&EPA The Environment and Your Business: A Primer For Building Compliance into Your Operation ------- United States Office of Compliance EPA-305-B-02-002 Environmental Protection (2224A) August 2003 Agency ------- Table of Contents Page Section 1 - Background 1 -1 How will this document help my business? 1-1 EPA's Role in Protecting the Environment 1-2 EPA Programs for Small Businesses 1-2 Section 2 - Environmental Laws and Regulations 2-1 What are environmental regulations? 2-1 Where do I find federal environmental regulations? 2-2 To whom should I talk first? 2-2 Environmental Regulatory Summaries 2-2 What can you do to ensure compliance? 2-3 Section 3 - Getting Help 3-1 1. Understand Your Situation 3-1 2. Contact Your Assistance Provider 3-1 3. Get On-Site Assistance 3-2 4. Listen 3-2 5. The Small Business Compliance Policy 3-3 6. Establish a Program 3-4 Section 4 - Managing Your Business to Ensure Environmental Compliance How can you manage environmental issues in your business 4-2 1. Characterize your facility 4-2 2. Evaluate the regulatory requirements 4-3 3. Determine your compliance status 4-3 4. Identify what actions are needed to achieve compliance 4-4 ------- 5. Develop a strategy 4-6 6. Communicate these actions to other employees 4-6 7. Initiate the actions 4-7 8. Evaluate the program's successes 4-7 Section 5- Compliance Management Systems 5-1 Environmental Management Systems 5-1 Conclusion 5-2 ------- ACRONYMS CAA Clean Air Act CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations CWA Clean Water Act EMS Environmental Management System EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know Act FIFRA Federal Insecticide, Fungicide and Rodenticide Act HAPs Hazardous Air Pollutants HSWA Hazardous and Solid Waste Amendments HW Hazardous Waste NCP National Oil and Hazardous Substance Pollution Contingency Plan (or National Contingency Plan) NPDES National Pollutant Discharge Elimination System OPA Oil Pollution Act OSHA Occupational Health and Safety Administration P2 Pollution Prevention PCBs PolychlorinatedBiphenyls POTW Publicly-Owned Treatment Works RCRA Resource Conservation and Recovery Act SBO Small Business Ombudsman SDWA Safe Drinking Water Act SIC Standard Industrial Classification Group SIP State Implementation Plan SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure TRI Toxics Release Inventory TSCA Toxic Substance Control Act TSDF Treatment, Storage, and Disposal Facilities USDA U.S. Department of Agriculture UST Underground Storage Tank ------- Section 1 - Background As a small business owner, you may have already encountered the issue of how to control waste. Whether your business emits chemicals to the air or produces solid or hazardous waste, you need to know about federal rules that protect the environment. Complying with environmental rules is important to the health and safety of you and your workers, for your business and your planet. But where do you start? Environmental Protection Agency (EPA) prepared this document for you and your small business. With business markets becoming more competitive, both personnel and financial resources are precious to the viability of many small businesses. EPA understands that many small businesses often do not have the resources or the time to identify and understand all of the federal environmental regulations that may apply to them. Often the problem with understanding federal environmental regulations is knowing where to start. EPA wants to provide practical, streamlined assistance to small business owners who understand the importance of running an environmentally responsible operation. This guide provides that first step for small businesses unsure of their environmental compliance status and responsibilities. How will this document help my business? This primer should provide you with enough information to get started in understanding the federal environmental regulations that apply to your business operations. Businesses that are good environmental citizens build community trust and good public relations, and build good relationships with state and federal regulators. This primer provides the first step to understanding basic federal environmental Document at a Glance Section 1 Background Section 2 - Environmental Laws and Regulations < What are They and Do They Apply to My Facility? Section 3 - Getting Help Section 4 - Managing Your Business to Ensure Environmental Compliance Section 5 - Compliance Management Systems requirements and describes an approach to integrating environmental considerations into your daily operations. 1-1 ------- EPA's Role in Protecting the Environment EPA is the federal government agency responsible for protecting the environment. EPA establishes environmental safeguards in the form of regulations. EPA then works with industries and the public to make sure they understand how to comply with the rules and requirements. EPA uses compliance assistance documents, like this one, to assist businesses in understanding how the rules affect them. EPA relies upon its ten offices around the country to enforce the federal regulations. These regional offices ensure compliance by supporting state environmental programs and by conducting compliance and enforcement activities. EPA's regional offices also provide direct assistance to the regulated community through various technical assistance programs. EPA has given the primary responsibility for compliance and enforcement of many regulations to state and local environmental regulatory programs. EPA also works closely with the states and local governments to provide compliance assistance. In many cases, businesses must also comply with state, local, and tribal laws. Tribes, states and localities are the first source of information on their requirements and procedures. EPA Regional Offices Region 1 One Congress St. Suite 1100 Boston, MA 02114 (617)918-1111 Region 2 290 Broadway New York, NY 10007 (212) 637-3000 Region 3 1650 Arch Street Philadelphia, PA 19103 (215)814-5000 Region 4 61 Forsyth Street SW Atlanta, GA 30303 (404) 562-9900 Region 5 77 West Jackson Chicago, IL 60604 (312) 353-2000 Region 6 12th Floor 1445RossAve Dallas, TX 75202 (214)665-6444 Region 7 901 North 5th Street Kansas City, KS 66101 (913) 551-7000 Region 8 999 18lh Street Denver, CO 80202 (303) 312-6312 Region 9 75 Hawthorne St San Francisco, CA 94105 (415)744-1305 Region 10 1200 Sixth Ave. Seattle, WA 98101 (206) 553-1200 EPA Programs for Small Businesses EPA is very interested in helping small businesses understand and meet their responsibilities. In 1982, EPA established a Small Business Ombudsman (SBO) who serves as a "first-stop shop" for environmental compliance information. (www.epa.gov/SBO) This office provides small businesses with a point of contact, assistance in getting questions answered, and assurance that small business' views are considered during Agency rulemakings. The SBO has a free hotline (800-368-5888) that can answer specific questions or connect you with an EPA program expert or a regional small business liaison in your geographic area. EPA also supports ten on-line compliance assistance 1-2 ------- centers (see box on right) that provide information on regulations and compliance approaches as they apply to certain types of businesses or activities. As you talk to people at EPA, and as you read this primer, you may become aware of certain environmental responsibilities that you never knew you had and that you have not satisfied. As you review the requirements that follow, do not become alarmed if you discover that you may be in violation of some environmental laws. EPA has many programs to help small businesses come into compliance. Are you concerned about contacting EPA because you think if you ask them for help, they may discover you are out of compliance and impose large fines? EPA has a Small Business Compliance Policy (discussed in Chapter 3) which can result in a reduction or complete waiver of fines if you follow certain procedures. EPA wants to work with you to ensure a clean environment. RESOURCES A variety of compliance assistance and tools are available to help you comply with federal environmental laws. These resources can help you understand your environmental obligations and find cost- effective was to comply through the use of pollution prevention and other innovative technologies: Compliance Assistance Centers: Provide comprehensive, easy-to- understand compliance information targeted specifically to 10 industry and governmental sectors. www.assistancecenters.net National Compliance Assistance Clearinghouse: Provides an extensive collection of compliance assistance materials and contacts. www.eDa.gov/clearinghouse Small Business Environmental Home Page: Helps small businesses access environmental compliance and pollution prevention information. www.smallbiz-envirqweb.org EPA Pollution Prevention Resource: Provides resources on P2 programs and technical assistance. www.epa.gov/p2/resources/index.html Pollution Prevention Resources Exchange: Improves the dissemination of pollution prevention information. www.p2rx.org 1-3 ------- Section 2 - Federal Environmental Laws and Regulations - What Are They and Do They Apply to My Company? What are environmental regulations? One of the most confusing aspects of federal environmental regulations is understanding how they come into existence. This short description should help you better grasp this process. Federal, environmental laws are passed by Congress and signed by the President in the same manner as laws relating to education, crime, taxes, highways, and so on. Congress gives EPA the authority to write regulations that implement the laws. EPA also has the authority to enforce these regulations by checking to see whether facilities are complying with the rules. In many cases, Congress gives EPA the authority to allow tribes and states, and in some cases local governments, to implement and enforce EPA writes and enforces Federal environmental regulations. Example: "Used oil is not a hazardous waste but must be managed according to EPA s used oil regulations in 40 CFR..." States often are given the authority to enforce Federal regulations. They may also develop more stringent regulations. Example: "Used oil IS considered hazardous waste in our state. You must follow the hazardous waste regulations for storage and disposal See section..." Local authorities may add even more stringent rules. Eurasia: "Used oil may not be collected in areas zoned for..." Your operation must comply with ALL regulations. 