U.S. ENVIRONMENTAL PROTECTION AGENCY

              REGION I

    POLLUTION PREVENTION STRATEGY




          FISCAL YEAR 1991
                Final—For External Distribution
                January 1991

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OVERVIEW
     This document represents EPA Region I's second annual effort
     to outline its plans for implementing pollution prevention
     during the fiscal year.  Lessons learned from the strengths
     and weaknesses of Region I's first (1990)  Strategy were
     applied in constructing the 1991 Strategy.  The new Strategy
     is designed to:

          reduce number and length of objectives to make the
          Strategy a more streamlined and realistic document;

          emphasize innovative projects over ongoing national
          program commitments;

          highlight iniatives designed to change the way the
          Agency does business toward a prevention orientation;

          include only those objectives which fit the definition
          of pollution prevention; and

          set five central goals to unify the Strategy across
          media and program barriers, and provide a long-term
          view of what the Region wants to accomplish.

     Institutional barriers prevented the 1991 Strategy from
     succeeding entirely in achieving the above aims.  Therefore,
     the Strategy is prefaced by a discussion of the barriers
     encountered and recommendations for overcoming them.

     CONTENTS

          I.   Background:  Meaning and history of pollution
               prevention.

          II.  Summary of the 1990 Strategy;  Development process
               and  lessons  learned.

          III. Development  of the 1991 Strategy:  Goals and
               results.

          IV.  Recommendations;  Ideas for overcoming barriers
               and  creating successes.

          V.   1991 Objectives;  Division and Office objectives,
               grouped under the five central goals.

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I.   BACKGROUND

                             VISION

     EPA Administrator Reilly's vision of pollution prevention is
     to shift our efforts away from an emphasis on controlling
     and cleaning up existing pollution,  toward anticipating and
     avoiding generating pollutants in the first place.   Since
     the Environmental Protection Agency  issued its draft
     pollution prevention policy statement in the Federal
     Register in January 1989,  the pollution prevention  program
     in Headquarters and the Regions has  come a long way.

                             HISTORY

     Region I was first in developing a Pollution Prevention
     Strategy for fiscal year 1990.  In the Strategy,  each Region
     I Office and Division committed to a set of pollution
     prevention activities designed to begin to institutionalize
     pollution prevention and produce demonstrable successes.
     Progress on these activities was tracked during the
     remainder of fiscal year 1990.  In addition, Region I
     produced an interim definition of pollution prevention,
     pending issuance of the final national policy statement and
     national strategy.

                            DEFINITION

     The national policy statement and strategy are about to be
     issued in final form.  In the revised draft policy
     statement, pollution prevention is defined as "the  use of
     processes, practices, or products that reduce or eliminate
     the generation of pollutants and wastes or that protect
     natural resources through conservation or more efficient
     use."  Pollution prevention is the top rung in an
     environmental management hierarchy.   Closed-loop recycling
     is considered pollution prevention.   Other forms of
     recycling, then treatment and disposal, make up the
     remainder of the hierarchy.

     Because recycling, in its most efficient forms, accomplishes
     many of the same aims as pollution prevention, the  national
     and Region I programs are committed  to promoting
     environmentally-sound recycling as a companion to pollution
     prevention.  We also recognize that  many important
     environmental protection activities  cannot be defined as
     pollution prevention.  However, these activities are not
     classified as pollution prevention,  and so are not  included
     in the Strategy.

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II.  SUMMARY OF THE FISCAL YEAR 1990 STRATEGY

                              GOALS

     The successes and failures of Region I's 1990 Pollution
     Prevention Strategy were instructive in developing the 1991
     Strategy.  The first Strategy aimed to:

          involve all Region I Divisions and Offices, and as many
          programs as possible, in pollution prevention;

          catalog existing prevention-oriented activities;

          identify initial Region-wide pollution prevention
          goals; and

          begin to develop mechanisms for institutional change
          toward pollution prevention.

                           PARTICIPANTS

     The key participants in the Strategy development and
     implementation process were:

          the Pollution Prevention Task Force (comprised of
          representatives from each Region I Division and Office,
          plus interstate organizations and state agencies);

          the Pollution Prevention Program staff within the
          Planning and Analysis Section; and

          the Leadership Team  (Directors of Divisions and
          Offices).

