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Re: Whose had success with P2 in Permits, Rules, & Inspections?


Ohio EPA's Division of Hazardous Waste Management (DHWM) has been integrating P2 into activities since the 1990s.  You can read more about our integration efforts on our web site at: http://www.epa.state.oh.us/dhwm/guidancedocs.html#waste.  In 1998 our division developed a P2 Integration Strategy that is on our web site.  In 2005 we revised our strategy which is also on our web site. 
To answer a few of your questions:
1) How is P2 currently integrated into DHWM?

We currently integrate P2 into the following activities: inspections, complaint investigations (when appropriate), compliance assistance activities, enforcement, permit renewals, presentations made to industry/trade groups, articles in DHWM?s Notifier newsletter and P2 assessments completed at generator facilities.  DHWM works closely with our Office of Compliance Assistance and Pollution Prevention (OCAPP) to complete P2 assessments at hazardous waste generator facilities.

The division currently has a P2 team to support integration and measure progress and impact of P2 efforts.  During the past few years the P2 team has focused on developing and delivering industry sector specific training for staff.  P2 training on parts washing, metal finishing and painting and coating was delivered to staff the past few years.  This training was designed to help staff understand industry processes and help them identify P2 opportunities for these types of industries. 

2) How Successful is Our Integration of P2 ?

In 2004, DHWM used a telephone survey to measure the impact that inspectors have made on businesses when P2 was discussed during an inspection.  U.S. EPA provided grant money for the measurement project.  Facilities were called by their inspector approximately six weeks following the inspection.  The survey found that DHWM inspectors made a positive impact by prompting P2 discussions and activities at the facilities they inspected.  Specific data on cost savings and actual waste volumes reduced was usually not available.  However, it was concluded that DHWM can still show progress by tracking the numbers of facilities which have implemented or are discussing P2 activities.  Survey data also indicated that we are more likely to have an impact at companies where we?ve identified violations.  The report to U.S. EPA we completed is attached.   

As far as enforcement, our Administrative Consent Orders are on our web site at:  http://www.epa.state.oh.us/dhwm/aco.html and a symbol indicates if an order included a SEP.

3) Other 

We have been moving to more on-line training for staff since we have had positive feedback on it.  Our recent on-line offerings include laboratories and foundries. Our on-line training is posted on our OCAPP web site at: http://www.epa.state.oh.us/ocapp/p2/onlinep2training/onlinep2training.html 

We constantly re-evaluate our program, what is working and what is not.  If you review our 1998 strategy and compare it to our 2005 strategy you will see some changes.  We feel that it is important to do this.  

Other projects we currently have going on include: 
i) Our hazardous waste permits now have a 10 year renewal so we are recommending to our management team to have our waste minimization plans due every 5 years instead of every 2 years.  
ii) Our inspectors kept seeing violations with used fluorescent lamps so we are developing an initiative to encourage managing this waste stream under the universal waste rules and recycling.  

Please call me if you have further questions after you review the information I have directed you to. Good luck on your project! 

Helen Miller 
Environmental Specialist
Division of Hazardous Waste Management
Ohio EPA PO Box 1049
Columbus, OH 43216-1049

>>> "TELIHA, KAREN" <kteliha@idem.in.gov> 1/31/2007 3:41:26 PM >>>
We're planning a workshop for our agency permit writers, rule writers,
enforcement case managers, and inspectors.  The goal of the workshop is
to present success stories from other states' agencies who've
implemented pollution prevention into permits and rules as well as
innovatively promoted P2 through inspections and SEPs.


Do any of you have success stories for your own state agencies in the
area of P2 regulatory integration?  I'd love to hear some examples as
well as who I can contact for more info.


Karen Teliha 
Pollution Prevention Branch 
Indiana Dept. of Environmental Management 


Attachment: RCCfinal1.pdf
Description: Adobe PDF document