vxEPA
United States
Environmental Protection
Office Of Water
(WH-547)
EPA832-R-93-001
June 1993
Municipal Water Pollution
Prevention Program
National MWPP Conference
Washington, D.C.
« 27-28,1993
-------
MUNICIPAL WATER POLLUTION
PREVENTION CONFERENCE
April 27 & 28, 1993
The Municipal Water Pollution Prevention (MWPP) program is a cooperative voluntary
effort by the U.S. Environmental Protection Agency (EPA), State governments, and
municipalities. EPA established the MWPP program to promote State systems that stimulate
source reduction, prevent permit violations under the National Pollutant Discharge Elimination
System (NPDES), and maximize the useful lives of publicly-owned treatment works (POTWs)
through reduced wastewater flows and effective operation and maintenance.
On April 27 and 28, 1993, EPA's Office of Wastewater Enforcement and Compliance
(OWEC) hosted a meeting of State and EPA Regional and Headquarters participants in the
MWPP program. The purpose of the meeting was to discuss progress made by States and
EPA in implementing MWPP, barriers and incentives to the MWPP program, measures of
success, and further actions. This report summarizes the major presentations at the
Conference and highlights the major issues raised by the participants. The Conference
included presentations and discussions of the following subjects:
the status of State MWPP programs;
MWPP programs in Region 6;
enforcement as an MWPP tool;
Wisconsin's MWPP program;
the EPA Pollution Prevention Program;
source reduction activities at POTWs;
current EPA initiatives in water and energy conservation;
pollution prevention in the Stormwater Program;
measures of MWPP program success;
the future of the MWPP program; and
issues for EPA Headquarters to consider.
Attachment 1 is the Conference agenda and list of speakers. Attachment 2 is a list of
participants.
-------
WELCOME & INTRODUCTION
Mike Quigley (OWEC, Municipal Support Division) and Steve Allbee (OWEC, Municipal
Assistance Branch) welcomed the participants and described the goals for the Conference.
Mr. Quigley reiterated Administrator Browner's emphasis on pollution prevention (PP). He
stated that Ms. Browner intends to ensure that EPA incorporates PP considerations into all of
its activities. Mr. Quigley observed that State Revolving Funds (SRFs) are becoming available
for more broad use, including use for PP initiatives. Mr. Quigley expressed his enthusiasm for
the MWPP program and his sense of encouragement based on the MWPP activity occurring
in the States.
Mr. Allbee agreed with Mr. Quigley that PP is among the highest priorities of the new
Administration. Mr. Allbee cited the President's report Vision for America as evidence of the
Administration's commitment to PP. He confirmed that PP is one of the eight priority areas
OWEC identifies in its strategic plan; and that PP will be integrated into all areas of activity,
including permitting, enforcement, and technical assistance.
Mr. Allbee described the primary mechanisms through which EPA funds MWPP
initiatives. OWEC has awarded ten $50,000 pilot grants during each of the past several
years; companion grants have been funded and awarded through EPA's Pollution Prevention
Division. In addition to these two primary mechanisms, OWEC provided lesser amounts of
funding for MWPP programs through several other ad hoc mechanisms. Mr. Allbee
acknowledged, however, that he is uncertain of the availability of future funding to sustain the
MWPP program.
ROUND TABLE PRESENTATIONS BY REGIONS/STATES ON PROGRAM STATUS
Region 1
Charles Conway (EPA, Region 1) reported that the goal of Regions 1 's MWPP
program is to ensure compliance and maintain the integrity of the wastewater treatment
infrastructure. The primary mechanisms for implementing the program are technical
assistance and facility self-assessments. Region 1 avoids using enforcement mechanisms to
promote MWPP. Instead, the Region has performed over 60 facility audits in the past 10
years. The Region 1 States use an annual self-assessment report to promote adequate
program planning. Mr. Conway believes that the self-assessment procedure promotes
communication and coordination between wastewater treatment facility operators and local
elected officials. Mr. Conway reports that New Hampshire, Rhode Island, Vermont, and Maine
Page 2
-------
have implemented MWPP programs and that 100 percent of the major and minor dischargers
in Region 1 States have performed self-assessments.
The greatest PP opportunities at wastewater treatment facilities, according to Mr.
Conway, are associated with the following areas:
energy reduction;
household hazardous waste management;
industrial pretreatment;
water supply system corrosion control;
beneficial use of sludge;
reduced use of chemicals; and
optimized process controls/changes.
Mr. Conway stated that EPA has not adequately demonstrated its support for the
MWPP program and that this support is critical to the long-term success of the program.
New Hampshire Brad Foster (NH, WPSCD) described how New Hampshire began its
MWPP program. The State first established a baseline measure of the performance of the
State's POTWs. Annual self-assessment reports (ASARs) provided data for the baseline. The
ASARs are, according to Mr. Foster, a very useful mechanism for enhancing communication
between treatment facility operators and local decision makers; both parties must "sign off' on
the ASARs prior to submission to the State.
Mr. Foster observed that many facilities are experiencing difficulty in managing their
finances. For example, some small facilities collect user charges that do not offset operation
and maintenance costs.
New Hampshire emphasizes technical assistance. Mr. Foster said that four State
personnel provide ongoing technical assistance to the State's approximately 110 facilities.
Maine Richard Darling (ME, DEP) stated that the MWPP program in Maine is very
similar to the program in New Hampshire. He said that Maine took steps at the outset to
computerize the ASARs and resulting data. Maine can now complete much of the ASAR form
with facility-specific information prior to distributing the form, on computer disk, to the
facilities. This technique, according to Mr. Darling, allows better data quality assurance,
lessens the burden on the facility operators, and facilitates rapid data analysis. DEP is
piloting this computerized approach at eight POTWs. Implementation at all 125 of the State's
POTWs is expected in the summer of 1993.
Page 3
-------
DEP has devoted 12 staff to maintaining this program three at its headquarters
offices and nine in its field offices. The field personnel also provide facility inspections. Mr.
Darling stated that he hopes to increase to five the number of staff at headquarters.
Region 2
Hank Mazzucca (EPA, Region 2) reported that New York has targeted 23 of its 800
facilities to test an effort that would provide insight into compliance trends. Difficulty in
identifying noncomplying facilities has, according to Mr. Mazzucca, hampered New York's
ability to aggressively implement the MWPP program. The initiative involved developing a
spreadsheet that could be downloaded by the State from the Permit Compliance System
(PCS) to identify facilities that are experiencing compliance problems. The initiative
encountered two difficulties, however. Software compatibility problems and a lack of
compliance problems at many of the 23 pilot facilities have prevented this test program from
yielding insight into noncompliance trends.
Region 3
Dennis Ducko (EPA, Region 3) introduced the Region 3 States. He reported the
status of the MWPP program in the States: Virginia does not have an MWPP program; West
Virginia and Maryland have both received pilot grants and have begun MWPP activity; and
Delaware and Pennsylvania are expected to receive grants soon.
