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Re: P2 in Pretreatment Permits and Programs

From: "LINDSAY MIZE" <Lindsay_Mize@owr.ehnr.state.nc.us>
To: "P2TECH" <p2tech@great-lakes.net>
Date: Mon, 31 Mar 1997 13:23:32 EST
Subject: Re: P2 in Pretreatment Permits and Programs

In NC we have developed a relationship with the State Pretreatment 
Staff (NC is a delegated state) and the Local Pretreatment 
coordinators.   This relationship started with a P2 grant program but 
has evolved into mostly technical and compliance assistance.  The 
reason for the discontinued grant program was that $20,000.00 was not 
enough for these local coordinators.  They already wear 5 different 
hats, so as I was told "make it a Hundred thousand and I'll apply".  
Of course NC doesn't have those resources, so we found other ways of 

Our Staff (the State's P2 Program) worked with the State's 
Pretreatment Staff and modified the Pretreatment regulations to allow 
the following:

The SIU application shall contain (M) Description of waste reduction 
activities being utilized.

The POTW Director is authorized to:  (vi) Require SIUs to develop a 
waste reduction plan and implement waste reduction techniques and 

These changes allow the local staff to implement P2 as needed.  The 
Charlotte-Mecklenburg Utility Department has required its SIUs to 
develop plans.

Our staff has also worked with compliance issues.  Since we are 
non-regulatory, we have developed some language to be used by the 
local pretreatment staff in their compliance orders.  It states that 
the industry will contact us or a consultant to conduct a waste 
reduction survey.  A summary of this survey will be submitted to the 
regulatory authority.  This arrangement has been so successful that 
we have had to limit its use.  We have approximately 10 staff for the 
State of NC and some municipalities want to write this language into 
their permits as well as their compliance orders.  With approximately 
1200 SIUs in the state this can't be done.   We place a priority on 
situations that are causing POTWs to fail their NPDES limits.

This relationship has allowed us to benefit the POTWs in other ways 
such as presenting information on "hot" topics at their annual 
meeting, working with the local WEF chapter to work with industrial 
wastewater dischargers, and answering industrial P2 questions on 
a one to one basis.

I hope this information is useful.  Please feel free to contact me if 
you have questions. 
From:          "Mike Keefe" <keefem@psinet.com>
To:            "P2TECH" <p2tech@great-lakes.net>
Subject:       P2 in Pretreatment Permits and Programs
Date:          Thu, 27 Mar 1997 14:42:06 -0700
Reply-to:      p2tech@great-lakes.net

I am looking for examples/case studies of attempts (hopefully successful)
to integrate P2 into industrial pretreatment and discharge permits and
orders.  In lieu of examples or case studies, any input from P2TECH
subscribers regarding ideas and strategies for integrating P2 into
pretreatment programs sure would be welcome.

Thanks a ton.

Michael Keefe
Environmental Engineer
PRC Environmental Management, Inc.
Phone # (919) 715-6511
NC Division of Pollution Prevention
and Environmental Assistance