technologies.
The research projects PPIS has
funded may eventually help grantees
further pollution prevention efforts,
both in their states and nationally.
These efforts frequently include the
activities shown in Exhibit III-3.
   PPIS funds support research
both in the laboratory and in the
field. For example, inspired by the
terms of the Montreal Protocol,
which will effectively eliminate the
use and manufacture of chlorofluo-
rcarbon (CFC) based cleaning sol-
vents by 1995, the Navajo Nation
is researching alternative cleaning
solvents. The proposed research
and development work will be per-
formed to identify,  quantify, and
implement the best alternatives to
chlorinated and fluorinated clean-
ing industrial solvents. The goal is
Exhibit 111-3 ^^^^^^^^H
Data Collection and Research Summary
Data Collection and
Research Activities
Data collection and analysis
Database development
Number of
Percent of
Total Grantees
                                     Summary of PPIS Grant Activities "20

to develop an alternative, environ-
mentally benign industrial solvent
to eliminate industrial contami-
nants such as solder flux, mold
release, resins, curing agents, cover
coats, waxes, greases, oils, lubri-
cants, and other similar contami-
nants found in a typical manufac-
turing environment. The Navajo
Nation hopes that this research will
eventually help prevent pollution
within Navajo lands as well  as in
other areas across the country.17

   On the other hand, Rhode
Island's PPIS-funded research focus-
es more on the issues affecting one
specific industry—the textile indus-
try. The research, conducted by the
Rhode Island Department of
Environmental Management
(DEM), included the following
research components:
•  Researching  and identifying reg-
   ulatory and policy initiatives that
   would encourage textile compa-
   nies to  incorporate source reduc-
   tion measures and technologies
   into their process and facility
•  Identifying Rhode Island textile
   plants that represent the greatest
   potential risk to health and the
   environment through a compre-
   hensive statewide survey, analysis
   of chemical release and offsite
   transfer data, and a review of the
   regulatory history of facilities;
   Researching, identifying, and
   evaluating cost-effective manage-
   ment and process operational
   methods,  material substitutions,
   and technologies that could be
   used to reduce air/water releases
   and offsite transfers in facilities
   that represent the highest poten-
   tial environmental risk; and
  Analyzing textile industry dis-
  charges for toxicity.18
   The DEM hopes that these
research endeavors will expand the
knowledge base and technical
resources available to Rhode Island
textile companies to reduce pollu-
tants at their source.19
   The focus of the West Virginia
Department of Environmental
Protection's PPIS grant is to pro-
duce the annual West Virginia
Scorecard. Scorecard is a document
designed to provide the public with
an annual review and analysis of
Toxic Release Inventory (TRI) data
from all reporting industries, high-
lighting the 28 major chemical
companies in the state. It examines
trends in toxic chemical releases
across the state by region, industry
sector, and medium of release.
Information on the release of
known or suspected carcinogens as
a subset of total releases is also pro-
   Collection and analysis of the
data are voluntary efforts jointly
conducted by chemical industry
representatives, state environmental
personnel, nongovernmental organ-
izations, and citizen activists. In
addition to reporting emissions
data, companies participating in
the Scorecard project also provide
narrative statements about their
facilities, in which they enumerate
their goals for environmental per-
formance and  are given the oppor-
tunity to explain how these goals
were achieved  or why they may not
have achieved their release reduc-
tion goals. West Virginia believes
that Scorecard assists both the pub-
lic and industry in identifying
opportunities for further reductions
in the generation, treatment, and
disposal of toxic chemicals.20
B.3  Infrastructure

   A major goal of the PPIS grant
program was to help states develop
the infrastructure necessary to
establish a sustainable pollution
prevention program. Infrastructure
includes time and resources spent
on hiring and training staff, devel-
oping legislation and regulations
that promote pollution prevention,
evaluating program effectiveness,
and securing funding for the pro-
gram's future endeavors. EPA
believes that developing program
infrastructure is critical because it
ensures  a solid base and continuous
support for  a state's pollution pre-
vention efforts. Exhibit III-4 lists
the range of infrastructure activities
conducted through the PPIS grant

   PPIS funding enabled grantees
to build program infrastructure by:
  Hiring 60 staff members;
• Hiring and training 70 interns; and
  Providing 40 internal training

   In addition, many grantees
established an advisory committee
or workgroup to oversee the estab-
lishment of the pollution preven-
tion program. These committees
consist of staff from all program
areas to give the pollution preven-
tion program a true multimedia
perspective and to promote link-
ages between the  programs.

   A large component of Georgia's
PPIS-funded program involved a
                                    Summary of PPIS Grant Activities  "21

series of task force and advisory
committee meetings, which eventu-
ally led to the institutionalization
of the program in 1993. Three dif-
ferent groups were central to
Georgia's infrastructure-building
endeavors. One group, the
Environmental Protection Division
(EPD) New Industry Team, was
used to foster a working relation-
ship with  Georgia businesses. The
team informed new industries of
the state's  pollution  prevention
efforts and of available technical
assistance  to encourage new indus-
try prospects to design facilities
that incorporate pollution preven-
tion and waste minimization into
their operations.

   Another  Georgia group sup-
ported by PPIS funding was EPD's
Pollution  Prevention Strategy Task
Force. Throughout its 16 meetings,
the task force developed EPD's
strategy for integrating pollution
prevention into regulatory pro-
grams. Eleven  multimedia staff par-
ticipated in a survey to assess EPD-
wide pollution prevention training,
information distribution, and rele-
vant regulatory actions. The result
of the task force's  efforts was a
 Exhibit 111-4
 Infrastructure Summary
  Infrastructure Activities
strategy that included an emphasis
on a multimedia pollution preven-
tion approach to regulatory action,
increased staff training, and cre-
ation of a new EPD culture that
promotes pollution prevention over
pollution control.

   EPD's Pollution Prevention
Advisory Committee, a group
consisting of representatives from
several key organizations in state
government, was active in evaluat-
ing the pollution prevention efforts
of EPD. After frequent meetings,
the committee produced a matrix
of statewide pollution prevention
and waste minimization activities.
The matrix examined activities
across seven sectors of the division,
assessed each one, and assigned an
effectiveness rating. The committee
then made  recommendations to
improve the function of Georgia's
pollution prevention efforts.
   The efforts of EPD's various
committees served to create and
strengthen its pollution preven-
tion program. In 1993, legislation
was passed creating the Pollution
Prevention Assistance Division
(P2AD) in the Georgia
Department of Natural Resources.
   Number of Grants
 Securing funding sources
 Hiring interns
 Developing legislation
 Developing pollution prevention policy
 Program evaluation
 Hiring staff
 Training staff
 Forming workgroups/committees
According to the grantee, "where-
as the purpose of the PPIS grant
was to offer seed money to states
to develop pollution prevention
programs, this [legislation] is a
culmination of efforts initiated
over the last four years. The activ-
ities implemented by EPD under
this grant provide a strong foun-
dation for the new Pollution
Prevention Assistance Division."21
Long-term funding has also been
addressed in creating P2AD.
Although it will receive some
funding from the federal govern-
ment, the new division is primari-
ly funded through state-appropri-
ated funds and solid waste and
hazardous waste generator fees.22

   Other grantees have taken dif-
ferent approaches to developing
program infrastructure. For exam-
ple, the focus of the Alabama
OEM's  1991 PPIS grant was the
institutionalization of the Waste
Reduction and Technology Transfer
(WRATT) program. As a result of
PPIS funding, the WRATT
program, Alabama's free, nonregu-
latory vehicle for technical assis-
tance, became the WRATTLER
Foundation, a stand-alone, non-
profit organization. In institution-
alizing the WRATT program,
Alabama enabled its technical assis-
tance program to receive private
funding; the WRATTLER
Foundation  is now funded 50
percent by state monies and 50
percent by private funds.  WRAT-
TLER receives its private funding
primarily from facilities that donate
to the foundation after saving
money by implementing recom-
mendations  made during free waste
audits. In addition, the Foundation
has applied for several grants from
private foundations and to date has
                                    Summary of PPIS Grant Activities "22

received $350,000 in grant fund-
ing. With the WRATTLER
Foundation supporting it, the
WRATT program is able to con-
tinue to provide technical assis-
tance to Alabama businesses.23
   The activities of the WRATT
program are also infrastructure ori-
ented. For example, one goal of the
program was to develop strategies
for 1) promoting and facilitating
the incorporation of pure pollution
prevention techniques in the plan-
ning and design process for new
and expanding companies; 2) mak-
ing technical assistance more rele-
vant and more accessible to small
businesses in Alabama; 3) improv-
ing public awareness of waste
reduction issues; and 4) measuring
the effectiveness of pollution pre-
vention activities in reducing waste
generation. Another infrastructure
element of Alabama's program
focused on program evaluation.
The  DEM commissioned two stud-
ies to determine the effectiveness of
the programs technical assistance
efforts and the associated cost sav-
ings  to participating businesses.
Further details about the WRATT
program's measurement initiatives,
as well  as the efforts of other PPIS
grantees to measure program suc-
cess, are presented in Chapter IV.
B.4 Technical
      Assistance and
   A major component of many
PPIS -funded programs is technical
assistance. Grantees believe that
through onsite visits, assessments,
hotline and clearinghouse informa-
tion, and training, state pollution
prevention programs can help
industry and other groups better
understand and incorporate pollu-
tion prevention technologies into
their everyday operations. Exhibit
III-5 shows the technical assistance
and training activities that PPIS
funds support.
   A primary goal of the PPIS
grant program was to allocate
resources to the states to provide
technical assistance to businesses in
accordance with the 1990 Pollution
Prevention Act. Many states pro-
vided  technical assistance through
onsite waste assessments or audits.
In many cases, PPIS technical assis-
tance programs offer confidential,
onsite pollution and waste assess-
ments for both large and small
businesses. These assessments take
place outside  the regulatory envi-
ronment, and participation on the
part of businesses is strictly volun-
tary. Grantees believe that through
the assessments, businesses learn
how to save money, increase effi-
ciency, and build a good public
image. During a waste assessment,
engineers review all business
operations to uncover potential
waste reduction strategies and
opportunities. Later, the company
receives a detailed report that iden-
tifies and evaluates waste reduction
opportunities and provides specific
recommendations for action. The
decision to implement any recom-
mended option is entirely the
decision of the company.
   Some grantees have made onsite
visits a central component of their
pollution prevention programs. For
example, the Washington State
Department of Ecology has per-
formed site assessments of 1,700
businesses, including lithographers,
screen printers, and photoproces-
sors.2^ The South Carolina
Department of Health and
Environmental Control conducted
more  than 250 assessments.25 By
providing onsite assistance, many
PPIS grantees have helped busi-
nesses realize substantial cost sav-
ings. For example,  the
Massachusetts Office of Technical
Assistance helped companies save
 Exhibit 111-5
                                     Technical Assistance and Technical Training Summary
                                     Technical Assistance and     Number of  Number Developed
                                     Technical Training Activities    Grants     With PPIS Funds
 Assessments/Audits/Site visits         61
 Bulletin boards                       5
 Clearinghouses/Libraries              32
 Grants                              4
 Hotlines                             20
 Technical training                    13

                                   Summary of PPIS Grant Activities  "23

an annual average of $35,000 per
company.26 Kentucky Partners
helps Kentucky businesses save an
estimated total of $3,000,000 per
year.27 More results of this nature
are presented in Chapter IV.
   Other states have taken innova-
tive approaches to site assessments.
With its 1989 PPIS grant, the
Georgia Environmental Protection
Division initiated the Pollution
Prevention Mentor (PPM) pro-
gram, whereby EPD employed
retired engineers, working in con-
junction with graduate student
teams, to provide industry with the
technical expertise and support
necessary to implement source
reduction techniques and technolo-
gies. The teams spent five days on
site per facility, then submitted
pollution prevention recommenda-
tions. The final product of these
visits was a site-specific report out-
lining source reduction options for
each company. The PPM Program
conducted over 30 assessments.28
With later grants, the Georgia
Hazardous Waste Management
Authority (GHWMA) started the
Seniors' Assessment Technical
Assistance Program (SATAP), once
again combining the talents of
retired engineers with graduate stu-
dents at Georgia Technology
Institute. The SATAP program
conducted 20 site assessments.29
Many other states, such as
Tennessee, Florida, Alabama,
Vermont, and New Hampshire
have also enlisted the help of
retired engineers for their technical
assistance programs.
   Several grant recipients operate
clearinghouses, which provide busi-
nesses and the general public with
technical information on an as-
requested basis. For example, the
clearinghouse that the Virginia
DEQ maintains houses more than
3,000 books, articles, papers, and
videos that cover all aspects of pol-
lution prevention. The clearing-
house is open to other organiza-
tions, and DEQ is arranging for
the information clearinghouse
index to be available online so that
the library is accessible for search-
ing and requesting by other depart-
ment staff and the general public.
DEQ hopes that this capability will
greatly enhance both the utilization
and the usefulness of the informa-
tion clearinghouse.30
B.5 Pilot  Programs

   EPA encourages states to initiate
pilot and demonstration projects
that test and support innovative
pollution prevention approaches
and methodologies. The funding of
pilot and demonstration projects
allows EPA and the states to learn
how new initiatives will work
before businesses or the govern-
ment  invest a significant amount of
time and resources. Twenty-one
percent of PPIS grants were used to
fund either demonstration or pilot
projects that tested innovative pol-
lution prevention techniques. Some
projects were conducted by the
grantees themselves, while others
were carried out by contractors or
through minigrants channeled to
industry through state programs.
Many of these projects have
demonstrated remarkable successes,
including a project conducted by
Cornell University's Water
Resources Institute. The Water
Resources Institute used its 1990
PPIS grant as seed money for a
holistic farm planning demonstra-
tion project aimed at nonpoint
source  pollution in agriculture. The
project was the foundation of what
is now a $35 million, statewide,
multiagency initiative for New
York, and has been adopted as a
model  for many other states as
well. The grantee  hopes that  this
project will assist water districts in
maintaining water quality through
watershed control rather than
through the installation of costly
filtration systems. The project was
piloted in upstate New York, where
it is expected to save local water
systems more than $5 billion in
construction costs and $300 mil-
lion in annual operating costs
(related to a proposed filtration sys-
tem) by encouraging the adoption
of farming practices to protect
water quality.31

   Two PPIS grants were awarded
to assist in the formation and pilot-
ing of Wisconsin's Farmstead
Pollution Potential Assessment
System (Farm*A*Syst).
Farm*A*Syst, a joint effort between
EPA and the U.S. Department of
Agriculture (USDA), was designed
to help farmers and rural residents
voluntarily assess well water pollu-
tion risks at the farmstead (house,
farm buildings, and surrounding
land). The system identifies best
management practices and struc-
tures at a specific site that present
pollution risks. It  then recom-
mends actions to reduce or elimi-
                                    Summary of PPIS Grant Activities "24

nate identified pollution risks.
Ultimately, the system is intended
to increase users' knowledge and
understanding of their farmstead
environment, as well as existing
policies, regulations, and recom-
mendations that relate to their
activities and structures, with the
goal of helping users take voluntary
actions to reduce and prevent pol-
lution risks. The grantee used PPIS
funds for initial development of the
assessment tool, which consists of
12 workshops and  10 fact sheets.
Using PPIS funds,  the program was
first piloted in Wisconsin and
Minnesota. After 3 years, all 50
states have now developed a
Farm*A*Syst program based on the
Wisconsin model.32
B.6 Awards and

   Some PPIS grantees have insti-
tuted awards programs to recognize
outstanding achievements, usually
by industry, in the realm of pollu-
tion prevention. The winners gen-
erally receive free publicity for their
efforts and many programs have
developed case studies based on the
accomplishments  of award winners.
   Certain programs have placed
particular emphasis on awards.
Alaska's Office of the Governor
used its 1991 PPIS grant to estab-
lish a "Green Star" program that
targets businesses  and industries
across the state. To receive the
Green Star, participants in the pro-
gram must complete a minimum
of 12 of 18 possible source reduc-
tion standards. Six of the standards
are required for a company to
receive its Green Star, while the
remaining six can be selected from
a pool of 12 possibilities. Examples
of the standards include double-
sided copying, yearly waste assess-
ments, and assisting at least one
other business in becoming a
Green Star member. To date, over
183 businesses are enrolled in the
Green Star program, and 40 have
earned their Green Stars.33
B.7 Regulatory

   Many states have chosen to use
PPIS funds to integrate pollution
prevention into their regulatory pro-
grams. While strictly voluntary ini-
tiatives focusing on outreach and
technical assistance characterized the
activities of most earlier PPIS
    hibit III
grantees,34 regulatory integration is a
growing trend. Exhibit III-6 shows
the approaches that grantees have
employed to inject pollution preven-
tion into state regulatory structure.
   Compared with the level of reg-
ulatory integration in 1989, several
states have made great strides
toward regulatory integration with
PPIS funding. For example, one of
the primary objectives of the
Illinois EPA (IEPA) was to auto-
matically integrate pollution pre-
vention concepts in IEPA permit
decisions, compliance agreements,
and regulatory actions across all
media programs. A major goal of
the grant was to produce a pollu-
tion prevention guidance manual
for IEPA permit and inspection
staff in all bureaus. The manual
currently contains instructions use-
ful to Agency personnel but will
continue to evolve as successful pol-
lution prevention projects occur
and are documented.
 Summary of Regulatory Activities
 Incorporate pollution prevention
 reviews in permitting
   Number of    Percent of
      Grants   Total Grantees
  Perform mandatory waste audits
  Incorporate pollution prevention
  into enforcement and compliance
 Develop pollution prevention
 checklists for inspectors
 Develop pollution prevention policy
 statements regarding regulatory
  Place pollution prevention requirements
  in ordinances and regulations
                                    Summary of PPIS Grant Activities "25

    Thus far, the manual has been
used to train over 200 technical and
legal staff members in seven field
offices and headquarters. IEPA also
drafted a guidance document, based
on  U.S. EPA guidance, for incorpo-
ration of pollution prevention and
Supplemental Environmental
Projects (SEPs) into enforcement
    IEPA also launched a voluntary
technical assistance program for
industry whereby participating
companies worked with the agency
on  pollution prevention initiatives.
In return, IEPA provided both
technical regulatory assistance
(including expedited permits  and
variance support) and adjusted
standard support. Over  130 compa-
nies participated in the program.35

    According to the grantee,
"Illinois regulators and companies
forged a more cooperative working
and learning relationship as a result
of the PPIS grant. Permit writers,
inspectors and [lawyers]  are begin-
ning to incorporate P2 into their
work and learn more about the intri-
cacies of manufacturing processes."36
    The Narragansett Bay Water
Quality Management District
Commission (NBC) provides
another example of how pollution
prevention ideas can be integrated
into state regulations. NBC owns
and operates Pvhode Island's two
largest municipal wastewater treat-
ment plants. As part of its opera-
tions, NBC operates an Industrial
Pretreatment (IPT) program that
permits, monitors, and regulates
industrial and commercial dis-
charges.  One aspect of NBC's 1991
PPIS grant focused on integrating
pollution prevention into IPT. The
IPT program expanded its policy
of referring all noncompliant com-
panies to the NBC's Pollution
Prevention Program for assistance.
Furthermore, IPT  refers new per-
mit applicants to NBC's pollution
prevention program.
    In addition, NBC has incorpo-
rated pollution prevention into
settlement practices, including
implementation  of a pollution pre-
vention project to  offset assessed
fines. To be eligible as a pollution
prevention project, a proposal must
go beyond compliance and result
in an environmental benefit not
currently required by law. This
approach presents certain advan-
tages to facility owners who find
themselves involved in enforcement
action:  1) the use of company
funds to purchase and install pollu-
tion prevention equipment can
result in positive tax consequences,
as opposed to the direct payment
of fines; 2) the use of pollution
prevention equipment can increase
efficiency; and 3) the use of pollu-
tion prevention equipment often
results in decreased water usage,
which can substantially lower con-
sumption bills and/or permit fees.
    For these reasons, an increasing
number of Pvhode Island compa-
nies are opting to implement pollu-
tion prevention projects in lieu of
cash settlements. According to the
grantee, instituting pollution pre-
vention projects can also benefit a
company's public image while help-
ing; the environment.37
1 Kentucky Partners Fact Sheet, January 1994.
2 Pollution Prevention Incentives for States, Spring 1994, U.S.
3 Alabama Pollution Prevention Program Final Progress Report,
  1994, Alabama Department of Environmental Management.
4 Pollution Prevention Works for Iowa: Case Studies, April 1993,
  Iowa Department of Natural Resources.
5 Personal communication in May  1995 with George Smelcer,
  University of Tennessee Center for Industrial Services.
6 West Virginia Scorecard, 1992, National Institute for Chemical
7 Pollution Prevention in Rhode Island: Final Report on OEM's
  Pollution Prevention Program, June 1994, Rhode Island
  Department of Environmental Management.
8 The data presented in this section were gathered through a series
  of telephone interviews, during which many grantees were unable
                     to precisely quantify their activities. Many grantees presented
                     numbers for their activities in range format. In such circumstances,
                     EPA used the low end of the range to calculate totals. Therefore,
                     the numbers presented in this chapter most likely underestimate
                     the true level of activity of PPIS grant recipients.
                   9 This number is particularly high because Utah  used PPIS funds to
                     develop a 4-month campaign of "Enviro-Minutes." These Enviro-
                     Minutes were 30- to 60-second spots highlighting what citizens
                     can do to prevent pollution.
                   101994 Pollution Prevention Evaluation  Report, Virginia
                     Department of Environmental Quality.
                   11 Personal communication in November 1994 with Karen Bucklin
                     Sanchez, Montana State University Extension Service.
                   12 Personal communication in May 1995 with George Smelcer,
                     University of Tennessee Center for Industrial Services.
                   13 Erie County Pollution Prevention Program Evaluation, April 1993.
                                      Summary of PPIS Grant Activities "26

14 Personal communication in December 1994 with Joyce St. Glair,
  Kentucky Partners.
15 Erie County Pollution Prevention Program Evaluation, April 1993.