2-1 ------- federal regulations. Tribal or state laws must be at least as stringent as the federal ones, and may be even more demanding. Where do I find federal environmental regulations? The Federal Register is a daily publication created by the federal government that lists notices, federal actions, executive orders, proposed and final regulations and general information. It is intended for use by the regulated community and the general public. Regulations On-line All Federal Regulations are maintained on the Internet. Use the search engines to find specific Federal Register or Code of Federal Regulation references. The EPA homepage (www.epa.gov) has links to the Government Printing Office homepage which houses on- line versions of the Federal Register and the Code of Federal Regulations. The Federal Register and the Code of Federal Regulations can be accessed directly at the following sites: www.qpo.gov/su docs/aces/acesl 40.html & www.access.qpo.gov/nara/cfr/index.html All final regulations published in the Federal Register are compiled into the Code of Federal Regulations (CFR). Chapter 40 of the CFR describes all of the environmental requirements that have been developed by the federal government. The CFR is updated on an annual basis to reflect all new regulations that were published in the previous year. To whom should I talk first? As mentioned above, many environmental laws allow tribes and states to implement and enforce federal requirements. EPA has established useful references for identifying state environmental regulations, requirements, and resources: w\v\v.epa.gov/docs/epacfr40/find-aid.info/state www.epa.gov/smallbusiness/ When you begin your inquiries about what laws apply to your business, you will also need to determine where there are applicable local laws and regulations. Environmental Regulatory Summaries All businesses, regardless of size, are subject to environmental regulations. It can be difficult to understand how regulations apply to your business. It also may be unclear how regulations benefit the environment. In order to help you understand and comply with these regulations, the remainder of this section provides a brief overview of the major federal environmental programs established since EPA was created in 1970. What can you do to ensure compliance? The first step in the process is to recognize that there may be environmental regulations (federal or tribal) that apply to your business and may require some action on your part. The flowcharts on subsequent pages are designed to get you started. They are not a comprehensive summary of regulations or checklists that can be used to evaluate your entire facility. You should contact an 2-2 ------- environmental professional, industry trade association, or someone at your tribal environmental office to help you get started with specific questions. They can help you work through the regulations, to determine how they apply to your facility. The tribal agency also may have a person to deal specifically with small businesses like yours. They will probably encourage you to conduct an evaluation of your operations, a "self- audit", to help you to determine if you are in compliance. Your goal should be to understand any requirements that apply and integrate environmental activities into the operation of your facility. The next section in this document provides more specific guidelines on developing a system for managing environmental compliance. EPA Enforcement in Indian country EPA ensures compliance with federal environmental laws by appropriately exercising its authority to take civil and/or criminal enforcement actions against out-of- compliance facilities. When a facility regulated under federal environmental laws is identified as being out of compliance, EPA uses its authority to pursue: (1) an administrative enforcement proceeding; (2) a civil judicial suit; or (3) a criminal investigation and referral for prosecution. Regardless of the type of enforcement response, the action taken is designed to remedy the environmental harm, promote nationally consistent enforcement, and deter future noncompliance by the same facility and other facilities. EPA's enforcement actions in Indian country are guided by multiple policies, including the 1984 Indian Policy, the - Guidance on the Enforcement Principles Outlined in the 1984 Indian Policy (Civil Enforcement Guidance), the Exercise of Investigative Discretion policy (Criminal Investigative Policy), and various program- specific and Regional policies. These policies outline how EPA works in partnership with tribes to resolve current facility noncompliance and deter future noncompliance in Indian country in a timely and effective manner. The ownership and control of a facility impacts the process EPA uses to respond to non compliance. For facilities that are owned or managed by private parties, including tribal members, EPA responds to the noncompliance as it would anywhere else in the United States, after consideration of the tribe's interest in the facility. For facilities owned or managed by tribal governments, EPA will work cooperatively with the tribe and provide compliance assistance to help the facility comply, prior to filing a formal administrative or civil judicial enforcement action. Regardless of whether non compliance arises at a private party or a tribal facility, the availability and use of the appropriate enforcement response is designed to protect human health and the environment in Indian country. 2-3 ------- CAA Summary of Regulations Carbon Lead Monoxide Oxides ol as of Ground- level Ozone Particulate Matter trv -utirrtrral PH-totiLT f.xr;< t,ą\ut>,yw DC Hazardous Air Pollutants (HAPs) 188 Chemicals Listed by EPA Clean Air Act Does your facility emit dust or chemicals to the air? Yes Yes Does your facility use refrigerants? No Your operation may be subject to regulations under 40 CFR Part 82. including: EPA certification for technicians who repair refrigeration or air conditioning equipment, Recovery and recycling of refrigerants. Safe disposal of refrigeration and air conditioning equipment, Repair of leaks. Yes Does your facility emit organic chemicals. hazardous air pollutants. participates (dust), CO, NOX, SOX or lead? Your facility may have permitting requirements under several air pollution programs under 40 CFR Parts 60-63, including: Emission limits or specific air pollution control equipment, emission limits, and work practices for certain industries Additional requirements for facilities in areas with poor air quality Additional requirements for new facilities. ------- CERCLA Summary of Regulations Comprehensive Environmental Response, Compensation and Liability Act 11 not contained on-site. chemicals released to the environment may be a "Reportable Release" under CERCLA. AAA Yes It may be helpful to prepare a list of chemicals stored on- site and the quantity stored. Once you've prepared a list Check the list in 40 CFR 302.4 to see if any of your chemicals are on the list. If so, your facility may be subject to several requirements including: Immediately reporting spills that exceed the reportable quantity. 800-424-8802 (National Response Center) Submitting reports to State and local agencies responsible for emergency response planning (if more than 10,000 ibs of any one hazardous substance is stored on-site (40 CFR 370.21-.2S). Conducting annual release reporting for specific chemicals (40 CFR Part 375.35): Does your facility have any chemicals on-site? No ------- WA jmmary of Regulations You must TiaveTWateT You may have g storm water requirements. Not everything is allowed to go down the drain. "Send your water to a local waste water treatment plant? They often have their own requirements." In order to do so you need to apply for, be issued and operate in compliance with an NPDES permit issued by EPA or a State agency in conformance with state requirements and federal requirements set out in 40 CFR 1 22. Facilities that discharge stormwater may be required to develop and implement a stormwater pollution prevention plan. In order to do so you may be required to apply for, be issued and operate in compliance with a discharge permit from the municipality that owns the sewage treatment plant The permit may include local, state as well as federal requirements set out in 40 CFR Part 403. Additionally certain industries may be required to meet specific discharge standards set out in 40 CFR 405-471 . Yes Clean Water Act Does the facility use water or is any wastewater or stormwater generated onsite? TYes Does your facility discharge any water or wastewater (either process water or stormwater) through a pipe or from another discrete point to a water body such as a lake or stream? No Does your facility discharge any water or wastewater to a sanitary sewer? No Does facility have the ability to impact water? Yes Does facility generate domestic sewage sludge from onsite domestic sewage facility? Is the facility located near a wetland and/or planning any activity that may impact the wetland? Facility may be ; required to treat sewage sludge use and disposal requirements that are incorporated into NPDES discharge permit or a sludge only permit issued pursuant [ to requirements in ; 40 CFR 501. The facility may need to apply for and be issued a §404 permit by the Army Corps of Engineers for actions impacting a wetland such as drying or filling in a wetland. 1 Does the facility store chemicals above ground onsite that could spill and reach waters of the U.S.? 'Yes The facility may be required to prepare and implement a SPCC Plan pursuant to Oil Pollution Prevention regulations found at 40CFR112. Does your facility discharge to a separate municipal storm sewer? Yes > No In order to do so you may be required to apply for, be issued and comply with a State or Federal general permit or individual permit issued pursuant to 40 CFR122. Additionally you may be required to develop and implement a stormwater pollution prevention plan. Are you. discharging water or wastewater into the ground or any underground injection well such as a septic system, dry well, etc? Yes In order to do so you may be required to apply for and comply with a permit issued in conformance with state and or SDWA requirements. ------- >CRA :mmary of Regulations Emergency Planning and Community Right-to-Know Act No Planning Requirements: (40 CFR 370.2-370.40) Are there any chemicals on- site for which the OSHA regulations (health and safety) require a Material i Safety Data Sheet (MSDS)? | 1 Ho Are any of the chemicals present at greater than 10,000 pounds? Yes No Are any of the chemicals considered "extremely hazardous substances" and present at greater than 500 pounds (55 gallons) or their "threshold planning quantity"? See Appendices A & B to 40 CFR Part 355 You must submit a copy of MSDS and other information to fire department and other emergency planning organizations Release Requirements: (40 CFR 372.1-372.45) Is the facility included in the SIC codes 10-39,4911, 4931,4939,9553,5169, 5171, or 7389? I.. r. Does the facility have 10 or more full-time employees (or the equivalent of 20,000 hours per year)? Yes No Does the facility manufacture, import, process, or otherwise use any of the toxic chemicals listed in 372.45 in amounts greater than threshold quantities (25,000 Ibs/yr for "manufacture, import, or process'; 10,000 Ibs/yr for "otherwise use"; 10-100 Ibs/yr for certain "persistent, bioaccumulative, and