                             PROCESS

     The EPA Task  Force representatives solicited contributions
     to the Strategy  from their programs, gained approval on
     these objectives from their Directors, defined  the steps
     necessary to  implement the objectives, and provided periodic
     updates on progress.

     The Pollution Prevention  Program staff coordinated the
     Strategy development and  approval process, and  developed  and
     managed the achievement tracking system.

     The Leadership Team signed off on their programs' portions
     of the Strategy, approved the  final Strategy as a whole,  and
     began to report  progress  on pollution  prevention  initiatives
     during quarterly meetings with the Deputy Regional
     Administrator.

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                       SUCCESSES

The 1990 Strategy was successful in several ways.   Broadly,
it represented the energy and dedication of the Task Force
in the number and scope of the objectives submitted.  Region
I's initiative in developing the Strategy earned attention
and praise from Headquarters, other Regions, and non-EPA
organizations.

More concretely, the Strategy also functioned as a-tangible
reminder of the commitments each program made.  Each program
completed a number of objectives, generally those that were
also part of existing national program commitments,  but the
Strategy also gave support to a number of innovative
projects.  The experience of implementing the Strategy
pointed out the importance of cross-media cooperation in
developing new policies and procedures.

The following are highlights of 1990 pollution prevention
accomplishments by program:

o    Office of Regional Counsel developed policy and
     procedures for case settlements that alleviate negative
     cross-media impacts.  ORC also made progress in
     cataloging examples of Environmentally Beneficial
     Expenditure (EBE) cases in preparation for establishing
     a Region I EBE policy.

o    Water Management Division made progress in promoting
     growth management techniques, targeted permitting,
     wellhead protection (including workshops), and wetlands
     predesignation.  WMD has also participated in revising
     National Effluent Guidelines to incorporate prevention.

o    Air. Pesticides and Toxics Management Division
     supported vapor recovery programs, used TRI data to
     target prevention efforts (including an industry
     workshop), and began to incorporate pollution
     prevention considerations in enforcement.

o    Waste Management Division's Office of Special Programs
     completed major Geographic Information System (CIS)
     goals, and established a system for disseminating solid
     waste pollution prevention information dissemination to
     the public.  Waste also established a workgroup to
     develop prevention protocols for Superfund and RCRA
     corrective actions, planned and partially funded an in-
     house study on multi-material recycling, and developed
     prevention-oriented Best Demonstrated Available
     Technology (BOAT) policy/guidance for site remediation.

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     o    Environmental Services Division conducted a trash
          evaluation study and has a multi-material recycling
          program in place at the lab.   ESD has also taken
          several measures to minimize  lab waste.

     o    Planning and Management Division strengthened in-house
          recycling in the main office,  led in procuring recycled
          letterhead for the agency, incorporated  pollution
          prevention criteria into strategic planning and budget
          processes, and solicited pollution prevention data from
          federal facilities.

                         LESSONS LEARNED

     The 1990 Strategy also pointed to  a number of areas for
     improvement.

     Too many objectives were included  in the Strategy, resulting
     in an unwieldy document and a daunting list of commitments.
     Many objectives did not strictly fit the definition of
     pollution prevention.

     Many of the objectives reflected ongoing commitments rather
     than innovations.  (These objectives comprise a useful
     catalog of existing prevention-oriented activities.)  Where
     national program mandates and the  individual  initiative of
     dedicated Task Force representatives were not sufficient to
     support objectives, those objectives tended to not be
     completed.  Understandably, managers are motivated to
     support initiatives that are part  of National Program
     commitments, and to provide little or no support to
     initiatives that are not.

