Panel Discussion and Conclusion

"What can EPA do to help you, and what can you do to help EPA, integrate pollution prevention into the air program?"

Lou Paley (Moderator)

NOTES:

this Please contact matter.

me a t

- 2 -

your earliest canvenience

Sincerely,

J. P. Pol lu tor V . P Violate O a r s ,

t o discuss

Inc .

Violate Oars Inc. 3350 Airhead Drive 0

Somewhere in the midwest; 12345 August 31, 1993

Attention: Environmental Enforcers State Environmental Agency 678 State Drive Somewhere in the midwest 12345

Dear Environmental Enforcers:

As Senior Vice President of Violate Oars Inc. (VO), I am willing to work with you to settle this matter expeditiously. At our last meeting, you informed VO that your state agency assessed a preliminary deterrence amount of $2,500,000 where the economic benefit of noncompliance is $1,200,000 and the remaining $1,300,000 is assessed for the gravity component. You also informed VO that the penalty represents several alleged violations of failure to test and demonstrate compliance at VO's industrial-commercial electricity and steam cogeneration facilities in accordance with Federal and state permit requirements and Federal regulations under the New Source Performance Standards. The state claims that the kinds of violations at issue limit your office's ability to determine VO's facilities sulfur dioxide emission rates, however, the data collected from VO thus far may indicate sulfur dioxide emissions limits violations at both plants. environmental engineers at our facilities and VO would like to propose a supplemental environmental project for settlement of

I have been talking to our

.this action.

The project VO proposes is a tire.deriVed fuel facility (TDF) which would shred tires collected from landfills and blend them with coal that fuels W e e boilers at the facilities. This process wil.1 reduce un&ontrolled sulfur dioxide emissions at both facilities. This TDF project would be predicated upon the successful operation of the TDF.project at VO's other plant, s0mewhere.h the northwest. approximately 3 million tires could be processed per year. would result in the annual production of 45.,000 tons of TDF, replacing over 5 8 , 0 0 0 tons of coal. benefit to be derived from this endeavor is the conversion of tire scrapes into a useful resource.

VO projects at full capacity This

The primary environmental

VO realizes that your policy requires a %exus" or relationship between t he alleged violations and the type of project proposed. l1horizontala8 and ''vertical nexus. I* VO's in-house CPAs and Engineers estimate that the project will cost $1,500,000 to implement. In addition, VO offers to pay $500,000 cash.

We believe that this project offers b0th.a

e. Who is the primary beneficiary of the project? make a difference if the violator gains an economic benefit from implementation of the project?

3 . The preliminary deterrence amount is assessed to be $2,5000,000 where the gravity component is $1,300,000 and the economic benefit is $1,200,000. Is the violator’s settlement offer of a SEP valued .at $1,500,000, and a $500,000 cash penalty adequate? What additional project cost information would EPA need to determine if the $1,500,000 project assessment is valid? Assuming the amount of the project is a valid project assessment, is $500,000 an adequate cash penalty? gravity be reduced?

Does it

How much should the

/

Pollution Prevention Seminar August 31, 1993

Supplemental Environmental Project Case Study

Role: Environmental Enforcer

Mission: If you choose to accept, read the settlement offer letter from an alleged violator somewhere in the midwest. The alleged violator proposes a supplemental environmental project and cash payment for settlement. Your staff is unsure how to handle this project under the February 12, 1991, Supplemental Environmental Project (SEP) policy and needs your advice on the following:

1. of projects in the SEP policy? If yes, which project category(ies) and why?

Does the proposed SEP fall under one of the five categories

2. SEP policy (environmental benefit, llnexusll, is the project proposed in light of the enforcement action, violatorfs compliance status, economic and technical resources, primary beneficiary of the project). criteria are satisfied, what additional information would you need from the violator?

Does the proposed SEP satisfy the other criteria under the

If you are not certain if the

a. Is it environmentally beneficial to replace coal with tires scrapes to emit a smaller amount of sulfur dioxide when burned? How much sulfur is actually reduced beyond any Federal or state regulatory, statutory, or permit requirement? Are there supplies of tire scrapes to keep the project continuing from year to year?

b. Is the %exUstl stated in the violators letter accurate? What is the "h.orizontalt1 or Wertica1.nexust1 between the . violations and the project? If the violator wanted to implement the TDF project at a facility other than the violating facility, would that satisfy the nexus requirement?

c. Would the violator have developed the project without an 'enforcement action? Does it matter that the violator previously implemented a TDF project at another plant and was considering implementing a TDF project at the violating

d. Will the violator have the economic and manpower resources to operate and maintain the project? collecting and transporting the tire serapes: the city; the state; the violator? Does it make a difference who collects the tire scrapes?

-

. facility before commencement of the enforcement action?

