U.S. ENVIRONMENTAL PROTECTION AGENCY REGION I POLLUTION PREVENTION STRATEGY FISCAL YEAR 1992 Draft--12/6/91 ------- OVERVIEW This document represents EPA Region I's third annual effort to outline its plans for implementing pollution prevention during the fiscal year. Last year's (1991) Strategy represented a major effort to learn from the strengths and weaknesses of Region I's first Strategy (1990), and the resulting document was better organized and truer to the meaning of pollution prevention. The aim of the 1992 Strategy is somewhat different: it is an update or interim document designed to continue the themes and improvements of the 1991 Strategy, until the Division/Office Pollution Prevention Workplans for FY93 now in progress under Strategic Planning are in place. CONTENTS I. Background II. Summary of the 1991 Strategy III. Development of the 1992 Strategy IV. 1992 Objectives I. BACKGROUND 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. In January 1990, the Pollution Prevention Act was signed into law, providing a statutory mandate to support the grants and other programs already underway in the Pollution Prevention Program. In January 1991, the Headquarters Pollution Prevention Program submitted a National Pollution Prevention Strategy to Congress, outlining the Industrial Toxics (33/50) Project and calling for the development of detailed strategies for other sectors in addition to Industry. Sector strategies for Energy/Transportation, Consumers, Federal Agencies and Agriculture are currently in various stages of development. 1 ------- DEFINITION The national Pollution Prevention Program has defined pollution prevention 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. Pollution avoidance, source reduction, and closed-loop recycling are 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. II. SUMMARY OF THE FISCAL YEAR 1991 STRATEGY GOALS In planning the 1991 Strategy, the cross-program Pollution Prevention Task Force and the Pollution Prevention Program staff sought to apply the lessons learned from the 1990 Strategy. We developed five central goals to unify the Strategy across media and program barriers, and to provide a targeted long-term view of what the Region wants to accomplish: 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; highlighting initiatives 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. Further, the FY91 Strategy attempted to deal with the recurring problem of shifting program priorities and abandoned or incomplete pollution prevention objectives by listing several recommendations aimed at making pollution prevention a higher priority throughout EPA Region I. Several of these recommendations were implemented, while others are in progress: 1. Insure that Pollution Prevention is featured prominently in Strategic Planning. (Accomplished.) 2. Educate managers on what pollution prevention is and why it should be a priority. (Accomplished through the Pollution Prevention Workshop for Managers, July/August 1991.) 3. Secure upper level management commitment to increase their involvement in charting the course for pollution prevention in the ------- Region. (Managers' performance standards will be revised to include pollution prevention.) 4. Charter a committee of managers to determine the level of resources needed to better institutionalize pollution prevention in Region I. (Encompassed by Strategic Planning.) 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. (Training for Workplan Writers accomplished; training for general staff planned for January/February 1992; other training will depend on requests resulting from Workplans.) 6. Establish incentives and rewards to encourage staff to develop pollution prevention ideas and to recognize those in charge of implementing pollution prevention projects. (To be accomplished through the process and products of Workplan Writing teams.) RESULTS The results of this effort to improve the Strategy were generally positive, but as in 1990, organizational and other barriers limited the success of the 1991 Strategy. The five central goals and three primary methods emphasized seemed to help contributors to the Strategy consider more fully the range of pollution prevention activities applicable to their organizations. Many excellent activities were proposed and much was accomplished (for more information on accomplishments, see the mid-year Progress Report). However, as in the past, conflicts with national program and other priorities frequently caused pollution prevention projects to go partly or wholly by the wayside. It was often only through the energy and dedication of the Task Force that commitments were carried out. Both the prominent role of pollution prevention in the Strategic Planning process and the Pollution Prevention Workshop for Managers undoubtedly contributed significantly to Regional awareness and action on pollution prevention. III. DEVELOPMENT OF THE FISCAL YEAR 1992 STRATEGY As in previous years, the Pollution Prevention Task Force members solicited updates, deletions and new items from members of their organization for inclusion in the 1992 Strategy, and obtained their Division Directors' approval of the ------- revisions. However, as stated above, due to the concurrent intensive effort under Strategic Planning to develop Pollution Prevention