toxic" chemicals in 372.28: .1 grams for dioxins) Yes You must submit annual report {Form R) every July 1st on releases to the environment, both routine and accidental releases No EPCRA Requirements The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) actually is an amendment to the Superfund law (CERCLA). The chief EPCRA provisions relate to (1) emergency planning efforts at the State and local levels and (2) citizen access to information about potential chemical hazards In their communities. The regulations written to implement the EPCRA law pertain to submitta! of chemical inventories by businesses so that, in the event of an emergency, local emergency response personnel will know how to effectively deal with the emergency. Other EPCRA requirements relate to reporting annual releases, or discharges, of hazardous chemicals to the air, water, or land. The resultant Toxics Release Inventory is accessible to the public for information and research purposes. The annual release reporting requirements of EPCRA apply to businesses and industries falling within specific Standard Industrial Classification (SIC) Groups, primarily the manufacturing sector. In addition, the requirements apply only to those specific facilities that manufacture, import, process, or otherwise use toxic chemicals above a certain threshold quantity per year. The emergency planning provisions apply to facilities that store chemicals for which Material Safety Data Sheets are required. As with the release reporting requirements, a facility must store amounts above the soBRifieri threshold miantitv bnfnre the nlanninn ranulrements annlv. ------- IFRA immary of Regulations Federal Insecticide, Fungicide and Rodenticicie Act Yes Yes Are any of the pesticides classified as "restricted use" pesticides? Anyone who mixes and applies restricted use pesticides must be certified to do so by EPA or a State with an EPA-approved Certification Plan (40 CFR171). The disposal of many pesticides is subject to hazardous waste regulations (40 CFR 261 and 262). No Does your facility use, manufacture, or store pesticides? 1 NO ------- CRA ;mmary of Regulations Resource Conservation Recovery Act WASTE Does your facility produce waste materials or do you store petroleum products in underground petroleumstorage tanks? Is your waste defined as a solid waste under 40 CFR Part 261 .2? 1 No \ I 'Yes Yes r Could your waste be classified as hazardous waste? No i If your solid waste exhibits a characteristic of ignitability, corrosivity, reactivity, or toxicity or if it is on EPA's lists of hazardous wastes, it may be subject to regulation (40 CFR Part 261). If you generate less than 100 kilograms (about 22 gallons) per month, requirements are minimal (40 CFR 261.5). If you generate more than 100 kilograms per month, you are subject to: - Tank, container and drip pad requirements - Time and quantity accumulation limits - Labeling - Recordkeeping and reporting. Hazardous wastes must be shipped, off-site for recycling or treatment and disposal. Waste must be managed by an authorized transporter and taken to a facility authorized to treat or dispose of hazardous waste (40 CFR 263-265). On-site treatment of hazardous waste may require permit (40 CFR 270). Waste disposal must be done according to state and local requirements, which generally prohibit open dumping and open burning. TANKS Yes Is the tank capacity __ greater than 110 gallons? No 1 The tanks may be subject to requirements including: Installation specifications Monitoring requirements Leak detection, and Clean up of spills under 40 CFR Part 280. ------- CA Summary of Regulations Toxic Substance Control Act Does your company have or renovate any PCB-containing materials, lead paints, or asbestos- containing materials? No Yes PCBs LEAD I ASBESTOS Does your facility have any electrical equipment made before 1978? Yes Do you plan to abb* buildings that may have lead-based paint? No Yes If you have equipment containing fluids with greater than 50 ppm PCBs, you will be subject to regulations including labeling and inspecting equipment, notifying local emergency response groups, and having a PCB leak response plan, with trained personnel (40 CFR Part 261). Does your company renovate residences that require you to disturb 2 ft2 of lead- based paint? Do you plan to do any demolition or renovation of buildings? Yes Only ERA certified individuals can conduct renovation . actMies1n\i8tving lead-based paints (29 CFR1926). Paint cljips-fiontaining lead may be'subjactto regulation 261). No Yes Your company's staff must be trained and certified in accordance with EPA requirements {40 CFR 748). No Your facility may contain asbestos in plaster, vinyl tiles, shingles, and insulating materials. Any demolition/ renovation that involves asbestos-containing must bedonebyEPA-certified technicians (29 CFR 1926). ------- Section 3 - Getting Help You have discovered that you may have environmental regulatory requirements that apply to activities at your facilities. So what now? If you're like most people, you may want help in understanding the exact requirements, the obligations for your company, and the best approaches for meeting these obligations. EPA has developed several resources that can assist you in learning about the regulations that apply to your company. These resources include assistance from experts, self-help documents and guidance manuals, and web resources. You may want to access these resources to better understand your requirements and to identify common approaches to compliance. This section is intended to help you use the programs that EPA has established to assist you. We've broken this discussion into several steps to walk you through your first contact with an assistance program. O Understand Your Situation If you have identified a business practice that EPA or a tribe may regulate, you should be able to describe the nature of the process and the regulations you think may apply. You should be able to: 1. Describe the nature of the activities involved. 2. Provide information on the chemicals used or output generated by the activity. 3. Review equipment specifications to determine operation conditions and review product loss or emission rates. 4. Understand usage patterns for chemicals especially those released to the air or water. 5. Document your current management practices for all materials in question. 6. Identify which regulations you think may apply to your processes, wastes, or chemical uses. 7. Identify which assistance program is best- suited for your question. Keep in mind that federal and tribal regulations often vary. You will probably need to contact both EPA and a tribal regulator. A list of references for EPA assistance programs is provided in Appendix A. tŁF Contact Your Assistance Provider When you call for help, you should: 1. Describe your situation and ask them to clarify the requkement(s). 2. Ask whether or not they provide on-site compliance assistance or process reviews like pollution prevention opportunity assessments. If they do not, ask whether they know of any local organizations that do. 3. Ask if on-site assistance is confidential and non-regulatory. EPA and many non-federal organizations, including states offer technical assistance without the threat of enforcement for violations found during the assistance visit. 3-1 ------- 4. If you are uncomfortable with the thought of receiving on-site assistance, ask for any guidance that they may have concerning the requirements that apply to you. 13ij Get On-site Assistance If you decide to invite a technical assistance person to evaluate your operation, you should understand that they will investigate your operation to determine how regulations apply, identify practices that may reduce your environmental impacts, and suggest approaches you might consider to ensure your company is compliant with the requirements. To prepare for an assistance visit, you should: 1. Compile information on the operation of your facility or processes that will be evaluated. Include such information as the amounts of chemicals used, loss of chemicals, flow rates of waste water, amounts of chemicals vented to the atmosphere, amounts of wastes generated, and locations of releases to the environment. 2. Compile Material Safety Data Sheets for review by assistance staff. At a minimum, you'll need to know what chemicals are used in your processes. 3. Be comfortable with the assistance staff walking through your operation and looking at your activities. 4. Ask questions of the assistance providers and make sure that you understand the requirement and your options to attain compliance. 5. Be prepared to answer hard questions. Assistance staff will ask you about the practices you have employed to control materials and wastes. Be prepared to answer truthfully and help them to understand your situation. 6. Remember that you are doing this to attain compliance with regulations. Don't be shy about your information and the process. Assistance providers realize that you may be out of compliance. They want to help you get into compliance. vListen Non-regulatory compliance assistance programs were created to help companies just like yours. When discussing your company or participating in an on-site evaluation, pay attention to the process followed, questions asked, and the information you provide. Regulators and assistance providers do not ask questions or collect information for no reason. For example, if an assistance provider asks questions about the paints you use, the amounts used, the frequency of painting, and how fumes are vented, they are probably trying to determine your status under air regulations. That is, does your painting process and subsequent release of paint solvents to the air constitute a regulated unit. The figure on the next page lists the types of information that are critical to understanding your regulatory status. As you talk with the regulator or technical assistance provider, take notes on the conversation. Make sure you understand which regulations may apply and list all the data you will need to adequately identify your regulatory status. Assistance organizations may also provide you with strategies for resolving issues, information on permitting procedures, and approaches 3-2 ------- for reducing the amount of waste that you generate. Reducing waste at the source is important because you may be able to change your regulatory burden by reducing the volumes of waste produced. The Small Business Compliance Policy EPA established a Small Business Compliance Policy to help small businesses that discover they are out of compliance through self-inspections or compliance assistance. Use this policy to your advantage. If an assistance program finds that you are out of compliance, the Small Business Compliance Policy offers you a chance to avoid or reduce fines if you quickly correct the problem. The relief from penalties offered by the Small Business Compliance Policy is not available however, to businesses