16 Personal communication in November 1994 with John lannotti,
  Pollution Prevention Unit, New York State Department of
  Environmental Conservation.

17 PPIS Grant Assessment Study Report, November 1994, Navajo
  Nation Environmental Protection Agency.

18 Assessment of Regulatory and Non-regulatory Approaches to
  Source Reduction in the Rhode Island Textile Industry, Progress
  Report #3, April 30, 1994, Rhode Island Department of
  Environmental Management.
19 Assessment of Regulatory and Non-regulatory Approaches to
  Source Reduction in the Rhode Island Textile Industry, Progress
  Report #3, April 1994, Rhode Island Department of
  Environmental Management.
20 Personal communication in November 1994 with Dr. Jan Taylor,
  National Institute for Chemical Studies (West Virginia
  Department of Environmental Protection's partner in producing
  the Scorecard).
21 Georgia Pollution Prevention Incentives for States Grant Final
  Report, September 1993, Georgia Department of Natural
22 Georgia Pollution Prevention Incentives for States Grant Final
  Report, September 1993, Georgia Department of Natural
23 For more information on WRATTLER, call the WRATT
  Foundation, (205) 386-3633.

24 Personal communication in November 1994 with Darin Rice,
  Washington Department of Ecology.
25 Personal communication in November 1994 with Bob Burgess,
  Center for Waste Minimization, South Carolina Department of
  Health and Environmental Control.
26 The Central Massachusetts Pollution Prevention Project Summary
  Report, 1992, Massachusetts Office of Technical Assistance.
27 Kentucky Partners Fact Sheet, January 1994.
28 Pollution Prevention Technical Assistance for Selected Industries
  Final Report, September 1991, Georgia Tech Research Institute
  (Georgia Environmental Protection  Division's partner).
29 Pollution Prevention Incentives for States Program Semi-Annual
  Progress Report, April 1993, Georgia Hazardous Waste
  Management Authority.
301994 Pollution Prevention Evaluation Report, Virginia
  Department of Environmental Quality.
31 "New York City: Case of a Threatened Watershed," Keith S.
  Porter. EPA Journal, Summer 1994.
32 For more information on the Farm*A*Syst program,
  call 608 262-0024.
33 Personal communication in November 1994 with Sara Peacock,
  Alaska Office of the  Governor.
34 Massachusetts Department of Environmental Management
  received a grant in 1989 to begin integrating pollution prevention
  into the regulatory program.
351989 Pollution Prevention Incentives Grant Final Report, May
  1993, Illinois Environmental Protection Agency.
36 Activate the State/Lead by Example Final PPIS Grant Report,
  October 1994, Illinois Environmental Protection Agency.
37 Narragansett Bay Commission Pollution Prevention Incentives
  for States Third Status Report, September 1994.
                                          Summary of PPIS Grant Activities  "27

            Chapter IV
                   and  Evaluation
         he purpose of this chapter is to document activities underway in
         the states to measure the effectiveness of grantfunded activities.
         This chapter highlights different measurement methodologies used
         by the grant recipients, without judging the effectiveness of any
         particular methodology. As stated in the Introduction (Chapter I)
of this report, documenting grant-funded activities, including program evalua-
tion and measurement, is EPA's first step  in the evaluation of the PPIS grant
program. Understanding how states are approaching measurement issues will
help EPA determine an appropriate long-term strategy to evaluate PPIS-fund-
ed programs. This chapter begins with a description of how EPA traditionally
monitors and evaluates its media programs, which provides a context for
appreciating the limitations associated with  current tracking efforts as applied
to the PPIS grant program. The following section summarizes how states have
begun to measure the effectiveness of their programs. The final section out-
lines EPA's efforts to improve program evaluation in the future.
A.  Monitoring and
     Evaluating EPA
     Media Program
   EPA issues approximately $600
million in grants to the states each
year to help the states develop state
program capacity and fund ongo-
ing activities.  EPA issues these
grants under the authority of the
environmental statutes such as the
Clean Air Act, Clean Water Act,
Safe Drinking Water Act, and
Resource Recovery and
Conservation Act. In cases where
states are willing and able to imple-
ment portions of the federally-
mandated requirements under
these statutes, EPA delegates
authority for implementation to
the states. Given that the Agency is
ultimately responsible for imple-
mentation of the  law, EPA oversees
state activities to ensure that
Congressional requirements are
 Measurement and Evaluation • 29

   Traditionally, EPA has moni-
tored both the federal and the
state-delegated programs primarily
by counting the number of activi-
ties underway. The media programs
(air, water quality, drinking water,
and waste) track a variety of indica-
tors in the following regulatory
based categories:
• The number of permits issued;
• The number of compliance
  monitoring inspections; and
• The number of enforcement
  actions or formal consent decrees.
   While the names and numbers
of indicators tracked differ from
program to program, the basic con-
cept remains the same. Programs
track concrete administrative
actions (e.g., permits, inspections)
to ensure that annual targets set by
program managers  (or the legisla-
ture) will be met.
   Unlike other environmental
statutes, the Pollution Prevention
Act of 1990 does not establish a
regulatory framework. Conse-
quently, the traditional measure-
ment approach cannot be easily
applied to the PPIS program or to
the pollution prevention program
as a whole. Not only are there no
administrative measures, such as
permits or inspections, there are
also no federal models by which to
evaluate state pollution prevention
programs. In fact, EPA designed
the pollution prevention program
to be as flexible as possible to
accommodate individual state pro-
gram needs and priorities.

   The traditional  "bean-counting"
approach is limited by its focus on
simple counts of actions, rather
than trying to capture environmen-
tal results. The Agency recognizes
the need to move forward in mea-
suring results and away from
administrative measures. The media
programs are grappling with this
issue and the difficult questions of
how to define environmental
results. In the future, EPA hopes to
improve the documentation of
environmental results achieved
through the grant program.

    Recently, the National
Association for Public
Administration (NAPA) studied
EPAs programs and policies,
including its approach toward pro-
gram evaluation. The study found
that program evaluations are not
consistently conducted by EPAs
media programs. According to the
NAPA study, "There is no Agency
policy for the frequency of program
evaluation or for the conditions
under which it is performed."1
Furthermore, "The EPA program
offices have not taken on the
responsibility of conducting their
own rigorous [program]
evaluations... They do not know
how well activities were performed
nor how well those activities were
evaluated. None of EPAs ten
regional offices has done extensive
evaluation work either."2 Given
that the Agency lacks "a sound sys-
tem for conducting program evalu-
ations on a routine basis,"3  it
should come as no surprise  that
EPA has  not previously conducted
a rigorous evaluation of the PPIS
grant program. This assessment
study, however, represents an initial
step toward  understanding and
evaluating the PPIS  grant program.
B.   State  Strategies
      To Measure

   While many states are just
beginning to evaluate elements of
their pollution prevention pro-
grams, a few have successfully eval-
uated their programs. Some state
legislatures require the programs to
report on activities conducted with
state funding. PPIS grantees have
used a variety of techniques to eval-
uate their programs, ranging from
surveys to followup site visits. As a
result, many states have been able
to gauge the level of satisfaction
with particular services and a few
have been able to  quantify the
results of their pollution prevention
endeavors in terms of actual waste
reductions and cost savings.

   As detailed in David
Wigglesworth's 1993 book, Pollution
Prevention: A Practical Guide,'1 there
are both internal and external
approaches to measuring progress.
The internal approach is a basic
accounting or assessment of the pro-
grams activities. The external
approach uses input from outside
the pollution prevention program to
evaluate the programs services, either
from "clients" of the program or
independent sources. Generally,
methods for  measuring PPIS-funded
programs fall into  three categories:
   Overall evaluation of program
   Evaluation of specific services,
   either by amount of pollution
   prevented or by level of cus-
   tomer satisfaction; and
   Measures  of activity level.
                                      Measurement and Evaluation  • 30

B.1  Overall

   Overall evaluations enable state
programs to assess the effectiveness
of their entire pollution prevention
program. Usually, state programs
examine a range of data points
such as level of client satisfaction,
implementation rate of technical
recommendations, and amount of
pollution prevented. These evalua-
tions can help program managers
to understand the effectiveness of
different program elements and
relationships between the program
activities. They can be used to jus-
tify funding from state and federal
legislatures and help secure private
funding by demonstrating effec-
tiveness. One of the drawbacks of
conducting such  evaluations is that
they are often resource-intensive.
For this reason, only a few PPIS
grant recipients have conducted
such an evaluation. Examples of
programs that have conducted
overall program evaluations include
Alabama, Massachusetts, and Erie
County, New York.

   The Alabama Department of
Environmental Management con-
tracted with the Alabama
Universities TVA Research
Consortium (AUTREC)  to provide
an evaluation of the Waste
Reduction and Technology Transfer
(WRATT) program services. The
evaluation entailed contacting com-
panies that had received technical
assistance from the WRATT pro-
gram and conducting a survey
regarding WRATT services and
confidentiality. This process revealed
that clients were pleased with the
program,  and 90  percent  would rec-
ommend WRATT s services to oth-
ers. AUTREC performed an addi-
tional study to determine the cost
savings and waste reductions derived
from WRATT s services.
Information for this study was col-
lected by monitoring companies'
progress in implementing WRATT's
pollution prevention recommenda-
tions. While the data are still pre-
liminary, each company that
received technical assistance from
WRATT appears to have saved
approximately $160,000. This
translates to a 1:60  ratio—for every
dollar WRATT spends on conduct-
ing the assessments, industry saves
60 dollars.?

   The Massachusetts Office of
Technical Assistance (OTA) also
used the services of an outside con-
sultant to evaluate its program. The
goal of OTAs PPIS grant was the
expansion of the Central
Massachusetts Pollution Prevention
Project, a relatively new technical
assistance program. When the pro-
ject was complete,  the consultant
interviewed, by telephone, 110
companies (62 companies within
the project area and 58 similar
firms  outside the project area as a
control group) to determine the
awareness of, usage of, and atti-
tudes about OTA services. Eighty-
seven percent of the firms that used
program services were actively
reducing toxics, as  opposed to only
39 percent of firms that did not
use program services.
   In-depth personal interviews
were also conducted at 28 compa-
nies to evaluate  the firms' Toxics
Use Reduction (TUR) performance
and to collect additional data on
OTA effectiveness.  On average,
those who received OTA assistance
  "In addition to being a requirement
  of the P2 Act, it is important to eval-
  uate the program to demonstrate its
  effectiveness to the legislature, to
  industry, and to the general public in
  order to continue the program.
  Another function of program evalua-
  tion is to help determine how the
  program should evolve over time to
  meet changing needs."
      —Colorado Department of Public
               Health and Environment
reduced toxics by 65 percent.
Twenty firms that received OTA
assistance eliminated 1,250,000
pounds of chemical use through
TUR modifications. OTA technical
assistance recipients reduced an
average of 45,000 pounds per
chemical targeted. At seven firms,
OTA documented a combined
annual cost reduction of $248,000,
or an average annual cost savings of
more than $35,000 per company.6
   Western New York Economic
Development Corporation
(WNYEDC) also used an integrat-
ed approach to program measure-
ment.7 The purpose of
WNYEDC's PPIS grant was to
evaluate the effectiveness of a
county-level technical assistance
program, using the Erie County
Office  of Pollution Prevention
(ECOPP)  as a model. The grantee
attempted to quantify pollution
prevention and the associated eco-
nomic  benefits on a case-by-case
basis in order to assess  the impact
of the program. This effort focused
on companies to  whom the pro-
gram had provided onsite technical
assistance. ECOPP established a
routine call-back program for
onsite assistance clients.
                                     Measurement and Evaluation • 31

Approximately 6 months after a
site visit is completed, ECOPP
staff telephone a representative
from the facility and complete a
telephone survey designed for pro-
gram evaluation. Companies that
implemented ECOPP's technical
assistance recommendations,
achieved quantifiable economic
benefits,  and reduced or prevented
waste were asked to be the subject
of case studies.

    In addition to these quantita-
tive self-evaluation efforts,
WNYEDC retained a private com-
pany to review and independently
evaluate the  efficacy of each ele-
ment of the  program, and to pro-
duce an evaluation report of the
results. This outside contractor
measured a range of elements,
   Perceived  clarity of technical
   information provided by
•  Quality of ECOPP's service;
•  Implementation rate of the pro-
   grams recommendations; and
   Perceived waste reductions as a
   result of the programs assistance.

    This information was gathered
both through telephone survey
questions and a focus group meet-
ing, which entailed a brainstorming
session of 12 former and ongoing
ECOPP clients from a cross section
of industry groups.

    Overall, 77 percent of the sur-
vey respondents had, at the time of
the survey, implemented at least
one of the recommendations made
by ECOPP representatives. Sixty-
eight percent of the respondents
perceived a reduction in the
amount of waste generated, while
43 percent perceived a reduction in
operating cost. In addition to the
recommendations implemented to
date, 78 percent of the respondents
indicated that they anticipate
implementing ECOPP recommen-
dations in the future.
B.2 Evaluation of
      Specific Services

   Some PPIS grantees evaluate
priority services such as technical
assistance or outreach. These evalu-
ations are more limited in scope
than overall evaluations, and often
focus on a single area of service
delivery. To evaluate technical assis-
tance services, some grantees con-
duct spot assessments and followup
visits to client companies. These
onsite visits can provide valuable
information about the implementa-
tion rate for a technical assistance
program's pollution prevention rec-
ommendations, as well as specific
data on waste reductions  and cost
savings, useful for the development
of case studies. Other benefits of
this approach include the deepen-
ing of the relationship between the
state and the  facility, an opportuni-
ty to help the facility overcome dif-
ficulties implementing pollution
prevention methods, and motivat-
ing the facility to implement addi-
tional measures.
   Grantees  also evaluate the
quality of technical assistance and
other services such as workshops
or training sessions by surveying
clients. This approach enables the
grantee to assess whether or not
priority services are perceived as
useful and sometimes document
cost savings and waste reduction.
Program managers can use the
results of the assessment to make
changes in services to better meet
client needs. Neither of the above
approaches are as resource-inten-
sive as a comprehensive evalua-
tion. On the other hand, these
evaluations do not provide the
same level of detail and documen-
tation as a comprehensive evalua-
tion, particularly for cost savings
or pollution reductions. Examples
of states that have conducted eval-
uations of specific program ser-
vices include Pvhode Island, Iowa,
Missouri, Alaska,  Colorado, and
New Jersey.
   The Rhode Island DEM used
PPIS monies to conduct technical
assistance assessments at 125
Pvhode Island companies.  Each
company visited received a written
report listing pollution prevention
options available, including process
and operational changes and recov-
ery/reuse technology. Once a
company's projects started, DEM
continued to periodically visit the
facility to check on operations and
note improvements. Approximately
40 to 50 percent of the companies
DEM assisted implemented source
reduction measures.
   Many companies achieved sub-
stantial cost savings as a result of
DEM's technical assistance. For
example, a jewelry manufacturer
realized an annual savings of
$26,000 in feedstock, treatment,
and disposal costs by implementing
a recommendation to replace
trichloroethylene with an aqueous
cleaner. Similarly,  a fastener manu-
facturer anticipates saving $17,000
                                      Measurement and Evaluation • 32

annually by changing its paint mix-
ing process.8
   The Iowa Waste Reduction
Assistance Program (WRAP) also
evaluated its technical assistance
efforts quantitatively and produced
a series of case studies containing
the results. Program staff visited 16
client companies' facilities by prior
agreement and interviewed respon-
sible officials  to obtain as much
detail on successful pollution pre-
vention projects as was feasible. A
seventeenth client was a Governor's
Waste  Reduction Award winner,
and WRAP used this client's award
application to obtain information
about its pollution prevention
efforts. WRAP compiled the pollu-
tion prevention results of 14 com-
panies into 32 case studies.9
Together, these companies showed
a recurring cost savings of $1.5
million per year and reduced over
10,000 tons of waste per year. A
sample WRAP case study appears
on page 34.

   As  seen in Chapter III, PPIS
grantees commonly conduct out-
reach activities, such as workshops
and presentations. Grantees indicat-
ed that evaluating these activities
helps them gauge the effectiveness
of their targeting efforts, as well as
the level of customer satisfaction
with the events. Several grantees,
such as the University Extension at
the University of Missouri-
Columbia,  distribute questionnaires
or surveys to workshop attendees to
evaluate the workshops' impact.
   The program used its PPIS
funds to  conduct three 3-day
courses based on a model devel-
oped by EPA. Twenty-eight repre-
sentatives from manufacturing
organizations, government agen-
cies, and the armed forces attended
the workshops. At the end of each
course, participants completed an
evaluation form which asked atten-
dees such questions as:
•  "Which parts of the course will
   be most useful?"
   "What subject matter would you
   recommend be added to the
   "Would you recommend this
   course to other professionals?"

    University Extension then
compiled all responses and pro-
duced an evaluation summary for
each workshop. This process
allowed the grantee to gauge the
perceived usefulness of the train-
ing course and make improve-
ments to course content.