Workplans in each Division and Office for FY93, the emphasis was on updating the Strategy as an interim document rather than on overhauling it. The resulting document was presented to the Leadership Team for approval. IV. 1992 OBJECTIVES NOTE: Initiatives may be listed/formatted slightly differently across Divisions, according to the notation style preferred by those individuals. Names of persons responsible for carrying out initiatives are not noted here, both because that information was not provided consistently across Divisions, and to protect the privacy of the individuals involved. GOAL1: DEVELOP A POLLUTION PREVENTION ETHIC WITHIN EPA Regional Counsel o Continue to promote work practices that minimize paper use and maximize recycling. o Conduct in-house training and cross-program meetings concerning opportunities for pollution prevention through Supplemental Environmental Project (SEP) use in enforcement cases. Environmental Services o Encourage Environmental Service Division-wide discussions of pollution prevention by making pollution prevention this year's theme of the monthly all-employee meetings, First Thursday. o Continue to provide pollution prevention-oriented technical information to all media operating divisions requesting our technical assistance. o Continue to improve Environmental Service Division facility management by tracking and reducing paper consumption and enhancing our comprehensive in-house recycling program. ------- 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. Substitute less hazardous products in testing processes when possible. Develop methods to recycle hazardous products in cases where substitution is not possible (e.g., where the analytical method requires using the product). Support the Region I Pollution Prevention Key Priority Area (under Strategic Planning) as needed. Water Management Organize multi-media training sessions for EPA & State Permits & Compliance staff on cross-media inspection and source reduction referral opportunities. Discuss initiatives and progress on pollution prevention at staff meetings and schedule presentations at two of the Waste Division's monthly forums, open to the entire Region. (** Priority) Develop a FY93 Pollution Prevention Workplan for Region I Strategic Plan, involving all programs. Waste Management Continued Objectives: o As part of the Pollution Prevention Training Committee, plan and deliver pollution prevention awareness training for general audiences, and for technical/professional staff on pollution prevention in inspections, enforcement, and permitting. o Use contractor support to develop educational materials on source reduction and recycling for use within Region I offices. o Develop a work plan and evaluate EPA's status with respect to recycled products procurement. Additions: o Follow up on use of the Multi-Media Inspector Checklist and Multi-Media Enforcement Tracking System (METS) by Waste Division inspectors. ------- Through brief, weekly Local Area Network (LAN) bulletins, promote Waste Division pollution prevention initiatives, Resource Conservation and Recovery Act (RCRA) Inspection and Enforcement initiatives, program-specific activities, and non-program activities. Distribute Headquarters policies on Waste Minimization for RCRA Inspectors and on Supplemental Environmental Projects (SEPs) at Division-wide Enforcement meetings. Brainstorm opportunities for and barriers to policy implementation with technical staff. Participate in a team that will develop a work plan for conducting 15% pollution prevention-related work during FY93, and on a workgroup that will review the work plans. Planning and Management o Take the lead in insuring that several steps in the pollution prevention Key Priority Area (KPA) Action Plan under Strategic Planning are accomplished: finalize guidance and criteria for developing Division/Office workplans; train workplan writers; review draft workplans; and prepare a summary of the KPA process/outcome. o With the help of a cross-media staff committee, develop and deliver a basic pollution prevention orientation course for all EPA general staff. Also, develop and deliver pollution prevention Workplan Writer training (see above). Based on need and interest expressed by Divisions and Offices in their pollution prevention Workplans, develop further pollution prevention training (e.g., for permit writers and inspectors), and begin to offer training to states. o Coordinate development of the Region I Pollution Prevention Strategy; also coordinate periodic updates and issue progress reports. o Continue to chair the Region I pollution prevention Task Force, and support the efforts of the Task Force's pollution prevention Enforcement Workgroup. o Participate on the national EPA Executive Committee for Pollution Prevention, the working group for the Pollution Prevention Policy Council (see below). The goal of both the Executive Committee and the Policy Council is to support the institutionalization of Pollution Prevention in all EPA activities. ------- Support RA/DRA in their membership on the national Pollution Prevention Policy Council. Implement actions as recommended in the waste stream audit of the three EPA regional facilities. The Recycling Committee will serve as one of the key elements to enhance the recycling objectives. 