that are determined to be non-compliant through a routine inspection by federal or tribal regulators. Can You Use the Policy? The policy applies to facilities owned by small businesses. For the purposes of this policy, a small business is a person, partnership, corporation, or other entity that employs 100 or fewer individuals. EPA has similar policies for facilities operated by small communities or local governments, (see, (www.epa.aov/compiance/incentive/ smallcommunities/) The Small Business Compliance Policy is intended to promote environmental compliance among small businesses by providing incentives for them to make use of compliance assistance programs, environmental audits, or compliance management systems (CMS). The policy is intended to encourage small businesses to participate in any activities that may increase their understanding of the environmental requirements with which they must comply. The Policy accomplishes this in two ways: by waiving or reducing civil penalties to which a small business might otherwise be subject, and by deferring to tribes, states and local governments that offer incentives consistent with the criteria established in this Policy. Small Business Policy Restrictions The Policy does not apply if the small business has been subject to any of the following: Receipt of a warning, letter, notice of violation or citation for a violation of the same requirement within the past three years; A penalty reduction under this Policy (or a similar state or tribal policy) for a violation of the same or similar requirement within the past three years; Any two enforcement actions in the past five years, or an enforcement action for the same violation as the one just uncovered ; and Violation(s) were already discovered by a regulatory agency through information requests, inspections, investigations or other methods. Or, the violation: Caused actual serious harm to public health, safety or the environment; or May present an imminent and substantial endangerment to public health, safety or the environment; or Involves criminal conduct. 3-3 ------- EPA may eliminate or reduce civil penalties in several ways including: Waiving or reducing civil penalties in cases of good faith efforts; and Reducing penalties where small businesses are unable to pay fines without harming the business; or Reducing the civil penalty to the amount of economic benefit the business received by not complying. EPA anticipates that a situation where a small business would realize significant economic benefit through noncompliance will rarely if ever occur. EPA will enforce all regulations for violations not remedied within the specified time frames established in the policy. For a complete version of the Small Business Policy (see www.epa.gov/compliance/incentives/smallb usiness/. Š Establish a Program Once you've gotten assistance, go back and evaluate your entire facility. Develop a program that includes all f acility activities and operations. The remainder of this document will give you some ideas on how to establish a comprehensive environmental compliance management system. 3-4 ------- Section 4 - Managing Your Business to Ensure Environmental Compliance As we discussed earlier in this document, small businesses may be subject to a number of environmental regulatory programs. EPA's Small Business Compliance Policy favors companies that are vigilant in identifying and complying with all applicable requirements (See the discussion of the Small Business Compliance Policy in Section 3 of this document). EPA also supports companies that put forth a "good faith effort" to address all environmental requirements. A "good faith effort" involves educating oneself about the basics of the various regulatory programs, assessing current site operations to determine if any environmental regulations apply, and "fixing" those aspects of the business operations that are not in compliance. EPA encourages all regulated facilities to plan for and address environmental requirements as part of their business operations. Companies that comply with requirements as part of their facility operations reduce their costs, face fewer risks, and have a lighter regulatory burden than companies that only react once regulators conduct inspections. To strengthen your environmental program, you should try to integrate environmental factors into daily decision-making and both short and long-term planning. This is an efficient means of ensuring that your site remains in compliance, instead of reacting to incidents of non-compliance, which can be costly and dangerous. For example, if your facility is planning to renovate an old warehouse, you must consider not only the cost of the new building materials, the labor costs, and the potential effect on productivity, but also whether the renovation may involve disturbing asbestos- containing materials. If so, you will need to determine whether the renovation can be done without disturbing these materials. If not, you may want to re-evaluate the renovation effort. It would be better to perform this examination before the renovation is initiated, rather than somewhere in the middle when you risk exposing workers to asbestos. You do not necessarily need to know all the details of the asbestos regulations. Instead, you need to know whether asbestos is an issue at your site. Waiting for issues to arise into problems also can result in expensive fines, damaged property, lost public relations, and lost productivity. For example, if hazardous material is not appropriately handled and eventually spills, the facility must use valuable time, personnel and money to contain the spill, clean it up, contact the appropriate regulatory agencies, pay any resulting fines, and purchase more material. A proactive approach helps to avoid this kind of situation. The information presented below provides you with common sense ways to incorporate environmental considerations into the standard operating procedures in your business. 4-1 ------- How can you manage environmental issues in your business? N. There is nothing magical about managing environmental issues. The concepts are much like the ones used to manage employee safety and health, a business budget, or quality concerns. Integrating environmental issues into a site's activities simply takes some planning and cooperation from management and other site personnel. In an ideal situation, your business would have the resources and time to appoint a person or a team of people whose responsibility is addressing environmental concerns. This may not be feasible for a small business (e.g., six-person shop would likely not be able to devote a full-time person to environmental compliance). However, EPA cannot excuse non-compliance due to staff shortages. An environmental compliance position maybe worth exploring, especially in a franchise or chain organization where one individual could be responsible for environmental issues at several small operations. Characterize your facility To begin, it is critical to understand how your business generates non-product outputs or wastes. Wastes often lead to environmental impacts that may be the target of regulatory requirements. While most managers or owners understand their processes, they may not have ever characterized all of their non- product outputs and how these wastes result from their operations. Steps to Managing Environmental Issues in Your Business Characterize your '. facility Evaluate the regulatory requirements o 1 Determine your compliance status ' O Identify what actions are needed to achieve Develop a strategy 0- "- * ^^ Communicate | these actions to | other employees j 1 Initiate the actions ^^^^^^Bm^i LW.isjf in "^ ~ T Evaluate the action's success 4-2 ------- Identify non-product outputs by listing all of the places in your process that result in: Solid wastes - material that are drummed, collected in dumpsters, put in trash bags, or similarly collected and disposed of; Liquid wastes - free-flowing outputs discharged to sewers, floor drains, storm sewers, rivers, ponds or any other receiving waters; and Gaseous wastes - vapors or fumes of gases released to the environment through vents, exhaust fans, fume hoods, open windows or doors, or other openings used to ventilate an area. Once your wastes are identified, the next step is to characterize the composition of your facility's wastes. Start by identifying which chemicals and materials are likely to contribute to the waste. The composition of the waste will be important in determining which regulations apply. At this point, several steps may be helpful: Quantifying the amount of waste generated - important for determining regulatory status; Calculating costs for materials lost - important for documenting losses in profitability due to loss of raw materials or products; Identifying procedures that contribute to wastes (equipment clean outs, chemical change outs, batch changes, maintenance, etc.); and Identifying people responsible for wastes - important for determining how to change current procedures. Evaluate the regulatory requirements Take the list you generated in step 1 and divide the waste streams into discharges to "land, air, and water." Now, review the regulatory summaries presented in Section 2. For each waste stream, note which regulations might apply to it. For example, if there are discharges to a floor drain in your facility, the discharge would qualify as a wastewater stream. Then, after examining the regulatory summaries, you may discover that the discharge is subject to regulation. Going through this process, did you find areas of concern in any of these categories? G Hazardous waste Q Air emissions Q Wastewater or stormwater discharges Q Presence of PCBs or asbestos on site Q Use of other toxic substances As was mentioned above, the regulatory summaries are provided to help you grasp the major requirements for each federal regulation. They are not a substitute for reading the actual regulations and speaking with an environmental professional. Also, remember that some state regulations may be more stringent than the federal regulations. Call your state agency to discuss your regulatory situation. * Determine your compliance status Examine the flow diagrams that accompany each of the regulation summaries in Section 2. Work through the diagrams with the waste stream list you develop. The purpose of this effort is to determine any area where you 4-3 ------- might be out of compliance with the federal environmental regulations. For example, assume the floor drain mentioned above runs directly into a ditch leading to a small stream on-site. Using the CWA flow diagram, you determine that the discharge from this drain is entering a water body such as a lake or stream. It, therefore, may require a permit. Document the results of this effort by making notes of your findings for all activities at your facility. This will help you discuss environmental issues with your state agency or trade association. It also provides a written record that can help you target specific environmental compliance issues. At this point, it may be helpful to review your findings with an environmental professional, a trade association representative, or state compliance assistance liaison to confirm applicability of the regulations and areas of non-compliance. 