West Virginia Leroy Gilbert (WV, Pollution Prevention Services) reported that West
Virginia's MWPP, which is non-regulatory, is well-funded, with two full-time staff positions
one for municipal dischargers and one for industrial dischargers. Funding is provided by
federal grants and permit fees generated within the State. The State's program is almost one
year old and has been well received by the municipalities, the State, and the EPA Regional
office. Mr. Gilbert said that the West Virginia MWPP program has significantly reduced
wastewater discharges and violations.
Mr. Gilbert explained that many industrial dischargers have recently become regulated.
Therefore, one of the highest priorities of his office is to aggressively provide outreach to the
industrial community. West Virginia has successfully used an array of outreach mechanisms,
including targeted mailings, trade shows, referral networks, and public news media.
David Byrd (WV, Division of Environmental Protection, Municipal Section) said that
outreach, in addition to being vital to the industrial community, is also vital to the municipal
community. Mr. Byrd stated that he has contacted over 200 wastewater treatment facilities
Page 4
-------
and over 100 drinking water treatment facilities to advise them of the MWPP assistance the
State can provide. He also targets school districts for technical assistance. Mr. Byrd
explained that most of West Virginia is rural and that there are only 10 major NPDES
permittees in the State. Because of this rural orientation, Mr. Byrd has implemented a rural
demonstration project. This project seeks to identify alternate types of treatment facilities that
can be used in small West Virginia communities.
Pennsylvania Tom Brown (PA, Bureau of Water Quality) said that Pennsylvania does
not have an MWPP coordinator, but that the State pursues MWPP activities through its
Section 104(g) program. Mr. Brown described Pennsylvania's "Peer-Based" training system,
through which his office maintains a pool of experienced independent wastewater
professionals that he draws upon and assigns to assist municipalities with specific problems.
Mr. Brown attributes the tremendous success of the Peer-Based training to the practical "real
world" experience that the trainers possess. Mr. Brown reported that his experience indicates
that the threat of enforcement action is sometimes required to encourage facilities to take
advantage of MWPP outreach and assistance.
Maryland Hal Benson (MD, Department of the Environment) stated that Maryland is
just beginning its MWPP efforts. The State has established an advisory team using
Department of the Environment employees and has contracted with the Maryland Center for
Environmental Training for field support. Mr. Benson pointed out that much POTW-related
pollution results from spills, equipment failure, or inadequate funding. Maryland's programs,
therefore, emphasize ensuring critical preventative maintenance and providing funding
oversight.
JaKe Bair (MD, Maryland Center for Environmental Training) described Maryland's
aggressive outreach and training initiative. The initiative includes 140 classes per year and 30
energy audits at drinking water and wastewater plants. Mr. Bair alerted the conference
participants to the U.S. Department of Energy's "Energy Restitution Trust Fund," which he
described as a source of funding for a State's energy audit program.
Delaware Bob Zimmerman (DE, Division of Water Resources) described the following
MWPP initiatives taking place in Delaware:
distributing home audit kits;
providing training for businesses;
revising NPDES requirements to reflect PP;
conducting multi-media inspections at industrial and municipal facilities;
piloting a Wisconsin-like approach;
Pages
-------
proposing a reduction of SRF interest rates for facilities "in good health;" and
pursuing energy conservation.
Region 4
Ben Chen (EPA, Region 4) reported that Alabama, Georgia, and North Carolina, the
leaders in the Region in implementing the MWPP program, may achieve full-scale
implementation by the end of this year. He said that the Region has a very good working
relationship with the States and that the flexibility of the MWPP program facilitates integrating
the program with existing State programs. He described the MWPP program as a partnership
in which the States provide practical, "in the trenches" experience and knowledge and the
Region provides MWPP resources and promotes education and outreach. MWPP is a
component of all of the Region 4 Section 205 workplans.
Alabama Mr. Chen said that Alabama's MWPP program is based on Wisconsin's
compliance maintenance annual reporting (CMAR) program, a formal reporting mechanism.
The State uses a self-audit questionnaire similar to Wisconsin's, but has added questions
related to ammonia and toxicity. Alabama uses the questionnaire during its review of SRF
loan, industrial indirect discharge, and federal and State grant applications. The State is in
the process of developing a computer system to integrate CMAR with EPA's Permit
Compliance System (PCS) and the SRF priority system.
North Carolina Mr. Chen reported that North Carolina is also using a system based
on Wisconsin's, but with two differences. The primary difference between Wisconsin's
program and North Carolina's is in each program's early warning system (EWS). In North
Carolina, the EWS is based on intensive State-level analysis of State-developed PCS data.
Based on a linear regression of PCS data for two full years, North Carolina's staff predicts
when facilities will become non-compliant. Mr. Chen reported that the State has had excellent
success with this approach and is using it on a quarterly basis for all of its 305 facilities. The
State targets for performance audits facilities that are expected to become non-compliant
within one year. Second, North Carolina's MWPP program is implemented through the
construction grants program.
South Carolina South Carolina, according to Mr. Chen, did not actually begin an
MWPP program until 1992, although it received an MWPP pilot grant in 1991. South
Carolina's EWS is based on a questionnaire, much like Wisconsin's EWS. The State is
currently operating a pilot program of the EWS with 12 POTWs results are expected in
Spring, 1993. The State has assembled a 12-member, cross-sector advisory committee that
Page 6 /\
W
-------
formulates the MWPP program elements. To encourage participation in the MWPP program,
the State has been using participation as a criterion for receipt of SRF loans.
Georgia Ernest U. Earn (GA, Municipal Engineering Program) said that Georgia uses
a voluntary approach for its MWPP program and uses incentives to encourage participation
by major and minor NPDES permit holders. However, POTWs may participate in the SRF
only if they prepare a compliance maintenance plan. While Georgia's CMAR is based on
Wisconsin's, the State has- revised the reporting form each of the last two years based on
comments received from POTWs. Recent modifications to the reporting form include changes
designed to ensure that the POTWs in greatest need of funding are given priority over those
that less urgently need funds.
Georgia has performed detailed evaluations of 18 to 20 POTWs over the past three
years. It found that the rate of compliance by POTWs with their permit requirements has
been steadily increasing. In 1991, the State observed a 55 percent compliance rate. In 1992,
the compliance rate rose to 60 percent. In 1993, trje expected compliance rate is 65 to 70
percent.
Mr. Earn concurred with Mr. Chen that the Region 4 States have a good working
relationship with the EPA Regional office. Like other speakers, Mr. Earn believes that the
MWPP program has encouraged communication and cooperation between facility operators
and local decision-makers.
Mississippi Mike Freiman (MS, Municipal Permit Compliance Branch) said that in
Mississippi, as in Georgia, MWPP is a voluntary program. However, he said that the State is
considering making MWPP a mandatory requirement of NPDES permits. The present
voluntary program targets all major and mechanical NPDES permit holders. The State has
recently developed an MWPP training course for facility operators and the elected officials
responsible for those facilities two courses are presently planned.