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 Supplemental Environmental Projects (SEPs) in case settlements with counterpart state enforcement programs to ensure consistency, as needed, between state and federal enforcement. Environmental Services Emphasize pollution prevention in technology transfer to states, consulting firms and others who request our technical assistance. Work with other Divisions/Offices to assemble a packet of materials on pollution prevention that staff can disseminate during inspections of industries. Water Management o (** Priority) Emphasize pollution prevention in Regional grant guidance and conditions; e.g., Sections 106, 319, 320 and 314 of the Clean Water Act. Give added weight in ranking competitive projects. Condition grants for mitigation to require applicants to develop land use plans, regulations, and Best Management Practices to prevent nonpoint source pollution from potential development and land use changes. Extend these conditions to grants for nonpoint source control, wetland and estuarine management, and wellhead protection. o Work with Northeast Waste Management Officials Association and the Massachusetts Office of Technical Assistance to conduct workshops for 8 ------- local, state and EPA pretreatment officials through the Interstate agencies' Joint Environmental Training Coordinating Committee. Air. Pesticides and Toxics Management o Provide Assistance for New Pesticides Initiatives. Work with states on EPA's pollution prevention goals through implementation of the new pesticides initiatives for the protection of groundwater and endangered species. Provide technical and grant assistance and oversight to states developing Pesticides in Ground Water Management Plans and delivery mechanisms for distribution of bulletins and other material related to the protection of endangered species. Continue to encourage the use of geographic information systems by states to target groundwater resources and endangered species which may be affected by pesticide use. o State Meetings. In semi-annual meetings with the USDA Cooperative Extension Services and State Pesticide Lead Agencies, discuss pollution prevention strategies such as integrated pest management (IPM) and sustainable agriculture for major Region I commodities. Review state certification programs for pesticide applicators to assure that training on pollution prevention is included in each state as relevant and practicable (groundwater, endangered species, IPM, etc.). Waste Management Continued Objectives: o To assess state pollution prevention program needs, support technology transfer, coordinate EPA/state activities, and develop programs for potential funding, continue to attend the Northeast Waste Management Officials Association's (NEWMOA) Multi-Media Pollution Prevention (NEMPP) roundtable meetings and work with NEWMOA staff. o Conduct outreach activities with state agencies to promote recycled products procurement under EPA Guidelines, and evaluate their progress in this area. ------- o Using funds provided by the Waste Management Division, NEWMOA will demonstrate different education methods for addressing industrial source reduction as a means of assuring hazardous waste disposal capacity in two Region I states. o Review state reports provided by NEWMOA on measuring program effectiveness, review RCRA Implementation Plan Flexibility, and initiate meetings to give states with established pollution prevention programs credit for conducting pollution prevention work under their implementation plans. o Attend national pollution prevention meeting to participate in discussion of state grant flexibility and other state grant issues. Develop guidance on use of Grant-Flex to allow states to conduct pollution prevention work under RCRA base grants. o Conduct projects under the Chesprocott Initiative, including a survey of businesses in the four-town Chesprocott Health District to target industries for development and dissemination of education materials regarding waste audits and source reduction. Consider developing an inspection program with local officials. Additions: o A Waste Management Division representative will work at NEWMOA offices on a detail for a six month period to coordinate EPA/state activities, increase knowledge of state programs and needs, and facilitate information sharing between northeastern states on pollution prevention program operation. o Using funds provided by the Waste Management Division, Connecticut Technical Assistance Program (ConnTAP) will conduct pollution prevention site assessments and follow-up visits at facilities in Connecticut discharging to Long Island Sound. o Oversee implementation of Waste Capacity Assurance Plan (WasteCAP) initiatives in Maine, New Hampshire, and Vermont, for which funds were provided by the Waste Management Division. This project will use source reduction and recycling as methods of assuring capacity for solid waste disposal. Planning and Management Support Region I state pollution prevention programs to help them prepare competitive applications for the FY92 Pollution Prevention Incentives for 10 ------- States grants application process. Keep states informed of other available pollution prevention grant monies as they appear. Working with the pollution prevention program in Headquarters