Who will be

In evaluating Innovative P2R Measures and Injunctive Relief, EPA should consider: ( Continued )

Applicability of the P2R Approach to Others

Will Compliance be achieved and maintained?

Penalty Considerations if P2R Used for Injunctive Relief

Willingness of violator to remedy violation via P2R may warrant reduction of gravity component of penalty

Caution: If P2R remedy is not innovative, but well demonstrated and less expensive to implement than end-of-pipe treatment, gravity reduction may not be warranted

BEN Calculation: In order to encourage P2R, compliance projects, EPA will use smallest BEN calculation, comparin-g:

Traditional compliance project

Versus

Pollution PreventiotdRecycling Project

Caution: P2R projects may be less expensive than traditional treatment. If using lNNOVATlVE.P2R compliance project, may be difficult to estimate necessary BEN inputs..

Interim Policy on the Inclusion of Pollution Prevention and Recycling Provisions in Enforcement Settlements

Purpose of Policy: Promote use of pollution prevention and recycling conditions in administrative and judicial enforcement settlements either as:

Injunctive Relief (to remedy violations)

or SEP

Note: Recycling is included in the scope of this policy P2R = Pollution Prevention and Recycling

Implementation of Innovative P2R Measures as Injunctive Relief

EPA Enforcement Policy Calls for Expeditious Return to Compliance

General Rule: No Significant extension of Normal Time Period for returning to compliance

Significant defined by each Program Normal time period defined by traditional (end-of-pipe) means of compliance

.

Consent decree or order must require implementation of alternative proven compliance method if innovative P2R strategy does not work by given time period

Additional penalty required if such failure further delays compliance and increases BEN ..A

In evaluating Innovative P2R Measures and Injunctive Relief, EPA should consider:

Seriousness of Existing Violations: some violations may need to be corrected ASAP and not wait for innovative P2R

Aggregate Gain in Extra Pollution Prevention: schedules extended only if important net permanent reduction in toxicity or amount of pollution

Reliability/Availability of the P2R Approach: the more experimental or untried the P2R technology, the more rigorous the evaluation of the potential benefits and costs

Type of S E P Project ( Continued )

Cross-Regional Impacts Other Regions (FYI if minor impact, concurrence if major)

"Substitute Performance"l OE concurrence by AA

1Sep may be done by entity other than violator, in whole or part, if: reasonable geographic or media-specific relationship to violation; it is enforceable; and if substitute performance fails, violator remains responsible for project or payment of penalty offset.

Vertical Nexus:

Compared to the original violations, SEP will reduce excess loading of the s a m e pollutants in the s a m e medium to offset earlier excess loading. Generally a t s a m e facility.

Horizontal Nexus: - Compared to the original violations, SEP will reduce pollutant loading at either:

different medidsame facility OR sa i u m / d s a c i l iti es 7

Horizontal nexus subject to SPECIAL SCRUTINY to ensure that: SEP will reduce overall public health or environmental risk posed by facility responsible for violation; OR enhance prospects for reducing or eliminating chance of

Nexus Requirement

There must b e a n appropriate relationship between: the nature of the violation and the environmental and public health benefits to be derived from the proposed SEP

Violations - SEP

Nexus may b e vertical or horizontal

4. Environmental Auditing Projects

Auditing must go beyond general business practices, AND:

Seek corrections to existing management and/or environmental practices whose deficiencies appear to be contributing to recurring or potential violations

Audit projects may encompass other facilities owned or operated by the defendanthespondent, in order to identify and correct practices that could lead to recurring or future violations of the type which are the basis for the enforcement action

5. Environmental Public Awareness Projects

Publications, broadcasts or seminars which:

remind regulated community of the importance of complying with environmental laws, or

disseminate technical information about the means of complying with environmental laws

Remember: Must promote compliance and deterrence, not benefit the defendant as advertising. Must include public statement that being done as part of settlement.

Not subject to formal nexus requirements, but must be related to the type of violations which were subject of underlying complaint

Concurrence Process for SEP Approval for Both Administrative and Judicial Actions

Type of SEP Project Approval Required

Vertical Standard per Existing Delegations

OE concurrence by Enforcement Counsel Horizontal

Types of SEPs:

1. Pollution Prevention Projects

P2 Project substantially reduces or prevents the generation of pollutants through source reduction or applicable closed-loop recycling

Project which substantially reduces discharge of pollutants through innovative recycling may be considered as a P2 project if the pollutants are kept out of t h e environment in perpetuity

Watch out for substitution projects: substitute chemical must be non-polluting and clearly less toxic

2. Pollution Reduction Projects -- Enhanced Treatment

Project which goes substantially beyond compliance with existing and soon-to-be-eff ective discharge limitations using treatment

May include accelerated compliance project if a violator will:

achieve compliance with future regulatory requirement at least 24 months before the compliance deadline

AND

achieve significant pollution reduction (i.e., can'objectively quantify a substantial amount of pollution reduction)

