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P2 and NPDES Permits (sorry for any cross-postings)




Hello all,
I am helping develop a P2 toolbox for use by Water Quality Permit writers
(could conceivably be used for other permits as well).  The idea is to
provide a usable tool permit writers can access when requiring facilities to
implement P2 Plans and/or opportunities.  I am gathering and categorizing
resources right now, and I would appreciate any information regarding:
	1)  legal authorities equating All Known, Available, and Reasonable
methods of prevention, control, and Treatment (AKART), Best Available
Technology, etc. with P2/source reduction requirement in permits.
	2)  precedence, 
	3)  boilerplate language, 
	4)  Implementation stories (successes, obstacles, etc)
	5)  and any other relative info you feel might be helpful.
Thanks in advance for any help that you can give, and I will try to provide
a summary of the project back to the listserve once I have finished.

Kevin Shupe 
WA Dept. of Ecology NWRO, Toxics Reduction Unit 
3190 160th Ave SE Bellevue, WA  98008 
(425)  649-7281 fax: (425) 649-7098 
kshu461@ecy.wa.gov <mailto:kshu461@ecy.wa.gov>