     In sum, the successes and areas for improvement in the 1990
     Strategy pointed to important lessons to be incorporated in
     developing the 1991 Strategy.  These lessons  should be
     viewed in the context of how difficult it is  to explicitly
     shift priorities, disinvest in old commitments and invest in
     new projects: in short, to accomplish institutional change.
III. DEVELOPMENT OF THE FISCAL YEAR 1991 STRATEGY

                              GOALS

     In planning the 1991 Strategy, the Task Force and the
     Pollution Prevention Program staff sought to apply the
     lessons learned from the 1990 Strategy.  Five central goals
     were developed to unify the Strategy across media and
     program barriers, and to provide a targeted long-term view
     of what the Region wants to accomplish.  These goals were
     endorsed by the Deputy Regional Administrator:

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     1.    Develop a Pollution Prevention Ethic Within EPA

     2.    Assess State Needs and Coordinate Activities Among
          EPA Region I Programs and With States

     3.    Protect New England's Natural Resources

     4.    Reduce Waste Streams by Changing Plant Processes
          (source reduction and process-oriented recycling)

     5.    Reduce Waste Streams by Influencing Public
          Behavior (demand for products and municipal
          recycling)

Three methods of achieving those goals were given emphasis,
to remind those developing objectives of the range of tools
available:

     1.    Technical Assistance

     2.    Outreach/Publicity

     3.    Compliance/Enforcement

In addition, the new Strategy aimed to improve on the
drawbacks of the 1990 Strategy by:

     reducing the number and length of objectives submitted,
     to make the Strategy a more streamlined and realistic
     document;

     emphasizing innovative projects (including cross-media
     projects) over ongoing national program commitments, no
     matter how few objectives this might result in;

     highlighting iniatives designed to change the way the
     Agency does business toward a prevention orientation;

     including only those objectives which fit the
     definition of pollution prevention; and

     emphasizing objectives which would contribute to long-
     term goals, but which would also produce early,
     tangible successes.

The Deputy Regional Administrator communicated these goals,
methods and principles to Division/Office Directors for use
in assisting their Task Force members in soliciting 1991
objectives from Section and Branch Chiefs and program staff.

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                             RESULTS

     The results of this effort are mixed.   Most of the
     objectives submitted address the five  central goals and
     three primary methods,  but not all adhere to the other
     standards described above.  The reasons for this incomplete
     success lie in persisting institutional barriers too large
     to overcome in a single year.  Rather  than operate without a
     Strategy until these issues are resolved, the Task Force
     decided to perform limited edits and let the Strategy stand.
     The Task Force presented a set of recommendations to the
     Leadership Team for addressing these institutional barriers
     in 1991 and beyond.  The Leadership Team has pledged to
     incorporate the recommendations of the Task Force in the
     process of developing a Strategic Plan for pollution
     prevention for the Region.
IV.  RECOMMENDATIONS

     To accomplish tangible, innovative pollution prevention
     successes, we need to make pollution prevention a priority
     throughout EPA Region I.  The following are necessary first
     steps in making pollution prevention a Region I priority:

     1.   Insure that Pollution Prevention is featured
          prominently in Strategic Planning.

     2.   Educate managers on what pollution prevention is and
          why it should be a priority.

     3.   Secure upper level management commitment to increase
          their involvement in charting the course for pollution
          prevention in the Region.

     4.   Charter a committee of managers to determine the level
          of resources needed to better institutionalize
          pollution prevention in Region I.

     5.   Develop and deliver training for EPA permit writers.
          inspectors, enforcement staff and other personnel to
          provide guidance on how to incorporate pollution
          prevention in daily functions.

     6.   Establish incentives and rewards to encourage staff to
          develop pollution prevention ideas and to recognize
          those in charge of implementing pollution prevention
          projects.

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V.   1991 OBJECTIVES


     GOAL 1:   DEVELOP A POLLUTION PREVENTION ETHIC WITHIN EPA


                      Regional  Administrator


     o    Incorporate pollution prevention into goal setting with
          senior staff at retreats and meetings.
          (Outreach/Publicity)

     o    Encourage senior managers to use internal communication
          mechanisms to disseminate pollution prevention
          messages.  These internal channels include the employee
          newsletter and staff meetings at all levels.
          (Outreach/Publicity)

     o    Involve the new Region I Senior Scientist in an
          advisory capacity on developing Region I pollution
          prevention initiatives.  (Technical Assistance)

     o    The Office of Civil Rights and Urban Affairs will
          collaborate with other Region I Divisions, Offices and
          programs to focus on pollution prevention opportunities
          with the potential to reduce environmental risks which
          particularly affect urban, low income, and minority
          communities.   (Outreach/Publicity)