3. Projects Remediating Adverse Public Health or Environmental Consequences (Restoration Projects)

Restoration project not only repairs damage done to environment because of the violation, but goes BEYOND to enhance environment in the vicinity of the violating facility

Under CWA, simply removing contaminated sediments that defendant's violations caused is part of injunctive relief and not, by itself, a SEP

Eight Basic Criteria for Potential SEP ( Continued ) (all criteria must be satisfied):

4. Main beneficiary of SEP must be the environment and public health

"Sound business practice" project not acceptable as SEP, except if pollution prevention and:

Public health and environmental benefits of project are demonstrated by violator to be so substantial that public interest would best be served by providing additional incentives to perform project

Caution: If SEP saves violator money, then may be difficult to quantify how much to reduce settlement penalty . .

5. Oversight - If S E P requires third party oversight:

violator pays for 3rd party oversight or audit 3rd party auditor submits periodic reports to EPA

6. S E P conducted pursuant to enforceable milestone implementation schedule (e.g., CD)

If S E P not performed, violator must b e required to promptly pay penalty offset amount with interest.

7. ONLY five types of possible SEPs:

Pollution Prevention Pollution Reduction Environmental Restoration

' Environmental Auditing Public Awareness Projects

Studies alone generally not S E P need study plus enforceable commitment to implement results of study

Exception: Approved P2 studies without commitment to implement results may be allowed

8. Appropriate "Nexus" or relationship between nature of violation and the environmental benefits from the SEP

Policy o n the Use of Supplemental Environmental Projects in EPA Sett lements , February 12,1991 (SEP) and Interim Policy o n the Inclusion of Pollution Prevention and Recycling Provisions in Enforcement Sett lements, February 25,1991

S E P may be useful vehicle in promoting pollution prevention

WHAT a r e SEPs?

Actions to remediate the adverse public health or environmental consequences of the violations

Actions BEYOND that required to remedy the violations and maintain compliance

NOT a substitute for compliance

Settlement penalty may be reduced to reflect good faith efforts by defendantkespondent to perform the S E P

Reduced penalty > economic benefit + s o m e gravity

S E P Policy broader than previous policy; but S E P Policy may be more complicated

S E P s previously called "credit projects" or "alternative payments"

Eight Bas ic Criteria for Potential S E P (all criteria must be satisfied):

Violations corrected to ensure future compliance 'j . No extra time given to correct the violation in return for the S E P

2. Deterrence objectives obtained by substantial $$ penalty -

Substantial penalty = economic benefit + s o m e gravity

3. S E P must improve the injured environment or reduce the total risk posed to public health or environment by the violations

Pollution Prevention in SEPs

Joanne H. Berman

.. .

TitPe VI Stratospheric Ozone Protection

\h5& IIa Creates new Stratospheric Ozone Program.

1

Phases out use of CFC's/Halons by 2000

Encourages substitution to less harmful chemicals

Title IX Clean Air Research

Section .I 03(g):Pollution Prevention and Emission Control

' I . . . t h e Administrator shall conduct a basic engineering research and technology program to develop, evaluate, and demonstrate nonregulatory strategies and technologies for air pollution prevention ..."

Title V Permit Program

Enforces Title I and I l l emission standards.

Allows States flexibility to establishing compliance terms based on prevention strategies

Provides fee structure based on emissions.

Establishes small business technical assistance program.

Will issue thousands of permit to.new and existing sources. $,* PQ-* yrz ywz”

Title I1 Mobile Sources

Controls VOC, NOx, CO, PM emissions from motor vehicles.

Established national standards for vehicles.

Requires new fuels - especially for nonattainment areas

Reformulation Clean Fuels

Enacts transportation control measures in extreme areas

Fuels and transportation control measures = prevention opportunities

Acid Rain Program

Establishes emission allowance program Allows use of low sulfur coal instead of scrubbers

SOX from electric utilities

Imposes an emission cap Must purchase allowance to build or increase emissions after 2000. Encourages long-term energy conservation. Promotes building of cleaner plants.

-Opportunities

The emission standard can be written as a performance standard (95% reduction efficiency).

The emission standard can be written as a production limit (Ibs/ton of product or Ibs/hr)

Prevention approaches can be used to meet the standard.

Information

Discuss pollution prevention strategies or upcoming research in:

Preamble and Regulation Enabling documents

Provide information in Clearinghouses:

Control Technology Center BACT/LAER and MACT Clearinghouse

( Small Business Clearinghouse (, Pollution Prevention Information Clearinghouse

Other Opportunities

Section 1 12(g) - Modifications, Construction & Reconstruction

Emission offsets to avoid modification requirements

Broad source definition if greater emission reductions can be obtained

Section I 126) - "The Hammer"

Regulation through pe Tit program Flexibility to consider P

Section 1 12(i)(5) - Early Reductions

90% reduction of HAP before MACT proposal 6 year compliance extension Incentive for innovation and prevention

Title 111 Hazardous Air Pollutants

":"\./ -c3 Regulates emissions of 189 hazardous air pollutants (HAPS).

