U.S. ENVIRONMENTAL PROTECTION AGENCY




              REGION I




    POLLUTION PREVENTION STRATEGY









          FISCAL YEAR 1992
                              Draft--12/6/91

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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.

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                                 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)

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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

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            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

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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.

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      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.

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      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.

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      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
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      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.

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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
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      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.
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      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.
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            (** 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
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      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
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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


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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
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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.
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            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.
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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


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      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.
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                           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.
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