                         Regional Counsel

     o    Continue to promote work practices that minimize paper
          use and maximize recycling.  (Outreach/Publicity)

     o    Conduct in-house training and cross-program meetings
          concerning opportunities for pollution prevention
          through Environmentally Beneficial Expenditure  (EBE)
          use in enforcement cases.   (Outreach/Publicity)


                      Environmental Services

     o    Continue to provide  pollution prevention-oriented
          technical information to all media operating divisions
          requesting  our technical assistance.   (Technical
          Assistance)

     o    Continue to improve  BSD  facility management by  tracking
          and reducing paper consumption and enhancing our
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comprehensive in-house recycling program. (Technical
Assistance)

Continue to reduce the volume of samples used in
testing, thereby minimizing the amount of chemicals
needed to analyze samples and the volume of waste
generated by testing, and work to substitute less
hazardous products in testing processes.  (Technical
Assistance)
               Water Management

Integrate pollution prevention priorities into Division
activities through discussion at staff meetings,
workshops, and Strategic Planning commitments.
(Outreach/Publicity)

Train permit staff on cross-media inspection and source
reduction referral opportunities.  (Technical
Assistance)
               Waste Management

 (* Also listed under Goal 4.)  Finalize pollution
prevention guidelines for EPA and contractor
involvement at Superfund sites and RCRA Corrective
Action projects.   (Technical Assistance)

 (* Also listed under Goal 4.)  Install a pollution
prevention "checkpoint" in the Superfund review process
prior to signing of Records of Decision for Remedies to
assure consideration of pollution prevention options.
 (Technical Assistance)

Develop pollution  prevention/cross-media inspector
training for Region I RCRA and Superfund inspectors
through the Training Office.   (Outreach/Publicity,
Compliance/Enforcement)

Publicize and promote the use of pollution prevention
enforcement initiatives by RCRA inspectors through
 internal Waste Management Division publications.
 (Outreach/Publicity)

 Implement pollution prevention training for all Waste
Management Division employees through the Training
Office.   (Outreach/Publicity)

Use contractor support to develop educational materials
 on pollution prevention practices (source reduction and

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     recycling) for use within the Region I offices.
     (Outreach/Publicity)

     Develop a Waste Management Division pollution
     prevention bulletin to recognize and promote program-
     specific pollution prevention activities, and to
     provide information on non-programmatic pollution
     prevention activities by Waste Management Division
     staff.  (Outreach/Publicity)

     Promote procurement of products containing recycled
     materials at EPA Region I where possible.
     (Outreach/Publicity)
                Planning and Management

     Conduct a waste stream audit of the three EPA Region I
     facilities, and use the results to recommend
     improvements to the recycling program.  Assist the
     Waste Management Division in conducting the pilot audit
     at the Canal Street offices.  (Technical Assistance)

     Take the lead in helping EPA Region I develop a four
     year Strategic Plan which features pollution prevention
     as a primary objective.  (Outreach/Publicity)

     With the help of a cross-media staff committee, develop
     basic pollution prevention training for EPA Region I
     managers and general staff to implement in FY91.  In
     FY91 or later, also develop pollution prevention
     training for EPA Region I permit writers and
     inspectors, and begin to offer training to states.
     (Outreach/Publicity)

     Coordinate development of and tracking for the Region I
     Pollution Prevention Strategy.  (Technical Assistance)
GOAL 2:   ASSESS STATE NEEDS AND COORDINATE ACTIVITIES AMONG
          EPA REGION I PROGRAMS AND WITH STATES
                    Regional  Counsel

     Share Region I's policies and approaches on the use of
     Environmentally Beneficial Expenditures (EBEs) in case
     settlements with counterpart state enforcement programs
     to ensure consistency, as needed, between state and
     federal enforcement.  (Compliance/Enforcement)
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Government: Relations and Environmental Review