and the Region I programs, pursue a more streamlined system for awarding grant funds under various authorities to states for pollution prevention activities. Continue to publish the Pollution Prevention Bulletin, to keep the states and other interested parties up-to-date on pollution prevention news from EPA Region I, EPA Headquarters, and Region I states. GOAL 3: PROTECT NEW ENGLAND'S NATURAL RESOURCES Water Management A. Assist States and localities to screen and designate critical resources; build consensus re: protection. o (** Priority) Continue advance wetlands identification and predesignation studies to supply local officials with information to make more environmentally sound land use decisions. Map wetlands in the Merrimack Basin, identify the most important regional wetland systems and assist States and localities to protect these through permits and ordinances. Use Geographic Information Systems (CIS) and local information & Heritage Program inventories. o Continue to work with the Information Management Branch and Waste Management Division to acquire and digitize location information on critical resources and pollution sources both regionwide (very limited) and for pilot areas for land use decision-makers. Expanded CIS coverage will assist localities to identify environmental constraints to guide development to protect critical resources and avert future nonpoint source pollution. Target Prime Wetlands (Merrimack Initiative), Wellhead Protection Areas, Water Supplies, Waquoit Bay, Buzzards Bay, Long Island Sound and Casco Bay. B. Develop and apply load allocations, carrying capacity and "build out" analyses to provide States and localities tools to evaluate environmental impacts of development scenarios for informed growth management. 11 ------- o (** Priority) The Waquoit Bay Land-Margin Ecosystems Research Project (LMER) will continue to model nitrogen loadings to predict impacts of land use changes and nutrient input on estuarine water quality. The Cape Cod Commission will apply models in the designation of Districts of Critical Planning Concern. This approach will be adaptable to other localities affected by nutrient enrichment for making environmentally sound land-use decisions. The four-year interagency project involves: EPA, $200K; NSF, $218K; NOAA, $100K (per year); as well as a University Consortium, including the Woods Hole Oceanographic Institute. o The Buzzards Bay National Estuarine Project will refine and apply nitrogen overlay district approach (adopted by Buttermilk Bay localities) to two other embayments of Buzzards Bay threatened with eutrophication from future development unless careful planning and zoning are done in advance. o Provide financial and technical assistance to strengthen Maine Department of Environmental Protection technical assistance and plan review to help towns consider phosphorous loading limits in their growth management plans and ordinances, required under State Growth Management Legislation. Target towns in priority watersheds (e.g., Casco Bay and Lake Sebago). C. Assist States and localities to develop land use policies and ordinances to protect critical resources and nonpoint runoff and infiltration. o The Lower Merrimack River Corridor Project, through a grant to the New Hampshire Department of Environmental Services and the Nashua Regional Planning Council, has helped four localities (including Nashua) to develop ordinances for shoreland protection, wetlands protection, aquifer protection and erosion and sediment control. The project has established a lay monitoring program. The project will continue to assist the towns in presenting proposed ordinances to town meetings next spring. o Provide consultant assistance to identify stormwater sources and impacts as basis for prospective preventive measures to be developed by (a) four Merrimack River towns in Massachusetts and for (b) three watersheds into Harraseeket River, tributary to Casco Bay. Towns will develop ordinances for advance location, siting and design and Best Management Practices to avert urban stormwater pollution in developing as well as urbanized areas. 12 ------- (** Priority) Work with USDA and State Water Quality & Agricultural agencies to demonstrate innovative integrated pesticide & nutrient management systems, using competitive pollution prevention funds. Target several critical & interested farms in priority watershed(s). Evaluate environmental effectiveness and socio-economic feasibility, involving Land Grant Colleges through the Cooperative Extension Service. (** Priority) Encourage the Federal Highway Administration to integrate air and water quality and wetlands/ecosystem protection into the earliest stages of corridor planning, location, siting and design of transportation systems. Target Rhode Island Department of Transportation (DOT) and Department of Environmental Management as demonstrations. Expand upon past Rhode Island efforts (FY90-91) to build stormwater Best Management Practices into a DOT design for a specific highway alignment. (** Priority) Work with States and public water utilities regulated under the Safe Drinking Water Act (SDWA) to ensure effective implementation of watershed control programs. Under the Surface Water Treatment Rule (SDWA), States must determine by 12/31/91 that a water system