Mississippi mails an ASAR to its treatment facilities. In 1992, 80 percent of these
facilities responded. During its review of the completed ASARs, the State assigned facilities to
one of the following three categories:
(1) no action required or recommended generally new or recently upgraded
facilities;
(2) action recommended facilities not yet out of compliance but in need of
further evaluation; and
Page 7
-------
(3) action required facilities already under one or more administrative orders.
The State concluded, based on the 1992 self-assessment reports, that 38.6 percent of the
treatment facilities did not require action and no actions were recommended. Actions were
recommended at 31.6 percent of the facilities and required at 29 percent of the facilities.
Mr. Freiman explained that the State does not associate its MWPP program with any
enforcement activity. However, if a municipality chooses not to implement an MWPP but later
falls into non-compliance, enforcement actions will be especially swift.
Kentucky Jerry Hurst (KY, Department of Natural Resources and Environmental
Protection) explained that Kentucky would like to develop and implement an MWPP program,
but that due to resources constraints, has been unable to do so. Despite these constraints,
the State is laying the ground work for an MWPP program through its enforcement office. To
date, the State has:
#
rearranged channels of communication to promote MWPP. It has involved the
offices responsible for construction, permitting, and planning in this effort.
developed a computer program to facilitate communication between EPA's
PCS and Kentucky's own mainframe.
changed existing regulatory language to require submission of plans and
specifications when each POTW has reached 80 percent of its design capacity.
The language also bans line extensions.
selected a preliminary list of EWS indications.
established a goal to impose average and maximum limits on flow.
While the State feels that it has accomplished much as a result of its early efforts
through the enforcement office, it does not feel that the enforcement office is an appropriate
"home" for an MWPP program. it. is looking for another office to lead the MWPP effort.
Tennessee Karen Grubbs (TN, Division of Construction Grants and Loans) said that
Tennessee has only recently become active in the MWPP initiative. She said that the MWPP
efforts are organized by the assistance bureau, not by the regulatory offices. Although the
State is still considering how to proceed with its MWPP program, it has begun working with a
university to test its reporting questionnaire. In addition, the State has begun coordinating
Page 8
-------
with the source reduction branch in order to link MWPP with the State's household hazardous
waste program. Ms. Grubbs reported that although Tennessee has not received an MWPP
pilot grant, the State intends to proceed, albeit slowly, with implementing its MWPP initiative.
Region 5
Ohio Jim Borton (OH, EPA) described Ohio's MWPP program as being similar to
Wisconsin's. While the program is mandatory, it does allow POTWs to adjust the scope of
the program, as local circumstances require, within the limits of established guidelines. The
State has established a technical advisory group to guide implementation of its MWPP
program.
Michigan Doug Erickson (Ml, Surface Water Quality Division) said that the Pollution
Prevention Unit, which had four full-time staff members, assembled a data base and a ranking
system that supports Michigan's MWPP program. The Unit has been disbanded, however.
The Unit's data base continues to serve a wide array of needs. For example, the State is
using the data base to target selected minor (and all major) POTWs to re-evaluate how these
POTWs manage their facilities.
Region 6
Texas Jan Sills (TX, Water Commission) described Texas' "75/90" program. Under
this program, all municipalities must initiate development of capacity expansion plans as soon
as the facility reaches 75 percent of its design capacity. Once the facility reaches 90 percent
of its design capacity, it must implement its expansion plans. The program requires that the
facility develop an expansion schedule and an audit tracking system.
Louisiana Bob Paul (LA, Department of Environmental Quality) stated that Louisiana's
MWPP program was initiated in 1981 by Section 308 orders. Since 1992, the State has
included MWPP language in all discharge permits. The State uses an ASAR form that is 27
pages long and assigns a point value to each operating area. Local governing bodies must
review the completed form and pass a resolution to correct deficiencies. Local resolutions
are intended to be specific in their description of how deficiencies will be corrected, but they
are often very general. The State is considering putting specific language in permits that will
ensure the specificity of local resolutions.
Region 7
Page 9
-------
Harold Owens (EPA, Region 7) reported that the Region considered several MWPP
models (e.g., Wl, NM) prior to encouraging the States in the Region to design and implement
their own program. The Region then worked closely with the States to plan and coordinate
the MWPP program. The MWPP programs in Region 7 are based, to varying degrees, on the
Wisconsin CMAR.
Of the Region VII States,- Nebraska has had the greatest success with MWPP. The
State has been conducting a pilot program with small communities. The communities were
initially reluctant to cooperate without additional funding. When the State made these
communities aware of the potential benefits of MWPP, however, the communities not only
agreed to participate, they expanded the scope of the pilot project by addressing effluent and
influent. Nebraska uses training and up-front assistance, rather than enforcement, to promote
MWPP.
Region 8
Harold Thompson (EPA, Region 8) said that Utah was the first State in the Region to
receive an MWPP pilot grant. Initially, the State required POTWs to estimate wastewater
treatment capacity needs for the next five years and to make plans to meet any anticipated
shortages of treatment capacity. However, POTWs were only required to carry out this
procedure once, and communities were not required to submit plans to the State or Region.
Currently, the State requires POTWs to prepare a compliance maintenance report every two
years. The reporting requirement is implemented through the construction grants program
and promoted through outreach it is not a part of the NPDES requirements. In Colorado,
on the other hand, the State has implemented planning and reporting requirements through
the NPDES program. Several other Region 8 States, including Montana, North Dakota, South
Dakota, and Wyoming are in the early stages of implementing MWPP programs.
Region 9
Angela Ivey (EPA, Region 9) reported on the Region 9 States. She said that the
Region 9 States have been reluctant to implement a self-audit reporting program. The Region
has been working with both State and local organizations to promote MWPP. Despite the
States' reluctance, she said, many of the municipalities have chosen to take the lead and
implement their own self-audit programs.
Within the Region, a variety of mechanisms are being used to require MWPP, including
NPDES permits and Sections 104(g) and 205(g). Permittees must conduct outreach to public
Page 10
-------
and private users of the wastewater treatment systems and they must identify opportunities
and alternatives that will promote MWPP.
Region 9 participates in several pilot programs, including EPA's Industrial Pollution
Prevention Program (IP3), opportunity assessments in Arizona and Nevada, and California's
South (San Francisco) Bay pilot project. Ms. Ivey pointed out that Hawaii actively performs
POTW inspections and corrective action reviews. She reported that Nevada and Arizona are
not actively pursuing participation in the MWPP program.
Region 10
Dan Steinborn (EPA, Region 10) reported that the Region 10 States are taking
individual approaches towards MWPP. Oregon, according to Mr. Steinborn, has chosen not
to implement a formal MWPP program. Alaska is finding that the MWPP program is not well
suited to its wastewater treatment infrastructure. The State consists of numerous small,
decentralized villages, many of which do not have any treatment systems. Those villages that
do have treatment systems have an urgent need for broad-based assistance, including
performance of basic maintenance and overall facility management. Idaho has begun its
MWPP program by developing a self-assessment procedure. The State is still identifying the
target systems, however, and has not yet decided whether or not the self-assessment will be
mandatory. Washington has completed a preliminary self-assessment package and will pilot
the package at treatment facilities this summer.