9 Identify what actions are needed to achieve compliance You have documented your facility's areas of non-compliance. You now have to decide what specific actions are necessary to become compliant. There are two major ways to achieve compliance. The first is called an "end of the pipe" approach. This method does not examine the reasons why the pollution is created, it simply provides for installation of a device or system to remove the pollutant before it is discharged into the environment. For example, in the floor drain example above, if a treatment filter was installed at the end of the drain pipe, it could remove the contaminant before it reached the stream. You will still need a permit and may have to meet continuing permit requirements to operate this filter and drain. A related example is that you may find you generate regulated quantities of hazardous wastes (e.g. cleaning solvents). You will need to assess your requirements as a hazardous waste generator. It may be that the solvent is very effective for your specific operation and that an adequate substitute is not available. In that case, you would need to check with your state to confirm what actions you need to take (e.g., get an EPA I.D. number, manage your spent solvents in the appropriate, labeled containers, arrange to have your waste manifested off-site to a hazardous waste treatment facility or recycler, and comply with biennial reporting requirements). This example is similar to an "end of the pipe" approach because it achieves compliance by focusing on the generated wastes, not by reducing the amount or type of chemical used. The other major way to achieve compliance is through pollution prevention (P2). P2 focuses on reducing or even eliminating pollution by: Improving process efficiency, Using less toxic products and raw materials, Improving facility housekeeping, Recycling waste chemicals, and Controlling the use and storage of chemicals. 4-4 ------- The following chart provides some starting points for thinking about P2 at your site. APPLYING POLLUTION PREVENTION What should I do? Why? 1. Get managers or other people in charge to support the P2 approach. Without support from managers, employees may be reluctant to change. Vocal support from all levels of managers sends a clear message that P2 is a priority. 2. Get the program started by looking at operations throughout the company, developing a written P2 plan if possible, and training employees in P2. The existence of the P2 program as a way to achieve environmental compliance must be known throughout the company. The person heading the P2 campaign must inspire all employees so that they understand that P2 is going to be the foundation for conducting business. Employees have to know that they will be held responsible for identifying chemical or process changes, and that such changes will be encouraged and supported. 3. Assess your operations to determine the raw materials used and points of waste generation. Use that information to define a baseline inventory to be used in setting P2 goals. In order to minimize environmental risks and to maximize cost savings, you have to know what you are working with. It is critical to re-think each step of your operation, whether it is manufacturing a product or providing a service, to assess the raw material and energy inputs and the waste outputs. 4. Get ideas from the employees about possible P2 opportunities. Employees are the ones most familiar with the details of operations. They are also in the best position to suggest how things could be done differently. Some research likely will be required as the P2 possibilities are identified. An excellent source of help on P2 is EPA's EnviroSense program. 5. Determine costs of waste management and disposal. To institute changes to the operation, you will need the data that proves P2 will yield cost savings. You must have a baseline against which you can measure progress after putting P2 techniques in place. 6. Select the best P2 options for the company and implement those choices. It probably will not be feasible to implement all of the P2 options that are identified. A cost/benefit analysis may help in selecting P2 projects that will yield the most benefits in the shortest period of time. If there will be capital expenditures (e.g., purchase of a new in-line recycling device), you will need to calculate the "pay-back time". You may decide to invest in projects that have a pay-back time of less than 5 years. 7. Document performance of each P2 project You will want to measure the changes in waste generation and energy usage that result from using P2 techniques. You can then translate these changes to money saved. If the changes aren't what you anticipated, some adjustments may be necessary. 8. Maintain and sustain the P2 program for continued growth and benefits to the company. As the P2 approach becomes a normal part of the operation, it may be possible to initiate the lower priority P2 projects to yield even more environmental and cost benefits. Thoughout this process, it will be necessary to make sure employees "stay on board." It is their commitment that will contribute to the success of the P2 program. 9. Re-evaluate the program as economic situations change and/or process equipment requires upgrading. As with most aspects in the competitive business arena, you must be regularly assessing your P2 program to see if there are further technological advances that should be tried that will give you a competitive advantage. In addition, as your equipment ages and needs to be replaced, remember to re-evaluate P2 opportunities relating to that aspect of your operation. 4-5 ------- The P2 approach, which is also called "waste minimization," is generally an effective and efficient way to manage environmental issues. Some of the benefits associated with this approach include decreased disposal costs, energy savings, improved regulatory compliance, and reduced environmental liability. * Develop a strategy Environmental requirements can be complex and confusing even for small facilities. If your facility is subject to several requirements, it may make sense to develop a plan of attack for addressing requirements. This plan may include: Identifying environmental tactics for staff, Determining who needs training, Identifying equipment and resource needs, Developing procedures and policies, Documenting incentives and penalties for superior and poor environmental performances, respectively, Determining who monitors compliance within your organization, and Establishing a schedule for achieving compliance and ongoing maintenance of environmental compliance. * Communicate these actions to other employees Line-staff personnel and managers often have numerous job requirements. It is absolutely critical that you educate the employees about their part in gaining environmental compliance. This may be simply a matter of posting reminders hi the work area (e.g., "Don't mix used oil and spent solvents!"). Intensive training may be required initially, and regular refresher training provided as well, to enforce the point that the business is serious about sticking to the policies and procedures. If your company has a formal policy that says environmental compliance is part of everyone's job, make sure your employees know it! Once the employees are trained, they need to know what is expected of them with regard to environmental compliance. They need to understand how they are responsible for ensuring the company's compliance with environmental regulations. Tying environmental compliance to performance evaluation can be a very effective strategy. Furthermore, it will be difficult for personnel to add environmental compliance requirements to their jobs if management does not appear committed to complying with environmental regulations. There are many ways in which management can demonstrate commitment. For instance, time can be set aside during meetings to discuss environmental issues; abasic statement signed by management highlighting the need for environmental compliance can be posted for all workers to see; and/or employees can be congratulated or rewarded for reducing the company's environmental liabilities and costs. Once employees see how important environmental issues are to management, they will then place more emphasis on these topics. * Initiate the actions Once all of your employees are informed of your company's environmental policies and procedures, it is time to intitate them. For the first week or so that the new policies are in place, you will have to be very attuned to your employees' actions and correct them where 4-6 ------- necessary. However, this transition period should be fairly short if you have invested the appropriate time in educating and informing your employees of the policies. At the same time policies and procedures are put into place, staff may also be bringing new equipment on-line to address specific requirements. It is critical that staff understand how all efforts are part of the company's efforts to comply with environmental requirements, protect the community, and, if applicable, improve profitability by using pollution prevention technologies. of environmental requirements through the Code of Federal Regulations. In some cases, the regulations do not change very much. At other times, the rules can be altered drastically. You should check with sources like trade associations, state agencies, environmental professionals, or EPA, which can alert you to regulation changes. In most cases, you should contact your state environmental regulatory agency at the beginning of each year for an update on their regulations or monitor regulation changes through the Internet. * Evaluate the program's successes The last, and perhaps most important, step is to evaluate your environmental program's success. You should regularly evaluate your system for successes and flaws. When the program is first put in place, you should perform an analysis within the first month. This is to chart the progress of your initial program and make any necessary corrections. After the program is working smoothly, you should only have to assess it and make changes twice a year. You should also perform an analysis of your environmental program when you make major changes to your operating process. For example, if you are a small-scale parts manufacturer, adding an additional production line would force you to incorporate changes into your environmental program. If this production change occurs when you have not revisited your environmental program for some time, you should spend the extra effort to review the whole process. You should also review your