either: (1) has adequate filtration or, to avoid filtration, (2) is implementing a successful watershed program that meets drinking water quality requirements (SDWA). Preventive watershed programs minimize health and ecological risk; they may avert or reduce the need to construct and operate costly filtration works. Even if water is treated, preventive watershed management programs are needed to reduce the potential for pollutants that are not handled by filtration from entering water supplies. Continue technical assistance and funding to states for state-specific education materials and workshops to implement EPA-approved State Wellhead Protection Programs. Waste Management Continued objective: o Under the revised Pollution Prevention Pit Stops proposal (if funded), the Waste Management Division will provide information on hazardous waste minimization techniques specifically for auto repair facilities in geographically sensitive areas. Additionally, the Underground Storage Tank Office will use 13 ------- a GIS-based targeting scheme to prioritize its activities in the geographic area chosen. Planning and Management The Public Water Supply Location Project is continuing to locate all public water well in Region 1. CIS staff are working with the field contractor who completed data collection for Rhode Island (approximately 500 wells) and New Hampshire (approximately 3000 wells). The latitude/longitude data is being stored in the Region 1 Geographic Information System (GIS) and will be critical for pollution prevention, risk assessment and other analyses with significant spatial components. The contractor is using Global Positioning System technology to measure well locations in the field. GOAL 4: REDUCE WASTE STREAMS BY CHANGING PLANT PROCESSES (source reduction and process-oriented recycling) Regional Counsel o With the media Divisions, develop methods for encouraging use of SEPs in enforcement case settlements. o Develop database recording information about SEPs that have been successfully incorporated into various types of enforcement case settlements. Environmental Services Communicate pollution prevention options to industries during the course of regular inspections or upon request for assistance in reducing energy use or materials waste. Request that technical assistance contractors use minimum sample collection volumes. Water Management 14 ------- A. Assist States to develop multimedia inspection and technical assistance programs to encourage process change. o (** Priority) Provide oversight and assist Massachusetts and New Hampshire to carry out joint workplan for Merrimack River pilot project of National Industrial Effluent Guidelines pollution prevention Project). FY92 work will: (1) screen critical waters and industries (coordinated with Merrimack Initiative); (2) conduct joint workshops; (3) provide technical assistance; and (4) coordinate with the National Project. FY91 & 92 funds total $240K. o Continue to assist coastal industries, as part of the Long Island Sound National Estuary project and Waste Management program. The Near Coastal Waters (NCW) Program awarded $62,000 and Waste Management Division $20,000 to Connecticut Hazardous Waste Management Service's Technical Assistance Program (ConnTAP) for a "Pollution Prevention Site Assessments for Coastal Areas" project. The project is to help industry to reduce its hazardous waste generation and volume and the toxicity of wastewater dischargers, thereby improving water quality in Long Island Sound. o Continue to work with trade associations and state and local organizations to develop distribution strategies for the brochures publicizing findings of the Light Industry Project (ground water protection for the auto repair and dry cleaning industries). o (** Priority) Oversee a competitive grant of $100,000 under National Municipal Wastewater Pollution Prevention Project to provide intensive technical assistance to a major Massachusetts Wastewater Treatment District on industrial source reduction opportunities. A consultant will assist to build specific source reduction opportunities into industrial pretreatment programs. B. Redirect financing toward source reduction and pollution prevention. o Suggest further exploration into the feasibility of a dedicated pollution prevention fund from fines, recognizing problems. o Participate in demonstrations of Supplemental Environmental Projects through the Pollution Prevention Task Force workgroup chaired by Regional Counsel. Air. Pesticides and Toxics Management 15 ------- o Use of Pollution Prevention Checklist in conjunction with compliance inspections. Pesticides and Toxic Substances Branch inspectors will run through the pollution prevention checklist at facilities that use chemicals in the course of their business, taking the opportunity to identify source reduction opportunities as they are apparent and appropriate. After a pilot period of 6 months, we will compile a report concerning company reactions with suggestions for continuing, changing or ending the pilot. There may be opportunity to expand the program to Toxic Substances Control Act (TSCA) state grantees; however, involvement would be limited to PCB programs, and only a subset of those inspections would be relevant. o Use of Pollution Prevention Checklist in conjunction with