FOCUS ON MWPP PROGRAMS IN REGION 6
After the completion of the round table presentations by Regions and States, Roger
Hartung (EPA; Enforcement Branch, Region 6) and Harold Smith (EPA; Technical Section,
Municipal Facilities Branch, Region 6) described MWPP programs in Region 6 in more detail.
Mr. Hartung stated that the process of States assuming delegation for the MWPP program in
Region 6 is almost complete, and explained the development of the MWPP program in the
States of the Region.
In 1990, Louisiana and New Mexico piloted an MWPP program and were the first
States in the Region to do so. The two States adopted a tailored version of Wisconsin's
program. After a series of workshops, the States and Region adopted a more generic
Region-wide approach. This approach establishes MWPP as a reporting requirement under
the NPDES system for all major dischargers and minor dischargers that are under the
jurisdiction of majors. The reporting requirements require completion of an ASAR and
/\ Page 11
W
-------
adoption of a resolution by local governing bodies that any identified deficiencies will be
corrected. Two versions of the ASAR were developed one for large municipalities and one
for smaller municipalities. The questionnaire generated 30,000 pages of paper in the first year
and over 25,000 pages in each subsequent year, in total, 183 questionnaires need to be
reviewed and followed-up on per quarter.
Mr. Smith, based on the results of the ASARs and audits of 42 facilities, described
some of the problems of treatment facilities. Problems are generally associated with small
treatment facilities; the three most common problems are associated with overflows and
bypasses, infiltration and inflow, and user charges.
ENFORCEMENT AS AN MWPP TOOL
Walter Brodtman (OWEC, Enforcement Division) described enforcement and the
MWPP initiative as "hands washing each other;" there is a constant interplay between the two.
He identified ways in which the two policy approaches reinforce and support each other.
Using MWPP as an enforcement tool provides three benefits:
(1) MWPP saves time and costly enforcement resources;
(2) MWPP identifies pretreatment targets; and
(3) MWPP identifies need for corrective actions.
Using enforcement as an MWPP tool provides three benefits:
(1) enforcement can be the "gorilla in the closet" to encourage and promote
voluntary cooperation;
(2) enforcement settlements can specify MWPP compliance audits; and
(3) enforcement can be used to encourage corrective actions.
UPDATE ON WISCONSIN'S PROGRAM
Jim Fratrick (Wl, Department of Natural Resources) provided a report on Wisconsin's
compliance maintenance (CM) program.
The fundamental principles of CM are to:
Page 12
-------
ensure adequate operation and maintenance;
provide sound fiscal management;
evaluate the adequacy/performance of the POTW as it approaches the end of
its design life;
commence construction before permit violations occur; and
maintain the wastewater treatment system to the same extent as other
municipal systems.
The principal means of implementing the CM program is through the CMAR.
Wisconsin's CMAR consists of the following elements:
financial information,
subjective self-evaluation, and
point scoring.
Like MWPP programs in other States, Wisconsin requires that CMARs be reviewed by
local governing bodies and that these bodies pass resolutions to correct deficiencies revealed
by the reports. The State prepares and delivers a written follow up to all communities
regarding their report. The State uses this follow up as an opportunity to provide comments
and encouragement on the communities' compliance maintenance program.
Mr. Fratrick reported that the 1993 Wisconsin CMAR has been amended to more
completely address lagoons and ground water discharge systems, which were not adequately
addressed by prior CMARs.
Wisconsin has implemented the "Clean Water Fund," a low-interest loan program that
provides funds for water-related projects. These projects include, from highest to lowest
priority:
(1) ensuring compliance maintenance,
(2) responding to new or changed permit limits,
(3) installing systems in unsewered communities,
(4) providing urban stormwater controls,
(5) responding to non-point sources of pollution, and
(6) correcting violations.
Page 13
-------
EPJLATA £HEIT
Substitute for pages Li/' 15
POLLUTION PREVENTION AT EPA
Jim Craig (EPA, Pollution Prevention Division) provided an overview of EPA's PP
program. He emphasized that PP is an Agency-wide priority, not a priority in only certain
offices. He continued by summarizing Administrator Browner's Earth Day Statement:
Administrator Browner referred to PP as the "guiding core" and "central principle" for all EPA
activity. The Administrator defined PP as source reduction, with only limited inclusion of in-
process or closed-loop recycling.
Mr. Craig described EPA's five PP goals. They are to:
(1) make PP the principle of choice in mainstream work at EPA;
(2) help build and facilitate networks of regional, State, and local PP programs;
(3) identify and pioneer other PP-related programs (e.g., cross-media initiatives
and new models for government);
(4) generate and share information to promote PP and to track progress; and
(5) engage partnerships with the private sector on technical innovation;
SOURCE REDUCTION ACTIVITIES AT POTWs
North Carotin* Lindsey Mize ((NC, Pollution Prevention Program) described the
assistance the NC Pollution Prevention Program provides to POTWs. This assistance
includes operating an information clearinghouse, training POTW operators and others,
identifying waste reduction opportunities, performing audits, and assisting in outreach and
education. The Program provides support to large and small POTWs.
North Carolina's program is non-regulatory and relies on six full-time staff members.
In 1991, the State received an EPA/PP Division Grant to implement a PP pilot project North
Carolina's goals under the grant were to:
formalize a State-level MWPP structure,
establish an MWPP structure at the local level,
identify incentives and barriers to MWPP at the local level, and
formalize a system, of information transfer.
To help promote these goals, the State has been working with two municipalities on
two pilot studies. At the end of these pilot studies, the State hopes to start funding as many
municipal challenge grants as staff and funds allow. In addition to providing funds, the State
Pag* 14
-------
provides personnel that will work full-time at POTWs for a limited period (e.g., one month) to
improve PP. During this period, the State staff person works closely with the facility, its
operators, and its indirect dischargers.
Orange County Sanitation District Adriana flenescue (CA, Orange County Sanitation
District) described the multi-faceted pretreatment and PP programs that she has helped to
implement. The Orange County Sanitation District Authority embraces 23 cities, 454 square
miles, 2.1 million people, and 1,200 permittees (400 of whom are significant industrial users).
The staff at the Authority includes 40 engineers and inspectors.
The Authority's pretreatment program includes four components:
(1) ordinances,
(2) local limits,
(3) permits, and
(4) monitoring and inspections.