The Government Relations staff, in its outreach and
casework activities, is in frequent contact with
elected officials and their staffs and will take these
opportunities to emphasize EPA's pollution prevention
mission and enlist their support.  (Outreach/Publicity)

The Government Relations Staff will promote pollution
prevention during its review of those items of proposed
state environmental legislation which we have selected
as important to EPA's mission.  (Outreach/Publicity,
Technical Assistance)
            Environmental  Services

Emphasize pollution prevention in technology transfer
to states, consulting firms and others who request our
technical assistance.  (Technical Assistance)

Work with the other Divisions/Offices to assemble a
packet of materials on pollution prevention that staff
can disseminate during inspection visits to industries.
(Outreach/Publicity, Technical Assistance)
               Water Management

Make pollution prevention priorities a part of
oversight and grants.  (Outreach/Publicity)

Review with NEIWPCC and states how to accomplish
pollution prevention goals through new initiatives and
ongoing efforts (such as writing the Best Management
Practices manual and agricultural Best Management
Practices projects).  (Outreach/Publicity)
    Air. Pesticides and Toxics Management

(* Also listed under Goal 4.)  Work with state air
programs to help them develop EPA-required state
standards for existing municipal waste combustors,
encouraging them to incorporate proposed New Source
Performance Standards that require 25% input weight
reduction, which in turn promotes recycling and source
reduction.  Coordinate efforts with the Waste Division.
If feasible, join with states in educating
municipalities and sources on the regulations
developed.  (Technical Assistance)

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(* Also listed under Goal 4.)  Conduct workshops for
state agencies on transportation control, to help them
find ways to reduce mobile source contributions to
ground level ozone pollution.  (Technical Assistance)
               Waste Management

Prepare a compendium of waste minimization activities
in each state to assess state needs and target
increased state/EPA coordination.  (Outreach/Publicity)

Support technology transfer to the states by
distributing waste minimization manuals, and exchanging
information and coordinating activities with New
England Waste Management Officials Association
(NEWMOA).  (Outreach/Publicity)

Hold source reduction and recycling conferences to
assess state needs in solid waste pollution prevention.
(Outreach/Publicity)

Maximize use of Capacity Assurance Plans as a pollution
prevention tool: provide support (strategy review and
plan development assistance) to states to implement
pollution prevention in their Hazardous Waste
Management Master Plans.  (Technical Assistance)

Incorporate pollution prevention goals and objectives
into state RCRA programs and other state federally-
funded programs.  (Technical Assistance)

Examine state grant flexibility, and develop guidance
for writing innovative pollution prevention activities
into state grants.  (Technical Assistance)

Provide states with prototypes for developing pollution
prevention regulations.  (Technical Assistance)

Conduct a pilot project in Connecticut under the EPA
CIS program to promote exchange of pollution prevention
information and coordination of enforcement efforts
among media programs.   (Technical Assistance,
Compliance/Enforcement)
           Planning and Management

Involve the Region I states in the Strategic Planning
process to learn of their needs and concerns.
(Outreach/Publicity)

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     Encourage states (primarily Massachusetts and Maine at
     first) to incorporate pollution prevention into their
     cross-media enforcement and compliance systems.
     (Outreach/Publicity)

     Hold a second meeting of all Region I state pollution
     prevention contacts to discuss the FY91 pollution
     prevention grants application process, and issues in
     developing pollution prevention programs in each state.
     (Outreach/Publicity)
GOAL 3:   PROTECT NEW ENGLAND'S NATURAL RESOURCES
     Government Relations and Environmental Review

     During National Environmental Policy Act (NEPA) review
     of environmental impact statements (EISs) on proposed
     federal actions significantly affecting the
     environment, the Environmental Review staff will
     advocate that pollution avoidance opportunities be
     fully disclosed in the EIS and be adopted by the
     proposing agency as the least environmentally damaging
     alternative and as mitigation measures.
     (Compliance/Enforcement)
                    Water Management

Introductory Comment;

In contrast to treatment and remediation, resource
protection measures are defined as pollution prevention in
that they:

     require anticipatory, proactive thinking and action
     prior to establishing a potential source of pollution;

     insure that protecting one resource does not lead to
     shifting pollutants to another resource; and

     use resource protection demonstration projects as
     models for protecting other resources elsewhere.

