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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