The Authority weaves PP themes through each of these components. Ms. Renescue
described an array of techniques the Authority is actively using or planning to use. Two
techniques used by the Authority that Ms. Renescue believes are critical to the success of a
PP initiative are:
(1) Mass Limits The Authority imposed mass-based limits in 1984 to augment
concentration-based limits. Only through the use of mass-based limits can a
POTW effectively prevent indirect dischargers from using dilution as a
management technique to meet concentration-based limits. Ms. Renescue
described mass-based limits as PP "enablers."
(2) Partnership with Industry Ms. Renescue stressed the importance of
cooperating with industry as partners jointly seeking resolution to a common
set of problems and concerns. This approach is critical to achieving
consensus, cooperation, and buy-in. The Authority promotes partnerships by
working face-to-face with the industrial community - sitting down together to
"discuss issues, conflicts, and barriers associated with PP. To date, the
Authority has established PP ad hoc committees, a mentor system, and an
Orange County Advisory Committee - ail designed to solidify the partnership
between the Authority and industry.
75
-------
WATER AND ENERGY CONSERVATION: CURRENT AGENCY INITIATIVES
John Flowers (OWEC, Municipal Assistance Branch) provided an overview of EPA's
water use efficiency initiative. The Water Use Efficiency Task Force was established in 1988
to develop a statement of principles and develop an incentive grants program. The statement
of principles accomplishes the following goals:
relates water quality to water quantity;
provides a context for PP;
addresses municipal, agricultural, and industrial users; and
establishes EPA's role as a provider of technical assistance and information.
In FY91 and FY92 the incentive grants program provided $1 million to fund 26 water use
efficiency projects. For FY93, EPA allocated $350,000 to provide seed money for a water use
efficiency clearinghouse and to promote the Water Alliances for Voluntary Efficiency (WAVE)
program.
The water use efficiency clearinghouse will be targeted to water management
professionals needing technical and programmatic information related to water use efficiency.
The American Waterworks Association (AWWA) is expected to submit a proposal to EPA to
develop and operate the clearinghouse.
The WAVE program is a voluntary, market-driven initiative to promote water use
efficiency. Through the WAVE program, EPA will engage in partnerships with water users and
suppliers. EPA is planning its initial partnership with the lodging (i.e., hotel and motel)
industry, whose most promising water efficiency opportunities are related to fixtures, kitchen
and laundry equipment and procedures, cooling, and landscape design and irrigation. EPA
estimates that aggregate annual savings to the lodging industry from the WAVE program will
be 32 billion gallons of water, 1 trillion BTUs of energy, and $85 million in avoided energy,
water, and sewer costs.
POLLUTION PREVENTION IN THE STORMWATER PROGRAM
Bill Swietlik (EPA, Permits Division) described the first phase of EPA's NPDES
stormwater program. Under the stormwater regulations, published in November 1990,
POTWs and certain other facilities meeting specified conditions are required to obtain a
stormwater permit. In order to obtain a permit, facilities must prepare a PP plan. Facilities
must complete the following five steps in order to prepare and implement a PP plan:
Page f6
-------
(1) plan and organize;
(2) evaluate the site;
(3) identify the best management practices;
(4) implement the plan; and
(5) evaluate and monitor of the plan.
Mr. Swietlik identified two resources available to POTWs addressing stormwater
issues:
(1) the Stormwater Hotline: 703/821-4823; and
(2) the Stormwater Manual for Industrial Activities (available from the Stormwater
Hotline).
MEASURES OF MWPP PROGRAM SUCCESS
Gary Champy (VT, Department of Conservation) reported that Vermont has an MWPP
program that is similar to the programs in Wisconsin and New Mexico. In 1992, the State
distributed 42 self-reporting forms to POTWs and received 40 completed forms in return. Mr.
Champy attributed this high return rate, in part, to the State's willingness to work closely with
the facility operators in the planning and design phase of the program. For example, facility
operators wanted a self-reporting form that did not look "regulatory." In response to this, the
State worked closely with operators when developing the reporting form, which focuses on
sludge and financial management, and on associated training.
Analysis of the returned forms has revealed that municipalities that did not receive
outreach do not manage their finances as well as other facilities. The State also concluded
that the turnover of operators and local officials is sufficiently high that training must be a
long-term, continuous undertaking.
Tom Reich (EPA, Region 6), who has been preparing a report, MWPP Results and
Trends, identified nine potential measures of long-term program success. He then asked the
conference participants to rank the measures from most to least useful/important. The
measures and their relative importance, in descending order, are:
(1) municipal response (e.g., timeliness of response, quality/specificity of response,
promptness of implementation);
(2) accomplishing pollution prevention (e.g., source reduction, reuse, recycling,
energy savings);
Page 17
-------
(3) establishing State programs;
(4) trends (e.g., type/severity problems at wastewater treatment facilities);
(5) projected versus actual cost;
(6) cost savings;
(7) useful life (e.g., design life versus projected life versus actual life);
(8) positive team spirit; and
(9) extent of operator certification.
Doug Johnson (EPA, Region 8) described the model MWPP program evaluation
strategy that Region 8 has been developing. The goals of the model evaluation strategy are
to evaluate whether a State's MWPP program goals are being met and to determine the PP
potential of each major POTW in the State and the PP potential for the State as a whole. The
model strategy is based on the goals articulated in South Dakota's self-assessment report.
The model strategy establishes the following evaluation objectives:
validate the utility and benefit of the MWPP program;
identify the most prominent characteristics of the MWPP program;
identify areas to reduce source loadings/capital expenditures;
inventory and compare NPDES compliance rates of major POTWs;
determine major POTWs' compliance life;
identify major POTWs planning and funding incentives; and
identify the factors limiting POTWs' performance.
The model strategy uses a qualitative approach based on data elements taken from
the State's self-assessment report. Mr. Johnson reported that data confidentiality is a critical
issue. Efforts should be taken to ensure that direct comparisons are not made between
POTWs and that data are used and published only anonymously or in aggregate. Mr.
Johnson said that program evaluation is critical to the long-term success of a State's MWPP
program and that a standardized evaluation procedure can increase the utility of any program
evaluation.
Katherine Dawes (EPA, OPPE) commented that those who do not evaluate the past
are doomed to repeat it. She idpr+ified three critical program evaluation questions:
(1) is MWPP doing the right things (i.e., is the program following guidelines and
directives)?;
(2) is MWPP doing the right things right (i.e., are success stories accruing)?; and
Page 18
-------
(3) is MWPP really making a difference (i.e., is the water any cleaner)?
The greatest utility comes from evaluations, according to Ms. Dawes, only when the
results/findings of the evaluation are passed "up the chain" to State and ultimately to national
decisionmakers and "down the chain" to local partners that will use the information to make
changes.
ROUND TABLE PRESENTATION: WHERE DO WE GO FROM HERE AND HOW DO WE
GET THERE?
Jeffrey Lape (OWEC, Special Assistant to Director) discussed EPA's efforts to
incorporate PP into NPDES programs. His presentation began by describing four kinds of
NPDES programs:
(1) municipal sources (e.g. POTWs),
(2) nonmunicipal sources (e.g., industrial facilities),
(3) stormwater, and
(4) pretreatment.