Establishes national standards for 174 source category (industry).

Emission standards promulgated in phases over a 10 year period.

Standards are based on maximum achievable control technology (MACT).

MACT is the maximum degree of reduction in HAP emissions that is achievable taking into consideration the costs, non-air quality health and environmental impacts and energy requirements.

However, MACT can be no less stringent than the MACT floor.

MACT Floor

Existing S o u r c e s ... the average emission - limitation achieved by the best performing 12% of existing

01% ,ip s o u r c a t h e source 6 m - 3 k

New Sources . .. the emission control achieved in practice by the best performing similar source

As a result ... MACT will must often be defined by add-on controls.

Sec t ion 11 2(d)(3)

EPA must consider measures to "reduce the volume or, or eliminate emissions of, such pollutants through p r o c e s s changes. substi tution of materials or other modifications ..."

Clean Air Act Amendments

Title I Non attainment for Criteria Pollutants

Title I 1 Mobile Sources

Title I l l Hazardous Air Pollutants

Title IV Acid Rain

Title V Operating Permits

Title VI Stratospheric Ozone

Title XI Clean Air Research

Title I Non attainment Areas

JControls emissions of criteria pollutants (NOx, S02, VOCs, CO, Lead, PM-10)

Requires EPA to provide States with guidance for control of existing sources through Control Techniques Guidelines (CTGs).

Requires reasonable further progress (3% VOC reduction per year to 15% total in 6 years.) / q96

Continues to require: Reasonably available control technology (RACT) Best available control technology (BACT) Lowest achievable emission rate (MER)

Title I Opportunities:

13 new CTGs can include P2 strategies.

> 1 to 1 offsets to avoid modification.

Title I Obstacles:

..

States may pursue maximum reduction to meet 15% requirement

Short CTG deadlines may default to end of pipe controls

Section 101 (a)

Congress finds that ...

(3) that air pollution prevention (that is, the reduction or elimination, through any measures, of the amount of pollutants produced or created at the source) and air pollution control at its source is the primary responsibility of States and local governments;

(4) that Federal financial assistance and leadership is essential for the development of cooperative Federal, State, regional and local programs to prevent and control air pollution.

Section 101 (c)

"A primary goal of this Act is to encourage and otherwise promote reasonable Federal, State, and local government actions, consistent with the provisions of this Act, for po I I u t i o n prevention .'I T

Opportunities

Regulatory

Incorporate into emission standards Promote innovative technologies to meet new and existing requirements

Non-regulatory

Research new and existing pollution prevention strategies. Collect permit fees based on air emissions. Develop of control technology guidelines. Promote market based incentives for emission allowances and trading.

Obstacles

Statute establishes minimum requirements for setting emission standards.

Time constraints focus standards on add-on controls.

Lack of emission measurement techniques makes quantification of emission reductions difficult, and may be an obstacle to enforcement.

.... There is a need to adapt traditional approaches and methods to air pollution control to remove obstacles to pollution prevention.

Pollution Prevention and the Clean Air Act

Lynn E. Hutchinson

Making it happen *

Is there a better way?

Find it.

Develop it

Do it

. .

ImplementatioR of Pollution Prevention

Combination of techniques

optimize benefits of each step in hierarchy

prevention

recycling

treatment

disposal

implement as possible in all phases

regulations

permits

inspections

SEPs

be innovative and flexible

technology

process

operation & maintenance

focus on the problem

develop partnerships

utilize State, local and industrial expertise

Small improvements add up

- P2 in Regulatory Programs

Benefits

enhanced protection of environmenVminimum d adverse effects

utilizes expertise of regulated industries

costs likely to be lower than add-on controls

reduces regulatory burden on sources and agencies

Unique barriers

specificity of statutory and legal requirements

increases risk to sources

add-on controls "guarantee" compliance

costs to sources may be higher

mutual distrusVadversaria1 relationships

harder to determine compliance/take enforcement actions

moves baseline down

short-term resource burden

Greatest barrier - resistance to change

"Structural" Requirements

Management support

Training and empowerment of those closest to the situation

Oversight and guidance (continuous improvement) / 1 -

Why ( Continued ) -

"Traditional" Pollution Control

begins at end of process

primarily add-on controls

very effective, but increasingly costly

adverse side effects

cross-media transfer

disposal of waste

energy consumption

global warming gases

How

PPA establishes hierarchy of pollution control

1. prevention of pollution at source

2. recycling

3. treatment

4. disposal

"Traditional Control" begins with step 3

"Pollution Prevention" begins with step 1

- Examples ( Continued )

Regulatory

Low Solvent Coatings

Air quality still a major problem

Spending > $1 00 billion/yr.