    Several PPIS grantees also use
short survey forms to evaluate spe-
cific aspects of their programs. For
example, the Alaska Department of
Environmental Conservation devel-
oped a one-page questionnaire
asking respondents to evaluate the
usefulness of assistance and infor-
mation that the program provides.
The Colorado Department of
Public Health and Environment
(CDPHE) sent a multiple-choice
survey to businesses that had used
CDPHE's pollution prevention
library. Similarly, the New Jersey
Institute of Technology (NJIT) dis-
tributed a two-page survey asking
recipients of technical  assistance ser-
vices to  evaluate their experiences
with the program. New Jersey's sur-
vey results showed that 83 percent
of the program's clients ranked
NJIT's service between very good
and excellent, and over half of the
respondents found that the pro-
 Rhode Island DEM
 Technical Assistance

 Total amount of waste reduced:
   3,375,000 pounds liquid waste
   20,800 pounds solid waste
gram's technical recommendations
were very helpful.
   These measures of effectiveness
are valuable to the grantees in that
they help program managers under-
stand the perceived benefits of the
services delivered.
B.3 Measures of
      Activity Level

   The majority of state pollution
prevention programs account for
resources expended simply by
tracking the level of activity of the
program. This approach includes
tracking the number and types of
assessments completed, the size and
types of audiences at presentations,
or the number of phone calls for
assistance received. Some programs
also examine the number of
newsletters written, facilitywide
permits granted, grants dispersed, or
case studies generated. For formal
reporting, grantees also add narra-
tive descriptions of accomplish-
ments. Such an  accounting of
resources fills  legislative reporting
   Examining the quantities of ser-
vices a program provides is a rela-
                                     Measurement and Evaluation • 33

lively simple process that does not
require the same level of energy or
resources as an overall program eval-
uation or evaluation of specific ser-
vices. The disadvantage of this
approach is that it does not enable
the program to assess environmental
results nor the quality of services.
Measures of PPIS grantees' activity
levels from 1989 to 1993 can be
found in Chapter III.
C.  Improving Future

   EPA's success in measuring the
effectiveness of the grant program
depends, in part, on the states' abil-
ity to measure their own progress.
In turn, their ability to measure
progress depends on the ability
and/or willingness of participating
facilities to measure pollution
reductions.  EPA began its effort to
improve measurement and evalua-
tion by writing this study, which
documents  current efforts. Grantees
identified barriers to measurement
during the course of EPA's study.
Barriers identified by the grant
recipients include the following:

  Limited time and resources.
  During the early development of
  state pollution prevention pro-
  grams, the states devoted little
  effort to evaluating the effective-
  ness of program elements. States
  focused their limited resources
  on program delivery, rather than
  on program evaluation. While
  some of the mature  programs
  have now begun to evaluate their
  programs, developing programs
  may not have the resources to
  conduct full-scale evaluations.
  Sample WRAP Case Study
  Company: Douglas and Lomason Company
  Product/Industry: Automotive hardware
  Waste stream: Wastewater and sludge
  Modifications: Source reduction/technology
  changes and procedural changes. Eliminated
  zinc phosphating processing and improved
  autophoretic deposition process. Improved
  wastewater treatment operation.
  Benefits:  Reduced wastewater treatment and
  sludge disposal costs, and eliminated the
  materials cost of an entire process. Saved
  over $145,000 per year.
  Opportunity: Douglas and Lomason manu-
  factures automotive hardware for several
  national accounts.  The company requested
  that WRAP perform an onsite assessment to
  assist it in implementing a waste reduction
  program. Previously many parts and sub-
  assemblies were coated in a zinc phosphating
  process that involved multiple stages and
  used immersion tanks. The process was cost-
  ly, experienced some operational difficulties,
                and generated considerable wastewater and
                sludge that required treatment and disposal.
                Change: Douglas and Lomason eliminated
                the zinc phosphating process by changing the
                manufacturing process and adding protective
                measures. The wastewater and sludge from
                this process are no longer being generated,
                and the  equipment and tanks are being
                removed. The company also finalized options
                to reduce the usage and sludge generation in
                an existing  autophoretic deposition coating
                Savings/Benefits: The elimination of zinc
                phosphating has drastically reduced the  load
                on the in-plant wastewater treatment facility
                and thus reduced its operating costs. The
                reduction in treatment operating costs  and
                sludge disposal costs is approximately
                $20,000 per year. The material cost savings
                for eliminating the process totals over
                $125,000 annually. Improvements to the
                autophoretic deposition process have reduced
                sludge generation by 85 percent.
                                 Measurement and Evaluation • 34

  Linking reductions to elements
  of state pollution prevention
  programs. Isolating a grantee's
  efforts from overall influences
  that encourage waste-reducing
  behaviors is difficult. For exam-
  ple, much of the pollution pre-
  vention process originates in the
  private sector, making it difficult
  for state programs to measure
  overall  results derived solely from
  their PPIS-funded initiatives.
  Obtaining data from facilities
  on pollution reductions. Some
  facilities that receive technical
  assistance from the state are
  reluctant to share information
  on results obtained. Such facili-
  ties view this information as
  confidential, proprietary infor-
  mation. Other facilities lack the
  time and resources to measure

  Use of unsuitable data. Certain
  methodologies used by the states
  may yield inconclusive results.
  Some PPIS grantees, for exam-
  ple, attempt  to  evaluate their
  programs using overall state
  quantitative data on emissions
  and wastes, such as the TRI.
  This type of measure, however,
  may not accurately consider the
  possibility of multiple causes for
changes in generation or release
rates, such as:
— Fluctuations in production
   levels or economic activity;
— New treatment techniques
   that reduce the amounts
   reported while leaving gener-
   ation rates unchanged;
— Increases in overall education
   efforts and awareness of pol-
   lution prevention;
— Changes that shift releases to
   different media; and
— Material substitutions that
   may result in new types  of
   wastes or releases that are reg-
   ulated differently or not at all.
Lack of measurement method-
ologies and EPA guidance.
Given that it is difficult to mea-
sure something that does  not
exist (i.e., pollution not made),
states have had trouble develop-
ing measurement methodologies.
A number of PPIS grantees cited
lack of EPA guidance on mea-
surement as an impediment to
program evaluation. Specifically,
grantees believe that EPA did
not provide adequate direction
for measuring progress outside
the traditional "bean count"
   methodology used by other
   media programs.

   While EPA cannot address all
of the barriers described above, it
is making efforts to help grantees
measure progress. In recent years
EPA has provided evaluation assis-
tance to an increasing number of
programs. The Agency will contin-
ue to increase its measurement
support to the states in the future.
   For example, in FY96,  EPA
plans to narrow PPIS award crite-
ria to fund states to develop mea-
surement methodologies.
Additionally, EPA plans on pilot-
testing block grants to states that
will enable the states to measure
progress according to environmen-
tal performance, rather than activ-
ity measures alone.  Over time, as
the states gain more experience
and knowledge about measure-
ment and begin sharing this infor-
mation, EPA will learn  more
about what works and what does
not work. EPA will then facilitate
the exchange of information on
lessons learned between the states
to improve subsequent measure-
ment efforts.
1 National Association for Public Administration, A New Direction for
 EPA, p. 168.
2 National Association for Public Administration, A New Direction for
 EPA, p. 169.
3 National Association for Public Administration, A New Direction for
 EPA, p. 168.
4 Wigglesworth, D.T., ed. 1993. Pollution prevention: A practical
 guide for state and local government. Boca Raton, FL: Lewis

5 Figures based on telephone interview with Alabama DEM staff.
6 Massachusetts Office of Technical Assistance for Toxic Use
 Reduction. 1994. The Central Massachusetts Pollution Prevention
 Project summary report.
                7 Further details of measurement procedure and results may be
                  found in the Erie County Pollution Prevention Program evaluation
                  (April 1993).
                8 More information about these examples and other Rhode Island
                  case studies are available in Pollution Prevention in Rhode Island:
                  Case Studies of the Rhode Island On-Site Technical Assistance
                  Program, a document published by the Rhode Island Department
                  of Environmental Management, Office of Environmental
                9 Further examples of pollution in Iowa may be found in Pollution
                  Prevention Works for Iowa: Case Studies, an April 1993 document
                  published by the Iowa Department of Natural Resources.
                                       Measurement and Evaluation  • 35

                            Chapter V
                                  Case  Studies
          This chapter explores in detail how the PPIS grants influenced the establishment
          of comprehensive pollution prevention programs in five states. These in-depth
          case studies examine how the PPIS grants were integrated into state pollution
          prevention programs as a whole and highlight the effectiveness of the grants in
          building infrastructure and self-sustaining programs. As in previous chapters of
this report, this chapter does not seek to describe  a preferred state program model nor
compare different approaches undertaken by the states. Rather, the purpose of the chap-
ter is to showcase several state pollution prevention programs and describe the influence
of PPIS funding in each state.
   EPA designed the grant  program to be flexible to meet different state needs.  States
defined the type of program organization that works best for them and the best method
of building a  sustainable  program.  Thus,  the  states  highlighted (Delaware, New
Hampshire, New Jersey, North Carolina, and South Dakota) differ in a number of ways.
For example, some states implement their programs from a centralized office in the state
regulatory agency (e.g., North Carolina, Delaware). Other states have used a decentral-
ized approach to structure their programs. South  Dakota, for instance, implements  its
grant  activities through the media programs  and partnerships with local  agencies.
Another difference between the states is the method used to secure future funding. While
New Jersey and North Carolina fund their programs through fees on waste generation,
New Hampshire is trying to secure future funding through general funds. Other states,
such as South Dakota, are trying to integrate pollution prevention into the state regula-
tory agency so that future funding is not needed. While these different approaches to pro-
gram implementation may raise questions as to which methods are the most effective, this
report limits the discussion to recounting how states developed their pollution prevention
programs and whether they  achieved the initial PPIS program goals established by EPA.
                      Case Studies i 37

                         A. Summary of  Findings
                            This section summarizes the findings of the case study states, examining PPIS-fund-
                         ed activities in light of the grant program's goals. As described in Chapter I, EPA estab-
                         lished the following goals at the outset of the program:
                          • Empowering states to build a pollution prevention infrastructure.
                            Learning from  and  building upon  innovative means of implementing pollution
                            prevention at both state and facility levels.
                            Supporting states in establishing and expanding pollution prevention programs.
                          • Providing resources for pollution prevention technical assistance and training.
                          • Fostering federal and state information sharing and communication.
                         A.1 Building a Pollution  Prevention Infrastructure
                            PPIS provided seed money to the states to  develop sustainable pollution prevention
                         programs.  States used a variety of tools to institutionalize pollution prevention, including
                                           developing pollution prevention legislation and strategies, establishing
                                           advisory  committees,  designing information systems, and securing
Infrastructure development activities:      future funding.  For example, New Jersey and Delaware worked with
• Strategies and legislation               state legislatures to  develop pollution prevention legislation concur-
• Advisory committees                    rent with their  PPIS grant applications. Legislatures in both states
• Information systems                    enacted proposed legislation. The enactment of this legislation will
• Secure non-federal  funding             help ensure that pollution prevention remains a formal state commit-
                                           ment. The New Jersey legislation also established a fee on hazardous
                                           waste generation, thus providing a source of funding for the program.
                            Three  of the  case  study states, Delaware, New Hampshire, and  South Dakota,
                         established a task force or advisory committee  to guide the state's pollution prevention
                         program. These committees  have  brought together representatives  from state media
                         programs and other state agencies.  The committees guide the development of the state
                         pollution prevention program, foster communication between the media programs, and
                         help institutionalize pollution prevention. In Delaware, the advisory committee includes
                         other pollution  prevention stakeholders, such as universities, utilities, local governments,
                         and chambers of commerce. The meetings have created linkages between these different
                         organizations interested in promoting pollution  prevention,  ensuring that pollution
                         prevention activities continue long  after PPIS funding ceases.
                            Although New Hampshire and South Dakota have not enacted legislation, these states
                         have developed  pollution prevention strategies to ensure the implementation of pollution
                         prevention activities well into the future. These strategies also  help states to incorporate
                         pollution prevention into their regulatory programs. The strategies in both states make it
                         clear that pollution prevention is the  highest priority of the state environmental agency
                         and direct regulatory managers to design their programs to foster pollution prevention.
                                              Case Studies  38

   Another method of institutionalizing pollution prevention is to develop the structure
within the state to support pollution prevention. North Carolina used PPIS funding to
develop an integrated management system to link all of the environmental databases in
the state regulatory agency, including the Toxic Release Inventory (TRI), annual reports
from hazardous waste generators, permit information, and monitoring data. The agency
uses the system to compare data reported  by industry and assess opportunities for waste
reduction at specific facilities. The system also helps the pollution prevention program
target activities, including technical assistance, training, grants, research, and demonstra-
tion projects, to high-priority industries in the state.
   Since the outset of the program, PPIS has  encouraged states to develop permanent
sources of funding within the state. Given that state legislatures  across the country have
begun cutting back funding for all nonmandated programs, the case study states demon-
strate that they are making inroads to securing permanent funding. To receive the PPIS
grant, each state has secured matching funds of 100 percent  (half of the total cost of the
grant) to support program activities. In addition, New Jersey and North Carolina have both
secured future funding from their state legislatures to continue program activities.
   Delaware currently provides funding for two staff in the pollution  prevention pro-
gram. In the future, Delaware plans to leverage additional resources by working with the
NIST-funded  Manufacturing Extension Partnership center in the state.
   New Hampshire currently has a bill pending in the state legislature to fund staff posi-
tions in the Department of Environmental Services. The state is also evaluating the fol-
lowing options:
   Grant flexibility. Use a portion of each media or program grant to  create a pool of
   funds to support multimedia pollution prevention activities. Alaska and  New York
   have successfully used this approach.
   Small Business Technical Assistance Program (SBTAP). At least partial funding for
   pollution prevention assistance efforts  could be obtained through proposed funding
   mechanisms in the Clean Air Act, through the SBTAP.
   Pollution Prevention Planning/Toxics Use Reduction  (TUR)  Law. Passage of pol-
   lution prevention planning by businesses could provide for the set-up and operation
   of a technical assistance program without a self-sustaining, fee-based system.
   Other methods. The state is investigating other options for supporting  pollution pre-
   vention,  such as environmental block grants with a pollution prevention component,
   state general funds, existing funding sources currently used  for cleanup and remediation,
   and permit fees.1
   South Dakota is not currently seeking future funding. Rather, the state plans to focus
on integrating its pollution prevention program into the regulatory structure, so that a
special pollution prevention program would no longer be needed. The state envisions that
pollution prevention activities will be carried out through media programs, county gov-
ernments, and other partners. Furthermore, the state hopes that its educational efforts
will instill the value of pollution prevention in students and  teachers to ensure its future.
                                           Case Studies   39

                      A.2 Implementing Innovative Approaches to  Pollution
                         The case studies demonstrate the innovative approaches that PPIS supports to  offer
                      incentives to target groups to reduce waste, including voluntary challenges to businesses,
                      grants, and recognition. The states also used innovative approaches to reduce barriers to
                      preventing pollution,  including those prompted by regulatory requirements, limited
                      technical information, and research gaps. Delaware established a voluntary challenge pro-
                      gram (modeled on EPA's 33/50 program) to encourage industries to reduce the amount
                      of toxic chemicals they emit. New Jersey instituted a Governor's Award Program to rec-
                      ognize the achievements of businesses that successfully reduce waste and other  organiza-
                      tions and people that  have furthered pollution prevention in the state. North Carolina
                      offers challenge grants to industry to  reduce waste.
                         To reduce cross-media transfer of pollutants, possibly prompted by regulatory require-
                      ments, New Jersey and Delaware conducted demonstration projects to test the feasibility
                      of issuing industrial facilities a facilitywide permit. When issued, these permits will include
                      all regulatory requirements of the air, water, and waste programs. The states are testing
                      these permits to gauge their administrative feasibility and to assess their effectiveness.
                         North Carolina conducts  pollution prevention research, in conjunction  with the
                      Pollution Prevention Research Center at North Carolina State University, to provide
                      innovative solutions to persistent pollution problems at North Carolina businesses.
                      A.3 Establishing and Expanding  Pollution Prevention
                                           Four of the five states whose case studies are featured—Delaware,
                                        New Hampshire, New Jersey, and South Dakota—had limited pollu-
Four Of the five States Whose case       tion prevention activities under way but no sustainable pollution pre-
Studies are featured—Delaware,         vention program in place prior to receiving PPIS funding. In all of
New Hampshire  New Jersey and       these states, PPIS provided the seed money to establish pollution pre-
South  Dakota—had limited pollu-         vention programs.
tion prevention activities under              North Carolina, one of the first states to establish a pollution pre-
way but no Sustainable pollution         vention program, used PPIS funding to expand its activities. PPIS
prevention program in place prior         funding enabled the state to better target pollution prevention tech-
tO receivina  PPIS fundina                nical assistance by developing  an information management  system
                                        that  integrated  all of  the state's  environmental databases,  and to
                                        expand technical assistance activities  in conjunction with a media
                      program. In sum, each case study demonstrates that PPIS funding supported the states in
                      establishing or expanding their pollution prevention programs.
                                             Case Studies  40

                                                                          NJTAP conducted more
A.4 Providing  Resources for  Technical
     Assistance and Training                                   assistance audits with PPIS
                                                                          funds. Including all funding
   All  of the states highlighted in the  case studies have provided onsite              . MJTAP ho
technical assistance to targeted groups to help them prevent pollution in
                    ,   ^               .,      rrfr     r        assisted nearly 200
innovative ways. South Dakota is promoting better farmland and ranch
             ,     run         r>  •    TU-     •     •          u       companies.
management  through the Bootstraps Project. 1ms  project aims to teach
farmers and ranchers  that sustaining a profitable operation  is directly relat-
ed to using practices that maintain or improve the environmental health of
range and crop  lands. Under Bootstraps, each family learns how to complete a natural
resource inventory for their ranch or farm, develop  a management plan, and select the
best  management practices  (BMPs)  to  implement  the plans.  South  Dakota provides
technical assistance to help select and implement the BMPs to both protect the environ-
ment and promote economic stability. Delaware targeted the printing industry as a high-
priority industry. The state has developed a fact sheet to help printers  reduce waste and
offers site assessments to all printers in the state.  New Hampshire  conducted nearly 40
site assessments  to offer businesses innovative solutions to reducing waste.
   The New Jersey Technical Assistance Program (NJTAP) conducted more than  75
onsite  technical assistance audits  with  PPIS funding. Including  all  funding sources,
NJTAP has assisted nearly 200 companies. While NJTAP responds to  any business that
requests services with  either a phone call or an onsite visit, it also targets high-priority sec-
tors  in accordance with the state  pollution  prevention law. North Carolina  identified
appropriate small business categories and developed and distributed informational mate-
rials  to the targeted industries. During this process, the Office of Pollution Prevention
formulated training materials and  identified  future research needs for  pollution preven-
tion  in small businesses.
A.5 Fostering Information  Sharing and  Communication

   The case studies demonstrate that PPIS funding helped the case study states share
information with each other and other states. For example, some of the case study states
used their funding to transfer lessons learned from their demonstration programs to other
states. South Dakota has made presentations to North Dakota to explain lessons learned
from its innovative Bootstraps Project and plans to do the same in Colorado, Nebraska,
Missouri, and Kansas. South Dakota has also received inquiries from foreign govern-
ments.  New  Jersey shared information on  its facilitywide permitting project  with
Delaware as Delaware designed a similar project. In addition, as New Jersey formulated
its technical assistance program, it consulted North Carolina for  advice on how to design
the program. Without PPIS funding, states would be operating in a vacuum. By sharing
lessons learned with each other,  the states avoid  duplication of effort, as  well as save
money, time,  and other resources.

   States share information with EPA through a variety of vehicles, including semiannu-
al progress reports,  final grant reports, conferences, and publications. Together, the states
featured in the case studies submitted more than 40 reports to  EPA to document their
                                          Case Studies • 41

progress implementing pollution  prevention activities.  From  these reports, EPA learns
about grantee accomplishments, as well as what obstacles grantees encountered during
implementation and how they overcame the obstacles. EPA can then compile data on
grant activities and share this information with other states. States also share the publica-
tions created under the grant with EPA. For example, Delaware shares all new case stud-
ies  on its  information clearinghouse with EPA's  Pollution  Prevention  Information
Clearinghouse (PPIC).
   PPIS has also enabled grantees  to sponsor conferences to share information. Although
not highlighted in the case studies, EPA has consistently supported the states to cospon-
sor semiannual conferences of state pollution prevention programs with the National
Pollution Prevention Roundtable.
A.6 Conclusion
   In sum,  the case studies demonstrate that PPIS has achieved the initial objectives
establsihed at the outset of the grant program. States are making efforts to build sustain-
able programs by writing legislation, developing pollution prevention strategies, securing
independent funding, and incorporating the pollution prevention ethic throughout state
governments. The states are providing innovative solutions to persistent pollution prob-
lems and providing direct technical assistance to small and medium-sized businesses, as
stipulated by Congress. Furthermore, since the inception of the program states are shar-
ing information and trying to leverage resources with other environmental organizations.
   Prior to the inception of the PPIS program, very few organizations provided environ-
mental assistance. Only a handful of states offered  any kind of technical assistance. PPIS
funding has  dramatically increased the number of states offering outreach, training,  and
technical assistance.  Today, several other organizations have begun providing environmen-
tal assistance, many of them with a pollution prevention focus, including:
   Small Business Administration  (SBA) funds Small  Business Assistance Centers
   throughout the country that provide technical assistance to small businesses.
   National Institute of Science and Technology (NIST) funds the Manufacturing
   Extension Partnerships (MEP), also located  in a number of states.
 • Small Business Development Centers provide technical assistance to small business-
   es to meet the requirements of the Clean Air Act Amendments emphasizing pollution
   EPA's Office of Enforcement and Compliance Assistance (OECA) is funding four
   compliance assistance centers.
   Given  this growing awareness  of groups providing environmental services, the FY95
PPIS grant recipients are required to leverage the capabilities of other organizations in
their states.  Such coordination will ensure that there is no duplication of effort and will
help to spread pollution prevention information.
                       Case Studies  42

B. Case Studies

   Each case study begins with an overview of the state's pollution prevention program,
including the organization structure,2 program funding and budget, and any pollution
prevention  legislation or strategy in place.  The case studies  then describe the different
activities supported by the grants as well as  state accomplishments related to  these activ-
ities. Finally, the case studies assess the impact of the PPIS grants on the state program
and describe future challenges for each state. As described above, EPA selected the fol-
lowing states in five EPA regions for the case studies:3
   Delaware (Region 3)
 • New Hampshire (Region 1)
   New Jersey (Region 2)
   North Carolina (Region 4)
 • South Dakota (Region 8)
B.1  Delaware
   Delaware established its pollution prevention program in June 1990 with the passage
of the Waste Minimization/Pollution Prevention Act.  The mission of the Delaware
Pollution Prevention Program (DPPP), as specified in the act, is to demonstrate and facil-
itate the potential for pollution prevention in Delaware by:
 • Providing technical assistance to targeted industries
 • Providing education and outreach in waste minimization and pollution prevention
 • Developing a statewide recycling program
   Organizational  Structure. The  DPPP, located  in the  Department  of Natural
Resources and Environmental Control (DNREC), focuses on education, technical assis-
tance, and financial incentives to help businesses and residents take actions that will not
only improve environmental quality but also save  money. The initial technical assistance
arm of DPPP was the Delaware Waste Reduction Assistance Program (DELWRAP) at the
University of Delaware. The technical assistance program has since moved to the DPPP.
DPPP also has joint activities with the Delaware  State Chamber of Commerce, the
Delaware Economic Development  Office, and  the Departments of Transportation and
Administrative Services. Each of these organizations helps to implement  the pollution
prevention strategy.  Exhibit V-l summarizes the  pollution prevention infrastructure in
   Program Funding and Budget. PPIS funds, including the state match, provide over
80 percent of DPPP's funding, including funding for  two staff positions.  Coastal man-
agement and  nonpoint source grants fund the  remainder of the program. Exhibit V-2
summarizes FY95 funding sources.
                                          Case Studies  43

Exhibit V-
                    During the period of this study, Delaware received two PPIS grants. The first grant,
                 Development of a Pollution Prevention Program for the State of Delaware, was awarded in
                 June 1990. The grant established a multimedia, nonregulatory pollution prevention pro-
                 gram to demonstrate and facilitate the potential for pollution  prevention and waste
                 reduction in Delaware.  EPA awarded the second grant, Enhanced Pollution Prevention
                 Program, in January 1993- The purpose of this grant was to integrate pollution preven-
                 tion into the media-specific regulatory programs and to prepare a pilot multimedia per-
                 mit for one facility. Exhibit V-3 summarizes Delaware's grants.