Mr. Lape then provided the following examples of EPA's efforts to integrate PP into
NPDES programs:
industry case studies,
PP workshops for permit writers,
review of State legal authorities,
model PP language for NPDES permits,
PP guidance for stormwater management,
PP training for pretreatment coordinators, and
PP assessments.
The IP3 Task Force, according to Mr. Lape, is investigating ways to address effluent
guidelines and categorical limits, which, in some cases, are expressed as concentration-
based standards. The Task Force is responding to potential barriers to PP, such as those
expressed by Ms. Renescue (i.e., concentration-based limits promote dilution and do not
encourage PP). The Task Force has not yet made any recommendations on this issue.
Mr. Flowers provided brief overviews of two recent statutory initiatives that affect the
MWPP program.
Page 79
-------
(1) Energy Policy Act of 1992 This Act includes water use efficiency standards for
newly manufactured toilets (1.6 gallons per flush), faucets (2.5 gallons per
minute), and showerheads (2.5 gallons per minute). The Act also requires that
federal agencies must install in all federally-owned buildings all energy and
water conservation measures whose payback is less than or equal to ten
years.
(2) Clean Water Act A proposal prepared by the National Wildlife Federation
would consider water use efficiency projects eligible for funding by SRFs. The
proposal would require all drinking water and wastewater utilities applying for
loans or grants to meet certain standards (i.e., the former must implement
monthly billing, leak detection controls, and pressure controls; the latter would
have to meter all connections, base its rates on meter readings, and restrict
block rates). All applicants for funds would have to complete integrated
planning efforts that compare life cycle costs of demand management to other
alternatives.
Mr. Brodtman discussed Supplemental Environmental Projects (SEPs) and how EPA
has used them to accomplish PP. According to Mr. Brodtman, there are five categories of
SEPs:
(1) pollution prevention,
(2) pretreatment,
(3) environmental restoration,
(4) public awareness, and
(5) environmental auditing.
One or more of these categories of SEPs may be incorporated into an EPA
enforcement order. By so doing, the noncomplying facility must undertake the specified
environmental project. In return, the facility receives certain penalty reductions. SEPs,
according to Mr. Brodtman, have been used primarily with industrial facilities. EPA is
rethinking its penalty policy, he said, to allow greater use of SEPs with municipalities. Likely
areas in which SEPs may be considered include water use efficiency, beneficial use of
sludge, and household hazardous waste.
Mr. Brodtman said that the Agency has been challenged on the appropriateness of
SEPs and that it is seeking clarification of its authority to use SEPs. In the interim, the
Agency is continuing to study the data that are needed to facilitate implementing SEPs and is
developing model SEP language to make the drafting of SEPs more efficient.
Page 20
-------
ITEMS FOR EPA HEADQUARTERS
Mr. Allbee led the conference wrap-up by asking the participants to prepare a list of
issues that EPA Headquarters should consider further. The issues were as follows:
Prepare a written memo to Division Directors articulating the Agency's top-level
commitment to MWPP.
MWPP should be voluntary for States, but it should include funding incentives
for the first two or three years.
Provide long-term funding for the MWPP program.
Give the States the flexibility to use two percent of the SRF for MWPP.
Provide recognition and awards similar to those it now provides for operation
and maintenance.
Provide more/better information about PP opportunities for POTWs.
Provide strategies for evaluating and demonstrating MWPP program
effectiveness.
Provide examples of source reduction, energy conservation, water use
efficiency, and audits for facilities to use as guides.
Emphasize the importance of operation and maintenance.
Provide training.
Negotiate partnerships among the various players.
Provide better identification/diagnosis of POTW problems/weaknesses.
Provide training/guidance to facility personnel on operation fundamentals and
management of local governing boards.
Promote "peer-help" programs.
Page 21
-------
Encourage use of appropriate technology.
Ensure anti-backsliding/anti-degradation requirements.
Provide consistent guidelines, policies, and interpretations.
SUMMARY REMARKS
Mike Cook (OWEC, Office Director) confirmed previous commenters1 observations that
MWPP and water use efficiency are priority initiatives on Capital Hill, within EPA, and among
the national organizations. He said that Administrator Browner's priorities are clear with
respect to PP - PP will be a central component of all EPA programs. Mr. Cook
acknowledged that some individuals may have questioned the Agency's previous
commitment and top management support for the MWPP program. He believes, however,
that the Administrator's clearly articulated support will provide the demonstration of
commitment that many individuals seek. Mr. Cook predicted that reauthorization of the Glean
Water Act will result in more rigorous PP planning requirements and echoed Mr. Brodtman's
comment that the Agency is soliciting clarification of its authority to use SEPs.
Page 22
-------
ATTACHMENT 1
CONFERENCE AGENDA
-------
MUNICIPAL WATER POLLUTION PREVENTION CONFERENCE
SHERATON CITY CENTRE
1143 NEW HAMPSHIRE AVENUE, NW
WASHINGTON, D.C. 20037
April 27 - 28, 1993
AGENDA
Day 1:
8:30 - 8:40 Welcome and Introduction
Michael Quigley, Director
Municipal Support Division
U.S. EPA Headquarters
8:40 - 9:10 MWPP Program Overview: Headquarters Perspective
Steve Allbee, Chief
Municipal Assistance Branch
U.S. EPA Headquarters
9:10 - 10:15 Round Table Team Presentation by Regions/States
on Status of MWPP Programs
- Type of Program
- Use of the Compliance Maintenance Annual
Report (CMAR)
- Region/State Relationship
- Community Buy-In
- Enforcement's Role
- Funding
10:15 - 10:30 Break
10:30 - 12:00 Continuation of Round Table Presentations
12:00 - 1:30 Lunch
1:30 - 2:30 Region VI MWPP Programs
Harold Smith, Chief
Technical Section
Municipal Facilities Branch,
U.S. EPA - Region VI
Roger Hartung, Chief
Enforcement Branch
U.S. EPA - Region VI
- Issues Encountered
- Issue Resolution
- Results/Trends/EPA Response
- Initiating MWPP through Use of 308 Orders
-------
2:30 - 3:00 Enforcement as an MWPP Tool
Walter Brodtman
Enforcement Division
US EPA Headquarters
3:00 - 3:15 Break
3:15 - 4:30 Update of Wisconsin's Program
Jim Fratrick
Area Engineer
Wisconsin Department of Natural Resources
- Overcoming Issues in Rulemaking
- Program Direction
- Funding
Day 2:
8:00 - 9:00 Pollution Prevention at EPA
James W. Craig, Chief
Pollution Prevention Division
Policy Analysis Branch
U.S. EPA Headquarters
9:00 - 10:00 Source Reduction Activities at POTWS
Lindsey Mize
Environmental Engineer
North Carolina Pollution Prevention Program
Adriana Renescu
Special Projects Engineer
Orange County Sanitation District
10:00 - 10:15 Break
10:15 - 10:45 Water and Energy Conservation: Current Agency
Initiatives
John Flowers, Chair, Water Use Efficiency
Task Force; WAVE Program Manager
U.S. EPA Headquarters
10:45 - 11:15 Pollution Prevention in the Stormwater Program
Ephraim King, Chief
NPDES Program Branch
U.S. EPA Headquarters
-------
11:15 - 12:15 Measures of Program Success Panel
Harold Thompson (Moderator)
U.S. EPA - Region VIII
Denver, CO
Gary Champy
Vermont Department of Environmental
Conservation
Tom Reich
U.S. EPA - Region VI
Douglas Johnson
U.S. EPA - Region VIII
Office of Policy and Management
Katherine Dawes
U.S. EPA Headquarters
Office of Policy, Planning and Evaluation
12:15 - 1:30 Lunch
1:30 - 3:00 Round Table Discussion: Where do we go from here
and how do we get there?