Resource protection differs qualitatively from many other
types of pollution prevention initiatives (such as
industrial process change), in that it links preventive
measures to the resource to be protected rather than to the
potential source of pollution.

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Screen and predesignate critical wetlands for
protection under 404(c) of the Clean Water Act: at
least one wetland in the Lower Merrimack Basin and one
in the Lake Champlain Basin.  This will demonstrate
opportunities to develop local consensus, and publicize
EPA's intent to protect critical wetlands by heading
off development proposals, rather than merely reacting
to permit applications.  (Technical Assistance,
Outreach/Publicity, Compliance/Enforcement)

Apply Maine's phosphorous load methodology to local
growth management programs mandated by state
legislation, including zoning, buffers and conservation
areas to protect lakes and estuaries from cumulative
impacts of future development.  With Maine DEP and
other involved groups, provide intensive technical
assistance and public education to five towns in the
Sebago Lake Watershed.  Apply a similar approach for
nitrogen and stormwater load allocations to localities
in the Casco Bay watershed.   (Technical Assistance)

Apply preliminary nitrogen load allocation from
interdisciplinary Waquoit Bay modeling to the newly
empowered Cape Cod Commission's designation of Areas
for Critical Protection.  Similarly, apply nutrient
loadings to assist Buzzards Bay towns to protect
nitrogen-sensitive embayments.  (Technical Assistance)

Assist the New Hampshire DES in implementing a
Merrimack River corridor protection program to protect
the river from future nonpoint source pollution.  This
will include working with the Nashua Regional Planning
Commission to help the affected towns enact the
appropriate ordinances to govern the location, siting,
design and Best Management Practices of future
development.  (Technical Assistance)

Assist states in developing watershed management
programs to prevent nonpoint source pollution of
drinking water supplies.  In Massachusetts,  the
programs will center on the Quabbin-Wachusetts as well
as several smaller watersheds; in Maine, they will be
done for the Lake Sebago watershed.  Land use planning,
zoning and acquisition will limit future development
and avert or reduce costly infiltration investments.
(Technical Assistance)

Develop prototype urban stormwater management programs,
with four pilot communities along the Merrimack, to
demonstrate how to site and design new malls and
residential developments to minimize future urban

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stormwater pollution.  NPDES provides regulatory
backup.  (Technical Assistance, Compliance/Enforcement)

Work with RI DEM/DOT and the Federal Highway
Administration (FHwA) to revise federal/state DOT
regulations to design highway projects to prevent
pollution due to infiltration and runoff.  (Technical
Assistance)

Take steps toward implementing wellhead protection
programs in each state: 1) conduct workshops on local
management tools; 2) develop "train the trainers"
module for use by states and Regional Planning
Commissions; 3) provide guidance documents and
brochures for light industries; 4) increase the number
of land use inventories, delineations and local
management regulations; and 5) require water
conservation programs.  (Technical Assistance,
Outreach/Publicity)

Condition grants to remedy existing pollution  (such as
Clean Lakes and Nonpoint Source Control grants), on a
requirement that the grantee and associated state and
local agencies develop measures so that future
development will not generate additional pollution.
(Compliance/Enforcement)

Work with the states to expand CIS systems to assist
localities to identify environmental considerations in
growth management.   (Technical Assistance)
               Waste Management

Coordinate and expand the use of Geographic Information
Systems  (CIS) to target pollution prevention.
Participate  in multi-media pollution prevention
activities in sensitive areas.  Work with the states on
CIS projects, applying resources to the highest
priority areas.   (Technical Assistance)
            Planning  and Management

Continue to develop  the Geographic Information  System
capability  for use in  identifying and protecting
sensitive resources.   (Technical Assistance)
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GOAL 4:   REDUCE WASTE STREAMS BY CHANGING PLANT PROCESSES
          (source reduction and process-oriented recycling)
                   Regional Counsel

     With the media Divisions,  develop methods for
     encouraging use of EBEs in enforcement case
     settlements.   (Compliance/Enforcement)