                    Strategy and  Legislation. As  described above, Delaware  enacted  the Waste
                 Minimization/Pollution  Prevention Act in 1990. In addition to establishing DPPP, the
Delaware Chamber of
Key Activities
• Industry roundtable co-sponsor
• Outreach
Delaware Economic
Development Office
• On-line information
• Clearinghouse
• Financial assistance
Delaware Solid Waste
• Recycling centers
Department of
Administrative Services
• State office paper recycling
• Green procurement policy
Department of Natural
Resources and
Environmental Control
• Implementation committee
• Strategy/Legislation
• Industry roundtable
• Technical assistance
• Outreach and education
• Voluntary reduction program
• Training
• Regulatory integration
• Multimedia permitting project
• Waste exchange
• Program evaluation
Department of
• Tree recycling
• Reuse of fly ash
NIST Manufacturing
Extension Partnership
• Technical assistance
• Training courses
• Demonstrations
University of Delaware
• Research
• Seminars
• Teleconferences
                                        Case Studies i 44

         Exhibit V-2
         FY 1995 Pollution Prevention Program Funding Sources
          Coastal management/nonpoint source
          PPIS—EPA portion
          PPIS—State match

          Total Funding

act also declared an environmental policy for the State of Delaware in accordance with
EPA's waste management hierarchy:
     Waste that is generated should be, in order of priority, reduced at its source,
     recovered, reused, recycled, treated, or disposed of so as to minimize the pre-
     sent and future threat to human health and the environment.4
   The act also required DNREC to establish an implementation committee  to guide
program development and ensure implementation  of the waste management hierarchy.
The  act stipulates that the implementation committee must consist of representatives of
a wide range of groups, including state and local governments, nonprofit organizations,
utilities, and academia.
Exhibit V-3
         PPIS Grant Summary
                                        Year     Amount
Development of a Pollution Prevention
Program for the State of Delaware
Enhanced Pollution Prevention Program
Total Funding
Activities Funded by PPIS Grants

   PPIS supports a wide range of activities at DPPP in the areas of infrastructure devel-
opment, technical assistance, education and outreach, and regulatory integration:
   Infrastructure development. PPIS-supported activities to build  Delaware's infra-
   structure include an implementation committee, an industry roundtable, and a vol-
   untary program that challenges businesses to reduce hazardous emissions.
   Technical assistance. Activities supported by PPIS funding include onsite audits, an
   information clearinghouse, and an internship program.
   Outreach and education. DNREC conducts a wide range of activities to promote
   pollution prevention concepts to businesses, citizens, local governments, and farmers.
                                          Case Studies  45

Implementation Committee
• Department of Administrative
• Department of Agriculture
• Delaware Development Office
• Department of Public Instruction
• Department of Transportation
• Delaware Solid Waste Authority
• University of Delaware
• Delaware State College
• Delaware Technical and Community
• State Chamber of Commerce
• Central Delaware Chamber of
• Maryland/Delaware Solid Waste
• League of Women Voters
• Delaware League of Local
• Chemical Industry Council
• D&J Recycling
• Delmarva Power & Light
   Activities include developing outreach materials, giving presentations and workshops,
   and developing curriculum materials.
   Regulatory integration. PPIS  supports the integration of pollution prevention into
   Delaware's regulatory program by training media program staff in pollution prevention
   techniques, a pilot project to assess facilitywide permitting, and regulatory review.
   These activities are described further, below.
   Implementation Committee.  PPIS  funding  allowed  Delaware to  establish the
Pollution Prevention Implementation Committee, which oversees the activities of DPPP
and guides  the program's future direction. The Implementation Committee consists of
members from a wide range of backgrounds, including other state agencies, industry,
civic and environmental organizations, and faculty from the University of Delaware
College of Engineering. The committee selected the first two target industries and iden-
tified locations for  technical assistance utilizing  SARA Title III Section 313 data. The
committee has met on a monthly basis from 1990 through 1992 and quarterly from 1992
through 1994.
   Industry Round-table. DNREC and  the Delaware Chamber of Commerce estab-
lished the Pollution Prevention Industry Roundtable in August 1991  to create a forum in
                     which companies could learn from each other and share experi-
                     ences  and  information on pollution prevention and recycling.
                     Meetings have included tours of facilities  (including  Zeneca
                     Pharmaceuticals and DuPont Edge  Moor Plant)  and presenta-
                     tions on waste reduction programs. Membership has expanded
                     from eight participants at the first meeting to an average atten-
                     dance of  30  industrial  facility  representatives  per meeting.
                     Currently,  the roundtable has 115  members that represent 62
                     Delaware companies. The roundtable meets on a quarterly basis.
                        Voluntary Reduction Program. Modeled after EPA's 33/50
                     program, DNREC  has  established a voluntary program to
                     encourage manufacturers to reduce the amount of toxic chemi-
                     cals they release into the  environment. The goal of the program
                     is to reduce toxic emissions  as reported under the TRI by 50 per-
                     cent statewide by the end of 1995- Twenty Delaware companies
                     have agreed to participate in the program. Thus far, facilities par-
                     ticipating in the program have reduced emissions by 12 percent.
                        Onsite Assistance Audits. DELWRAP, and now the DPPP,
                     provides pollution prevention technical assistance to small and
                     medium-sized  companies on a voluntary,  nonregulatory,  and
                     confidential basis. According to the DPPP, technical assistance
                     focuses on smaller companies  because they generally do not have
                     the economic or technical resources  necessary to evaluate pollu-
                     tion prevention opportunities.
                        DELWRAP  initially targeted the printing industry and later
                     expanded to include all manufacturing options. To publicize the
                     program and  encourage  participation by Delaware companies,
                     DELWRAP conducted a number of outreach activities. These
                                             Case Studies  46

activities included radio interviews, articles in local newspapers
and business newsletters, and a mailing to all 77 printers in the
state. The mailing included a letter, a brochure describing DEL-
WRAP, and an application for technical assistance. Other meth-
ods of marketing the program included  publicity through the
Delaware State Chamber of Commerce, trade shows, and refer-
rals from DNREC's regulatory program, where appropriate.
   DELWRAP  completed 17 onsite technical assistance visits
and responded to 30 technical inquiries. Each facility received a
report outlining waste reduction recommendations and an offer
of followup  and assistance  on implementation. An  oversight
committee  (consisting of  officials from the University  of
Delaware, DNREC, and  the  Delaware State Chamber  of
Commerce) evaluated the program by reviewing the  pollution
prevention assessment reports that were  given to clients and
comparing them with reports written by other states. The com-
mittee concluded that the level of activity was comparable and
that the reports were well written.
   Information Clearinghouse. DNREC and the Delaware Development Office estab-
lished a waste minimization/pollution prevention information clearinghouse as part of
the Delaware  On-Line Database housed at the Delaware Development Office. The clear-
inghouse includes bibliographies and case studies sorted by standard industrial classifica-
tion (SIC) codes. DNREC updates the clearinghouse as new documents are added to its
pollution prevention library and as  new Delaware case studies  are received. DNREC
shares new case studies with EPA's Pollution Prevention Information Clearinghouse.
   Internship Program. In  coordination  with the University of Delaware, DNREC is in
the process of establishing an internship program for engineering students. Through this
program, interns will join DPPP staff on technical assistance  visits. At these visits, the
interns will provide their expertise and learn about pollution prevention in the process.
   Outreach Materials. Delaware used PPIS funds to create many outreach documents,
including fact sheets, manuals, and home audit kits. Pollution  prevention fact sheets for
the following industry sectors were developed:
 • Auto repair
   Dry cleaning
 • Chemical manufacturing (targeted to small manufacturers)
   Construction and demolition
 • Metal finishing
   General business
   The program developed  a Waste Reduction Self-Evaluation Manual to help businesses
conduct  self-assessments of pollution prevention opportunities.  To date, 82 businesses
have ordered copies  of the manual. In addition, DPPP has supplied copies of the manu-
al to DNREC regulatory programs. The program also sent promotional material  to tar-
geted groups. For example,  DNREC distributed 175,000 home audit kits to Delaware
Avoiding Duplication
DELWRAP tentatively identified the
plastics industry as a second target
industry for technical assistance.
DELWRAP surveyed 67 Delaware
companies in the  plastics industry to
gather data to develop the program. Of
the 22 responses received, most com-
panies were already  receiving assis-
tance from the Composite Center at the
University of Delaware. To avoid  dupli-
cation of effort,  DELWRAP decided not
to target the plastics  industry, but rather
provide assistance to any type of busi-
ness that requests its services.
                                          Case Studies • 47

homes through Sunday newspapers. Additionally, the Delaware Chamber of Commerce
publication, News, included a magazine insert that featured articles on DNREC pollu-
tion prevention activities and services for businesses, articles on DELWRAP, and articles
by companies on pollution prevention activities at their facilities. News has a statewide
circulation of 14,000.
   Workshops and Presentations. Delaware conducted several hundred presentations,
seminars, and workshops with the help of PPIS funds. These activities targeted specific
companies, schools, and community and government groups. Examples of topics
   Pollution prevention training for Delaware industries
   Promoting landfill alternatives
   Facility planning
   Twenty-three  attendees representing  17 companies  attended the  facility planning
workshop. After the workshop, DELWPvAP  contacted participants with a letter and a
phone call to answer any pollution  prevention  questions and  encourage them  to take
advantage of DELWPvAP technical assistance services. As a result of the workshop and
followup activities, 10 companies  requested onsite technical assistance audits. Six addi-
tional companies expressed a strong interest in DELWPvAP services and requested future
   Education. To provide early education on protecting the environment and  to help
instill a waste reduction ethic in Delaware's youth, DNPvEC developed a pollution pre-
vention curriculum for grades K-8. The curriculum ties  reducing, reusing, and recycling
into the basic curriculum subjects, such as history, science, and math. More than 300
teachers have been trained in using the curriculum since 1991. These  teachers have the
potential to reach more than 7,500 students each year.
   DNPvEC staff also use curriculum materials  during  outreach events, such as special
children's programs at schools, fairs, and festivals. To supplement the curriculum, the pro-
gram routinely publishes an environmental education newsletter for children.
   To address the special needs of day-care centers and preschools, DNPvEC purchased a
special waste reduction  curriculum for children ages 3 to 5. The curriculum is available
at all teacher learning and resource centers in the state.
   Reference Materials. DNPvEC has established a pollution prevention reference col-
lection in each of Delaware's libraries and bookmobiles. Books included in the collection
address water and energy conservation, household hazardous substances, environmental
consumerism, and nonpoint source water pollution.
   Training. PPIS funded DPPP to train DNREC staff in the fundamentals of pollution
prevention to enable staff to incorporate pollution prevention into their daily activities.
Approximately 50 regulatory staff, including scientists, engineers, and  senior managers,
attended the 1-day pollution prevention training course, and more than 30 staff from the
regulatory programs, including air, water, and hazardous waste programs, have attended
a 3-day course on pollution prevention assessments. DNREC also provides cross-training
to media program staff concerning the other regulatory programs.
   Facilitywide Permitting. A major initiative funded by the second PPIS grant is a pilot
project to evaluate the issuance  of multimedia permits in Delaware. A multimedia permit

                        Case Studies • 48

is a facilitywide permit that incorporates the requirements of the air, hazardous waste,
solid waste, and water pollution control programs. By issuing the permit on a multime-
dia basis, DPPP hopes to promote pollution prevention and avoid cross-media transfer of
pollutants in  the regulatory process.
   To implement the demonstration project, DNPvEC formed a multimedia focus group
consisting of staff from the air, NPDES, RCRA, solid waste, and pollution prevention
programs. The focus group contacted several states with experience in multimedia per-
mitting to learn about  their experiences. The focus group then invited a DuPont facility
to participate in the project. Following meetings with DuPont, the focus group decided
first to develop a mock permit for a fictitious company to work out the details of issuing
a multimedia permit.  DuPont assisted  in developing the mock permit. DNREC has
received the pilot project facility's permit application  and is currently working on pollu-
tion prevention opportunities with the facility prior to permit review.
   Regulatory Review. At the request of the NPDES  program, DPPP staff reviewed pro-
posed NPDES regulations  for opportunities  to  incorporate pollution prevention. The
revised regulations (currently in draft form) embrace the concept of pollution prevention
as the preferred waste management method and provide incentives for facilities to reduce
their discharges through pollution prevention. These draft regulations serve as a model
for many other states as they review their NPDES regulations.
Analysis of PPIS Impact

   Prior to PPIS funding, Delaware had no formal pollution prevention program. PPIS
funding has enabled the state to provide technical assistance and outreach, but perhaps
more importantly, Delaware has developed the infrastructure necessary to sustain DPPP
over time.
   Infrastructure. The passage of legislation concurrent with the PPIS grant application
was the first step toward institutionalizing pollution prevention in Delaware. PPIS fund-
ing created a network of people interested in instilling the pollution prevention ethic in
businesses throughout the state. The  implementation committee brought  together a
diverse group of individuals to steer state pollution prevention policy.  Implementation
committee meetings enabled participants  to  brainstorm  ideas, share information, and
link services. The industry roundtable and Voluntary Reduction Program cemented the
program links with  Delaware  businesses.  The Implementation Committee is actively
seeking funding for the program once PPIS funds are terminated. The legislature is also
considering  legislation that  would establish a state matching  grants program to assist
businesses with pollution prevention projects.
   Regulatory Integration. Delaware's activities currently focus on  the transition to
multimedia integration. A prime example is the multimedia permit pilot program, which
seeks to determine the feasibility of reorganizing the regulatory structure of DNREC.
DPPP has also formed a multimedia focus group within the agency to work on the bar-
riers to multimedia regulation. The program has worked with all of the media programs
and has trained  its entire staff in cross-media transfer issues. Finally, the technical assis-
tance program looks at all media when working with a facility to reduce waste generation.
                                           Case Studies  49

The small size of the programs and the centralized location of the staff makes coordina-
tion and communication easier.

   In addition to the multimedia activities of DPPP, the program is expending a signifi-
cant effort to  integrate pollution prevention into the regulatory programs of DNREC.
DPPP staff will join compliance inspectors from the hazardous waste, air, and water pro-
grams to help  identify pollution prevention opportunities and to inform facilities about
the services of DPPP DPPP has also helped draft NPDES permit regulations that include
pollution prevention incentives.

   As in most states, there  was limited  coordination between regulatory programs in
Delaware before the  formation of the DPPP. At  present, many lines of communication
have opened between the media programs, resulting in increased efforts to implement a
pollution prevention strategy and projects by all the major media programs (air, NPDES,
RCRA,  and industrial solid  waste). Enhanced communication  between the media pro-
grams is a major step toward integrating pollution prevention into the regulatory process.

   Program Evaluation. Currently, DPPP is struggling with the question of how to eval-
uate the success of a pollution prevention program. In its enabling legislation, DPPP is
required to report  activities  conducted to  the state legislature in an annual report. This
report is a narrative description of activities undertaken  and accomplishments  achieved.
The document does not attempt to measure actual pollution reductions. According to the
grantee, one difficulty is measuring any direct, quantitative results of its activities  when
companies generally do not share the results  of pollution prevention projects. Another
challenge is accurately attributing pollution prevention results  to DPPP efforts,  consider-
ing that pollution prevention information is available from multiple sources.

   Nonetheless, DPPP has evaluated several components of its program. For example, it
conducted a survey of the Pollution Prevention Industry Roundtable and considers atten-
dance at presentations and workshops an indication of its success at publicizing its work.
The study's findings include the following:
   Eighty-seven percent  of  respondents  stated that the programs  and services of the
   DPPP have been beneficial to their companies.
   Eighty-nine percent of the respondents  rated the industry roundtable meeting formats
   as "good" or "excellent."
 • Seventy-eight percent of respondents rated the information  exchange between com-
   panies as "medium" to "high."

   Additional publication of roundtable meetings was suggested by several respondents
as a way to increase membership.

   The technical assistance  program  evaluates the  quality  of its  services by compiling
followup questionnaires to the facilities.5  DELWRAP also  followed  up with workshop
participants to see if they would like additional assistance in implementing pollution pre-
vention activities. As described above, 10 out of 17 companies  requested that DELWRAP
conduct an onsite visit after  attending one of the workshops.  Six of the remaining seven
companies expressed an interest in receiving additional information.
                        Case Studies   50

Program Future

   To enable DPPP to focus on source reduction, the top of the waste management hier-
archy, DNPvEC  separated pollution prevention and  recycling  programs.  DPPP was
moved to the Office of the  Secretary to  enable  better coordination with programs
throughout DNREC. The two programs will continue to coordinate assistance efforts.

   Delaware currently provides funding for two DPPP staff. No additional  funding for
DELWPvAP was obtained; the  technical assistance function has been moved to the DPPP
and the NIST-funded Delaware  Manufacturing Alliance.  The reception to assistance
from the DPPP has been quite positive.