> 10,000 pages of Federal regulations J Substantial new requirements under CAAA of 1990

Incremental improvements increasingly costly

Need to consider innovative strategies

PPA of 1990

'!...national policy of the United States ..." Administrator's Policy Statement

"...make pollution prevention the guiding principle for all our programs ..."

Administrator's Policy Statement (Continued )

"...mainstream activities a t EPA, such regulatory development, permitting, inspections and enforcement, must reflect our commitment to reduce pollution a t the source ..."

as

What P2 Is Not D

"Magic bullet"

Small imp rovemen ts

Combination of old and new techniques

Add on (e.g., spell checker)

Basic cultural change in the way we do our jobs

Reduction in stringency or timeliness of requirements

Enhanced protection of environment

What P 2 b

Pollution Prevention Act of 1990

"...any practice which reduces the amount of any hazardous substance, pollutant or contaminant entering any waste stream or otherwise released into the environment ..." Protection of natural resources through conservation

Preventing the Production of Pollution .

Examples

Voluntary

Green Lights

33/50 program

. In-House

OAR'S Judiciary Square building

Pollution Prevention in Air Programs:

What, Why and How

Gerard C. Kraus USEPA

Tar g et/Act ion Category PG :

EPA SHOULD CULTIVATE PUBLIC/PRIVATE PARTNERSHIPS TO FOSTER POLLUTION PREVENTION

G. l . Assist Industry Groups in Measuring Environmental Results of Their Codes of Conduct

G.2. Develop a Facility-based System for Organizing All of EPA's Data

TargeVAction Category H:

EPA SHOULD TAKE A LEADERSHIP ROLE IN PROVIDING EDUCATION AND INFORMATION ABOUT POLLUTION PREVENTION ,

H. 1 . Begin General Pollution Prevention Education Initiative

H.2. Facilitate the Sharing of Pollution Prevention Information with Industry

H.3. Develop a Chemical Use Inventory

TargeVAction Category 1:

EXECUTIVE BRANCH SHOULD INTEGRATE POLLUTION PREVENTION INTO ITS PROCUREMENT AND DEVELOP FEDERAL AGENCY RELATIONSHIPS TO PROMOTE POLLUTION PREVENTION NATIONWIDE

1.1. Advance Principles of Pollution Prevention in Executive Branch Through Procurement of Goods and Services

Establish a Permanent, -Inter-agency Team Reporting to the Vice President to Gather, Evaluate, Develop Ideas for Pollution Prevention Throughout the Federal Govemment a n d to Coordinate Potlution Prevention Activities Throughout the Federal Government

1.2.

TargeVAction Category J:

GOVERNMENT SHOULD USE MARKET INCENTIVES, INTERNALIZING THE EXTERNALITIES AND FISCAL POLICIES TO PROMOTE POLLUTION PREVENTION

J. 1. Develop "Take Back" Legislation and Regulations

J.2. Establish a Federal Environmental Sales Tax .

TargevAction Category E:

EPA SHOULD ENHANCE PARTNERSHIPS WITH STATE, LOCAL, AND TRIBAL GOVERNMENTS TO IMPLEMENT POLLUTION PREVENTION

E.1. Work With the States on Pollution Prevention at as High a Management Level as in Other Programs

E.2. improve Funding for Pollution Prevention Activities by States

E.3. Promote One-stop Shopping for Environmental Regulatory Assistance Pol I ut ion Prevent ion Technical Assistance I and Other Assistance Programs

E.4. Adopt Standard Practice of Allowing Flexibility for States and Local Governments to Comply with Environmental Requirements Through Pollution Prevention

E.5. Facilitate Pollution Prevention by Native American Tribal Governments

E.6. Develop a "Demand-side Management" Strategy for Municipal Water Programs

E.7. Develop Municipalities' Capabilities to Use Pollution Prevention as a Centerpiece of Their Pre-Treatment Programs

TargeVAction Category F:

EPA SHOULD TAKE AN ECONOMIC SECTOR-BASED APPROACH TO THE DEVELOPMENT OF ENVIRONMENTAL POLICIES AND PROGRAMS, WITH POLLUTION PREVENTION AS A KEY MEANS OF ACHIEVING COST-EFFECTIVE ENVIRONMENTAL PROTECTION.

F.1.

F.2.

F.3.

Develop Sector or Sub-sector Specific Policies, Projects, and Programs to Most Effectively Drive Private Sector Behavior and Promote Desired Private Sector Actions.

Establish Multi-Disciplinary Working Groups Within EPA and With Outside Entities to Develop Sector and Subsector Strategies.

Take a More Proactive Role to Develop Legislation That Would Provide Greater Flexibility for EPA to Promote Innovative Programs Pursue Regulatory Trade-offs and Prioritize Risks.

.

