INVENTORY OF USEPA/STATE PERMIT IMPROVEMENT INITIATIVES August 1995 USEPA Permits Improvement Team Lance Miller, Executive Director INVENTORY OF USEPA/STATE PERMIT IMPROVEMENT INITIATIVES TABLE OF CONTENTS Introduction I. Multimedia A. EPA HQ B. Region 1 C. Region 2 D. Region 3 E. Region 5 F. Region 6 G. Region 9 H. Region 10 II. Pollution Prevention (P2) A. EPA HQ B. Region 1 C. Region 2 D. Region 3 E. Region 5 F. Region 9 G. Region 10 III. Air A. EPA HQ B. Region 1 C. Region 2 D. Region 3 E. Region 5 F. Region 6 G. Region 10 IV. Hazardous Waste A. EPA HQ B. Region 1 C. Region 2 D. Region 5 E. Region 6 F. Region 9 G. Region 10 V. Water A. EPA HQ B. Region 1 C. Region 2 D. Region 3 E. Region 5 F. Region 6 G. Region 9 VI. PCBs A. EPA HQ B. Region 5 C. Region 9 INVENTORY OF USEPA/STATE PERMIT IMPROVEMENT INITIATIVES Introduction The Permits Improvement Team (PIT) was created in July 1994 to examine all of EPA's permitting programs (air, water, and hazardous waste) and identify how they can be improved. The Team consists of EPA, state, tribal and local government officials. It was recognized early on that a number of permit improvement initiatives were already completed or underway at EPA headquarters, the EPA regional offices and state, tribal and local governments. Rather than "reinvent the wheel", the PIT began to inventory these initiatives. This inventory was used to help the PIT identify specific recommendations on how to improve EPA's permitting programs. As the PIT's efforts proceeded, it also became evident that the inventory could serve another purpose. That being, to provide a source of information on what was already underway across the country to those involved in permitting at the federal, state, tribal and local level. This inventory was assembled by the PIT from information provided by EPA and other governmental officials. The process began by having each team member identify ongoing efforts in their jurisdiction. In addition, a general request for permit improvement initiatives was made of each EPA headquarters permitting and regional office. The same request was also made of the state associations for air, water and waste officials. The inventory was assembled and additions continued to be added as the PIT became aware of them. The inventory is organized first by category of permit improvement initiative (multi-media, pollution prevention, air, water, hazardous waste, PCB's) and then by government agency conducting the initiative (EPA headquarters, EPA region, state, tribal or local government). State, tribal and local government initiatives are presented by EPA region. Table 1 provides a listing of states and their associated region. The inventory is arranged by title of each initiative included. State, tribal and local government initiatives begin with the governmental organization for ease of reference. This document is envisioned to be continuously updated as new information becomes available to the PIT. The inventory is being placed on the Internet so that it can be accessible to all interested parties. In addition, it has been provided to the state associations electronically, so they can place it on any of their bulletin boards. If an EPA, state, tribal or local governmental official wants to update and existing entry or provide a new item they should send that information to Lance Miller, Executive Director PIT, USEPA, 2890 Woodbridge Ave., Mail Stop 100, Edison, NJ 08837. TABLE 1 STATES AND ASSOCIATED REGION STATE REGION STATE REGION Alabama 4 Nevada 9 Alaska 10 New Hampshire 1 Arizona 9 New Jersey 2 Arkansas 6 New Mexico 6 California 9 New York 2 Colorado 8 North Carolina 4 Connecticut 1 North Dakota 8 Delaware 3 Ohio 5 District of Columbia 3 Oklahoma 6 Florida 4 Oregon 10 Georgia 4 Pennsylvania 3 Hawaii 9 Rhode Island 1 Idaho 10 South Carolina 4 Illinois 5 South Dakota 8 Indiana 5 Tennessee 4 Iowa 7 Texas 6 Kansas 7 Utah 8 Kentucky 4 Vermont 1 Louisiana 6 Virginia 3 Maine 1 Washington 10 Maryland 3 West Virginia 3 Massachusetts 1 Wisconsin 5 Michigan 5 Wyoming 8 Minnesota 5 American Samoa 9 Mississippi 4 Guam 9 Missouri 7 Puerto Rico 2 Montana 8 Virgin Islands 2 Nebraska 7 INVENTORY OF USEPA/STATE PERMIT IMPROVEMENT INITIATIVES I. Multimedia A. EPA HQ Common Sense Initiative (CSI): Work group of industry executives, environmental leaders, government officials and labor and environmental justice representatives to focus on 6 pilot industries to find ways that tougher goals and greater flexibility can result in "cleaner, cheaper, smarter" performance in 6 areas: regulation, pollution prevention, reporting, compliance, permitting, and environmental technology. Status: Ongoing Contact: Vivian Daub, 202-260-6790 Customer Service Plans: Pursuant to Executive Order 12862, "Setting Customer Service Standards", EPA must establish and implement customer service standards to carry out the principles of the National Performance Review. The customer service plan describes customer service standards, future plans for customer surveys, and the agency's benchmark for customer services. Identification of training for managers and employees to carry out the customer service plans should also be included. Agency plan and 5 individual pilot plans for handling inquires, water grants management, conducting inspections, increasing public access to