   DPPP believes its challenge for the future is to continue the program's existing inte-
gration efforts and to expand its assistance to greater numbers of small businesses in the

Andrea Farrell
Delaware Pollution Prevention Program
Phone:  302739-3822
Fax:    302 739-6242
                                          Case Studies • 51

                 B.2 New Hampshire


                    Organizational Structure. New Hampshire divides responsibilities for implementing
                 pollution  prevention activities  among several  organizational  units. Within the
                 Department of Environmental Services (DES) Waste Management Division is the New
                 Hampshire Pollution Prevention Program (NHPPP), a nonregulatory program that con-
                 ducts pollution  prevention workshops and provides onsite technical  assistance assess-
                 ments for businesses upon request. In addition, NHPPP staff provide technical assistance
                 over the phone  and maintain a library of information on new technologies, pollution
                 prevention products and vendors, fact sheets, and case studies, which are available to busi-
                 nesses and industries.  The department also has a full-time pollution prevention coordi-
                 nator in the Office of the Commissioner. The coordinator is responsible for pollution
                 prevention policy development and regulatory integration initiatives. Although not fund-
                 ed by the PPIS program, DES  also  maintains a Small Business Technical  Assistance
Exhibit V-4
               HIRE POLLUTION
Department of Environmental
— Office of the Commissioner
Key Activities
• Task force
• Regulatory integration
• Strategy
Department of Environmental
— Pollution Prevention Program
• Technical assistance (on and
  off site)
• Information clearinghouse
• Outreach materials
• Presentations and workshops
• Conferences
• Educational partnerships
• Recognition program
Department of Environmental
— Small Business Technical and
   Environmental Compliance
   Assistance Program
• Technical assistance
• Outreach materials
• Presentations
• Small business ombudsman
• Regulatory assistance
University of New Hampshire
— Pollution Prevention
• Pollution prevention curriculum
• Internship program
• Advisory committee
Business and Industry
Association of New Hampshire
— WasteCap
• Materials exchange
• Newsletter
• Technical assistance
• Presentations and workshops
• Onsite asssessments
                                       Case Studies  52

Program (SBTAP) in the Air Resources Division. SBTAP was established and funded
under the Clean Air Act to help small businesses meet and go beyond current and pro-
posed regulations.
   A Pollution Prevention Partnership with the  University of New Hampshire comple-
ments DES activities. The university is currently developing a pollution prevention cur-
riculum and coordinates a student internship program. Exhibit V-4 further describes the
roles of each organization.
   Program Funding and Budget NHPPP currently has a staff of 1.8 full-time employ-
ees and is still working under the original 3-year PPIS grant of $296,000. This funding
for the NHPPP is 100 percent federal funding and was awarded in September 1991. The
first grant was designed to formalize nonregulatory pollution prevention initiatives in the
DES with a pollution prevention program (NHPPP). EPA awarded  a second grant, A
Pollution Prevention Partnership, in October 1993- The purpose of this grant was to incor-
porate  pollution  prevention into the  higher education system and to provide an addi-
tional university-based, nonregulatory source for technical assistance in New Hampshire
via an internship program. Exhibit V-5 summarizes grant awards during the period of this
           Exhibit V-5
           PPIS Grant Summary
            New Hampshire                       1991        $296,000
            Pollution Prevention Program

            A Pollution Prevention Partnership       1993        $84,000

            Total Funding                                     $380,000
   Strategy and Legislation. Currently, there is a bill pending in the state legislature to
formally establish the pollution prevention program, mandate the offering of technical
assistance services, and  fund two positions. Prior to enacting any legislation, the state
incorporated pollution prevention goals into  DES's Strategic Plan and  developed a pol-
lution prevention strategy. The plan, released in early 1994,  articulates  the department's
mission statement, goals, objectives, and implementation schedule. The plan is intended
to shape DES's activities over the coming years.  Of the seven goals established by the
plan, the first goal is "to prevent,  minimize, and clean up environmental degradation in
order to protect public health, safety, and the natural environment." To implement this
goal, DES identified several objectives, including to "continually guide, educate, and pro-
vide technical assistance to those affected by the  department's  permitting  and other
requirements, with an emphasis on pollution  prevention."6
   In addition to  the  Strategic Plan, DES released a  pollution prevention strategy in
January 1995- The Pollution Prevention Strategy describes  the department's pollution
prevention goals, outlines existing pollution prevention activities,  and discusses and rec-
ommends actions on specific issues in the areas of infrastructure, targeting activities, out-
                                           Case Studies  53

Goal Statement
"It is the goal of the department to
promote pollution prevention actions
consistent with the definition as the
preferred option for meeting established
environmental quality goals. We recog-
nize,  however, that in some cases  pol-
lution prevention may not be feasible at
this time. In those cases,  the
Department will strive to ensure that
pollution prevention options are consid-
ered first, followed by recycling, treat-
ment, and disposal. Decisions that do
support efforts to prevent  pollution  at
the source of generation or release
should be re-examined periodically in
an effort to continually strive toward our
pollution prevention objectives."7
                      reach, and regulatory integration. Specific activities, including
                      timetables for completion, identified by the strategy include:
                        Develop appropriate pollution prevention outreach materials
                        for internal distribution.
                        Provide pollution prevention orientation training for all DES
                        employees (more than 80 percent complete).
                        Provide advanced pollution prevention training for appropri-
                        ate field and technical staff such as inspectors, permit writers,
                        and engineers.
                        Provide multimedia training for selected regulatory and tech-
                        nical assistance staff.
                        Reward employees who provide significant contributions to
                        pollution prevention efforts within DES.
                         The strategy also discusses the need for identifying long-term
                      funding of pollution prevention activities. It recommends that
                      DES examine several options for securing long-term funding:
                        Grant  flexibility. Use  a portion of each media or program
                        grant to create a pool of funds to support multimedia pollu-
                        tion prevention activities. Alaska and  New York have success-
                        fully used this approach.
 • Small Business Technical Assistance Program (SBTAP). At least partial funding for
   pollution prevention assistance efforts could be obtained through proposed funding
   mechanisms in the Clean Air Act, through the SBTAP.
   Pollution Prevention Planning/Toxics Use Reduction (TUR)  Law. Passage of a pol-
   lution prevention planning by businesses could provide for the set-up and operation
   of a technical assistance program without a self-sustaining,  fee-based system.
   Other methods. The state is investigating other options for supporting pollution pre-
   vention, such as environmental block grants with a pollution prevention component,
   state general funds, existing funding sources currently used for  cleanup and remedia-
   tion, and permit fees.8

Activities Funded by PPIS  Grants

   PPIS funds  have allowed New Hampshire to develop  a pollution  prevention infra-
structure, provide technical assistance to businesses, integrate pollution prevention into
the regulatory programs, and educate New Hampshire businesses, residents, and students
about pollution prevention. These activities are described further below.
   Infrastructure. PPIS-funded  activities to develop infrastructure include an agency-
   wide task force, the pollution prevention strategy document,  and strategic plan.
   Regulatory integration. Activities to incorporate pollution prevention into the regu-
   latory programs include identification of regulatory barriers to  pollution prevention,
   staff training, increasing coordination between the NHPPP and the regulatory offices,
   and  incorporating pollution prevention into some permits and enforcement settle-
   ments through Supplemental Environmental Projects (SEPs).
                                              Case Studies   54

   Technical assistance. PPIS funding enables DES to provide a range of technical assis-
   tance services to businesses, including onsite assessments and an information clear-
   Outreach and education. New Hampshire sponsors a wide range of education and
   outreach activities including conferences, a pollution prevention curriculum, a student
   internship program,  and an advisory committee. The NHPPP has also worked with
   the New Hampshire Department of Education to develop and provide teacher train-
   ing at the grade school level.
   Task Force. In May 1992, PPIS funds enabled DES to establish a multimedia pollu-
tion prevention task force to guide and integrate pollution prevention into all department
activities. Task force representatives consisted of staff from each
of the DES media programs (air, water, and waste) and included
a cross section of staff levels, including staff from technical,     Task Force  PurpOSG
enforcement, policy, and administrative positions. The task force     "JQ (Jjrgct  coordinate  and promote
identified the following objectives:                                 strategies  that prevent pollution of air,
   Facilitate information exchange among and between task force     land  and water Such Strategies
   members and related organizations.
 • Pursue, where appropriate, integration of pollution prevention     reduction,  waste minimization, and best
   measures directly into  the regulatory process  for air quality,     management practices to conserve nat-
   water quality (including surface water, ground water, and wet-
   ,    ,,     ,           &               .           .        ,     ural resources and protect human
   lands), and waste  management permits, inspections, and
     c                                                           health and the environment."9
   Establish a target list of pollution types and sensitive resources
   to be addressed through pollution prevention efforts, based on priorities established
   by air, water, and waste programs.
   Make recommendations in the area of pollution prevention technical assistance to be
   offered by the Department.
   Develop a pollution prevention strategy that recommends procedures and policies for
   implementing pollution prevention projects  and initiatives.
   The task force has achieved many of these goals. The task force has increased the
dialogue between the different media programs  and fostered the integration of pollution
prevention throughout DES, as described further below. Additionally, the task force com-
pleted the Pollution  Prevention Strategy, as described above, to further institutionalize
pollution prevention in the state.
   Barriers Study. The task force analyzed barriers to integrating pollution prevention
throughout  the department's regulatory programs.  To identify barriers, the  task force
researched barriers identified by the media program staff. DES also solicited information
on barriers from the regulated community. In a workshop sponsored by DES, 30 com-
pany representatives identified specific barriers to implementing pollution prevention  at
their facilities and ways the department could facilitate implementation of pollution pre-
vention projects. The report, Barriers to Pollution Prevention Within a Regulatory Agency,10
identifies several types of barriers, including:
   Specific prohibitions of pollution prevention activities
 • Lack of flexibility in interpreting rules/policies
                                           Case Studies  55

   Informational barriers
   Procedural and processing barriers
   Lack of positive incentives
   In the future, the department will continue to identify additional barriers and means
of resolving the  barriers to pollution prevention  in the regulatory program. The depart-
ment also plans  to improve  its procedures for making and tracking consistent and effi-
cient regulatory  determinations. By doing so, the department will address some of the
procedural barriers identified by the facilities.
   Staff Training. One  important barrier  identified  in  the  report  is "resistance  to
change."  To overcome this  barrier, the task force recommended staff training and edu-
cation. To this end, more than 85 percent of the department personnel of 420 has par-
ticipated in a 3-hour introductory pollution prevention training seminar.
   Incorporating Pollution  Prevention into  Compliance and Enforcement. As a
result of the task force and strategy, DES has increased communication between the com-
pliance  and enforcement programs and NHPPP. For example, during air, water, and
waste inspections, regulatory staff routinely refer facilities to  NHPPP for  assistance.
During the inspection itself,  inspectors may pose questions on pollution  prevention activ-
ities  at the facilities, refer the facility to NHPPP for technical assistance,  or distribute pol-
lution prevention literature.  Furthermore, inspectors also refer facilities to NHPPP when
they discover deficiencies at the facility. The standard language for "Letters of Deficiency"
emphasizes that  the goal of the  department is to promote pollution prevention at the
source as  the preferred means of achieving environmental goals. The standard language
of the letter also refers the facility to the DES pollution prevention coordinator.
   The Hazardous Waste Compliance Section has instituted a "partial inspection" program
to reach a greater number of New Hampshire small-quantity hazardous waste generators.11
Using an abbreviated checklist, inspectors focus on waste generating processes and storage
in the partial inspection. A strong component of these inspections is the pollution preven-
tion  referral.
   Another way that DES is incorporating pollution prevention into compliance and
enforcement is negotiating Supplemental Environmental Projects  (SEPs) that encourage
pollution prevention as part of enforcement settlements. SEPs allow a facility that violates
environmental rules to conduct a project that benefits the environment in lieu of a por-
tion  of the fine. Examples of SEPs with a pollution prevention  focus  at DES include
offering free  seminars to other facilities on waste prevention and management and the
development of outreach materials (such as brochures or videos) on proper waste man-
agement techniques. An additional project required the facility to install an Ammoniacal
Etchant recovery system that will allow the facility to regenerate etchant on site.12
   Regulatory Review. As described above, DES plans to do a thorough review of its
procedures to make regulatory determinations to  make the procedures more efficient and
welcome  to pollution prevention. As part of this process, DES has identified several
instances  where  it can encourage pollution prevention through the regulatory process.
Examples of regulatory changes that encourage pollution prevention include:
   Reuse of cloth wipers via industrial laundering. New Hampshire developed specif-
   ic requirements for laundering contaminated  cloth wipers. By managing the cloth in
                        Case Studies   56

   an environmentally sound manner, as described in the requirements, facilities may
   avoid full regulation under the New Hampshire Hazardous Waste Rules and RSA. Ch
   Use of performance standards over prescriptive regulations. The air program seeks
   to encourage pollution prevention by writing regulations that are performance based.
   For example, DES changed regulations to allow facilities to meet emission limitations
   through performance standards. The standards encourage facilities with coating oper-
   ations (e.g., can, paper, film, metal parts manufacturers) to obtain and use coatings
   that are inherently low in volatile organic compounds that do not require the use of
   stack  emission control devices.14 This approach allows facilities to use innovative tech-
   nologies and pollution prevention to comply with air regulations.
   Incorporating Pollution Prevention in Permitting. DES is incorporating pollution
prevention into the permitting process in several areas. For example, DES uses a permit
process questionnaire to obtain feedback from the regulated community on the permit
process.  DES  plans to use this tool to facilitate pollution prevention in  the permitting
process. In addition, DES and the City of Lebanon are developing a model pretreatment
program and Sewer  Use Ordinance. Through this  project, the POTW  will work with
local businesses to reduce the amount of pollution discharged to the POTW.
   Onsite  Assessments.  NHPPP provides onsite,  nonregulatory technical  assistance
directly to businesses upon request. For each client, NHPPP examines processes that the
business  uses that generate waste and recommends actions to prevent waste and pollution.
The program uses the expertise of retired engineers to deliver this assistance. Thus far, the
program has conducted more than 40 onsite assessments.
   In a review of technical assistance service delivery, the task force recently found that
New Hampshire companies are not taking full advantage of available technical  assistance
services.  Even though DES  promises that onsite assessments are confidential, the task
force believes that some businesses do not request onsite assessments for fear that  DES staff
might find violations of environmental regulations and initiate enforcement procedures.
   Because businesses seem to be hesitant to use technical assistance services on a volun-
tary basis, the  Pollution Prevention  strategy recommends  that the technical  assistance
program "emphasize targeted pollution prevention assistance through workshops,  fact
sheets, technical bulletins, etc." While the strategy does not refuse service  to any business
that requests assistance, it does recommend that the program "direct onsite activities
toward those companies that have either regulatory difficulties or special needs, as well as
toward municipalities and other state agencies."
   Information  Clearinghouse.  NHPPP  maintains a technical assistance hotline to
answer phone inquiries about pollution prevention options. The  program also maintains a
library and electronic database of approximately 1,500 documents, vendors, and  case stud-
ies. The  NHPPP maintains close contact with other state technical assistance  programs
through the National Pollution Prevention Roundtable to share clearinghouse  materials.
   Conferences. PPIS  funding  allowed New Hampshire to  strengthen ties  between
NHPPP  and the University  of New Hampshire (UNH). To facilitate networking  and
information exchange between government, universities, and  the business community,
several jointly sponsored pollution prevention  conferences have been held statewide.
                                           Case Studies i 57

   Workshops and Presentations. NHPPP has conducted workshops, seminars, and annu-
al conferences for diverse groups of people. At the time of the case-study interview, NHPPP
had conducted 70 presentations and workshops and two annual conferences that have been
attended by approximately 1,750 people. The program also hosted a "Solvent Alternatives
Bazaar,"  attended  by 150  companies and  35 vendors, and  co-sponsored  a "Tracking
Workshop" to provide information and training on electronic waste-tracking packages.
   Curriculum and  Internships, To instill the pollution prevention ethic  into future
engineers, UNH developed a curriculum and internship program for chemical engineer-
ing students. The University created a model pollution prevention training program for
the students. The University also contacted New Hampshire companies to identify those
interested in sponsoring interns at their facilities. The program is now self-sustaining as
participating businesses fund the students for their work. As of the second year of the pro-
gram, the Pollution Prevention Partnership trained and placed 25 chemical engineering
students. According to the state pollution prevention coordinator, the program has been
well received by students and businesses alike.
   Publications NHPPP  has published several documents  to help companies learn
about pollution prevention,  such as fact sheets on pollution prevention options and
resources  for  targeted  industries.  NHPPP  is  also  preparing  case studies  of New
Hampshire success stories in pollution prevention. In addition, approximately 500 com-
panies,  individuals, and  government officials receive  Wastelines, a quarterly newsletter
published by NHPPP.
Analysis of PPIS Impact

   Pollution prevention activities in New Hampshire were very limited before the state
received  PPIS grant funding.  Because the federal hazardous waste Capacity Assurance
Program (CAP) required states to examine  their capacity to manage hazardous waste,
New Hampshire initiated limited waste reduction activities, including a needs survey of
New Hampshire businesses, before receiving any PPIS funding. Additionally, at the time
of the PPIS grant application, New Hampshire co-developed the WasteCap program to
help businesses reduce their generation of solid wastes. Once PPIS funding was approved
for New Hampshire, NHPPP activities were formally organized. These activities includ-
ed the  training of retired engineers  for onsite assistance, the  establishment  of  the
Pollution Prevention Task Force, the organization of the clearinghouse and database, and
outreach activities such as workshops and newsletters. The NHPPP program coordinator
comments, "Although some pollution prevention activities already existed in several pro-
grams  [prior to the task force], there was general recognition  that many opportunities
existed to  shift traditional "command and control" efforts toward pollution  preven-
   Infrastructure.  As in so many other states, a formal pollution prevention program
would not  exist in New Hampshire without PPIS grant funding. Through the NHPPP's
efforts and those of the pollution prevention coordinator and  the pollution prevention
task force, pollution prevention has become firmly established in the culture of DES.
   Although NHPPP has not yet secured independent  funding after the grant expires,
there is a bill pending in the state legislature to fund two pollution prevention positions in

                       Case Studies   58

the department. Even if New Hampshire does not receive the projected funding for two
positions in FY96 (as part of the pending bill), the task force will continue its regulatory
integration activities within the DES. In addition, technical assistance and the intership
program will continue through existing resources and the partnership with UNH.
   The final element of infrastructure development is the Pollution Prevention Strategy,
which lays out a timetable and specific  goals for DES to continue pollution prevention
efforts. To achieve this, all staff are being educated about the  fundamentals of pollution
prevention and how to incorporate them into their daily activities. As described earlier,
more than 85 percent of DES staff (375 employees) have already been trained.
   Regulatory Integration. Although the location of the  technical assistance program
within a regulatory agency may have caused some concern in the business community, it
has enabled NHPPP to more easily integrate pollution prevention into the state's regula-
tory program. For example, regulatory staff refer facilities to NHPPP during compliance
inspections and in letters of deficiency, negotiate pollution prevention SEPs, review rules
to encourage pollution prevention, and  endeavor to reduce  barriers to pollution preven-
tion in the permitting process.
   The task force is perhaps the most notable example of the success of program coordi-
nation through the  PPIS grant. The task force meets every month, has evaluated internal
barriers to pollution prevention, and has developed the Pollution Prevention Strategy to
overcome these barriers and make pollution prevention the driving force within DES.
The task force has also provided an arena in which to  discuss multimedia issues and to
help move the department in that direction.
   NHPPP and the pollution prevention task force have made great strides in enhancing
communication between the regulatory programs. To date, DES has initiated some cross-
media inspections and is currently considering methods to  expand these efforts. The
Pollution Prevention Strategy sets goals  and timetables to evaluate the feasibility of mul-
timedia permits and concurrent changes in inspections and  enforcement procedures.
   Program Evaluation. Before the first grant application, state staff conducted a survey
of New Hampshire businesses to see which  services they would like from a pollution pre-
vention program. The results of this pre-evaluation survey were used to develop the struc-
ture of NHPPP. The program is presently  surveying businesses to  assess once again  the
direction and effectiveness of the program.  Results are expected by  late September 1995-
In order to obtain reliable information, a marketing firm was utilized to collect and eval-
uate the survey data. The results of this  effort will allow the NHPPP to accurately assess
the present demand for its services.
Program Future

   A pollution prevention bill was drafted by the department and introduced in the 1995
New Hampshire legislative session. The bill contained provisions to:
 • Formally establish a pollution prevention program.
   Create a legislative mandate to provide regulatory and technical pollution prevention
   assistance to small businesses.
                                           Case Studies  59

   Create and fund two positions (currently funded through two PPIS grants) with non-
   federal funds.
   While the bill was successful in the Senate, it was not as successful in the House. On
a vote of 10-3, the House Environment and Agriculture (E & A) Committee voted to re-
refer the bill. Through this procedure the legislation has been tabled for this session but
will automatically be reintroduced in the 1996 session, which begins January 1.  While
E & A Committee members endorsed the policy implications of the bill, they did  not all
support funding the program. A legislative subcommittee had been working with the
department to revise the legislation and address funding issues. The revised version of the
bill will be introduced into the 1996 legislative session. Should the legislation pass, it will
provide additional resources  for DES pollution prevention efforts.
   With the assistance of PPIS funding, DES has succeeded in establishing a strong pres-
ence for pollution prevention in the media programs and creating a multimedia techni-
cal  assistance  program. DES  will continue to seek further  integration  of pollution
prevention into the media programs while evaluating multimedia structures. Without the
PPIS grants, efforts to incorporate pollution prevention into DES and the higher educa-
tional system in New Hampshire would have been greatly impaired.