environmental program when the environmental regulations change. Each year EPA releases a revised set 4-7 ------- Section 5 - Compliance Management Systems As you evaluate your facility's environmental compliance situation, you might find that a more formal process is needed. Section 4 outlined a series of practical environmental considerations for you to initiate in your daily operations. However, there is a more formal method to account for environmental compliance issues in your management structure; this is commonly referred to as a Compliance Management System (CMS) (You may also have run across the term "Environmental Management System" (EMS) which is an even more formal type of management system that includes organizational structure, planning activities, achieving, reviewing and maintaining the environmental policy. For the purposes of this document, you may think of a CMS as a simplified subset of an EMS). A CMS is a continual cycle of planning, implementing, reviewing and improving the actions that an organization takes to meet its environmental compliance obligations. While there are several costs associated with the creation of a CMS, the benefits include: improved environmental performance, improved environmental compliance, new customers and markets, increased efficiency and reduced costs, enhanced employee moral, enhanced public image, and enhanced reputation with regulators. The CMS is traditionally divided into several different components or steps. These components are described below, so that you might better understand how it functions. Environmental Policy: An environmental policy is your management's declaration of commitment to the environment. The policy should serve as the foundation for your CMS and provide a unifying vision of environmental concern by the entire organization. Planning: In this step, you examine your environmental aspects and legal requirements, set your objectives and targets, and create your environmental management program. Implementation: This step creates the accountability structure for the CMS, implements the training program and communication system, documents the CMS, and establishes your control and emergency response procedures. Checking and Corrective Action: This step establishes the CMS's monitoring and measurement system, corrective and preventative action system, organizes relevant records, and conducts compliance audits. For additional help concerning audits, please see EPA's Protocols for Conducting Environmental Compliance Audit series (www.epa.gov/oeca/compliance/ incentives/auditing/protocol.html) Management Review: Your CMS must be reviewed by management from time to time to stay "healthy." Management reviews are the key to continual improvement and to ensuring that the system will meet your organization's needs over time. Evaluation of Performance: A CMS is designed and implemented to achieve compliance with 5-1 ------- achieve compliance with requirements. As such, you should evaluate how well your management system performs in meeting environmental regulatory requirements. Conclusion EPA knows how confusing environmental compliance can be, especially for small businesses. Small businesses face many special situations which make compliance difficult, including lack of time and resources, difficulty in understanding the regulations, lack of environmental staff, etc. EPA understands these problems and wants to help. This document is one of many resources EPA can provide to assist your compliance efforts. More information can be found in the Compliance-Focused Environmental Program Checklist that follows this section and EPA's website (www.epa.gov). Good luck in your business and thank you for your interest in environmental compliance. Please remember that while a CMS may seem overwhelming, its complexity and depth are determined by the size of your company and the number and type of environmental issues that your facility faces. In many cases, smaller companies may be able to skip or simplify steps because the size of the organization eases communication and implementation requirements. The Compliance-Focused Environmental Program Checklist on the next page may help you develop a CMS for your operation. 5-2 ------- Listed below are a few ideas that you might find particularly useful for your small business. This list is based on work done by theNEIC. Compliance-Focused Environmental Program Checklist Environmental Program Element Questions to ask employees for each Element 1. Management Policies & Procedures Environmental Policy Site-specific Environmental Policies & Standards Environmental compliance program Ongoing means of communicating environmental issues and information to personnel. Specific actions to be taken to improve communication regarding environmental compliance. Does an environmental policy exist? How is the policy communicated to all staff? Are you familiar with the environmental policy? What does the environmental policy say? How does the policy affect you? How has the policy been communicated to you? What documentation exists regarding general policies, rules, and procedures for environmental principles and practices? Who is responsible for environmental compliance? Who will pay for penalties imposed as a result of noncompliance? Have fines been imposed? How do fines affect operations and bonuses? How do you receive information regarding changes in the environmental program? How do you know what is important and pertinent to your operations? Describe the communication system withing the facility .How do you know what is important? 2. Organization, Personnel, and Oversight of the Environmental Policy Outlines formal organization for managing the environmental program Do you know how the environmental policy is implemented and maintained? How does management advocate the policy? 5-3 ------- Identify duties, responsibilities, and authorities of key environmental program personnel. What are the lines of authority? Who has ultimate authority to enforce environmental directives? 3. Accountability & Responsibility Specifies accountability of plant management for environmental protection practices and corrective actions implemented in their area of responsibility Specifies potential consequences of departure from specified operating procedures What level of responsibility do you have for environmental protection? What are the consequences of not following written Standard Operating Procedures (SOPs)? 4. Environmental Requirements Process for identifying, understanding, and communicating environmental requirements and changes in those requirements to affected operations. Describe the process. Show where this has been done. Specifically, how do you detect and deal with environmental requirement changes? What sources are used to identify environmental requirements? Did you check with your EPA, a tribal agency and trade organization? a 5. Assessment, Prevention, and Control Identify the ongoing process for: - assessing - monitoring and measuring operations as they relate to environmental protection and regulatory compliance What are the major environmental concerns/risks at the facility? 5-4 ------- Identifying operations and waste streams where equipment malfunctions and deterioration, operator errors, and discharges or emissions may be causing, or may lead to releases of HW or hazardous constituents to the environment, or a threat to human health and the environment. Performing root cause analysis of identified problems to prevent recurring issues. Process for developing and approving documented operating criteria for activities that could cause environmental impacts and/or non-compliance. What are the environmental concerns/risks related to your job or work area? What are the procedures for follow-up on an environmental incident? Do you have any reporting requirements? Where are records kept? How are these records reviewed? How do you develop criteria for operations that could have an environmental impact? Describe the system for conducting routine self- inspections by department supervision and environmental coordinators. How was the system initially developed? How was the system developed? Who conducts inspections? Who receives inspection reports or results of inspections? How are deficiencies communicated and resolved? Describe the inspection process. What inspection responsibilities do you have? Process for ensuring input of environmental concerns and requirements in planning design, and operation of ongoing, new and/or changing buildings, processes, maintenance activities, and products. Describe the process for ensuring environmental concerns are considered. How are environmental issues incorporated into daily planning and operating activities, purchases, maintenance, new processes, etc.? 6. Environmental Incident and Non-compliance Investigations Outline standard procedures and requirements for: - incident reporting - non-compliance reporting - investigation and development and tracking of corrective and preventative actions Who develops the procedures? How, by whom, and how often are they updated? What procedures are in place? Describe incident reporting - what do you do? What is an incident? 5-5 ------- 7. Environmental Training, Awareness, and Competence Identify specific education and training for personnel Document training provided, including employees in non- environmental departments with environmental responsibilities. List overall and environmental job responsibility. How is necessary training and education determined? How is competence evaluated? How are specific training programs evaluated and identified? Who is trained? How do you know who has to be trained? What training do environmental department personnel have? What training have you received? 8. Maintenance of Records and Documentation Identify types of records developed in support of the environmental policy. Specify system for recording and tracking: - any internal waste tracking or manifest systems - environmental data - HW determinations Who maintains the records and where are they maintained? What training do they have? Are there formal policies and procedures to operate the system? What protocols exist for responding to outside inquiries? Is the tracking system accessible to all employees? How are SOPs currently available to all employees? Who will respond to outside inquiries? Where is the following information kept: * waste tracking * manifests * TRIdata * other environmental data 9. Pollution Prevention Program Describe internal program for reducing, reusing, and minimizing waste and emissions, including procedures to encourage material substitutions. The section also includes mechanisms for identifying candidate materials to be addressed by program. Describe the program. How and when was it developed? Do you tap your employees for pollution prevention ideas? What are the results? Describe any baseline assessments. How do you track progress? Are there additional areas that you are considering? 