community right-to- know information and environmental permitting will be prepared. Status: Draft plans due to White House 8/25/95, final plans to be published 9/8/95. Contacts: Shelley Metzenbaum, 202-260-4719, Karl Hausker, 202-260-4335 Community Environmental Protection Approach: EPA initiated the Community Environmental Protection Approach to comprehensively protect entire ecosystems, an effort which is being led jointly by the Office of Water (OW), Office of Policy, Planning, and Evaluation (OPPE), and Office of Administration and Resource Management (OARM). In simplest terms, community environmental protection is place- based environmental management driven by the local needs of communities and ecosystems to achieve our national environmental protection and human health goals. EPA's experience with the Great Lakes, Chesapeake Bay, and National Estuary programs have proven the merits of a place- based approach. Several elements are necessary to achieve the community-based approach to environmental problem- solving that lies at the heart of ecosystem management: development of a framework for setting priorities and environmental objectives and for implementing actions with the stakeholders: development of national tools that can be used in place-based environmental management; and collaboration with a range of partners, both public and private. EPA's role will vary from one ecosystem to another -- EPA may work as a convener, facilitator or provider of tools, depending on ecosystem needs. Status: Ongoing Contacts: Maurice LeFranc, OPPE 202-260-4908, Ed Hanley, OARM 202-260-6980, Menchu Martinez, OW 202-260- 9818 Environmental Appeals Board Practice Manual: The Agency's Environmental Appeals Board is currently completing a manual explaining its operations. The Manual discusses rules applicable to appeals from Resource Conservation and Recovery Act (RCRA), Underground Injection Control (UIC), Prevention of Significant Deterioration (PSD) and National Pollutant Discharge Elimination System (NPDES) permits, and gives the reader practical information on how the appellate process works. It includes sample forms and pleadings. Status: Completed, 11/94 Contact: David Heckler, 202-501-7060 Environmental Justice: Environmental Justice Steering Committee established to provide Agency vision and overall program direction. Environmental Justice Policy Working Group formed to develop policy and coordinate multi-media issues. Each program and region has developed Environmental Justice Implementation Plans. National Environmental Justice Advisory Group formed with representatives of interested parties to provide advice to the Agency. Status: Ongoing Contact: Clarice Gaylord, Office of Environmental Justice, 202-260-0850 Environmental Leadership Program (ELP): In the June 21, 1994 Federal Register, EPA published a notice soliciting proposals for ELP pilot projects and outlining the eligibility criteria for facilities to participate. These pilot projects will explore ways that EPA and states might encourage facilities to develop innovative auditing and compliance programs and reduce the risk of non-compliance through pollution prevention practices. These voluntary pilot projects will encourage industry to take greater responsibility for self-monitoring, which can lead to improved compliance, pollution prevention, and environmental protection. EPA will recognize facilities for outstanding environmental management practices, and give them an opportunity to examine and address barriers to self- monitoring and compliance efforts. In addition, the projects will help EPA design a full-scale leadership program, and determine if implementing such a program can help improve environmental compliance. Status: Ongoing Contact: Tai-ming Chang, OECA, 202-564-5081 Environmental Management System (EMS) Standards: EMS provide structured ways to incorporate environmental principles and goals into a management decision framework. They can be applied by any organization interested in improving its overall environmental performance, both in terms of improved compliance and in moving beyond compliance in areas such as pollution prevention, life cycle assessment, and sustainable development. The International Standards Organization (ISO) is working to develop international EMS standards, while the National Sanitation Foundation (NSF) is developing a national EMS standard primarily for use by firms doing business in the US. Status: ISO standards to be completed in early 1996. NSF standards to be completed in early 1995 Contact: Jim Horne, OW, 202-260-5802 Environmental Technology Initiative (ETI): ETI, which was created by President Clinton in his 1993 State of the Union address, is coordinated by EPA's Innovative Technology Council. ETI is designed to accelerate environmental protection, strengthen America's industrial base and increase exports of U.S. technologies and expertise. ETI awards grants to states, tribes and federal agencies to: adapt EPA's policy, regulatory and compliance framework to promote innovation; strengthen the capacity of technology developers and users to succeed in environmental innovation; strategically invest EPA funds in the development and commercialization of promising new environmental monitoring control, remediation and pollution prevention technologies; and