Vincent Perelli, Manager
New Hampshire Department  of Environmental Services
Pollution Prevention Program
Phone:  603271-2902
Fax:    603 271-2456
e-mail:  des-vp@granite.mv.net
Stephanie D'Agostino, Pollution Prevention  Coordinator
New Hampshire Department  of Environmental Services
Office of the Commissioner
Phone:  603271-6398
Fax:    603 271-2867
                       Case Studies  60

B.3 New Jersey

   Organizational Structure. New Jersey's 1991 Pollution Prevention Act established an
Office of Pollution Prevention (OPP) in the New Jersey Department of Environmental
Protection (NJDEP)  to implement a comprehensive, multimedia pollution prevention
program. OPP concentrates on integrating pollution prevention into the state regulatory
program and implementing the Pollution Prevention Act. Currently, the office is collect-
ing summaries of approximately 700 pollution prevention facility plans mandated by the
legislation. OPP also  assists businesses in the development of these facility plans. While
OPP  focuses on pollution  prevention in the regulatory  program,  the  New Jersey
Technical Assistance Program (NJTAP) concentrates on voluntary pollution prevention
assessments.  Located  within the New Jersey Institute of Technology (NJIT),   NJTAP
offers direct technical assistance to small and medium-sized businesses (including onsite
pollution prevention  audits), as well as training, seminars, and workshops. Exhibit V-6
summarizes the different elements of New Jersey's pollution prevention program.
   Program Funding and Budget. OPP currently has  a staff of 14  full-time employees
and a budget of $2,100,000 funded through a fee established by the 1991 New Jersey
Pollution Prevention Act. NJTAP has an annual budget of approximately $250,000 and
employs a full-time staff of four people and a part-time staff of four retired engineers.
PPIS  grant monies  account for approximately  8 percent  of NJTAP's  funding.  The
remaining portion comes from NJDEP and other grants.
  Exhibit V-6
                 .  POLLUTION
  New Jersey Institute of
Key Activities
• Pollution prevention opportunity assessments
• Information clearinghouse
• Seminars, workshops, and presentations
• Training
• Demonstration project
• Data collection, integration, and analysis
  Office of Pollution
• Legislation
• Regulations
• Regulatory integration
• Data collection and analysis
• Compliance monitoring
• Industrial training and outreach
• Facilitywide permit pilot project
• Award program
• Guidelines
                                          Case Studies • 61

    Prior to the establishment of OPP, NJDEP received three PPIS grants and helps to
oversee a fourth grant  administered to NJIT. New Jersey received one of the  original
grants, Multimedia Source Reduction and Recycling Technical Assistance Proposal for New
Jersey, in 1989  to establish a technical assistance program to help hazardous waste gener-
ators minimize the amount of waste they produce. The grant also funded research on
waste minimization opportunities, targeted technical assistance, and outreach and educa-
tion to waste generators.  EPA awarded the second grant, Pollution Prevention Incentives
for States Grant Application, in June 1990. This grant provided much of the base funding
for staff salaries that researched state legislation and that established the initial program
in the agency,  which later became permanent and stably  funded via legislation. NJIT
received its grant, Development and Demonstration of an Industrial Extension Program for
Local Level Implementation, in September 1991. This  grant had  two purposes:  1)  to
develop a model for county-level pollution prevention technical assistance and 2) to pro-
vide  a pollution prevention vocational  training program.  NJDEP's  third  grant,
Development of a Pollution Prevention-Based Facilitywide Permit Pilot Project,  awarded in
July 1993, assisted in funding additional  salary costs needed to undertake DEP's pollu-
tion prevention-based,  multimedia  permitting  pilot project. Exhibit V-7 summarizes
New Jersey's PPIS grants.
    Strategy and  Legislation. In addition to  establishing OPP, the 1991 Pollution
Prevention Act requires industrial facilities that are covered under TRI to prepare  a
Pollution Prevention Plan. In the Pollution Prevention Plan, among other provisions,
companies must conduct a process-level materials accounting, develop a list of potential
pollution prevention options, analyze a minimal list of full costs associated with their use
and generation of hazardous substances, and set 5-year goals for reducing the use and gen-
eration at the source of hazardous substances. These companies are also required to report
progress  achieving their goals. New Jersey's legislation is consistent with  EPA's waste
management hierarchy and its pollution  prevention definition is  consistent with EPA's
pollution prevention definition. New Jersey PPIS funds have only gone to true pollution
prevention-based programs.
  Exhibit V-7
  PPIS Grant Summary
Year  Amount
  Multimedia SRRTA Proposal for NJ                    1989  $300,000
  Pollution Prevention for States Grant Application        1990  $301,000
  Industrial Extension Program for Local Implementation   1991   $300,000
  Pollution Prevention Facilitywide Permit Pilot Project     1993  $207,000

  Total Funding                                            $1,108,000
                        Case Studies  62

Activities Funded by PPIS Grants

   PPIS funds have enabled New Jersey to develop the state's pollution prevention infra-
structure,  examine facilitywide permitting, develop a county-level technical  assistance
program,  and  educate both  students and businesses  about  pollution  prevention.
Specifically, PPIS funded the following activities, which are described  below in detail.
   Infrastructure development. PPIS-funded activities to develop New Jersey's infra-
   structure include strategy development,  data  collection, recognition program,  and
   green purchasing policy.
   Regulatory integration. To integrate pollution prevention into the regulatory pro-
   gram, New Jersey  provided  training to regulatory staff and tested the feasibility of
   facilitywide permitting.
   Technical assistance. PPIS-supported activities in the technical assistance area include
   onsite audits, a demonstration program, and an information clearinghouse.
   Outreach and education. Outreach and education efforts in New Jersey include inte-
   grating pollution prevention into vocational training, providing guidance manuals to
   educate businesses  on how to develop a successful pollution prevention plan, and con-
   ducting workshops and presentations.
   Strategy Development. The purpose of the 1990 grant was to develop an operational
strategy and procedures for OPP, work with the state legislature on developing a statewide
pollution prevention law, analyze existing NJDEP data to start measuring pollution pre-
vention trends, and institutionalize a pollution prevention program  in the agency. To
attain this goal, NJDEP expanded the staff of OPP by three full-time employees. These
employees established basic OPP operating procedures.
   Using the state's Release and Source Reductions Report and  Community Right-to-
Know data, NJDEP  evaluated facilities' successes in reducing pollution to determine
what industry sectors  to target and how to measure pollution prevention more effective-
ly. In response to this evaluation, the pollution prevention program worked with the New
Jersey Right-to-Know (RTK) program to maximize  the  RTK survey's ability to track
   Data Collection.  New Jersey conducted  a case study  of 15 facilities to determine if
throughput data, in conjunction withTRI  data, are a more effective measure of pollution
prevention progress than TRI  data alone.  In  addition,  NJDEP used TRI, materials
accounting, economic, and  environmental permitting and compliance data to develop
industry profiles of five industry sectors in  New Jersey.16 The state is using the profiles to
examine trends.
   Guidance Documents.  OPP developed  a guidance package  for facilities preparing
pollution  prevention  plans. NJTAP  developed  industry-specific manuals  for  electro-
platers,  printers, and the fabricated metal industry.
   Recognition Program.  Through PPIS funding, New Jersey developed a Governor's
Award for Outstanding Achievement in Pollution Prevention that includes a wide range
of categories.
   Green Purchasing Policy. OPP evaluated the state's procurement  policies for incen-
tives and obstacles to  implementing pollution prevention  activities.
                                           Case Studies  63

   Facilitywide  Permitting.  New  Jersey's  1991  pollution  prevention  law requires
NJDEP to conduct a facilitywide pollution prevention pilot project with 18 companies.
PPIS monies were provided to NJDEP to offset additional salary costs needed to  under-
take the facilitywide permitting project. Not only will the facilitywide permit meet the
requirements of  all  the  media programs,  it will also  attempt to integrate pollution
prevention planning into the  permit process. This unique experiment should provide
valuable lessons for the states and EPA as the organization of environmental  regulation
along media lines is evaluated.
   To implement the project, OPP established a strong relationship with NJDEP  staff in
charge of the media permits. As part of this relationship, OPP provided training  in pol-
lution prevention for the  media program staff. Then, NJDEP staff began working closely
with the industrial facility to assist in the facility's development  of a draft pollution
prevention plan and facilitywide permit application. Multimedia  teams from NJDEP
evaluated  and  commented on  the application,  which  led  to  necessary  revisions.
Ultimately, 18  facilities will receive these  permits, which will go through  a standard
permit review process. To date,  one final faciltywide permit has been issued, and the
remaining are expected in fall 1995-
   At the end of the pilot project, state law requires OPP to analyze the effectiveness of
facilitywide permitting. OPP will evaluate the environmental protection implications of
facilitywide permitting and make  recommendations to the state legislature about stream-
lining the permitting process through facilitywide permits.
   Onsite Audits. NJTAP has conducted more than 75 onsite technical assistance audits
with PPIS  funding. Including all funding sources, the program has assisted  nearly 200
companies. For a sample  of one success story, see the box below. NJTAP will respond to
any business that requests services with a phone call or onsite visit.
   The program targeted the following SIC codes for technical assistance, in accordance
with the 1991 Pollution Prevention Act:
   Paper and allied products (SIC 26)
   Chemicals and allied products (SIC 28)
   Rubber and miscellaneous products (SIC 30)
   Primary metals industries (SIC 33)
 • Fabricated metal products17 (SIC 34)
   NJTAP follows through with all companies that receive technical assistance and con-
ducts  an annual survey to evaluate the success of the program. NJTAP identifies two
salient barriers to measuring progress. First, companies often do not respond to the tech-
nical assistance evaluation form. The response rate to the survey routinely is around  30
percent. Second, the program cannot necessarily attribute results to its actions.  "If a com-
pany we visit decreases its wastes,  it is often  difficult to attribute it solely to our efforts or
to other process changes," says NJTAP director Dr. Marcus J. Healey.
   In August 1994, NJTAP surveyed 98 clients who received services in FY94. Of the 18
clients that responded to the mail  survey, 77 percent rated the overall quality of service as
"excellent" or "good."  According to one technical assistance recipient, Union Carbide,
NJTAP helped them by:
                        Case Studies   64

   Confirming that they were moving in the right direction
   Explaining some confusing regulations
 • Providing some good literature to review
   These 18 clients identified 40 distinct types of pollution pre-
vention assistance rendered by the program,  demonstrating the
wide  range  of  issues  addressed  by technical assistance  staff
Clients reported saving a total  of $70,000 through the imple-
mentation of NJTAP  recommendations. NJTAP believes that
clients will continue to save money as they implement  these
   Demonstration Project In this project, NJTAP is testing the
feasibility of using an industrial  extension service to provide pol-
lution prevention technical assistance to local  businesses. NJTAP
is developing the model in Burlington County, New Jersey, then
plans to test the model in Puerto Rico. Puerto Rico represents an
area with environmental problems that are similar yet different
enough to test the transferability of the model.
NJTAP Success Story
City Auto Radiator
Activity: Mechanical cleaning elimi-
nated a significant portion of dis-
charge to POTWs and saves the
company $1,650 per year.
Activity: The company implemented
counterflow  rinsing and tank refill pro-
cedures to achieve a zero discharge
process, reducing discharge to
POTWs by 100,000 gallons.
Activity: The company switched to
water-based paints from solvent-
based paints, which completely elimi-
nated volatile organic compound
   Activities funded by PPIS include identifying target industries
for technical assistance and conducting outreach on the program's goals and services to
those industries. Staff conducted site visits to evaluate process and procedures and deter-
mined what level of assistance the program should provide. As experience with program
implementation grows, staff will be evaluating the effectiveness of the model and devel-
oping a report on its implementation. A preliminary site assessment will be conducted in
Puerto  Rico to  determine  emission activity and program needs. Finally, an Advisory
Management Committee (AMC) will  be  created to  oversee the implementation and
potential expansion of the model in Puerto Rico.
   Notable achievements of the demonstration project include:
   The Burlington County program received the Governor's  Award for Outstanding
   Achievement in Pollution Prevention.
 • The Burlington County program compiled a list of local printers.
   The Burlington County program manager is developing  recommendations  for a
   small-quantity generator collection program.
   NJTAP  hosted the Puerto Rican Corporation for Technological Development of
   Tropical Resources (TROPICO) representatives for pollution prevention training.
   The Puerto Rico TAP agreed to host a workshop for the metal finishing and fabrica-
   tion industry.
   Information Clearinghouse. While PPIS funds do not specifically support an infor-
mation clearinghouse, NJTAP has collected more than 2,000  articles in 70 different pol-
lution prevention categories. In addition, the program has more than 50 videotapes on
pollution prevention.
   Curriculum. NJTAP implemented a  program,  the Vocational  Environmental
Education Program (V-Project), to integrate pollution  prevention  into vocational educa-
tion. The major goal of the V-Project is to develop curricular materials for vocational stu-
                                         Case Studies   65

dents in conjunction with the New Jersey Department of Education and NJDEP. In addi-
tion, V-Project staff will conduct training courses for  corporate management that will
combine pollution prevention activities with other aspects of a total quality management
program. Thus far, NJTAP has developed a workplan for the V-Project, and the techni-
cal committee is commenting on a draft curriculum.
   Workshops and Presentations. PPIS funding enabled NJTAP to conduct more than
40 presentations reaching more than 600 people. In addition to electroplaters, printers,
and the fabricated metal industry, NJTAP targeted textile finishers and the dry cleaning
industry for workshops and presentations. For these groups, NJTAP conducted extensive
training sessions for more than 100 people using PPIS funds.
Analysis of PPIS Impact

   PPIS provided seed money to launch New Jersey's pollution prevention program, both
at OPP and NJTAP. OPP began with one staff person funded by an existing NJDEP pro-
gram but did not have a significant operational budget. PPIS funding enabled the pro-
gram to hire additional staff and work with the legislature to develop enabling legislation.
Prior to PPIS funding, the technical assistance  program did  not exist. PPIS monies
enabled the program to get off the ground and to secure future funding from the state.
Now, PPIS funds  account for only about 8 percent of NJTAP's funding.
   Infrastructure. While OPP existed before the first PPIS grant, it had no permanent
funding source and was only just developing its program. PPIS allowed the development
of enabling legislation to make OPP a permanent part of NJDEP. During this time, OPP
evaluated potential roles of the regulatory programs in promoting pollution prevention
and developed guidelines for incorporating pollution prevention into NJDEP activities.
   PPIS funding enabled New Jersey to develop the RTK reporting to be an initial tool
for tracking industrial pollution prevention  progress. It was also instrumental in devel-
oping the processes by which the media programs would coordinate the development of
facilitywide permits. The project might ultimately result in the transition to a truly multi-
media regulatory agency.
   The grants have also helped NJTAP and OPP to coordinate  efforts. The programs
interact frequently (at least two to four meetings per month) to coordinate activities.
   Regulatory Integration. PPIS increased regulatory integration by funding a part of
the facilitywide permitting project. The project helped reduce barriers to pollution pre-
vention by promoting  increased  communication and coordination between regulatory
staff.  Staff from all of the media programs worked together with OPP staff to develop
procedures  for writing a facilitywide permit. Without PPIS funding, the regulatory pro-
gram would not have been able to support this project.
   Clearly, New Jersey is far ahead of many of the states in developing a multimedia per-
mit process. This  pilot  project, and  the report on  its effectiveness, will serve as a model
for all states that are considering multimedia reform.
   Program Evaluation. Currently, OPP is  conducting its own program evaluation and
has also contracted with an outside consultant to help determine the impact of the pro-
                       Case Studies  66

gram on pollution prevention. The study evaluates the pollution prevention planning
process and its impact on companies' actual waste generation. This process has been sim-
plified by the collection of throughput data, which allows an actual accounting of waste
generated based on production output.
Program Future

   NJDEP and NJTAP will continue to coordinate efforts in the future. While OPP con-
tinues to focus on regulatory affairs, NJTAP will focus on outreach, information dissem-
ination,  education, and training  and pollution prevention technology development.
Future PPIS grant requests from NJTAP will be project oriented.

Jeanne Herb
New Jersey Department of Environmental Protection
Office of Pollution Prevention
Phone:  609984-5339
Fax:    609 777-1330
Dr. Marcus J. Healey
New Jersey Technical Assistance Program
Phone:  201 596-5864
Fax:    201 596-6367
e-mail: healy@hertz.njit.t
                                          Case Studies  i 67

B.4 North Carolina

   North Carolina, one of the original states to establish a pollution prevention program,
began implementing pollution prevention activities, such as a waste reduction conference
and workshops, as early  as 1981.18 Early funding for pollution prevention education
activities was obtained from the Mary Reynolds Babcock Foundation. The state institut-
ed the program in the  state regulatory agency in FY85 with a $116,000 appropriation
from the state legislature.
   Organizational Structure. While North Carolina has reorganized its program sever-
al times since its inception, the  basic program structure has not changed since 1990. At
that time, the state established the Office of Waste Reduction within the Department of
Environment, Health,  and Natural  Resources (DEHNR). Within the Office of Waste
Reduction, the  state established two programs:  the Solid Waste Reduction Program and
the Pollution Prevention Pays  (PPP) Program. The Solid Waste Reduction Program
focuses on the reduction  of municipal solid waste. The PPP program provides a variety
of services to North Carolina businesses in multimedia waste reduction, including on-
and offsite technical assistance,  an information clearinghouse, education, training, out-
reach, and challenge grants. The goal of the program is to promote  the elimination,
reduction, or recycling  of industrial waste prior to treatment or disposal. PPP also coor-
dinates activities with other components of the state environmental protection program,
endeavors to  integrate the pollution prevention ethic into the regulatory staff, and evalu-
ates pollution prevention progress.
   The Pollution Prevention Research Center at North  Carolina State University also
provides  a number of pollution prevention services, including research, onsite technical
assistance for large businesses, outreach, and technical training. These activities are coor-
dinated with the PPP program.
   The Waste Reduction Center of the Southeast, established in 1989, was a joint ven-
ture between North Carolina, EPA Region 4, and the Tennessee Valley Authority. The
center provides onsite technical assistance and training to the Region 4 states19 using a
staff of retired engineers.
   Exhibit V-8 depicts the organizational structure of North Carolina's  pollution pre-
vention program.
   Program Funding  and Budget. The PPP program employs a staff of 12 full-time
people and has  a budget of $500,000 per year. More than 80 percent of funding comes
from the state (from the state general fund and emission fees). North Carolina, one of the
original 13 PPIS grant  recipients, also received two PPIS  grants. EPA awarded the first
grant, Multimedia Waste  Reduction Management System for Government and Industrial
Applications, in  March 1989- The grant was a cooperative effort between the Department
of Natural Resources and Community Development (the predecessor to DEHNR),  the
Governor's Waste Management Board,  the Department of Human Resources, and  the
Department of Crime Control and Public Safety. The department received a second PPIS
grant, Small Business Waste Reduction Technical Assistance, in September 1993- Under this
                       Case Studies  68

  Exhibit V-8
                OLINA POLLUTION
  Department of
  Environment, Health, and
  Natural Resources
Key Activities
• Technical assistance
• Training
• Outreach and education
• Information clearinghouse
• Matching grants
• Regulatory integration
• Program coordination
• Program evaluation
  North Carolina State
• Research
• Technical assistance
• Training
• Outreach
  Waste Reduction Center
  of the Southeast
• Technical assistance
• Training
• Outreach and education
• Information clearinghouse
grant, members of the PPP Program worked closely with the Office of Small Business
Ombudsman in the DEHNR's Air Quality Section to provide technical assistance  to
small businesses. Exhibit V-9 summarizes North Carolina's PPIS grants.
   Strategy and Legislation. North Carolina enacted its first piece of waste reduction
legislation in 1981. As a result of recommendations by the Governor's Waste Manage-
ment Task Force, North Carolina enacted the Waste Management Act of 1981, which
issued a strong policy statement that hazardous waste should be minimized:
         The General Assembly of North Carolina hereby finds and declares that
   prevention, recycling, detoxification, and reduction of hazardous wastes should be
   encouraged and promoted.20
   A second piece  of legislation, the  1989 Hazardous Waste Management Commission
Act,  formally established the PPP program at DEHNR. As specified in the act, the pur-
 Exhibit V-9
 PPIS Grant Summary
                  Year    Amount
 Multimedia Waste Reduction Management System       1989    $300,000
 Small Business Waste Reduction Technical Assistance   1993    $56,000

 Total Funding                                              $356,000
                                         Case Studies  69

pose of the program is  to  promote  voluntary waste  and pollution  reduction  efforts
through information, grants, and technical assistance. The legislation also establishes a fee
structure to encourage generators of hazardous waste to minimize the quantity and toxi-
city of the waste they generate and requires them to submit a description of any program
they have to minimize waste.
Activities Funded by PPIS Grants

   Unlike most other states, North Carolina already had an established, funded pollution
prevention program at the outset of the PPIS grant program in 1989- Thus, the state used
PPIS funding to further develop its pollution prevention infrastructure. To do so, the PPP
program created a new data management system. PPIS also  funded technical assistance
to businesses.
   Database Development. PPIS funded the development of a multimedia information
management system to link all of the environmental databases in the DEHNR, includ-
ing the TRI, annual reports from hazardous waste generators, and air emission and water
discharge monitoring data. The department uses the system to compare data reporting by
industries and assess opportunities for waste reduction at specific facilities. The system
also helps  the PPP  program  target  activities, including technical assistance, training,
grants, research, and demonstration projects, to priority industries in the state.
   To develop the system, the PPP program reviewed existing reporting formats to assess
the data they collect, including level  of detail, units of measurement, and compatibility.
From each report, the program extracted the most useful data to characterize sources and
types of releases. Using this analysis, the program assessed potential integration methods
for feasibility, ease of implementation, and applicability for the intended uses of the waste
reduction management system. The program developed a users' manual for the data sys-
tem and training  materials, then trained DEHNR staff on how to use the system.
   Technical Assistance. The federal Clean Air Act Amendments  (CAAA) require that
states assist small businesses in meeting new  air quality standards. PPIS funds allowed
North Carolina to provide waste reduction technical assistance targeted to  thousands of
North Carolina small businesses. Through PPIS funding, the PPP program ensured that
waste reduction remains a key component in  the state's overall small business assistance
program under the CAAA.
   To complete this grant, the PPP  program first identified appropriate small business
categories,  then developed and distributed informational materials to the targeted indus-
tries.  During this process, the program formulated  training materials and  identified
future research needs for pollution prevention in small businesses. Other activities includ-
ed monitoring of technical assistance and regulatory efforts to ensure that pollution pre-
vention methodologies are incorporated and establishing a quality assurance and quality
control  program.
   Thus far, PPIS funds have enabled North Carolina to provided technical assistance to
74 small businesses. Of these companies, 11 received onsite audits and 63 received pub-
lications or technical assistance over the telephone.
                        Case Studies i 70

Analysis of PPIS Impact

   Infrastructure. Instead of funding the development of a pollution prevention strategy
or the development of state legislation, PPIS funding helped North Carolina to create a
data management system. This system integrates reporting data statewide and enables the
program to target pollution prevention activities such as technical assistance and training.
Thus, PPIS helped North Carolina expand the infrastructure of its pollution prevention
program, rather than initiate a program as it did in New Hampshire or Delaware.