-Institutionalizing Programs
-Long Term Funding
-Incorporating Pollution Prevention
-Energy Act
-CWA
-National Wildlife Federation Proposal
Steve Allbee, Chief, Municipal
Assistance Branch (Moderator)
U.S. EPA Headquarters
Panel Members: Walter Brodtman
Enforcement Division
U.S. EPA Headquarters
Jeff Lape, Special Assistant
to Director of OWEC
U.S. EPA Headquarters
John Flowers, Program Manager
WAVE
U.S. EPA Headquarters
3:00-3:30 Summary Remarks
Michael B. Cook, Director
Office of Wastewater Enforcement and Compliance
-------
AGENDA FOR ROUND TABLE TEAM PRESENTATION
. April 27, 1993
9:10 a.m - 12:00 noon
Status of MWPP Programs
Each Region/State will discuss the development of their MWPP
Program including Region/State Relationship, community buy-in,
problems encountered and solutions, use of the CMAR, funding
and
any other relevant information. Each Region is allocated 15
minutes. If more time is needed, please advise.
Region Presentations by
I Richard Darling, Maine
Gary Champy, Vermont
Brad Foster, New Hampshire
II Hank Mazucca, U.S. EPA
New York
III David Byrd, West Virginia
Tom Brown, Pennsylvania
Hal Benson} Maryland
Jake Bair }
Robert Zimmerman, Delaware
IV Ben Chen, U.S. EPA
Ernest Earn, Georgia
Michael Freiman, Mississippi
Jerry Hurst, Kentucky
V Peter Smith, U.S. EPA
Heidi Sorin, Ohio
VI Jan Sills, Texas
Bob Paul, Louisiana
VII Harold Owens, U.S. EPA
VIII Harold Thompson, U.S. EPA
IX Angela Ivey, U.S. EPA
X Dan Steinborn, U.S. EPA
-------
ATTACHMENT 2
LIST OF PARTICIPANTS
-------
NATIONAL COOTERENCE SPEAKERS LIST
Lindsey Nize
Environmental Engineer
North Carolina Pollution Prevention Program
3825 Barrett Drive
Raleigh, NC 27609
(919) 571-4100 - W
(919) 571-4135 - PAX
Harold "Dick" Smith, Chief
Technical Section
Municipal Facilities Branch
U.S. EPA - Region VI
Dallas, TX
(214) 655-7130
Roger Hartung, Chief
Enforcement Branch
U.S. EPA - Region VI
Dallas, TX
(214) 655-6468
Jim Fratrick
Wisconsin Department of Natural Resources
P.O. Box 12436
2300 North Dr. Martin Luther King Drive
Milwaukee, WI 53212
(414) 263-8632
Adriana Renescu
Special Projects Engineer
Source Control Division
P.O. Box 8127
10844 Ellis Avenue
Fountain Valley, CA 92728-8127
(714) 962-2411 - W (Ext. 3828)