accelerate the diffusion of innovative technologies at home and abroad. Grants are also awarded to assist in private sector commercialization of successful technology projects and to the non-profit sector for innovative technology projects. ETI funding was set at $36 million for FY1994 and $80 million for FY 1995, with increases projected for future years. Status: Ongoing Contact: David Berg, OPPE, 202-260-2182 or Connie Sasala, OPPE, 202-260-9514 Office of Enforcement and Compliance Assurance (OECA): OECA is developing guidance in several areas that are relative to permitting: multi-media plain English guidance to regulations for the dry cleaning industry; Resource Conservation and Recovery Act (RCRA) Waste Analysis Plan guidance for boiler and incinerator furnaces; applicability and compliance guidance under the New Source Review provisions; and multi-media inspection enforcement program guidance and interim final status report. Other OECA activities include: completing work with Dun & Bradstreet to establish reliable corporate data linkages through Integrated Data for Enforcement Analysis (IDEA) System; developing demographic and ecosystem targeting methods to support Environmental Justice activities and ecosystem-based efforts such as addressing posted stream segments/contaminated sediments; developing and implementing a formal system for strengthening the participation of state, local, and tribal authorities in the development of OECA planning, priority setting, and policy development; pilot training in environmental justice communities designated to provide information on the basic statutory requirements; developing an ecosystem workplan; and re- engineering reporting using existing data and measures of significant noncompliance and compliance status/rates to incorporate multi-media, sector and environmental justice perspectives. Status: To be completed in FY 1995 Contact: Refer to September 20, 1994 memorandum from Steven Herman for specific office assignments. Call 202- 260-4134 Pesticide Regulation Integration: The Office of Water (OW) and Office of Pollution Prevention and Toxic Substances (OPPTS) working on a Memorandum of Agreement integrating NPDES and pesticide guidelines to provide permit writers and industry with information on how to incorporate pollution prevention into permits. Status: Ongoing Contacts: Donna Reed, OW, 202-260-9532; Karen Angulo, OPPTS, 703-305-5011 Sector Notebook Project: The Office of Compliance is developing information on 20 industry categories that will facilitate the transition from a single-media approach to a sector orientation and develop comparisons between industries for targeting purposes. Information to be compiled in each Notebook will include: general industry profile and regulatory requirements; environmental compliance profile; existing government/sector interaction; and pollution prevention activities being implemented by each sector. Status: Final Notebooks to be completed by 9/30/94. Contacts: Mike Barrette, 703-308-8676 or Greg Waldrip, 703- 308-8694 Senior Environmental Enforcement & Compliance Forum (SEECF): EPA and the Department of Justice created SEECF to work with states and tribes to coordinate environmental enforcement policy between the branches of government. Status: Ongoing Contact: Susan Susanke, OECA, 202-260-1008 Small Business Regulatory Reform: The EPA Small Business Ombudsman, in cooperation with other key EPA offices, the Small Business Administration, Office of Management and Budget's Office of Information and Regulatory Affairs, and five other federal agencies, have concluded a series of working group meetings. Participation in the project also included five small business sectors. As a result of these meetings, these agencies have jointly issued a Findings and Recommendations Report covering a number of environmental regulatory issues that significantly affect the small business community. Subjects covered in this project included recycling and waste disposal, chemicals and metals, trucking and transportation, restaurants, and food processing. The report has received widespread distribution throughout government and EPA. Follow-up activities for EPA implementation of the report's findings and recommendations, as well as implementation actions by other federal agencies that participated, are underway. Status: Report complete, implementation ongoing Contact: Karen Brown, OASBO/OSDBU, 703-305-5938 State/EPA Capacity Steering Committee: Joint policy statement on state/EPA relations developed that specifies the underlying basis for the relationship. This relationship is based on states being the primary environmental managers and EPA's primary roles being standard-setting, program review, research, collection/analysis/ sharing information, and technical assistance. Governing principles are: clear goals and expectations; clear roles and responsibilities; open and honest communication; shared responsibility and accountability for success; mutual respect, trust, and continuous improvement; and mutual commitment to pollution prevention. Status: Report of the Task Force to Enhance State Capacity issued July 1993; Draft State Capacity Implementation Plan issued 4/21/93; Joint Policy Statement on State/EPA Relations issued 7/14/94, National Environmental Performance Partnership System signed 