     With the media Divisions,  develop lists of types of
     EBEs that are promising and acceptable for use in
     various types of enforcement case settlements.
     (Compliance/Enforcement)
                 Environmental Services

     Communicate pollution prevention options to industries
     during the course of regular inspections or upon
     request for assistance in reducing energy or materials
     waste.  (Outreach/Publicity, Technical Assistance)

     Request that technical assistance contractors use
     minimum sample collection volumes.   (Technical
     Assistance)
                   Water Management

     Develop a workplan for and oversee a Headquarters grant
     (under the National Industrial Pollution Effluent
     Guidelines Project) to demonstrate how to encourage
     changes in industrial processes and products to prevent
     pollution from high-tech metal finishing industries on
     the Merrimack River.   (Technical Assistance,
     Compliance/Enforcement)

     Assist Connecticut Hazardous Waste Technical Assistance
     Program (ConnTAP) in establishing a site visit program
     to help industries in coastal communities identify
     opportunities to generate less hazardous waste.
     (Technical Assistance)

     Work with Regional Counsel and other Offices/Divisions
     to develop Environmentally Beneficial Expenditure
     strategies, and demonstrate through selected permits.
     (Compliance/Enforcement)

     Examine the possibility of directing fines from NPDES
     violations to a fund dedicated for pollution prevention
     projects.   Identify regulatory/statutory opportunities

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and barriers; recommend changes.
(Compliance/Enforcement)

Integrate water and energy conservation into technical
guidance in the NPDES permit program and selected
wastewater treatment permits.   (Compliance/Enforcement)

Organize workshops in each state to provide technical
guidance to wastewater treatment operators and
dischargers on building source reduction into .
pretreatment programs.  (Technical Assistance,
Outreach/Publicity)

Assign an Intergovenmental Personnel Act (IPA) staff
person to apply the Massachusetts Blackstone Project
experience to the Merrimack deomonstration project and
to EPA permit and pretreatment programs.  (Technical
Assistance, Compliance/Enforcement)
    Air. Pesticides and Toxics Management

In evaluating DEP's recommendations for Reasonably
Available Control Technology (RACT) plan approval on
eight Massachusetts industries (all emitters of ground
level ozone forming chemicals),  consider recommending
that DEP require pollution prevention measures in the
RACT plans.  Plant visits and reviews of technical
opportunities will be used to determine whether to
recommend pollution prevention measures, as well as
which measures to propose.  (Technical Assistance,
Compliance/Enforcement)

With Headquarters Global Change Division and numerous
industry sponsors, hold one or more Ozone Layer
Protection Workshops for the metal plating and
electronics industries to provide these users of ozone-
depleting chemicals with technical information on
process and materials substitution and recycling.
(Outreach/Publicity, Technical Assistance)

In cooperation with the Office of Regional Counsel,
continue to expand the use of Environmentally
Beneficial Expenditures in settlement negotiations.
(Compliance/Enforcement)
               Waste Management

Distribute information on waste minimization to
industry (distribute waste minimization manuals,
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          participate in forums, etc).  (Technical Assistance,
          Outreach/Publicity)

          Select a sample of industries in especially sensitive
          environments to receive special assistance from EPA in
          instituting waste minimization programs.  (Technical
          Assistance, Outreach/Publicity)

          Develop guidance for writing pollution prevention into
          RCRA permits.  (Compliance/Enforcement)

          Incorporate pollution prevention in settlements and
          enforcement initiatives through consultation with ORC
          and RCRA inspectors.  (Compliance/Enforcement)

          (* Also listed under Goal 1.)  Evaluate contractors'
          and responsible parties' success in adhering to
          pollution prevention guidelines for work at Superfund
          sites and RCRA Corrective Action projects.
          (Compliance/Enforcement)

          (* Also listed under Goal 1.)  Install a pollution
          prevention "checkpoint" in the Superfund review process
          prior to signing of Records of Decision for Remedies to
          assure consideration of pollution prevention options.
          (Compliance/Enforcement)
                     Planning and Management

          Emphasize pollution prevention in a conference for
          Federal Facilities in Region I, including presenting
          facility success stories.  (Outreach/Publicity)
GOAL 5:   REDUCE WASTE STREAMS BY INFLUENCING PUBLIC BEHAVIOR
          (demand for products and municipal recycling)
                      Regional Administrator