cold calls of chemical using industry. Pesticides and Toxic Substances Branch compliance staff will cold call industry from a master calling list and run through the pollution prevention checklist by phone. It is anticipated that a modest investment in time by compliance staff may result in a significant number of companies being contacted and introduced to pollution prevention through the checklist questions. After a pilot period of 6 months, we will compile a report concerning company reactions with suggestions for continuing, changing or ending the pilot. o Enforcement Settlements. The TSCA, EPCRA and FIFRA programs will continue to introduce the concept of SEPs into every settlement discussion, and in particular to encourage respondents to develop SEP projects related to our pollution prevention goals. SEPs are tracked both regionally and through the national FIFRA/TSCA tracking system (FTTS). o Core TSCA Outreach Workshops. The Toxic Substances Control Section intends to conduct two workshops for chemical manufacturers, importers and distributors on the requirements of the Toxic Substances Control Act (TSCA). A portion of the workshop will be devoted to explaining and emphasizing new Agency requirements regarding consideration of comparative risk assessment and pollution prevention in the manufacture of new chemical substances. In adding this requirement to the premanufacture notification form, the Agency intends to encourage industry to minimize their use of more toxic new chemicals when a less toxic substitute may be available. o Develop and Implement a Consolidated EPCRA-33/50-Pollution Prevention Outreach Strategy. The Toxics and Radiation Assessment Section will develop and implement a consolidated strategy of technical assistance and outreach to industry that incorporates the 33/50 program, the EPCRA Section 313 reporting requirements, and any additional workshops on ozone 16 ------- layer protection. All of these programs include elements of pollution prevention as discussed below: A. 33/50. The goal of the program is to encourage voluntary reductions in the release of 17 targeted chemicals through pollution prevention. Elements of the plan may include the following: meetings with particular companies who have committed to the program to document and publicize their successes and determine the need for additional technical assistance; pollution prevention/33/50 workshops similar to the regional one organized in August; follow-up mailings to companies to provide them with additional information about the program and EPA or state pollution prevention resources. B. EPCRA. Because the EPCRA reporting requirements this year incorporate the new pollution prevention reporting elements, outreach to industry about this program overlaps considerably with the goals of the pollution prevention program. Currents plans include holding 8 or 9 workshops for industry between March and July. The agenda for these workshops would focus on the pollution prevention reporting elements as well as general pollution prevention technical resources. C. Ozone Layer Protection. In FY91, the Division organized two successful workshops for industry on ozone layer protection, focusing on providing technical information on the use of alternatives to CFC- 113 and methyl chloroform. As part of this outreach strategy, the Division will evaluate the need to organize another such conference in September or October of 1992. Considerations include available resources, evaluation of the past two conferences, and the perceived need for another conference by key state and industry representatives. A decision will likely be made in December of 1991. Implement the Clean Air Act's Ozone Non-Attainment Provisions Emphasizing Pollution Prevention When Possible. A summary of this work is provided below: A. Air Division staff will work with states on the development of regulations for Control Technology Guideline (CTG) industrial categories. Many sources will comply with these requirements through the use of pollution prevention measures such as use of low VOC solvents. B. Sources for which there are no CTGs will be required to study ways to reduce their emissions and then propose control technologies. Many of these proposals will include pollution prevention measures. 17 ------- Failure to propose an adequate plan will trigger automatic controls on that facility. These controls will either be add-on controls or pollution prevention. C. Once control regulations have been adopted by the States, owners of subject facilities will be sending in VOC compliance plans. Air Division staff will attempt to help the states impose work practice standards, coating/solvent reformulations, coating/solvent eliminations, coating/solvent substitutions and/or add-on controls to ensure that each source is reducing its VOC emissions, wherever possible. D. Air Division staff have begun conducting industrial surveys of facilities that are likely to be subject to a non-CTG type of regulation. After completion of source-specific data gathering, staff will begin to assess what can be done and what should be investigated in order to reduce VOC emissions. Options that are examined are (1) end-of-pipe treatment, (2) raw material changes, (3) process changes, (4) a discussion of that facility's Waste Minimization