5/17/95 Contact: Chuck Kent, State/EPA Capacity Implementation Team, OROSLR, 202-260-2462 Sustainable Industries: Initiated in 1991 by OPPE, the fundamental goal of the Sustainable Industries program is an industry-specific approach to policymaking that focuses on promoting "cleaner, cheaper, smarter" solutions to environmental problems. The Sustainable Industries projects use the "backward mapping" approach, evaluating corporate decision-making factors (both "drivers" and barriers) that affect the environmental and economic performance of firms in the industries studied. Knowledge of these factors was then used to develop policy recommendations that seem most likely to achieve long-term eco-efficiency in the industries studied. Information was drawn from multi-stakeholder groups that included representatives from the industries, EPA, environmental organizations, and other key constituencies. Status: First phase completed in July 1994, working with the metal finishing, photoimaging, and thermoset plastics industries. Phase 2 of the metal finishing project is being pursued within the CSI; the thermoset and photoimaging projects are continuing within the Sustainable Industries program. Contact: Bob Benson, OPPE, 202-260-8668 B. Region 1 Region 1 - Environmental Justice: 1) Developing a matrix to better target inspections. The matrix uses criteria that combine regional and national initiatives and geographic targeting. 2) Developing a composite drawing on GIS of storage installations that will display the relative vulnerability of principal water sheds, feeder tributaries, recreational shorelines and natural habitats to potential pollution. Using EPA Region 1 EJ data project classifications will allow for additional analysis to obtain information on the total number of facilities falling into each of the EJ classifications. Status: 1) Complete; 2) Scheduled for completion 6/94 Contact: Environmental Services Division; 617-860-4316 Connecticut - Environmental Permitting Re-engineering and Restructuring Plan: CT DEP in consultation with the Environmental Permitting Task Force and their consultant prepared a plan to streamline their permitting processes. The plan includes the DEP's permitting mission and provides specific recommendations to: simplify and standardize workflows; eliminate redundant and nonsubstantive activities; eliminate processing bottlenecks; prioritize applications in a consistent manner; simplify application forms and provide applicants with checklists for completing applications; revise current fee structures, including reviewing fee amounts, fee collection, and other potential revenue sources for the department; streamline and eliminate unnecessary hearings; streamline the ways businesses report spills; share routine inspection reports with subject companies; use private contract services in the review process, and allow for the use of private consultants to certify whether permit applications are complete. Other recommendations focus on communication and outreach; coordination and management; information technology; and human resources and training. Report includes survey of 43 other state permit streamlining efforts. Status: Final Report issued 3/1/93 Contact: Robert Kaliszewski, Permit Ombudsman CT DEP, 203- 424-3003 Massachusetts - Environmental Protection Integrated Computer System: EPICS takes information supplied by 12 separate MA Department of Environmental Protection (DEP) divisions, including air emissions, hazardous waste and water supply, and combines it into a single database. This gives DEP employees instant access to all of the agency's information and allows them to search for data on a facility by entering its name and location. This and a two year cross-training program have allowed for inspectors to do multi-media inspections. Status: Online Contact: Patricia Deese-Stanton, Assistant Commissioner, MA DEP 617-292-5853. Massachusetts Permit Streamlining Legal Advisory Committee: The Legal Advisory Committee was established by the Secretaries of Environmental Affairs and Economic Affairs and included representatives from business and environmental constituencies. The Committee prepared a report, highlights of which are: * recommendations for outreach (permitting manuals, preapplication conferences, permitting assistance office, with regional presence, easy access to agency policies) * recommendations for coordination of permitting (single point of contact, coordination among different agencies issuing media- specific permits for single project, permit ombudsmen for projects) * recommendations for increased use of general permit mechanism in appropriate situations with emphasis on enforcement of permit conditions * recommendations for uniform timeframes for steps in permit process and decisions * recommendations for master uniform reporting form to be submitted on single annual date for all permits with annual reporting requirement * recommendation for additional study of issues involved in consolidated or integrated permit approach. Status: Final Report April 1995 Contact: Marilyn L. Sticklor, Co-Chair, Goulston & Storrs, 617-482-1776 C. Region 2 New York - Regulatory Reform: The NY Department of Environmental Conservation (DEC) established an internal regulatory review group to identify regulatory reforms for the agency. The