(714) 962-6957 - FAX
Gary Champy
VT Department of Environmental Conservation
Public Facilities Division
103 South Main Street, Bldg. 9 South
Waterbury, VT 05676
(802) 244-8744
-------
-2-
Tom Reich
U.S. EPA - Region VI
1445 Ross Avenue, 12th Floor
Suite 1200
Dallas, TX 75202
(214) 655-7169
Stephen P. Allbee
U.S. EPA Headquarters
401 M Street, S.W. (WH-547)
Washington, DC 20460
(202) 260-5856
Walter Brodtman
U.S. EPA Headquarters
401 M Street, S.W. (EN-338)
Washington, DC 20460
(202) 260-5998
Harold Thompson
U.S. EPA - Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1560
Jeff Lap*
U.S. EPA Headquarters
401 M Street, S.W. (EN-336)
Washington, DC 20460
(202) 260-9525
Michael Quigley
U.S. EPA Headquarters
401 M Street, S.W. (WH-547)
Washington, DC 20460
(202) 260-5859
janes W. Craig
U.S. EPA Headquarters
401 M Street, S.W.
Washington, DC 20460
(202) 260-4168
-------
-3-
John Flowers
U.S. EPA Headquarters
401 M street, S.W. (WH-547)
Washington, DC 20460
(202) 260-7288
Ephraim King
U.S. EPA Headquarters
401 M street, S.W. (EN-336)
Washington, DC 20460
(202) 260-9541
Michael B. Cook
U.S. EPA Headquarters
401 M Street, S.W. (WH-546)
Washington, DC 20460
(202) 260-5850
Douglas Johnson
U.S. EPA - Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1560
Ratherine Daves
U.S. EPA Headquarters
401 N Street, S.W. (PM-223Z)
Washington, DC 20460
(202) 260-5356
-------
MUNICIPAL WATER POLLUTION PREVENTION ANNUAL
MEETING ATTENDEE LIST
April 27 & 28, 1993
Washington, DC
Steve Allbee
US EPA
OWEC
401 M Street, S.W. (WH-547)
Washington, DC 20460
202/260-5856
Walter Brodtman
US EPA
OWEC
401 M Street, S.W. (EN-338)
Washington, DC 20460
202/260-5998
Jake Bair
Maryland Center for Environmental
Training
Box 910
La Plata, MD 20646
301/934-2251
Hal Benson
Maryland Department of the
Environment
2500 Broening Highway
Baltimore, MD 21224
410/631-3560
Kevin Bell
US EPA
OWEC
401 M Street, S.W. (EN-338)
Washington, DC 20460
202/260-8325
James Borton
Ohio EPA
Water Pollution Control
1800 Water Mark Drive
P.O. Box 1049
Columbus, OH 4366-0149
614/644-2011
Thomas Brown
Pennsylvania Department of
Environmental Resources
Bureau of Water Quality
P.O. Box 625
RD #3 Willmore Road
Ebensburg, PA 15931
814/472-6330
David Byrd
West Virginia Division of Environmental
Protection
Pollution Prevention Services
617 Broad Street
Charleston, WV 25301
304/558-0633
Gary Champy
Vermont Department of Conservation
103 South Main Street
Building II South
Waterberry, VT 05671
802/244-8744
Ben Chen
US EPA/Region 4
Water Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
404/347-3633
-------
Michael Cook
US EPA
OWEC
401 M Street, S.W. (WH-546)
Washington, DC 20460
202/260-5850
Charles Conway
US EPA/Region 1
Water Management Division
JFK Federal Building
Boston, MA 02203
617/565-3517
James Craig
US EPA
Pollution Prevention Division
401 M Street, S.W. (PM-22B)
Washington, DC 20460
202/260-4168
Dennis Ducko
US EPA/Region 3
Water Management Division
841 Chestnut Street
Philadelphia, PA 19107
215/597-3423
Doug Erickson
Michigan Department of Natural
Resources
Surface Water Quality Division
Permits Section
P.O. Box 30028
Lansing, MI 48909
517/373-8088
Ernest Earn
Municipal Engineering Program
Georgia Environmental Protection
Division
Floyd Towers East - Suite 1058
205 Butler Street, SE
Atlanta, GA 30334
404/651-5495
Richard "Dick" Dague
Iowa State University
Department of Civil Engineering
394 Town Building
Ames, IA 50011
515/294-3563
Wayne Farrand
Wastewater Section
Iowa Department of Natural Resources
Wallace State Office Building
Des Moines, IA 50319
515/281-8877
Richard Darling
Maine Department of Environmental
Protection
State House Station 17
Augusta, ME 04333-0017
207/287-7806
Katherine Dawes
US EPA
OPPE
401 M Street, S.W. (PM-223Z)
Washington, DC 20460
202/260-5356
John Flowers
US EPA
OWEC
401 M Street, S.W. (WH-547)
Washington, DC 20460
202/260-7288
-------
Brad Foster
WSPCD
New Hampshire Department of
the Environment
P.O Box 95
Concord, NH 03301
603/271-1497
Jim Fratrick
Wisconsin Department of Natural
Resources
2300 North Martin Luther King Drive
P.O. Box 12436
Milwaukee, WI 53212
414/263-8632
Michael Freiman
Municipal Permit Compliance Branch
Surface Water Division
Mississippi Department of
Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson, MS 39289-0385
601/961-5271
Nick Gatian
Mississippi Department of
Environmental Quality
Bureau of Pollution Control
3002-C Bienville Boulevard
Ocean Springs, MS 39564
601/875-2893
Leroy Gilbert
Pollution Prevention Services
General Delivery
MacArthur, WV 25873-999
304/256-6850
Karen Grubbs
Division of Construction Grants and
Loans
Tennessee Department of Environment
and Conservation
8th Floor, L & C Annex
401 Church Street
Nashville, TN 37243-1533
615/532-0463
Roger Hartung
US EPA/Region 6
Water Management Division
1445 Ross Avenue
Dallas, TX 75202-2733
214/655-6468
Jerry Hurst
Division of Water
Kentucky Department of Natural
Resource and Environmental Protection
14 Reilly Road
Frankfort, KY 40601
502/564-3410
Angela Ivey
US EPA/Region 9
Water Management Division
75 Hawthorne Street
San Francisco, CA 94105
415/744-1936
Douglas Johnson
US EPA/Region 8
Office of Policy and Management
Water Management Division
One Denver Place
Denver, CO 80202-2405
303/293-1469
-------
Tom Killeen
Louisiana Department of Environmental
Quality
7290 Blue Bonnett
Baton Rouge, LA 70810
504/765-0525
Jeff Lape
US EPA
OWEC
401 M Street, S.W. (EN-336)
Washington, DC 20460
202/260-7361
Mark Malone
US EPA/Region 1
Municipal Evaluation Section
JFK Federal Building
Boston, MA 02203
617/565-3492
Valarie Martin
US EPA
OWEC
401 M Street, S.W. (WH-547)
Washington, DC 20460
202/260-7259
Hank Mazzucca
US EPA/Region 2
Water Management Division
26 Federal Plaza
New York, NY 10278
212/264-8958
Lindsey Mize
North Carolina Pollution Prevention
Program
3825 Barrett Drive
Raleigh, NC 27609
919/571-4100
Joe Mulrooney
Delaware Department of Natural
Resources and Environmental Control
Facility Support Services Branch
89 Kings Highway
P.O. Box 1401
Dover, DE 19901
302/739-5081
Harold Owens
US EPA/Region 7
Municipal Wastewater Facilities Section
Water Management Division
726 Minnesota Avenue
Kansas City, KS 66101
913/551-7371
Bob Paul
Louisiana Department of
Environmental Quality
Kisatchie Central Regional Office
402 Rainbow Drive
Pineville, LA 71360
318/487-5656
Michael Quigley
US EPA
OWEC
401 M Street, S.W. (WH-547)
Washington, DC 20460
202/260-5859
Tom Reich
US EPA/Region 6
Water Management Division
1445 Ross Avenue
Dallas, TX 75202-2733
214/655-7169
Jeffrey Rein
Maryland Department of the
Environment
2500 Broening Highway
Baltimore, MD 21224
410/631-3560
-------
Adriana Renescu
Orange County Sanitary District
Source Control Division
P.O. Box 8127
10844 Ellis Avenue
Fountain Valley, CA 92728-8127
714/962-2411
Larry Robinson
Wyoming Department of
Environmental Quality - Water
Herschler Building
4 West
Cheyenne, Wyoming 82002
307/777-7075
John Roland
Virginia Department of Environmental
Quality
Water Division
P.O. Box 11143
Richmond, VA 23230-1143
804/527-5117
Stan Rudisill
Pennsylvania Department of
Environmental Resources
BWQM
Division of Permits & Compliance
10th Floor - MSSOB
P.O. Box 8465
Harrisburg, PA 17105-8465
717/787-8184
Mary Settle
US EPA
OWEC
401 M Street, S.W. (WH-547)
Washington, DC 20460
202/260-5810
Jan Sills
Texas Water Commission
1700 North Congress
P.O. Box 13087
Austin, TX 78711-3087
512/475-2185
Harold Smith
US EPA/Region 6
Water Management Division
1445 Ross Avenue
Dallas, TX 75202-2733
214/655-7130
Peter Smith
US EPA/Region 5
Water Management Division
230 South Dearborn
Chicago, IL 60604
312/886-0212
Dan Steinborn
US EPA/Region 10
1200 Sixth Avenue
Seattle, WA 98101
206/553-
Bill Swietlik
US EPA
Permits Division
401 M Street, S.W. (EN-336)
Washington, DC 20460
202/260-9529
-------
Harold Thompson
US EPA/Region 8
Water Management Division
One Denver Place (8WM-MF)
Denver, CO 80202-2466
303/293-1560
Robert Zimmerman
Delaware Department of Natural
Resources and Environmental Control
Division of Water Resources
89 Kings Highway
P.O. Box 1401
Dover, DE 19901
302/739-5726
------- |