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Re: Providing P2 Advice During Compliance Inspections
- Subject: Re: Providing P2 Advice During Compliance Inspections
- From: Sue Sommerfelt <Sue.Sommerfelt@uni.edu>
- Date: Fri, 20 Aug 1999 12:46:44 -0400 (EDT)
- List-Name: P2Tech
- Reply-To: Sue Sommerfelt <Sue.Sommerfelt@uni.edu>
The IWRC's Mobile Outreach for Pollution Prevention (MOPP) has been used
to train inspectors, regulatory and non-regulatory. Basically, it has
helped by simply making the inspector more knowledgeable on the various
P2 options. I give the equipment demonstration in the MOPP over a
hundred times a year but can successfully do the same training without
my "props" during an on-site review of a facility. The key is to make
the inspector comfortable enough to weave the P2 options into the
discussion of the regulations. As the walk-through of the facility
proceeds you build a rapport with the business operator by providing
regulatory advice along with alternative options. For example, the
common violation of open hazardous waste container can be presented as
an opportunity for improved housekeeping by using a funnel that screws
into the drum and has a sealable lid. That's not P2 but is practical
So I guess what I'm saying is, start sending your inspectors to P2
training. You can start by sending them to the upcoming MOPP
demonstrations in Pennsylvania this fall. Half the purpose of their
tour is to train their PA-DEP staff and the other half is to be there
for the public. The Meadville, PA, office is running a week-long
program September 20-24, 1999, which is conveniently close to Ohio.
Also I supplement the tours with handouts that include regulatory
summaries and lists of vendors of services and equipment I recommend
during the demonstration. Ohio EPA has a nice database of vendors and
ours is available on our website at www.iwrc.org.
You could simply, begin with a MOPP project. We can coordinate an Ohio
tour. Call me, Sue Sommerfelt, at the IWRC, 319/273-8905. The MOPP is
available for hire and (I've been told) at a reasonable price. Or you
could put together a similar training program for your client.
UNL-Lincoln has used the MOPP as training for their summer intern
on-site review program for the 3 years it has existed. I believe Jan
Hynstrom has been happy with the results.
Here's an overview of the MOPP:
The MOPP is a 34-foot motorhome that is customized with equipment useful
in waste reduction, recycling, and pollution prevention in the vehicle
maintenance, auto body, and manufacturing including metal finishing.
Most importantly, the MOPP has been used successfully to train waste
generators during a demonstration that introduces alternative parts
washing options. These include plant-based cleansers either with or
without bioremediation to replace solvent cleaning. The ins and outs of
hot soap degreasing such as an alkaline detergent without suspending the
metals and oils in the water. Lastly, other management options for
solvent-based cleaning. Those options include on-site distillation,
in-line filtration, settling and reuse, and just plain good
Other equipment includes used oil-fired furnace, used oil filter press,
samples of oil absorbent, and drum top drain tray. Antifreeze
filtration unit with discussion on antifreeze distillation too. And
painting and coating equipment such a small still for thinner and an
enclosed gun wash unit to reduce the amount of thinner used and sent
Painting is addressed using the IWRC's Spray Technique Analysis and
Research (STAR) training techniques in conjunction with the IWRC's Laser
Touch™ distancing and targeting tool (see our website at www.iwrc.org).
During the "mini" STAR training in the MOPP the painters are introduced
to waste reduction techniques that also improve transfer efficiency.
These techniques include keeping the spray pattern perpendicular to the
surface, banding, reducing wrist flicks (yawl and roll), maintaining
optimum spray distance, and so on. The lasers help visually drive home
the benefits of improved painting practices by showing the painter the
changes in spray pattern size and shape when poor techniques is used.
The targeting device appears as one "spot" when at optimum spray
distance and as two dots when either too close or too far away.
Waste Reduction Specialist and MOPP Coordinator