TargeVAction Category C: m

EPA SHOULD CHANGE ITS CULTURE AND ORGANIZATION TO MAKE POLLUTION PREVENTION THE CENTRAL OPERATING PRINCIPLE OF THE ORGANIZATION AND ITS EMPLOYEES

C.1. Identify Ways to Structure EPA to Promote Risk Taking, Exposure Reduction and Pollution Prevention

C.2. Require That Senior Level Managers be Accountable for I m plem ent ing Pollution Prevent ion Th roug hou t E PA's P rog rams

TargeVAction Category D:

EPA SHOULD INTEGRATE POLLUTION PREVENTION INTO ALL PROGRAMS INCLUDING REGULATION DEVELOPMENT, PERMllTlNG OPERATIONS, COMPLIANCE ACTIVITIES, AND ENFORCEMENT

D.1.

D.2.

D.3.

D.4.

Develop and Implement Every Regulation, Guidance Document, and Policy to Integrate Pollution Prevention into the Menu of Options for the Regulated Community

Provide flexibility in Permit Compliance, Fee Schedules, and Processing Time for Permit Applications to Encourage Pollution Prevention

Develop Pilot Projects for Integrating Pollution Prevention into Development and Implementation of Regulations, Guidance Documents, or Policies for Two or More Media for the Same Industry

Harness Enforcement Activities to Help-Promote and Implement Pollution Prevention

VlSdON STATEMENT

REPORT OF THE POLLUTION PREVENTION TEAM NATIONAL PERFORMANCE REVIEW

EPA believes that pollution prevention is the preferred approach for environmental improvement and promoting a sustainable economy.

We seek to build our programs, both regulatory and non-regulatory, on a foundation of pollution prevention, and encourage state, local, and tribal governments and other Federal agencies to do the same.

We work with our partners, including state, local, and tribal governments, businesses, the financial community, and others, to develop clean technologies, to promote innovation, to ensure that the maximum amount of pollution is prevented, and to ensure that the minimum amount of our natural resources are consumed.

TargeVAction Category A:

EPA SHOULD PROMOTE SUSTAIN ABILITY THROUGH ITS POLICIES AND PROGRAMS AS THE CENTRAL OPERATING PRINCIPLE FOR THE COUNTRY

A.1. Link Federal Policies and Programs to Sustain ability and Pollution Prevention

A.2 Recognize and Address the Role of Key "Drivers" (Such As Population, Consumption Patterns, and Technology)

Affecting Mankind's Ability to Create a Sustainable Future

TargeVAction Category B:

EPA SHOULD DEMONSTRATE THE BENEFITS OF P2 TO ENVIRONMENT, BUDGET & EFFICIENCY BY USING P2 STRATEGIES IN ALL ITS OWN OPERATIONS

B.1. Demonstrate a Commitment to Pollution Prevention in All EPA Internal Operations

-

Pollution Prevention National Performance Review

James C. Nelson

12:OO p.m.

12:lO

12:25

1 :30

1 :40

2:45

3:15

4:20

4:30

Introduction to Pollution Prevention in the Stationary Source Air Program -

Satellite Presentation

12:OO p.m. - 5 0 0 p.m. EDT August 31, 1993

Agenda

Introduction Louis Paley (Moderator)

Pollution Prevention National Program Review James Nelson

P2 in Air Programs -What, How a n d Why Gerard Kraus Discussion*

Break

P2 Opportunities in the Clean Air Act Amendments of 1990 Lynn Hutchinson Discussion*

Break

P2 in SEPs - . JoanneBerman Discussion*

Break

Panel Discussion a n d Conclusion "What can EPA do to help you, and what can you do to help EPA, integrate pollution prevention into the air program?' - Lou Paley (Moderator)

500 p.m. End

5 min.

15, min.

30 min. 25 min.

10 min.

30 min. 25 min.

30 min.

30 min. 25 min.

. ..

10 min.

10 min.

* WA sessions from audience to panel, consisting of presenters plus (possibly) OAQPS/State/Regional representatives.

Moderator: Louis R. Paley National Air Compliance Pollution Prevention Coordinator Stationary Source Compliance Division USEPA

-

Pollution Prevention National Program Review:

James C. Nelson Associate General Counsel for Pesticides and Toxic Substances and Leader, EPA National Program Review Pollution Prevention Team USEPA

Pollution Prevention in Air Programs - What, How and Why:

Gerard C. Kraus Chief, Organic Chemicals Section Stationary Source Compliance Division USEPA

Pollution Prevention Opportunities in the Clean Air Act Amendments of 1990:

Lynn E. Hutchinson Environmental Engineer Emission Standards Division USEPA

Pollution Prevention in SEPs:

. .