          The Regional Administrator and Deputy Regional
          Administrator will make pollution prevention a
          prominent theme in speaking engagements, media
          relations, and written pieces such as articles and op-
          ed statements.  (Outreach/Publicity)

          The Regional Administrator will co-chair the New
          England Pollution Prevention Council.
          (Outreach/Publicity)
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     The annual Environmental Merit Awards will be expanded
     to include special awards for pollution prevention.
     (Outreach/Publicity)

     The Office of Civil Rights and Urban Affairs will
     include information on pollution prevention in ongoing
     outreach efforts in urban, low income and minority
     communities.  (Outreach/Publicity)
                    Public Affairs

o    Write articles on pollution prevention for daily and
     weekly newspapers.  (Outreach/Publicity)

o    Include the pollution prevention message in all press
     releases.  (Outreach/Publicity)

o    Continue emphasizing the pollution prevention message
     in the Adopt-A-School program.   (Outreach/Publicity)

o    Set pollution prevention as the theme of the annual
     essay and poem and poster contests for schoolchildren.
     (Outreach/Publicity)

o    Offer information about pollution prevention at a
     variety of symposiums,  conferences and forums.
     (Outreach/Publicity)

o    Emphasize pollution prevention in EPA 20th Birthday
     activities.  (Outreach/Publicity)
                   Water Management

     In cooperation with a Headquarters grant, develop
     information on product lifecycles and substitution
     options (results will be publicized in the Merrimack
     and Blackstone initiatives in FY92).   (Technical
     Assistance)

     Work with the Headquarters Dioxin Task Force to
     identify opportunities to substitute paper products
     requiring less bleaching.  If feasible,  work with
     others to develop outreach/public education programs.
     (Technical Assistance)
         Air. Pesticides and Toxics Management

     (* Item 3 is also listed under Goal 2.)   Use
     transportation control measures to reduce mobile source

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contributions to ground level ozone pollution: 1)
assist in the development of SIP revisions for the
Cambridge and Boston parking freezes; 2)  review the
final Environmental Impact Statement for the Depressed
Central Artery/Third Harbor Tunnel project in Boston;
3) conduct workshops for state agencies on
transportation control; and 4) provide assistance to
the New England Pollution Prevention Council in
implementing their automobile pollution prevention
projects.  The emphasis will be on pressing for
developing less polluting transportation systems.
(Technical Assistance)

(* Also listed under Goal 2.)  Encourage state air
programs to incorporate proposed New Source Performance
Standards that require 25% input weight reduction,
which in turn promotes recycling and source reduction.
If feasible, join with states in educating
municipalities and sources on the regulations
developed.  (Technical Assistance)

               Waste Management

Hold conferences to encourage source reduction and
procurement of products containing recycled materials
by government officials  (federal, state and local) and
the general public.   (Outreach/Publicity)

Support market development for recycled materials by
conducting market studies.   (Technical Assistance)

Promote procurement by contractors and government
agencies of products  containing recycled materials;
evaluate progress made.  Evaluate all contracts for
inclusion of recycled product procurement language.
(Outreach/Publicity,  Technical Assistance)

Gather and disseminate information on source  reduction
and recycling to the  public, and distribute school
curriculum packets developed by the  Solid Waste
Librarian.   (Outreach/Publicity)

The Solid Waste Program, in  implementing the  Agenda  for
Action, will continue to provide grants and other
support  for source reduction and recycling efforts.
(Outreach/Publicity,  Technical Assistance)
            Planning and Management

Coordinate  the  activities of the New England  Pollution
Prevention  Council, and assist the Council  in

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developing pollution prevention activities in its
primary focus area, the transportation sector.
(Outreach/Publicity)

The Region I Library will continue to disseminate
information on pollution prevention in response to
increasing public demand, and begin a new section on
wetland protection.  (Outreach/Publicity)

Increase Boston Federal Executive Board involvement in
recycling, including designating federal employees to
promote recycling within their agencies.
(Outreach/Publicity)
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