5-6 ------- 10. Continuing Program Evaluation Determine if the environmental program is periodically reviewed. Annual program review schedule - who is involved and how will it happen? What prompts a review to occur? Are annual reports prepared? What are their distribution? Who is responsible for their preparation? Are results presented to upper management - how? 5-7 ------- Appendix A State Assistance Program Reference List ALABAMA OMBUDSMAN Gary Ellis AL DEM/Admin. Div. P.O. Box 301463 Montgomery, AL 36130-1463 gellis@adem.state.al.us Director of SB AP Technical Program Mike Sherman AL DEM/Admin. Div. P.O. Box 301463 Montgomery, AL 36130-1463 mhs @adem.state.al. us Voice # 334-394-4352 (N) 800-533-2336 334-271-7873 (N) 800-533-2336 Fax* 334-271-7873 334-271-7950 ALASKA OMBUDSMAN Bill Smyth Small Business Advocate 555 Cordova St. Anchorage, AK 99501 bsmvth@envircon. state, ak.us Voice* 907-451-2177 (S) 800-520-2332 Fax* 907-269-7600 Director of SBAP Technical Program Tom Chappie Alaska Dept. of Environ. Conserv. 555 Cordova Street Anchorage, AK 99501 tchanple@envircon.state.ak.us 907-269-7686 907-269-7687 ARIZONA OMBUDSMAN (vacant) DEQ/Customer Service 3033 N. Central Avenue Phoenix, AZ 85012 Director of SBAP Technical Program Ira Domsky (Dual Role as Ombudsman and SBAP Principal) Voice* 602-207-2365 800-368-5888 602-207-2254 (S) 800-234-5677 (x4337) Fax* 602-207-4872 602-207-4872 ------- Frances Dominguez Business Assistance Pima Co. DEQ 130 West Congress St. Tucson, AZ 85701-1317 fdomingu@igate.co.pima.az. us 520-740-3344 520-882-7709 Richard Polito Maricopa Co. Env. Serv./SBEAP 1001 N. Central Ave. Suite 500 Phoenix, AZ 85004 rpolito @ mail.maricopa. sov 602-506-5102 602-506-6669 Donald P. Gabrielson SBAP Director/SBO . Pinal Co. APCD P.O. Box 987 Florence, AZ 85232 pcaqcd@evergreen.com> 520-868-6760 520-868-6754 "Other" Contact Maureen Lynch Maricopa County SBEAP 1001 N. Central Ave. Suite 500 Phoenix, AZ 85004 mlvnch@mail.maricoDa.gov 602-506-5150 602-506-6669 ARKANSAS OMBUDSMAN Ron Alexander Small Bus. Asst. Manager ARDPE P.O. Box 8913 Little Rock, AR 72219-8913 ralexander@adea.state.ar.us Voice # 501-682-0866 (N) 888-233-0326 Fax* 501-682-0880 Director of SBAP Technical Program Ron Alexander Chief, Customer Service Division ARDPE P.O. Box 8913 Little Rock, AR 72219-8913 ralexander@adea.state.ar.us 501-682-0866 501-682-0880 ------- Other Amanda Gregory ARDEQ P.O. Box 8913 8001 National Drive Little Rock, AR 72219-8913 agregorv@adeq. state, ar.us 501-682-0709 (N) 888-233-0326 501-682-0880 CALIFORNIA OMBUDSMAN Kathleen TschogI CA Air Resources Board 2020 L Street Sacramento, CA 95812-2815 ktschogl @ arb.ca. gov Voice # 916-323-6791 (S) 800-272-4572 Fax* 916-322-4737 Director of SBAP Technical Program Larry Kolczak CAEPA-AirRes.Bd. Stationary Source 2020 L Street Sacramento, CA 95814-4219 lkolczak@arb.ca.gov 909-396-3215 (S) 800-388-2121 LaRonda Bowen Public Advisor SCAQMD/SBAP 21865 E. Copley Dr. Diamond Bar, CA 91765 lbowen@aamd.gov Cynthia Specht Manager of Desert Program Mojave Desert AQMD 15428 Civic Dr. Victorville, CA 92392 mdaqmdq @eee.ors Terri Mitchell Sacramento County Business Environmental Resource Center 10425 Norden Ave., Bldg. 3492 Mather, CA 95655-1101 tmiichell@sacberc.org Paul Davis San Diego APCD 9150CheapeakeDr. San Diego, CA 92123 sacberc@sna.com 909-396-3235 (N) 800-388-2121 909-396-3335 760-245-1661 x5597 760-243-8907 916-364-4106 916-364-4115 619-694-3339 619-694-2730 ------- Erin Craig Director, BEAC UC Extension 3120DeLaCruz Santa Clara, CA 95054 beac@cats.ucsc.edu Francis Gilliland Santa Barbara County APCD 26 Castillian Dr. Suite B-23 Goleta,CA93117 gillilandf@sbcapcd.org Christine Schaufelberger Bay Area AQMD 939 Ellis St. San Francisco, CA 94109 cschauffelberger@baaQmd.goy Nola Oriola SCAQMD/SBAP 21865 E. Copely Dr. Diamond Bar, CA 91765 noriola@aqmd.gov 408-748-2161 408-748-7388 805-961-8838 (Direct) 805-961-8801 805-961-8868 (Bus. Asst.) 415-749-4779 415-928-0338 909-396-2382 (N) 800-388-2121 909-396-3335 COLORADO Voice # Fax# OMBUDSMAN Nick Melliadis Dept. of Public Health and Environment OCS-INF-A1 4300 Cherry Creek Drive - South Denver, CO 80246-1530 nkk.rne11iadis@state.co.us Director OF SBAP Technical Program Chuck Hix Air Pollution Control Division Dept. of Public Health & Environment APCD/55/B-1 4300 Cherry Creek Drive - South Denver, CO 80246-1530 chuck.hix@state.co.us 303-692-2135 (S) 800-886-7689 303-691-1979 303-692-3148 (N) 800-333-7798 303-782-5493 "Other" Contact Doug Ryder Dept. of Public Health & Environment 4300 Cherry Creek Drive - South APCD/55/B-1 Denver, CO 80246-1530 doug.rvder@state.co.us 303-692-3144 (N) 800-333-7798 303-782-0278 ------- CONNECTICUT OMBUDSMAN Tom Turick SBAP/DEP 79 Elm St. Hartford, CT 06106-5127 tom.turick@po.state.ct.us Voice* 860-424-3382 (8)800-760-7036 Fax* 860-424-4063 Director of SB AP Technical Program Tom Turick Sm. Bus. Asst. Prog. Dept. of Env. Protection Env. Quality Div. 79 Elm St. Hartford, CT 06106-5127 860-424-33382 (S) 800-760-7036 860-424-4063 "Other" Contact Sharon Roe-Johnson Small Bus. Asst. Dept. Env. Prot. 79 Elm St. Hartford, CT 06106-5127 sharon.roe-iohnson@po.state.ct.us 860-424-3302 (S) 800-760-7036 860-424-4063 DELAWARE OMBUDSMAN Kim Finch DE/DNREC 89 Kings Highway Dover, DE 19901 kfinch@dnrec.state.de.us Voice* 302-739-6400 800-760-7036 Fax* 302-739-6242 "Other" Contact Bob Banish DNREC 715 Grantham Lane New Castle, DEI 9720 bbarrish@dnrec.state.de.us 302-323-4542 302-323-4561 "Other" Contact Andrea Kreiner DE/DNREC 89 Kings Highway Dover, DE 19901 akreiner@state.de.us 302-739-6400 302-739-6242 ------- CaraWaddell Jefferson County Sm. Bus. Assistance 810 Barrett Ave. Louisville, KY 40204 nmbudapc@iglou.com 502-574-5164 502-574-8188 LOUISIANA OMBUDSMAN Jim Friloux DEQ, Small Bus. Ombudsman P.O. Box 82263 Baton Rouge, LA 70804 iim f@deo.state.la.us Voice* 225-765-0735 (S) 800-259-2890 Fax# 225-765-0746 MAINE OMBUDSMAN Ron Dyer Dept. Env. Prot. Office of Pollution Prevention Station 17 State House Augusta, ME 04333 ron.e.dver@state.me.us Voice* 207-287-4152 (S) 800-789-9802 Fax* 207-287-2814 Director of SB AP Technical Program Julie M. Churchill Coordinator, SBAP Dept. of Env. ProL State House Station #17 Augusta, ME 04333 roy.krout@state.me.us 207-287-7881 (S) 800-789-9802 207-287-2814 "Other" Contact Jim Brooks Dept. of Env. Prot. Bureau of Air Quality Mgmt. Station 17 State House Augusta, ME 04333 iames.D.brooks@state.me.us 207-287-2437 207-287-7641 ------- MARYLAND OMBUDSMAN Don Jackson Director, Office of Community Assistance MDDept. ofEnv. 2500 Broening Hwy. Baltimore, MD 21224 diackson@mde.state.md.us Voice* 410-631-3165 (8)800-633-6101 x3165 Fax* 410-631^477 Director of SBAP Technical Program Andrew Gosden Environmental Permits Service Center MD Dept. of Env. 2500 Broening Hwy. Baltimore, MD 21224 agosden @ mde.state.md.us 410-631-4158 (N) 800-633-61201 x4158 410-631-4477 Laura Armstrong Coordinator Baltimore, MD Pollution Prevention Sm. Bus. TAP MDDept. of Env. 2500 Broening Hwy Baltimore, MD 21224 larmstrong@mde.state.md.us 410-631-3114 410-631-3936 MASSACHUSETTS OMBUDSMAN VACANT Director of SBAP Technical Program Exec. Office of Env. Affairs 100 Cambridge St., Suite 2109 Boston, MA 02202 Voice* 800-368-5888 Fax* "Other" Contact Nancy Wrenn Dept. of Env. Prot. 1 Winter Street Boston, MA 02108 nwrenn@state.ma.us 617-292-5587 617-292-5778 MICHIGAN OMBUDSMAN Susan Holben MI Jobs Comm. Victor Ctr., 4th R. 201 N. Washington Square Lansing, MI 48913 siolben@state.mi.us Voice # 517-335-5883 Fax* 517-335-0198 ------- Director of SB AP Technical Program Dave Fiedler MDEQ Environmental Assistance Div. P.O. Box 30457 Lansing, MI 48909 fiedlerd@state.mi.us 517-373-0607 (N) 800-662-9278 517-335-4729 "Other" Contact Donna Davis Env. Asst. Div. MI/DEQ P.O. Box 30457 Lansing, MI 48909-7957 517-373-2784 (N) 800-662-9278 517-335-4729 MONTANA OMBUDSMAN Charlie Kennedy MPCA/OEA 520 Lafayette Rd. St. Paul, MN 55155-4194 charlie. kennedv@pca.state.mn.us Voice* 651-297-8615 (S) 800-985-4247 Fax* 651-297-8324 Director of SBAP Technical Program Troy Johnson MPCA/MDRF/SBAP 520 Lafayette Rd. St. Paul, MN 55155 troy. Johnson @pca.state.mn.us 651-296-7767 (S) 800-657-3938 (hotline) 651-282-6143 651-282-6247 "Other" Contact Phyllis Strong MNPCA 520 Lafayette Road St. Paul, MN 55155-4197 phvllis.strong@pca.state.mn.us 612-282-5847 612-297-7709 "Other" Contact Barb Loida MPCA/MDRF/SBAP 520 Lafayette Rd. St. Paul, MN 55155 barb.loida@nca.state.mn.us 651-282-2604 (S) 800-657-3938 651-282-6247 ------- "Other" Contact 651-296-85777 Michael Nelson (S) 800-657-3938 MPCA/MDRF/SBAP 520 Lafayette Rd. St. Paul, MN 55155 michael. nelson @pca.state.mn. us MISSISSIPPI Voice* Fax* Dual Role as OMBUDSMAN and SBAP Principal 601-961-5167 601-961-5742 Jesse Thompson (N) 800-725-6112 MS DEQ P.O. Box 10385 Jackson, MS 39289-0385 jesse thompson@deq.state.ms.us "Other" Contact 601-961-5166 601-961-5541 Randy Wolfe (N) 800-725-6112 Air Quality Office of Policy Control/DEQ P.O. Box 10385 Jackson, MS 39289-0385 Randv Wolfe@deq.state.ms.us MISSOURI Voice* Fax* OMBUDSMAN (N) 800-368-5888 VACANT Office of the Governor P.O. Box 720 Jefferson City, MO 65102 heffna@mail.gov.state.mo.us Director of SBAP Technical Program 573-526-6627 573-526-5808 Byron Shaw (N) 800-361-4827 MO. Dept. of Natural Resources Technical Assistance Program P.O. Box 176 Jefferson City, MO 65102 nrshawb@mail.dnr.state.mo.us MONTANA Voice* Fax* OMBUDSMAN 406-444-3641 406-444-6836 Bonnie Rouse (N) 800-433-8773 Dept. of Env. Quality Small Bus. Ombudsman 1520 E. 6th Ave. Helena, MT 59620-0901 brouse@mt.gov ------- Director of SBAP Technical Program 406-444-3641 406-444-1499 Bonnie Rouse (N) 800-433-8773 Dept. of Env. Quality Air Quality Division MetcalfBldg. 1520 E. Sixth Ave. Helena, MT 59620 brouse@mt.gov NEBRASKA Voice* Fax* OMBUDSMAN 877-253-2606 Tom Franklin Public Advocate (Dual role as Ombudsman and SBAP Principal) Dept. of Env. Quality P.O. Box 98922 Lincoln, NE 68509-8922 tfranklin@mail.deq.state.ne.us MarciaWilhite 402-441-8188 402-441-8323 Lincoln/Lancaster Co. Health Dept. 3140 N Street Lincoln, NE 68510 mwilhite@ci.lincoln.ne.us SBAP Technical Program 877-253-2606 Tom Franklin (Dual role as NE Ombudsman and SBAP Principal) SBAP Director-Lincoln/Lancaster County 402-441-8644 402-441 -8323 Phil Rooney Health Dept. 3140 N Street Lincoln, NE 68510 nroonev@ci.lincoln.ne.us "Other" Contact 402-471-0275 402-471-2902 Tom Lamberson DEQ Asst. Dir. P.O. Box 98922 Lincoln, NE 68509-8922 deci 112@mail.deq.state.ne.us ------- NEVADA OMBUDSMAN Marcia Manley Div. of Environmental Protection 333 West Nye Lane Carson City, NV 89706-0851 mmanlev@ndep.carson-citv.nv.us Voice # 775-687-4670x3162 (S) 800-992-0900 x4670 Fax* 702-687-5856 SBAP Technical Program Janet Goodman Technical Assistance Coordinator Div. of Env. Prot. 333 West Nye Lane Carson City, NV 89706-0851 isoodman @ ndep.carson-citv.n v.us 775-687-4670 \3067 (S) 800-992-0900 x4670 702-687-5856 "Other" Contact Kevin Dick BEP-NSBDC, UNR 6100 Neil Rd.