Joanne H. Berman Staff Attomey Air Enforcement Division USEPA

___ This project has been funded wholly or in part by the United States Environmental Protection Agency under Cooperative Assistance Agreement CT-901889 to North Carolina State University. The cwtents of this document do not necessarily reflect the views and policies of the Environmental Protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use.

~ _ _ _

0 1993 North Carolina State University

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Printed on recycled paper in the United States of America

APT1 013B

Introduction to Pollution Prevention in the Stationary Source Air Program

August 31,1993

Sponsored by:

US. Environmental Protection Agency Office of Air Quality Planning and Standards

Air Pollution Training Institute Research Triangle Park, NC 2771 1

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I recognizing and reducing safety hazards that new inspectors may face, such ' 8 s walking, climbirig, inhaling, bums, and ex:Aosions. SI 446 also covers

u s e and care of personal protadion equipment, including respirators, masks, 2nd safety goggles. A review with questions and answers is provided at the conclusion of each cf the five lectures. Updated in 1930, this course was designed as a supplement to general industrial hygiene and safety procedures. lNSPEC7IQN PROCEDURES AND SAFETY is a 20-hour

Inspecticn personnel, permit engineers, adminiskators - anyone conplying with Federal and State permitting - will find this technical trairiing course valuable. Major national permitting programs, methods of analysis, fundamentals of permit drafting, and case studies are carefully examined. Updated in 1992, this seven- part lesson has expanded to include NOx increment requirements and renumbering of the state implementation plan (SIP) preparation regulations. FUNDAMENTALS OF EFFECTIVE PERMIT DRAFTING AND ANALYSIS requires 40 hours of study, and provides 4 CEU credits. Components: course manual (152 pp), final exam, certificate. $400.

------e- .----*_. --.- --- - ---1-1--- ---=zz---2---i- Printed on recycled paper

FACT SHEET Envirsnmsntal Programs INDUSTRIAL EXTENSION SERVICE COLLEGE OF ENGINEERING 0 NORTH CAROLINA STATE UNIVERSITY

I.

Auditing of ConGnuous Emission Monitors Workshop Emission Capture and Gas Handling System Inspection Baseline Source Inspection Techniques Introduction to Permits Intermediate Permitting Inspection Procedures and Safety

Advanced Source Sampling Workshop Hazardous Waste Jncineration

TELECOURSE SCHEDULE FOR 1993

Enhanced Ozone Momtom

2 3 3 3 3 3

3 4

AUB. 31

NOV. 15-17 Nov. 18,22,

I Sept. 22-23 I 011

461 446

Oct. 19-21 Oct. 25-27

I Nov. 1-3 I 460

Dec. 6-8 Dec. 13-16 \

Environmental Programs North Carolina State University College of Engineering Industrial Extension Service Box 75131903 Method Road Raleigh, NC 27695-7513

Environmental Programs North Carolina State University College of Engineering Industrial Extension Service Box 75131903 Method Road Raleigh, NC 27695-7513

Environmental Programs North Carolina State University College of Engineering Industrial Extension Service Box 75131903 Method Road Raleigh, NC 27695-7513