   Program Evaluation. PPIS funding has helped North Carolina measure the progress
of pollution prevention activities. The state recently conducted an evaluation of the tech-
nical assistance portion  of its program. The survey asked facilities which of the pollution
prevention recommendations they implemented and why or why not. Of the businesses
surveyed, 90 percent implemented at least one of the recommendations. Overall, 38 per-
  Regulatory Integration  Efforts in  North  Carolina*
    While the PPP program remains entirely voluntary, it does coordinate
  activities with regulatory programs in the state to foster pollution prevention.
  Activities include rule development, training, referrals,  and supplemental
  environmental projects (SEPs). Currently, the program is working closely
  with water quality staff to review new water discharge  rules to identify possi-
  ble  means of incorporating pollution prevention concepts. Draft  rules include
  a requirement that facilities consider pollution prevention activities under
  way when they submit the permit application. The program has  also assist-
  ed the hazardous waste program in developing pollution prevention SEPs
  and analyzing the annual hazardous waste report.  Regulatory staff often
  refer the facilities to the PPP program for technical assistance. Currently, the
  program is developing guidance materials for
  hazardous waste inspectors and boilerplate language  to promote pollution
  prevention in notices of violation.
    The PPP program has also developed a train-the-trainer program to
  educate regulatory staff. All air quality staff  were trained through the
  program. Permit writers were trained to point out pollution prevention
  options to facilities as they develop the permits.  Recently, the water
  quality program also requested such training. The PPP program is also
  planning to train regulatory staff on  pollution prevention  options by
  industry sector. While a few individuals have resisted  incorporating
  pollution prevention into their daily work, most  have embraced pollution
  prevention concepts. Given the increased time and  effort needed to fully
  incorporate  pollution prevention into daily work, pollution prevention staff
  are encouraged by the widespread  acceptance by the regulatory staff.
  * Regulatory integration activities are not directly funded by PPIS.
                                        Case Studies • 71

cent of the recommendations given were implemented.  All but one  of those surveyed
thought that the pollution prevention program was a good use of taxpayer dollars.
   The PPP program encountered a few difficulties conducting the evaluation. First, a
number of companies did not respond to the survey. A student intern, who designed the
survey, followed up with all of the companies to encourage them to respond to the sur-
vey and clarify responses. The PPP program manager believes that this  followup was cru-
cial to ensuring a high response rate and quality data. A major difficulty was quantifying
the amount of waste reduced as  a result of implementing the suggestions. While some
companies did not want to  release this information for fear of release to competitors,
most companies did not have the time or resources to measure waste reduction. Evidence
from companies willing to release information indicates that most saved between $10,000
and $20,000 per year as a result of the recommendations, and some  saved as much as
$500,000 per year.
   The program has not yet tried to measure the effectiveness of other activities, partic-
ularly its outreach efforts, although it is considering conducting a readership survey of its
newsletter. While not a formal means of measuring success,  the program manager notes
that during a 1-year period when the newsletter was not published, the program received
a number of requests for it.
   North Carolina is currently developing a methodology to help  itself and other states
measure pollution prevention progress. Modeled on the NIST program, the methodolo-
gy will help states measure the cumulative effect of services such as onsite  assistance,
newsletters, and grants to individual businesses.
Program Future
   As described above, North Carolina will focus some if its resources in the coming years
on developing a methodology to measure pollution prevention progress. The PPP pro-
gram also will continue providing outreach and education to state businesses and resi-
dents. In addition, the program hopes to further integrate pollution prevention into the
regulatory program. While North Carolina would like to retain the same level of pollu-
tion  prevention activity in the future, the state legislature has reduced the program's fund-
ing in FY96.
David Williams
North Carolina Department of Environment, Health, and Natural Resources
Pollution Prevention Program
Phone:  919571-4100
Fax:    919 571-4135
                       Case Studies i 72

B.5 South Dakota

   Organizational Structur   The South Dakota  Department  of Environment  and
Natural Resources  (DENR), the state environmental  regulatory  agency,  houses  South
Dakota's pollution prevention program. The primary mission of the program is to inte-
grate the pollution prevention ethic into all  state activities. With only  one half-time
employee and a budget of $427,000, the program's main function is to oversee the budget
and coordinate activities. To accomplish its mission, DENR has established partnerships
with other state agencies, county governments, the  academic community, and businesses.
Instead of hiring a large staff solely dedicated to pollution prevention within DENR, the
program employs the assistance of its partners  to implement pollution prevention activi-
  Exhibit V-10
                  .^k POLLUTION
 Department of
 Environment and Natural
Key Activities
• Regulatory integration
• Advisory committee
• Coordination
• Presentations
• Newsletter
• Public service announcements
• Conferences
• Staff training
• Program evaluation
• Clearinghouse
 Other State Agencies
• Staff training
• Green purchasing policies
• Integrated pest management
 South Dakota Discovery
• Teaching module
• Technical assistance for a
 State Library
• Library of pollution prevention
 State University
 Cooperative Extension
• University courses
• Workshops
• Pollution prevention training
  for teachers
• Bootstraps video
• Home*A*Syst modules
 Todd and Mellette County
 Conservation Districts
• Technical training
• Technical assistance
• Monitoring manual
• Technology transfer
• Evaluation
 Trade Associations
• Distribution of Bootstraps
• Computer programs based
  on Bootstraps
                                          Case Studies  i 73

 Exhibit V-11
 PPIS Grant Summary
Year    Amount
 Sustaining Pollution Prevention in South Dakota
 Enhancing Pollution Prevention in South Dakota

 Total Funding

ties. The fact that the partners implement the pollution prevention activities themselves
furthers the integration of the pollution prevention ethic into these organizations. Exhibit
V-10 describes the roles of pollution prevention partners in South Dakota.
   Program Funding and Budget. The  PPIS grants, along with state and local match
provided by program participants, fund the entire pollution prevention program in South
Dakota.  DENR received two PPIS grants. EPA awarded the first grant,  Sustaining
Pollution Prevention in South Dakota, in September 1992. The grant established a part-
nership  between  DENR  and  the  South Dakota  Departments  of Agriculture,
Transportation, Energy,  Health,  and Games, Fish,  and Parks.  The  partnership also
included the South Dakota State University Cooperative Extension Service and Research
Station. In October 1993, EPA awarded the second grant, Enhancing Pollution Prevention
in South Dakota, which provided funding to expand outreach efforts to all sectors (includ-
ing children) and to transfer lessons learned from Bootstraps to other programs. Exhibit
V-11 summarizes South Dakota's PPIS grants.
   Strategy and Legislation. In 1992, DENR formally incorporated pollution preven-
tion into its goal statement  and identified pollution prevention as the first alternative for
all programs.  In doing so, South Dakota has developed an environmental policy consis-
tent with EPA's policy. The state has also incorporated pollution  prevention into the
State-EPA Agreement. At this time, South Dakota does not plan to enact any specific pol-
lution prevention legislation.
Activities Funded by PPIS Grants

   PPIS funded a wide range of activities in South Dakota, from infrastructure develop-
ment to technical assistance and training, regulatory integration, and outreach and edu-
cation. These activities are described further below.
   Infrastructure. PPIS funding allowed South Dakota to form an advisory committee
   as well as build the pollution prevention infrastructure through "green" purchasing
   Regulatory integration. PPIS supports regulatory integration in  South Dakota by
   funding training for staff in the regulatory program.
   Technical assistance and demonstration projects. Bootstraps, a technical assistance
   demonstration project, has helped South Dakota farmers and ranchers to prevent pol-
                       Case Studies • 74

   lution through education and onsite assistance. PPIS also funds the transfer of lessons
   learned from Bootstraps to other states as well as an information clearinghouse.
   Education and outreach. Outreach activities funded by PPIS include conferences,
   teacher training, outreach materials, presentations, and public service announcements.
   Task Force and Advisory Committe<  The first PPIS grant enabled DENR to commis-
sion a task force to assess pollution prevention opportunities within both DENR and the
entire state government. The task force included one representative from each of the five
divisions within DENR. After examining the department's activities, the task force recom-
mended that pollution prevention become the department's primary objective. As a result
of the task force recommendation, DENR issued a policy statement declaring pollution pre-
vention as DENR's primary objective. PPIS funds also enabled the task force to develop an
action plan to implement pollution prevention throughout DENR and the  state.
   The second PPIS grant funded a reorganization of the five-member task force into an
11-member advisory committee. The advisory committee represents all of the major pro-
grams within DENR and continues to guide both DENR and other state agencies in fos-
tering pollution prevention.
   Green Purchasing Policies. In addition to examining opportunities within DENR,
the task force assessed pollution prevention opportunities throughout the entire state gov-
ernment. As a result of this assessment:
   The State Office of Purchasing and Printing purchases products made  from postcon-
   sumer materials when economically feasible.
 • State agencies purchase energy-efficient computers.
   The Division  of Buildings and Grounds substitutes nonhazardous materials for haz-
   ardous material when possible.
   The state uses integrated pest management principles, which minimize pesticide use,
   to control insects.
   Regulatory Integration. As a result of the recommendations of the  advisory com-
mittee, DENR management has instructed the regulatory programs to integrate pollution
prevention  into all activities. First,  the  program  trained DENR and Department of
Agriculture staff in pollution prevention techniques. DENR now conducts 10 to 12  mul-
timedia inspections each year and includes pollution prevention provisions in all mining
permits. In the future, DENR plans to conduct all inspections on a multimedia basis and
use a multimedia approach to issuing all permits.  The regulatory program is also incor-
porating pollution prevention into the enforcement process. For example, when the spill
prevention  program issues a notice of violation, it includes information on spill preven-
tion in the  notices of violation and recommends that the violator implement a spill pre-
vention program. The program also plans to supply onsite technical assistance to repeat
violators on how to develop a spill prevention plan.
   Technical Assistance. In coordination with the Todd, Mellette, Gregory, Stanley, and
Jerauld Conservation  Districts, and  the  Lower James  Resource  Conservation
Development Association, DENR is promoting better farmland and ranch management
through the Bootstraps Project, funded by PPIS. This project aims to teach farmers and
ranchers that sustaining a profitable  operation is directly related to using practices that
maintain or improve the environmental  health  of range and crop  lands.  Under
                                           Case Studies i 75

Bootstraps, each family learns how to complete a natural resource inventory for their
ranch or farm, develop  a management plan, and  select BMPs to implement the plans.
DENR provides technical assistance to help select and implement the BMPs to both pro-
tect the environment and promote economic stability.
   As part of the project, DENR and its partners created a manual and video to assist
participants. DENR received such positive feedback on the Bootstraps video and manual
that the National Cattleman's Association decided to reprint and distribute the manual
to association  members as a  primary tool for  improving  operations  and resource
management. The National Cattleman's Association also plans to  develop a computer
program based on the manual. Furthermore, DENR leveraged funding ($25,000) from
a private company, Moorman Feed Company, to produce the manual. As a result of their
participation in the Bootstraps Project, farmers in Todd and Mellette Counties have
embarked on a grassroots effort to increase ground water protection in their counties.
   DENR achieved the  following accomplishments with the Bootstraps Project:
   The Bootstraps video and manual were developed and distributed  (more than 140
   120 families from 100 farms or ranches participated in the  project.
 • More than 80 percent of the participants have implemented one or more BMP
   About 60 percent of the participants have implemented two or more BMPs.
   Pollution on approximately 620,000 acres of ranch and farmland in five counties was
   Technology Transfer. Lessons learned from the Bootstraps  Project will  be transferred
into a model for pollution prevention in rural communities including Native American
reservations. DENR has made presentations  on Bootstraps to  a wide range of organiza-
tions,  including  several  counties  in South  Dakota,  the  National Association of
Conservation Districts,  and the National Stockgrower's Association. South Dakota also
hopes to transfer the program to other states and possibly other countries. The program
has made presentations  to the  North Dakota Department of Agriculture,  and several
other states have also requested presentations, including Colorado,  Nebraska, Missouri,
and  Kansas.  Representatives from several Eastern European governments have also
requested additional information on  Bootstraps.  South Dakota has presented  lessons
learned from Bootstraps to over 500 people thus far.
   Information Clearinghouse. A central clearinghouse was developed to answer infor-
mational requests. Some of the topic areas available include:  household hazardous waste,
composting, spill prevention, energy conservation, Farm*A*Syst, and Home*A*Syst.
   Conferences.  To introduce the state's urban population  to pollution prevention,
DENR is planning two conferences to be held over an interactive television network. One
conference will target businesses and industries, and a second conference will target local
governments. DENR also plans to attend a conference on pollution prevention for Native
American tribes.
   Publications. DENR developed a brochure to explain the benefits of pollution preven-
tion to the general public of South Dakota and a booklet on household hazardous waste
reduction.  DENR also  developed  a brochure  describing South Dakota's  Green  Lights
Program, a voluntary program to encourage businesses to use energy-efficient lighting.
                       Case Studies  i 76

   Technical Training. In conjunction with the South Dakota Discovery Center, DENR
developed a training course for teachers on pollution prevention. Together, the organiza-
tions  trained  170  school  teachers from  20 school districts  on how to incorporate
environmental awareness into the classroom. The training included specific modules on
pollution prevention.  DENR has received approximately 60 to 70 followup calls  from
teachers for additional information and plans to offer the training at additional locations.
   Presentations and Workshops. DENR has presented pollution prevention information
to many South Dakota trade associations and businesses, as well as to the general public. In
addition to presentations designed to share the lessons learned from Bootstraps, DENR has:
   Purchased and distributed 1,500 "waste wheels" to inform homeowners of pollution
   prevention alternatives.
   Distributed  pollution prevention information to more than 50,000 people at the
   South Dakota State Fair.
   Conducted a holistic management workshop for farmers.
   Conducted a presentation on pollution prevention at a TRI workshop sponsored by
   EPA and DENR.
   Conducted a presentation at an annual  meeting of the South Dakota  Council of
   Teachers of Mathematics and the South Dakota Science Teachers Association (usual-
   ly attended by more than 700 teachers).
   To promote spill prevention in homes and businesses, the state is developing three pub-
lic service announcements. The series will discuss how to prevent home heating fuel spills.
Analysis of PPIS Impact

   Infrastructure. PPIS funding has enabled South Dakota to develop a pollution pre-
vention program and institutionalize the concept of pollution prevention. Prior to the
PPIS grant, South Dakota had no formal pollution prevention program. While some staff
in the media programs conducted ad hoc pollution prevention activities, such as training
industry representatives in ways they could  reduce pollutants in  their industrial  dis-
charges, no  formal pollution prevention strategy existed, and coordination  of activities
between the media programs did not occur.
   One of the major successes of this grant is that it has enabled DENR to coordinate
activities between several state agencies and South Dakota State University. The grant also
established links between DENR and trade associations, businesses, and national pro-
jects, including:
   Department of Agriculture
   Department of Transportation
 • Department of Energy
   Department of Health
   Department of Games, Fish, and Parks
 • State University Cooperative Extension Service and Research Station
 • National Cattleman's Association
 • Farm*A*Syst

                                           Case Studies • 77

   Regulatory Integration. The grant also helped DENR establish pollution prevention
links within all media programs in DENR, including the nonpoint source, spill preven-
tion, air, and hazardous waste programs.  The pollution prevention program supplies
technical information on  pollution prevention to each of these regulatory  programs.
Given the small size of DENR, pollution prevention staff can keep in close contact with
the regulatory programs.
   DENR, on the recommendation of the grant-funded task force, identified pollution
prevention as the first alternative for the department. Thus, PPIS directly contributed to
the shift of the prevailing attitude from pollution control to prevention, followed by recy-
cling. Through this policy, DENR management has instructed the  regulatory programs
to integrate pollution prevention into all activities. As described above, DENR is in the
process of converting both inspections and permitting from a single-medium approach to
a multimedia approach.
   Program Evaluation. The pollution prevention program has conducted a survey of
all Bootstraps participants on the Rosebud reservation and Todd and Mellette Counties
to measure the success of the program, including BMPs implemented. The survey found
that more than 80 percent of the participants have implemented one or more BMP. In
addition, the program includes an evaluation component in all of the tasks  it subcon-
tracts. For example, for the public relations campaign, the program  collected such infor-
mation as the number of people viewing television ads, demographics of viewers, etc. It
records the number of participants attending training sessions and surveys these partici-
pants for their reactions to the materials presented. For technical materials, the program
engages in a peer review of the materials to ensure a high-quality content.
Program Future

   While DENR has not secured future financing, the program believes that such financ-
ing will not be necessary once grant objectives have been achieved. For example, the state
will move the successful Bootstraps program to the nonpoint source program. By insti-
tutionalizing pollution prevention into the media programs, a separate pollution preven-
tion office will not be necessary.

Dennis Clarke
South Dakota Department of Environment and Natural Resources
Pollution Prevention Program
Phone:  605773-4216
Fax:    605 773-4068
                       Case Studies • 78

1   New Hampshire Department of Environmental Services, Pollution Prevention Strategy, January 1995.
2  While a state regulatory agency might coordinate program activities, different groups such as universities,
   local governments, or small business development centers often implement pollution prevention activities.
   These relationships are further explored in the exhibits throughout this section.
3  Chapter I describes the methodology for choosing these states.
4  Delaware 1990 Waste Minimization/Pollution Prevention Act.
5  Results of this survey were unavailable at the time of publication..
6  New Hampshire Department of Environmental Services Strategic Plan, 1994, Page 111-1.
7  New Hampshire Department of Environmental Services Pollution Prevention Strategy.
8  New Hampshire Department of Environmental Services, Pollution Prevention Strategy, January 1995,
9  New Hampshire Pollution Prevention Strategy.
10 New Hampshire Department of Environmental Services, Barriers to Pollution Prevention Within a Regulatory
   Agency, January 1995.
11 New Hamphshire Department of Environmental Services small-quantity generators produce under 100 kg
   hazardous waste per month.
12 For more information about incorporating pollution prevention into enforcement and compliance at DES, see
   Barriers to Pollution Prevention  Within a Regulatory Agency, January 1995.
13 New Hampshire Department of Environmental Services, Environmental Fact Sheet: Contaminated Cloth
   Wipers for Laundering, Technical Bulleting WMD-1994-17.
14 Barriers to Pollution Prevention  Within a Regulatory Agency, January 1995, p. 13.
15 Personal communication with Stephanie D'Agostino, November 1994.
16 NJDEP, Profile of New Jersey Industry: Issues Relating to Pollution Prevention at Facilities in SIC Groups 26,
   28, 30, 33, and 34, April 1994.
17 Except machinery and transportation equipment.
18 For additional information on the North Carolina program, see "Factors contributing to thedevelopment of
   state programs: A case study, In: Wigglesworth, D., ed.  Pollution Prevention: A Practical Guide for State and
   Local Governments.
19 Region 4 states include Alabama,  Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
   and Tennessee.
20 Hunt, G. 1993. Factors contributing to the development of state programs: A case study. In: Wigglesworth, D.,
   ed. Pollution prevention: A practical guide for state and local governments, p. 16.
                                                     Case Studies • 79

A. Ranked Distribution of Total Funding by State
B. Funding Breakdown by State
C. Funding Breakdown by Grant
D. Groups Targeted by PPIS Grantees
E. List of Contacts
       Appendix • 81

Ranked Distribution of Total
Funding By State
New York
New Jersey
Rhode Island
West Virginia
Region 9 Territories
New Hampshire
Number of Grants
Total Funding 1

                          Appendix • 82

Ranked Distribution of Total Funding By State (Continued)
South Carolina
North Carolina
Region 10 Tribes
Region 6 Tribes
South Dakota
New Mexico
Number of Grants
Total Funding

                                   Appendix • 83

B.  Funding Breakdown By State
      Region 1
      EPA PPIS and SRRTA Funding, 1989-1993
                                                    #•     *x
                                                    ?     «₯r

      EPA PPIS and SRRTA Funding, 1989-1993
            — 1.200


            Q  300

                                Appendix • 84

Funding Breakdown By State (Continued)
       Region 3
       EPA PPIS and SRRTA Funding, 1989-1993
             e 400
             | 300



       EPA PPIS and SRRTA Funding, 1989-1993


             ? 600

             g 500

             | 400

             ? 30°
             ^ 200
                                  Appendix • 85

Funding Breakdown By State (Continued)
       Region 5

       EPA PPIS and SRRTA Funding, 1989-1993


             •^ 600

             § 500

             £ 400

       EPA PPIS and SRRTA Funding, 1989-1993
             ~ 400



Funding Breakdown By State (Continued)
       Region 7
       EPA PPIS and SRRTA Funding, 1989-1993
       EPA PPIS and SRRTA Funding, 1989-1993
            £ 300
                                 Appendix • 87

Funding Breakdown By State (Continued)
       Region 9
       EPA PPIS and SRRTA Funding, 1989-1993
               600 i-
Dollars (in th

-L N tt


       EPA PPIS and SRRTA Funding, 1989-1993


             •^ 600

             § 500

             £ 400

             J 30°

             1 !