-Suite 400 Reno, NV 89571 dick@unr.edu 702-834-6677 702-834-6689 NEW HAMPSHIRE OMBUDSMAN Rudolph Carrier, Jr., PE (Dual Role as Ombudsman and SBAP Principal) Air Resources Div. Dept. of Env. Services 6 Hazen Drive-P.O. Box 95 Concord, NH 03302-0095 rcartier@des.state.nh.us Voice* 603-271-1379 (S) 800-837-0656 Fax* 603-271-1381 NEW JERSEY OMBUDSMAN Chuck McCarty Office Bus. Advocacy Commerce and Economic Growth Comm. P.O. Box 839 Trenton, NJ 08625-0839 cmccartv@commerce. state, nj. us Voice* 609-292-3863 (N) 800-643-6090 Fax* 609-777-4097 Director of SBAP Technical Program KyAsral Pollution Prevention - Permit Coord./SBAP NJDEP PO Box 423 Trenton, NJ 08625-0423 kasral@dep.state.ni .us 609-292-3600 609-777-1330 ------- Director of SBAP Technical Program Marian Mudar, Ph.D. Env. Program Manager NYS Env. Facil. Corp. 50WolfRd.-Rm.598 Albany, NY 12205 mudar@nvsefc.org 518-402-7462 (S) 800-780-7227 518-457-8681 "Other" Contact Patrick Lentlie NYS DEODAR 50WolfRd.-RmllO Albany, NY 12233 rixlentli@gw.dec.5tate.nv.iis 518-457-7450 518-457-0794 NORTH CAROLINA OMBUDSMAN Edythe McKinney Office of Sin. Bus. Ombudsman Dept. of Env. and Nat. Res. P.O. Box 29583 Raleigh, NC 27626-0583 edvthe mckinnev@n2pavs.org Voice* 919-733-0823 (N) 877-623-6748 Fax* 919-715-7468 Director of SBAP Technical Program Tony Pendola Dept. of Env. and Nat. Res. P.O. Box 29583 Raleigh, NC 27626-0583 tonv pendola@p2pavs.org 919-733-0823 (N) 800-623-6748 919-715-7468 "Other" Contact Karen Davis Office of Small Bus. Ombudsman Dept. of Env. and Nat. Res. P.O. Box 29583 Raleigh, NC 27626-0583 karen davis@D2pavs.org 919-733-1267 (N) 800-829-4841 919-715-7468 ------- NORTH DAKOTA OMBUDSMAN Dana Mount Div. of Env. Engr. Env. Health Sect. ND DH&CL 1200 Missouri Ave. P.O. Box 5520 Bismarck, ND 58506-5520 dmount@state.nd.us Voice # 701-328-5150 (S) 800-755-1625 Fax* 701-328-5200 Director of SBAP Technical Program Tom Bachman NDDept. of Health Div. of Env. Engr. 1200 Missouri Ave. P.O. Box 5520 Bismarck, ND 58506-5520 tbachman@state.nd.us 701-328-5188 (S) 800-755-1625 701-328-5200 OHIO OMBUDSMAN Mark Shanahan OH Clean Air Res. Ctr. Room 1901 50 West Broad St. Columbus, OH 43215 mark.shanahan@aqda.state.oh.us Voice # 614-728-3540 (8)800-225-5051 Fax# 614-752-9188 Director of SBAP Technical Program Rick Carleski OH EPA Div. of Air Pollution Control Lazarus Government Center Post Office Box 1049 Columbus, OH 43216-1049 rick.carleski @epa.state.oh.us 614-728-1742 614-644-3681 "Other" Contact Bob Hodanbosi OEPA/DAPC Lazarus Government Center P.O. Box 1049 Columbus, OH 43216-1049 614-644-2270 614-644-3681 ------- OKLAHOMA OMBUDSMAN Steve Thompson OKDEQ-Suitel212 1000N.E. lOthSt. Oklahoma City, OK 73117-1212 steve. thomnson@deqmail.state.ok.us Voice # 405-702-7100 800-899-1400 Fax* 405-271-8425 Director of SBAP Technical Program Steve Thompson OKDEQ Customer Services Division P.O. Box 1677 Oklahoma City, OK 73101-1677 alvvin.ning@deamail.state.ok.us 405-702-7100 (N) 800-869-1400 405-271-1317 "Other" Contact Kyle Arthur OKDEQ Customer Services Division 1000 N.E. 10th St. Oklahoma City, OK 73117 kvle.arthur@deqmail.state.ok.us 405-702-6100 (N) 800-869-1400 405-271-1317 OREGON OMBUDSMAN Rich Grant ODEQ 811S.W. 6th Ave. Portland, OR 97204-1390 rgrant@deo.state.or.us Director of SBAP Technical Program Jill Inahara ODEQ Air Qual Div. 811S.W. 6th Ave. Portland, OR 97204 inahara.iill@deq.state.or,us Voice # 503-229-6839 (8)800-452-4011 Fax# 503-229-6945 503-229-6147 (8)800-452-4011 503-229-5675 "Other" Contact Marianne Fitzgerald ODEQ Reg. Oper. Div. 811S.W.6thAve. Portland, OR 97204 fi tzgerald.marianne@deq.state.or.us 503-229-5946 503-229-6124 ------- PENNSYLVANIA OMBUDSMAN Bruce McLanahan Asst. to PA SBO/Office of P2 & Compl. Asst. RCSOB, 15th Floor P.O. Box 8772 Harrisburg, PA 17105-8772 b.mclanahan@dep.state.pa.us Voice # 717-772-5942 Fax# 717-783-2703 Director of SBAP Technical Program Gerald Laubach PRC Env. Mgmt. Inc. 6th Floor 1800 JFK Blvd. Philadelphia, PA 19103 glaubach @ ttemi .com 717-772-2333 "Other" Contact Scott Kepner Bur.of AirQual. Dept. of Env. Prot. P.O. Box 8468 Harrisburg, PA 17105-8468 Kepner.Scott@al .dep.state.pa.us 717-772-1663 717-772-2303 PUERTO RICO OMBUDSMAN VACANT Administrator of Commercial Development Administration Office P.O. Box 4275 San Juan, PR 00902 Director of SBAP Technical Program Angel Berrios-Sivestre PREQB-SBAP HC-91, Box 9197 Vega Alta, PR 00692 pr sbap@hotmait.com Voice # 800-368-5888 787-767-8025 .Fax* 787-294-0148 787-772-9497 RHODE ISLAND OMBUDSMAN VACANT Dept. of Env Mgmt. Office of the Director 235 Promenade Street Providence, RI02908 Voice # 800-368-5888 Fax# 401-222-6802 ------- Director of SB AP Technical Program Joe Antonio Dept. of Environment Management. Office of Technical & Customer Assistance 235 Promenade Street Providence, RI02908 iantonio@doa.state.ri.us 401-222-6822x4410 401-222-3810 "Other" Contact Joe Antonio Office of Technical & Customer Assistance 235 Promenade Street Providence, RI 02908 iantonio@dem.state.ri.us 401-222-6822 x4410 401-222-3810 SOUTH CAROLINA OMBUDSMAN Phyllis T. Copeland Small Business Ombudsman South Carolina DHEC 2600 Bull Street Columbia, SC 29201 copelapt@CQlumb30.dhec.state.sc.us Voice # 803-896-8982 (N) 800-819-9001 Fax* 803-898-3939 Director of SBAP Technical Program James Robinson SC Dept. of Health & Env, Control 2600 Bull Street Columbia, SC 29201 robinsic@columb30.dhec.state.sc.us 803-898-3981 (N) 800-819-9001 803-898-3939 Permitting Liaison: "Other" Contact Willie J. Morgan SCDHEC 2600 Bull Street Columbia, SC 29201 morganwi@columb30.dhec.state.sc.us 803-898-3957 (N) 800-819-9001 803-898-3939 ------- SOUTH DAKOTA Voice* Fax# OMBUDSMAN 605-773-3836 605-773-6035 Joe D. Nadenicek (S) 800-438-3367 Sm. Bus. Ombudsman SDDENR Joe Foss Bldg. 523 East Capitol Ave Pierre, SD 57501 ioen@denr.state.sd.us Director of SB AP Technical Program 605-773-6706 605-773-5286 Rick Boddicker (S) 800 438-3367 SDDENR Joe Foss Bldg. 523 East Capitol Ave. Pierre, SD 57501 rroddicker@denr.state.sd.us TENNESSEE Voice* Fax# OMBUDSMAN 615-741-5262 615-532-8007 Ernest B lankenship (N) 800-734-3619 TN Dept. of Env. & Conservation L&C Tower/8th Fl. 401 Church St. Nashville, TN 37243-1551 eblankenship@mail.state.tn.us Director of SB AP Technical Program 615-532-0779 615-532-8007 Linda Sadler (N) 800-734-3619 Small Business Assist. Program 8th Floor L&C Annex 401 Church Street Nashville, TN 37243 lsadler@mail.state.tn.us TEXAS Voice # Fax# OMBUDSMAN 512-239-5319 512-239-3165 Israel Anderson (N) 800-447-2827 Director, ' Office of Small Business and Environmental Assistance TNRCC (Mail Code 106) P.O. Box 13087 Austin, TX 78711-3087 ianderso@tnrcc.state.tx.us ------- Director of SBAP Technical Program Tamra Shae-Oatman Small Bus. Tech. Asst. Prog. TNRCC (Mail Code 106) P.O. Box 13087 Austin, TX 78711-3087 toatman@tnrcc. state, tx. us 512-239-1066 (N) 800-447-2827 512-239-1065 "Other" Contact Kathy Ramirez Small Bus. & Gov't. Asst. TNRCC (Mail Code 106) P.O. Box 13087 Austin, TX 78711-3087 kramirez@tnrcc.state.tx.us 512-239-3047 512-239-1055 UTAH OMBUDSMAN Renette Anderson UTDEQ Small Bus. Ombudsman 168 No. 1950 West Salt Lake City, UT 84114-4810 randerspn@deq.state.ut.us Voice* 801-536-4478 800-458-0145 Fax# 801-536-0061 Director of SBAP Technical Program Ron Reece Environmental Engineer Utah Dept. of Env. Qual. Div. of Air Quality P.O. Box 144820 Salt Lake City, UT 84114-4820 rreece@deq.state.ut.us 801-536-4091 (N) 800-270-4440 801-536-4099 VERMONT OMBUDSMAN VACANT Voice* 800-368-5888 Fax# Director of SBAP Technical Program Judy Mirro VT Env. Asst Div. Laundry Bldg. 103 S. Main St. Waterbury.VT 05671 iudvm@dec.anr.state.vt.us 802-241-3745 (S) 800-974-9559 802-241-3273 ------- "Other" Contact Kevin Bracey APCD/ANR Building 3 South 103 South Main Street Waterbury, VT 05671-0402 . kevinb@dec.anr.state.vt.us 802-241-3841 802-241-2590 VIRGINIA OMBUDSMAN John Daniel VADEQ/Air Division Manager, Small Bus. Assistance Program P.O. Box 10009 Richmond, VA 23240-0009 irdaniel@deo.state.va.us Voice # 804-698-4311 (S) 800-592-5482 Fax* 804-698-4510 Director of SB AP Technical Program Richard Rasmussen Air Division Director VA Dept. of Env. Quality P.O. Box 10009 Richmond, VA 23240-0009 rgrasmusse@deq.state.va.us 804-698-4394 800-592-5482 804-698-4510 VIRGIN ISLANDS OMBUDSMAN VACANT VI Dept. Planning & Natural Resources Division of Environmental Protection Wheatley Shopping Center n Charlotte Amalie, St. Thomas, V.I. 00802 Director of SBAP Technical Program Marylyn A. Stapleton VI Dept. of Planning & Natural Resources Div. of Environmental Protection Wheatley Shopping Center II Charlotte Amalie.St. Thomas, VI00802 "Other" Contact Jasmine A. Blyden VI Dept. of Planning & Natural Resources Div. of Environmental Protection Wheatley Shopping Center n Charlotte Amalie, St. Thomas, VI00802 Voice # 800-368-5888 Fax# 340-774-5416 304-774-3320X5167 340-714-8529 (Hotline) 340-777-4577 340-774-5416 340-774-5416 ------- WASHINGTON OMBUDSMAN Bernard Brady Dept. of Ecology P.O. Box 47600 Olympia, WA 98504-7600 bbra461 @ecv. wa.gov Voice* 360-407-6803 Fax# 360-407-6802 Director of SB AP Technical Program Bernard Brady Dept. of Ecology Air Quality Prog. P.O. Box 47600 Olympia, WA 98504-7600 bbra461 @ecv.wa.gov 360-407-6803 360-407-6802 WEST VIRGINIA OMBUDSMAN Terry Polen WV DEP Small Business Ombudsman 1356 Hansford Street Charleston, WV 25301 Tpolen@mail.dep.state, wv.us Voice # 304-759-0510 Ext.341 Fax* 304-558-3998 Director of SBAP Technical Program Gene Coccari WV DEP, Office of Air Quality Small Business Assistance Program 7012 McCorkle Ave., S.E. Charleston, WV 25304 gcoccari @mail.dep.state.wv.us 304-926-3731 (S) 800-982-2474 304-926-3637 "Other" Contact Gene M. Coccari Technical Specialist WV Office of Air Quality 7012 McCorkle Avenue Charleston, WV 25304 gcoccari @ mail .dep.state. wv.us 304-926-3731 304-926-3637 ------- WISCONSIN Voice # Fax# OMBUDSMAN Pam Christenson WI Dept. of Commerce-SBCAAP P.O. Box 7970-6th Floor Madison, WI 53707-7970 pchristenson@commerce. state, wi. us 608-267-9384 (N) 800-435-7287 Director of SBAP Technical Program Renee Lesjak Bashel WI Clean Air Asst. Prog. Dept. of Commerce 201 W. Washington Ave. 6th Floor P.O. Box 7970 Madison, WI 53707-7970 iakbashel@commerce. state, wi. us 608-267-6153 (N) 800 435-7287 608-267-0436 "Other" Contact Hampton Rothwell Director, Bus. Development Assistance Center WI Dept. of Commerce P.O. Box 7970 201 W. Washington Ave. Madison, WI 53707-7970 hrothwell@commerce.state.wi.us 608-267-0313 (N) 800-435-7287 608-267-0436 WYOMING OMBUDSMAN Dan Clark Dept. of Env. Quality Small Bus. Ombudsman Div. of Air Quality 122 W. 25th Street Cheyenne, WY 82002 dclark@missc.state, wv.us Voice # 307-777-7388 Fax* 307-777-3773 Director of SBAP Technical Program Charles Raffelson Dept. of Env.Quality Div. of Air Quality 122 W. 25th Street Cheyenne, WY 82002 craffe@missc. state, wv.us 307-777-7347 307-777-5616 ------- "Other" Contact 307-777-7391 307-777-5616 Dan Olsen WY Dept. of Env. Quality Div. of Air Quality 122W.25thSt. Cheyenne, WY 82002 dolseng'missc.state.wv.us ------- |