Shannon, Julie, PPD

- 7409 (202) 260-01 78 260-2736

Shaver, Betsy, AEERL MD-60 (91 9) 541 -5227 541 -7915

Smith, Carol, ATD, Region Vlll 8ART-AP (303) 293-1 229 293-1 768

Stone, David, ORC, Region II 20RC-AWTS(212) 264-4359 264-81 83

Trutna, Mike, AQMD MD-15 (91 9) 541 -0804 541 -5345

Vendinello, Lynn, Staff P2 1102 (202) 260-851 1 260-861 2

Webb, Jeffrey, GCD, OAR 6202J (202) 233-9578 233-9736

Williams, Douglas, CERI/OR&D G75 (51 3) 569-7585 569-7361

Garlow, Charles, AED, DE

Harper, Steven, OPAR, OAR

Hewson, John, APTMD, Region IV

Hillson, Marc, FOSD, OAR

James, Chris, ATD, Region X

Kenyon, Michael, ORC, Region 1

Kraus, Gerard, SSCD, OAR

Kroncke, Virginia

Kruger, Joseph, ARD, OAR

Lamason, Fielding, FOSD, OAR

Martin, Karen, AQMD

Matthews, Julie, ORC, Region X

Mikalian, Charles, ORC, Region IV

Mindrup, Mary, ATD, Region VI1

Mokry, Gary, APTD, Region VI

Monell, Carol, Region IV

' Padgett, Joe, OAQPS

Patel, Harish, AWMD, Region II

Pina, Carolyn, AMD, Region 1

Reich, Daniel, ORC, Region IX

Reilly, Bill, ARTD, Region I l l

Rosenberg, Peter, OE

Schulz, David, ARD, Region V

s

LE-134A (202) 260-4201

ANR-443 (202) 260-9766

APT4-AEB (404) 347-3059

64063 (202) 233-9557

AT-082 (206) 553-01 10

RCA (61 7) 565-1 141

EN-341 W (703) 308-8738

AT-1 8J (31 2) 886-061 7

6204J (202) 233-9585

6406J (202) 233-9557

MD-12 (9 1 9) 54 1 -0237

so-1 55 (206) 553-01 63

(404) 347-5246

ARTX-TOPE (91 3) 551-7065

6T-EC (214) 655-21 64

17-A (404) 347-1 043

MD-11 (91 9) 541 -2464

2AWM-AC (21 2) 264-6774

APC (61 7) 565-4939

RC-3-4 (41 5) 744-1 041

3AT-0 1 (21 5) 580-201 1

LE-1 33 (202) 260-7553

AE-17J (3 1 2) 353-8289 1- .

260-1 088

260-8953

347-2904

233-9304

553-1 194

565-1 137

308-871 9

353-5556

233-9 1 25

233-9024

541 -5274

553-1 169

347-2641

55 1 -7608

655-7233

347-7 1 09

541 -5589

264-6683

565-3728

744-1 336

597-9302

260-8869

886-6790

-~ ~ _ _ _

- Satellite P2 Training

Louis Paley, Air Compliance P2 Coordinator

Rafael Sanchez, Chemical Engineer

Joanne Berman, Air EnforcemenVP2 Coordinator

Joe Padgett, OAQPS P2 Coordinator

Jack Edwardson, Dep. Dir., Air Standards

Gerard Kraus, Chief, Org. Chem., Compliance

OAQPS "TTN BBS" (information #)

OR&D "PIES BBS 'I (information #)

LIST OF USEFUL NAMES AND NUMBERS

(703) 308-8723

(703) 308-8730

(202) 260-6224

(91 9) 541 -5589

(9 1 9) 541 -4003

(703) 308-871 9

(91 9) 541 -5384

(703) 821 -4800

1

"EPA Air Compliance & Enforcement P2 Work group" Contact List

Name & Organization

Berman, JoAnne, AED, OE

Carlson, David, AID, Region IX

Chow, Alice, ARTD, Region Ill

Cosgrove, Patty, ORC, Region V

Dolph, Becky, ORC, Region VI1

Eady, Veronica, ORC, Region Vlll

Edwardson, Jack, ESD

El kins, Joe

Fontaine, Peter (Multi-MedidOE)

Frank, Mathew, ORC, Region Ill

Mail Code

LE-1 34A

A-3-3

3AT23

CA-3T

CNSL

8RC

MD-13

MD-14

LE-1 34A

3RC-10

Fax Number Phone Number

(202) 260-4201

(41 5) 744-1 076

(21 5) 597-31 56

(31 2) 886-0747

(9 1 3) 55 1 -7064

(303) 294-7653

(91 9) 541 -0072

(91 9) 541 -1 903

(202) 260-4201

(21 5) 597-3235

260-6224

744-1 143

597-6550

886-6722

551 -701 0

294-7552

54 1 -4003

541 -5653

260-6240

597-6454

Moderator: Louis R. Paley National Air Compliance Pollution Prevention Coordinator Stationary Source Compliance Division USEPA

Pollution Prevention National Program Review:

James C. Nelson Associate General Counsel for Pesticides and Toxic Substances and Leader, EPA National Program Review Pollution Prevention Team USEPA

Pollution Prevention in Air Programs -What, How and Why:

Gerard C. Kraus Chief, Organic Chemicals Section Stationary Source Compliance Division USEPA

Pollution Prevention Opportunities in the Clean Air Act Amendments of 1990:

Lynn E. Hutchinson Environmental Engineer Emission Standards Division USEPA

Pollution Prevention in SEPs:

Joanne H. Berman Staff Attorney Air Enforcement Division USEPA

12:OO p.m.

12:lO

12:25

1 :30

1:40

2:45

3:15

4:20

4:30

5:OO p.m.

Introduction t o Pol I uti on Prevention in the Stationary Source Air Program -

Satellite Presentation

12:OO p.m. - 3 0 0 p.m. EDT August 31, 1993

Agenda

Introduction Louis Paley (Moderator)

Pollution Prevention National Program Review James Nelson

P2 in Air Programs - What, How a n d Why Gerard Kraus Discussion*

Break

P2 Opportunities in the Clean Air Act Amendments of 1990 Lynn Hutchinson Discussion*

Break

P2 in SEPs Joanne Berman Discussion*

Break

Panel Discussion a n d Conclusion “What can EPA do to help you, and what can you do to help EPA, integrate pollution prevention into the air program?. - Lou Paley (Moderator)

End

5 min.

15 min.

30 min. 25 min.

10 min.

30 min. 25 min.

.30 min.

30 min. 25 min.

10 min.

10 min.

* WA sessions from audience to panel, consisting of presenters plus (possibly) OAQPS/State/Regional representatives.