                                 Appendix • 88

C.  Funding Breakdown By Grant
Year Federal Funds State Match

Region 1
Technical Assistance Program
Department of Environmental Protection

Indian Tribes/Other Organizations
New Eng. Waste Management Officials Assn.

Department of Environmental Protection
Department of Environmental Protection
University of Maine

Department of Environmental Protection
Office of Technical Assistance
Coastal Zone Management
Department of Environmental Protection
Department of Environmental Management

New Hampshire
Department of Environmental Services
Department of Environmental Services

Rhode Island
Department of Environmental Management
Narragansett Bay Water Quality Mgt. Dist.
Department of Environmental Management

Agency of Natural Resources
Agency of Natural Resources




























                   REGION 1 TOTAL
                                  Appendix • 89

Funding Breakdown By Grant (Continued)
Year Federal Funds State Match

Region 2
New Jersey
Dept. of Environmental Protection and Energy
Institute of Technology
Department of Environmental Protection
NJ Hazardous Waste Facilities Siting Comm.

New York
Department of Environmental Conservation
Cornell University - Center for the Environment
Cornell University
Industrial Technology Assistance Corp.
Western NY Economic Development Corp.
Department of Environmental Conservation









Region 3
Dept. of Natural Resources and Env. Control
Dept. of Natural Resources and Env. Control
District of Columbia
Environmental Regulation Administration
Metro. Washington Council of Governments
Department of the Environment
Department of Environmental Protection
Center for Hazardous Materials Research
Department of Environmental Quality
Department of Waste Management
West Virginia
Department of Environmental Protection
Division of Natural Resources


                                 Appendix • 90

Funding Breakdown By Grant (Continued)
Year Federal Funds
State Match

Region 4
Department of Environmental Management
Department of Environmental Management

Department of Environmental Regulation
Department of Environmental Regulation

Hazardous Waste Management Authority
Hazardous Waste Management Authority
Department of Natural Resources

Department of Environmental Protection
Department of Environmental Protection

Department of Environmental Quality
Department of Natural Resources

North Carolina
Dept. of Env., Health, and Nat. Resources
Department of Nat. Resources & Comm. Dev.

South Carolina
Dept. of Health and Environmental Control
Dept. of Health and Environmental Control

Department of Environment and Conservation
Department of Health and Environment
































                          REGION 4 TOTAL
                                      Appendix • 91

Funding Breakdown By Grant (Continued)
Year Federal Funds State Match

Region 5
Hazardous Waste Research Information Research Center
Environmental Protection Agency
Environmental Protection Agency
Department of Environmental Management
Purdue University
Department of Environmental Management
Michigan State University
Department of Education
Department of Commerce and Resources
Department of Natural Resources
Office of Waste Management
Department of Development
University of Cincinnati
University of Wisconsin-Madison
Department of Natural Resources
























                                 Appendix • 92

Funding Breakdown By Grant (Continued)
Organization Year Federal Funds
State Match

Region 6
Department of Pollution Control and Ecology 1991
Indian Tribes/Other Organizations
All Indian Pueblo Council 1993
All Indian Pueblo Council 1992
Department of Environmental Quality 1993
Department of Environmental Quality 1 989
New Mexico
Environment Department 1993
Department of Environmental Quality 1 993
Department of Health 1990
Texas Water Commission 1 993
Lower Colorado River Authority 1993
Texas Water Commission 1 989


















                                 Appendix • 93

Funding Breakdown By Grant (Continued)
Year Federal Funds State Match

Region 7
Iowa Waste Reduction Center - U. of N. Iowa
Department of Natural Resources
Iowa Waste Reduction Center
Department of Natural Resources

Department of Health and Environment

University of Missouri
Department of Natural Resources

Department of Environmental Quality
University of Nebraska, Lincoln
















                     REGION 7 TOTAL

Region 8
Department of Health
Department of Health
Department of Health
Montana State University
Montana State University
South Dakota
Dept. of Environment and Natural Resources
Dept. of Environment and Natural Resources
Department of Environmental Quality
Department of Environmental Quality
State of Wyoming




















                                      Appendix • 94

Funding Breakdown By Grant (Continued)
Year Federal Funds
State Match

Region 9
Department of Environmental Quality
Trade and Commerce Agency
Department of Health Services
Department of Health
University of Nevada, Reno
Region 9 Territories
American Samoa EPA
Navajo EPA
N. Mariana Islands Dept. of Public Health
American Samoa EPA


Region 10
Department of Environmental Conservation
Office of the Governor
Department of Environmental Protection
Department of Health and Welfare
Indian Tribes/Other Organizations
Chugachmiut Tribe
Jamestown S'Klallam Tribe
Kwetthluk I.R.A. Council
Shoshone-Bannock Tribe
Swinomish Indian Tribal Community
Department of Environmental Quality
Department of Environmental Quality
Department of Ecology
Department of Ecology
Department of Ecology


                                 Appendix • 95

Groups Targeted by
PPIS Grantees
Targeted Industry Sectors ^^^^^^^^^^^^^1

Targeted Industries
Automotive industry (includes auto body
repair and vehicle maintenance)
Dry cleaners
Metal manufacturing
Solvents users
Metal plating
Chemical production
Food processing
Air conditioning/CFCs
Health care
Pulp and paper
Pesticide applicators
Glue manufacturing
Machine shops
Number of Grants
Percent of Total
                         Appendix • 96

Groups Targeted by PPIS Grantees (Continued)
Targeted Industry Sectors (Cont.) ^^^^^^^^^^^^^H
Targeted Industries Number of Grants
Surface coaters
Plastic manufacturing
Wood products
Beauty parlor
Underwater equipment
Percent of Total
       Targeted Group
Number of Grants
Percent of Total
Environmental regulators
Environmental groups
Trade associations
Local governments
Publicly Owned Treatment Works (POTWs)
Indian Tribes
                                   Appendix • 97

List of Grant Contacts
              Region 1
              Ms. Mary Sherwin
              Office of Poll. Prev., Waste Mgmt Bureau
              CT Dept. of Environmental Protection
              79 Elm Street
              Hartford, CT 06106-5127

              Ms. Rita Lomasney
              Connecticut Hazardous Waste
              Management Service
              50 Columbus Blvd
              Hartford, CT 06106

              Mr. Ron Dyer
              Director, Office of P2, Maine Department
              of Environmental Protection
              State House Station #17
              Augusta, ME  04333

              Ms. Susan Peck
              Bureau of Waste Prevention
              Massachusetts Department of
              Environmental Protection
              1 Winter Street
              Boston, MA  02108

              Ms. Barbara Kelley
              Director, Exec. Office of Env. Affairs
              Massachusetts Office of
              Technical Assistance
              100 Cambridge Street
              Boston, MA  02202

              Mr. Kakisz
              Toxic Waste Source Reduction Program
              Massachusetts Office of Env. Affairs
              Coastal Zone Management,
              Buzzards Bay Project
              2 Spring Street
              Marion, MA 02738
Mr. William Kacher
MA Dept. of Environmental Protection
Bureau of Waste Prevention
1 Winter Street
Boston, MA 02108

Mr. James McCaughey
Narragansett Bay Water Quality
Management District Commission
235 Promenade Street, Suite 500
Providence, RI 02908

Mr. Vincent Perelli
Waste Mgmt. Spec., P2 Program
NH Dept. of Environmental Services
Waste Management Division
6 Hazen Drive
Concord, NH 03302-0095

Ms. Stephanie D'Agostino
P2 Coordinator
Waste Management Division
NH Department of Environmental Services
6 Hazen Drive
Concord, NH 03302-0095

Ms. Terri Goldberg
Northeast Waste Management
Official's Association
129 Portland Street, 5th Floor
Boston, MA 02114

Mr. Richard Emander
Principal  Env. Scientist
Rhode Island Department of
Environmental Management
83 Park Street
Providence, RI 02903
                                      Appendix  • 98

List of Grant Contacts (Continued)
Ms. Marquita Hill
University of Maine
5737 Jenness Hall
Orono, ME  04469-5737

Mr. Gary Gulka
Vermont Agency of Natural
Resources/Department of
Environmental Conservation
103 South Maine Street
Waterbury VT 05671-0404

Region 2

Mr. Keith Porter
Cornell University
Water Resources Institute
Holister Hall
Ithaca, NY  14853

Ms. Ellen Harrison
Office of Sponsor Programs
Cornell University
120 Day Hall
Ithaca, NY  14853

Mr. Kevin Kelly
NY City Industrial Technology
Assistance Corporation
253 Broadway, Room 302
New York, NY 10007

Ms. Jean Herb
Director, Office of Pollution Prevention
New Jersey Department of
Environmental Protection & Energy
Trenton, NJ  08625-0427

Mr. Steven Anderson
NJ Dept. of Environmental Protection
Office of Pollution Prevention
401 East State Street, CN-423
Trenton, NJ  08625
Mr. Kevin Gashlin
New Jersey Institute of Tech.
Advanced Technology Center
University Heights
Newark, NJ  07102

Mr. John E. lannotti
NY Department of Environmental
50 Wolf Road
Albany, NY  12233-8010

Mr. Thomas Hersey
Environmental Compliance Service
Erie County Department of
Environment and Planning
95 Franklin Street
Buffalo, NY 14202-3973

Region 3

Mr. Steve Ostheim
Director, Env. Info & Education
Center for Hazardous Materials Research
University of Pittsburgh Trust
320 William Pitt Way
Pittsburgh, PA 15238

Ms. Andrea Farrell
DE Department of Natural Resources
and Environmental Control
89 Kings Highway/P.O. Box 1401
Dover, DE 19903

Mr. Nick Kauffman
DC Government Env. Reg. Admin.
2100 Martin Luther King Jr. Ave., SE
Suite 203
Washington, DC 20020
                                           Appendix  • 99

List of Grant Contacts  (Continued)
                   Ms. Liz Taddeo
                   Pollution Prevention Coordinator
                   Maryland Dept. of the Environment
                   Office of Strategic Planning and Policy Coord.
                   2500 Broening Highway
                   Baltimore, MD 21224

                   Mr. George Nicholls
                   Metropolitan Washington
                   Council of Governments
                   777 N. Capitol Street, NE, Ste. 300
                   Washington, DC  20002-4226

                   Ms. Meredith Hill
                   Chief, Source Reduction Program
                   Bureau of Waste Management
                   P.O. Box 2063
                   Harrisburg, PA 17105-2063

                   Ms. Sharon Kenneally Baxter
                   Office of Pollution Prevention
                   VA Dept. of Environmental Quality
                   629 East Main Street, 7th Floor
                   P.O. Box 10009
                   Richmond, VA 23240-0009

                   Mr. Randy Huffman
                   West Virginia Department of
                   Natural Resources
                   1356 Hansford Street
                   Charleston, WV 25301

                   Dr. Jan R. Taylor
                   West Virginia Div. of
                   Environmental Protection
                   Office of Waste Management
                   1356 Handsord Street
                   Charleston, WV 25301
Region 4

Mr. Daniel Cooper
Chief, Special Projects
AL Dept. of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463

Ms. Betsy Galocy
Florida Department
of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400

Mr. Greg Andrews
Georgia Pollution Prevention Assistance Div.
7 Martin Luther King Highway
Suite 450
Atlanta, GA 30334

Ms. Nini Hughes
KY Natural Resources and
Environmental Protection Cabinet
14 Reilly Road
Frankfort, KY  40601

Mr. Thomas Whitten
Director of Pollution Prevention Div.
Mississippi Dept. of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson, MS 39289-0385

Mr. Gary Hunt
NC Dept. of Environment, Health,
and Natural Resources
Office of Waste Reduction
P.O. Box 27687
Raleigh, NC 27611-7687
                                          Appendix • 100

List of Grant Contacts (Continued)
Mr. Bob Burgess
Center for Waste Minimization
South Carolina Department of
Health and Environmental Control
2600 Bull Street
Columbia, SC  29201

Ms. Tracy Thompson
Div. of Pollution & Env. Awareness
TN Department of Environment
and Conservation
401 Church Street, 14th Fl., L&C Tower
Nashville, TN  37243-0454
Region 5
Mr. Michael Hayes
Illinois EPA
Office of Pollution Prevention
2200 Churchill Rd./P.O. Box 19276
Springfield, IL  62794-9276

Mr. Tom Neltner
Dir., Office of Pollution Prev. & Tech. Ass.
IN Dept. of Environmental Management
100 North Senate Ave./P.O. Box 6015
Indianapolis, IN 46206-6015

Ms. Alice Tomboulian
798 West General Road
Rochester,  MI 48306

Ms. Barb Spitzley
Michigan Department of Commerce
and Natural Resources
P.O. Box 3004
Lansing, MI  48909
Ms. Kathy Eraser
Michigan State University
Cooperative Extension
1200 North Telegraph, Dept. 416
Pontiac, MI 48341

Ms. Marcia Horan
Department Specialist,
Waste Reduction Services, Waste
Management Division,
Departments of Commerce and Natural
Lansing, MI  48909

Mr. Kevin McDonald
Minnesota Office of Waste Management
1350 Energy Lane
St. Paul, MN  55110

Dr. Norman Chagnon
Ohio Dept. of Development, Technological
Innovation Division
77 South High Street
P.O. Box  1001
Columbus, OH 43216-1001

Dr. Lynn Corson
Director, IN Pollution Prevention Institute
Purdue University
1291 Cumberland Ave., Suite Cl
West Lafayette, IN 47906-1385

Ms. Jackie Peden
University of Illinois
Haz. Waste Research & Info Center
801 South Wright Street/109 Coble Hall
Champagne, IL 61820
                                          Appendix  • 101

List of Grant Contacts (Continued)
                  Mr. Tom Eggert
                  Director, Office of Pollution Prevention
                  WI Dept. of Natural Resources
                  101 S. Webster Street
                  P.O. Box 7921
                  Madison, WI  53707-7921

                  Mr. Gary Jackson
                  Farm*A*Syst program
                  B142 Steenbock Library
                  550 Babcock Drive
                  Madison, WI  53706-1293

                  Mr. Bruce Suits
                  Program Manager,
                  City of Cincinnati
                  Cincinnati, OH 45237

                  Region 6

                  Mr. Tim Chavez
                  All Indian Pueblo Council
                  Pueblo Office of Environmental Protection
                  3939 San Pedro, NE
                  Albuquerque, NM 87110

                  Mr. Bob Graham
                  Small Business  Ombudsman
                  AR Dept. of Pollution Control and Ecology
                  8001 National  Drive/P.O. Box 8913
                  Little Rock, AR 72219-8913

                  Ms. Joanna Gardner
                  LA Dept. of Environmental Quality
                  P.O. Box 82263
                  Baton Rouge, LA 70884-2263

                  Mr. Bill Mollere
                  LA Department of Environmental Quality
                  P.O. Box 82178
                  Baton Rouge, LA 70884-2178
Mr. Mark Johnson
Project Manager,
Lower Colorado River Authority
Environmental Services
P.O. Box 220
Austin, TX  78767
800/776-5272 X2868

Mr. Mitch Hanrahan
New Mexico Environment Department
Solid Waste  Bureau
1190 St. Francis Drive
Santa Fe, NM 87502

Ms. Dianne Wilkins
Pollution Prev. Program
OK State Department of Env. Quality
1000 Northeast 10th Street
Oklahoma City, OK  73117-1212

Mr. John Janak
Fin Admin./Budget & Planning Dept.
Texas Natural Resource Conservation
P.O. Box 13087, Capital Stat., 345 Rm.
Austin, TX  78711-3087
Region 7

Mr. John Atkinson
Curators of the University of Missouri
W1000 Engineering Building, East
Columbia, MO  65211

Mr. Mark J. Slatterly
Iowa Department of Natural Resources
Waste Management Assistance Div.
Wallace State Office Building
DesMoines, IA 50319
                                          Appendix • 102

List of Grant Contacts (Continued)
Mr. John Konefes
Iowa Waste Reduction Center
University of Northern Iowa
75 Biology Research Complex
Cedar Falls, IA 50614-0185

Ms. Theresa Hodges
KS Department of Health & Env.
Forbes Field
Building 740
Topeka, KS 66620-0001

Ms. Becky Shannon
Tech. Assistance Program
MO Dept. of Natural Resources
P.O. Box 176
Jefferson City,  MO  65102

Ms. Teri Swarts
NE Dept.  of Environmental Quality
The Atrium
1200 N Street, Suite 400
P.O. Box 98922
Lincoln, NE 68509-8922

Dr. Mohamed Dehab
University of Nebraska
W348 Nebraska Hall
Lincoln, NE 68588-0430
Region 8

Ms. Parry Burnap
Pollution Prev. Waste Reduction Prog.
CO Dept. of Health
4300 Cherry Creek Dr., S.
Denver, CO 80222-1530
Ms. Karen Bucklin Sanchez
P2 Coordinator
Montana State University
Extension Service
Taylor Hall
Bozeman, MT  59717-0312

Mr. James Raysor
SD Department of Environmental
and Natural Resources
Div. of Water Resources Management
523 East Capitol, Joe Foss Building
Pierre, SD 57501-3181

Ms. Sonja Wallace
Office of Executive Director
Utah Dept. of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4910

Ms. Pat  Gallagher
Senior Env. Analyst
Solid Waste Management
WY Dept. of Environmental Quality
122 West 25th Street, Hershler Bldg.
Cheyenne, WY  82002

Region 9

Ms. Sheila Wiegman
American Samoa Environmental
Protection Agency
Executive Office Building
Pago Pago, AS  96799

Ms. Sandra Eberdt
Arizona  Dept. of Environmental Quality
Office of Waste Programs
3033 North Central Avenue
Phoenix, AZ 85012
                                          Appendix  • 103

List of Grant  Contacts (Continued)
                                   Region 10
Ms. Kathryn Barwick
Waste Mgmt. Engineer/Dept. of
CA Dept. of Toxics Substances
P.O. Box 806
Sacramento, CA 95812-0806

Ms. Maria Morris
CA Trade & Commerce Agency
Office of Small Business
801 K Street
Suite,  1700
Sacramento, CA 95814

Ms. Carrie McCabe
Hawaii Department of Health
5 Waterfront Plaza, Suite 250D
500 Ala Moana Boulevard
Honolulu, HI  96813

Mr. Malcolm Curly
Office of Contracts & Grants
The Navajo  Nation
Navajo Environmental Protection
P.O. Box 9000/Navajo Nation
Winderock,  AZ  86515

Mr. Kevin Dick
University of Nevada, Reno
College of Business Admin.
Small Business Development
Center, MS  032
Reno, NV 89557-0100
                                   Mr. Paul Jackson
                                   Community Health Services Div.
                                   4201 Tudor Centre Drive, Suite 210
                                   Anchorage, AK 99502

                                   Mr. David Wigglesworth
                                   Pollution Prev. Office
                                   AK Dept. of Environmental
                                   3601 C Street, Suite  1334
                                   Anchorage, AK 99503

                                   Ms. Katie Sewell
                                   Dept. of Health & Welfare
                                   ID Div. of Environmental Quality
                                   1410 North Hilton
                                   Boise, ID 83706

                                   Ms. Lyn Muench
                                   Jamestown S'Klallam Tribe
                                   1033 Old Blyn Highway
                                   Squim, WA 98382

                                   Mr. Tim Michael
                                   Kwethluk I.R.A. Council
                                   Organized Village of Kwethluk
                                   Bethel, AK 99559

                                   Ms. Sandy Gurkewitz
                                   OR Dept. of Environmental Quality
                                   811 SW 6th Avenue
                                   Portland, OR  97204

                                   Mr. Charles Bidondo
                                   Shoshone-Bannock Tribes
                                   P.O. Box 306
                                   Foot Hall, ID  83203
Ms. Sarah Peacock
Director of Admin. Services
State of Alaska
Office of the Governor
P.O. Box 10001
Juneau, AK 99811

Ms. Lauren Rich
Swinomish Indian Tribal
P.O. Box 817
LaConner, WA 98257

Ms. Tamie Kellogg
WA Department of Ecology
P.O. Box 6741
Olympia, WA 98504-7600

Mr. Jerry Parker
WA State Dept. of Ecology
P.O. Box 47600
Olympia, WA 98504-7600

Mr. Darin  Rice
WA State Dept. of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
                                          Appendix • 104

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