Plans, and (5) a review of what similar companies (competitors) are doing. The results are then provided to the state. E. One type of non-CTG industry that exists in New England is leather finishing. These types of sources can emit significant quantities of VOC. However, because the industry is very diverse, a data base describing the available pollution prevention activities (related to finishing) is not available. To assist the State agencies in evaluating control plans, EPA Region I, with funding received from the Region's Pollution Prevention Program, is conducting an industrial survey through Northeast States for Coordinated Air Use Management (NESCAUM). It is hoped that the survey results will provide information on low-VOC emitting processing techniques that can be utilized by this industry to reduce VOC emissions. Waste Management Continued objectives: o Continue oversight of implementation of Pratt & Whitney's Waste Minimization Program. o Participate in Region I 33/50 Project program. 18 ------- o As part of Task Force's Enforcement Workgroup, Waste Management Division representatives will develop a strategy to increase pollution prevention communications with the regulated community and streamline EPA Region I's enforcement efforts relating to pollution prevention. o Continue to review SEPs for potential credit toward enforcement penalties, as aids to case settlement, and as methods of pollution prevention. Solicit new cases from Enforcement staff. Additions: o The Waste Management Division will assist in oversight and participate in development of the Industrial Pollution Prevention Project at POTWs in Massachusetts and New Hampshire which discharge to the Merrimac River. This is a multi-media project for which the Waste Management Division served as a conduit for Headquarters Office of Water and Office of Solid Waste funds. o Participate in monthly national Waste Minimization Conference Calls and in a national Waste Minimization meeting to be held in Washington, D.C., in Spring 1992. Both initiatives are being coordinated by Headquarters' Waste Minimization Branch. o Conduct multi-media inspections at Federal Facilities. Review Waste Minimization plans detailed in Inter-Agency Agreements for RCRA Corrective Actions at Federal Facilities. Planning and Management o Hold a workshop on pollution prevention self-audits for Federal Facilities in Region I. GOAL 5: REDUCE WASTE STREAMS BY INFLUENCING PUBLIC BEHAVIOR (demand for products and municipal recycling) Environmental Services o Introduce and/or encourage pollution prevention in grades K-12 children by giving presentations in schools as part of the Junior Environmental Training Program. As part of every presentation, discuss ways in which individuals 19 ------- can help to prevent pollution by using alternatives to hazardous and/or packaged products. Water Management o Involve the public in Merrimack Pilot Pollution Prevention activities as they progress in FY92. o Evaluate and disseminate results of innovative household/consumer education efforts; e.g., Nashua Regional Planning Council, Cape Cod Commission's "Cape Cod Planet Earth" environmental audit and progress reporting by households, localities and business. Waste Management Continued objectives: o A Source Reduction Conference is being planned by the Solid Waste Association of North America (SWANA) using funds provided by the Waste Management Division. The conference will be held during Summer 1992, and will facilitate transfer of information on reduction of several toxic metals in municipal solid waste. o A second Procurement Conference for recycled materials, similar to the one held during FY91, is being planned by EPA Regions 1, 2, and 3, and the Northeast Recycling Council. The conference will be held in Fall 1992, in Region 3. o Continue to support market development for recycled products through studies conducted by the Northeast Recycling Council (NERC) and funded by the Waste Management Division to design and implement an economic development strategy for promoting secondary materials markets in the Northeast. o Continue development of a slide show on solid waste source reduction and recycling. This project is funded by the Waste Management Division. o Disseminate curricula for grade-school children on Household Hazardous Waste (HHW) complied by groups including the Association of Vermont Recyclers (AVR). The curricula development project was funded by the Waste Management Division. 20 ------- Planning and Management o Coordinate the activities of the New England Pollution Prevention Council, and assist the Council in developing pollution prevention/transportation projects. Hold a Pollution Prevention Transportation Forum for state environmental and transportation officials, and assist the Council in developing next steps. Promote and manage Automobile Pollution Prevention Projects with sponsoring Council members and partner companies/institutions. o The regional Library continues to collect and announce pollution prevention articles and publications in the "What's New" bulletin issued bi-monthly. Library staff have assisted several users, both in-house and public, with accessing the Pollution Prevention Information Exchange System (PIES), which will soon be available through the dial-out option on the LAN. 21 ------- |