first report includes regulatory reforms in nine areas: eliminating unnecessary reviews/accelerating the permit process; encouraging voluntary site cleanups; expanding programs to help business comply with regulatory requirements; accelerating the permit hearing process; reducing DEC staff review of certain projects by increasing reliance on Professional Engineer certifications provided by applicants; reducing duplicative regulation among federal, state and local governments; improving information systems to reduce workloads on both department staff and the regulated community; eliminating unnecessary reporting requirements; developing resource management plans as a way to establish environmental goals within whole natural systems, ecosystems or areas; and creating a framework for expedited permitting. Status: Report issued July 1994; second progress report due spring of 1995. Contact: Lou Concra, NY DEC, 518-457-7424 D. Region 3 Delaware - Natural Resources and Environmental Control Permitting Reform Project: Permitting reform initiated in January 1994 to; maintain or improve environmental protection, achieve clarity in the permitting process, simplify permitting processes, promote efficiency in permitting, and achieve consistency. Flow charts prepared for each permitting process. 135 recommendations developed for specific permits and general action. Status: Final Report dated August 12, 1994 Contact: Phillip Cherry, 302-739-6400 Maryland - Multi-media Permits: As an added service to business and industry, the MD Department of the Environment (MDE) offers the opportunity to acquire multi-media permit coverage. This service is not only extended to new business and industry locating in Maryland, but to existing industry where multiple permits are required. Status: Ongoing Contact: Dana Bauer, MDE Water Management Division, 410- 631-3512 Maryland - Environmental Permits Service Center: The Center is designed to provide the public and regulated community with a consolidated environmental permits process that is more efficient, comprehensive, and proactive in meeting their management objectives. The Center will improve services to businesses, local governments, community organizations and interested citizens by: providing timely permit information and reliable permit guidance; enhancing staff skills through cross-training; improving coordination on air, water, and waste regulatory issues; incorporating pollution prevention into everyday regulatory requirements; including community involvement up front in the regulatory process; and instilling timeliness and accountability for meeting permit milestones. Status: Center opened 12/1/94 Contact: Mitch McCalmon, MDE, 410-631-3772 Pennsylvania - Process Improvement Team (PIT): The PIT was formed to study permitting and compliance processes of PA's Department of Natural Resources (DNR) and make recommendations on ways to increase environmental protection while improving the efficiency of our processes, reducing the current backlog of permits, and seeking more effective ways of achieving compliance. The PIT focused on four main program areas: residual waste, National Pollutant Discharge Elimination System (NPDES), sewage sludge and wetlands. The PIT identified ten major issues: administrative changes; automated production and electronic storage for permit documents; data management; public notification and comment; standardizing/streamlining minor sewage permits; watershed toxics analysis and its relationship to the permitting process; increased pollution prevention focus; fee structure; training and communications; and watershed teams. Recommendations were developed for each area. Status: Final report released 2/24/94. Implementation ongoing. Contact: Stuart Gansell, DNR, 717-787-8184 E. Region 5 Michigan - Auto Project: Target certain chemicals and develop voluntary effort to review controls. Status: Ongoing Contact: Marcia Horan, 517-373-9122 F. Region 6 Region 6 - Multimedia Permits Team: Interdivisional permits quality action team formed to develop a permit process to ensure high-quality EPA/state coordination in all permit programs. The Team interviewed internal and external customers of the permitting process and developed recommendations in a number of areas. The Team also developed a permit access system, which provides integrated access to EPA's data systems which contain information on permit status. Status: Recommendations made to Region 6 management; Permit Access System has been piloted on a small scale Contact: Gus Chavarria, 214-665-7165 Oklahoma - Uniform Permit Process: Tiered system developed for four categories: new sources; existing sources (facility in operation - new permits); existing sources (facility in operation -permit renewals and modifications); and plans and certifications. The tiers have different levels of public notice, public input and decision-makers. Status: Online Contact: Steve Thompson, OKDEQ, 405-271-7339 Texas - Permit Processing Review Initiative: The TX Natural Resource Conservation Commission (TNRCC) identified and evaluated issues and/or concerns of agency stakeholders relating to the fundamental permitting processes across the agency. Report summarizes 77 recommendations to be implemented and 41 that have been implemented. Status: Report dated 8/1/94 Contact: Chris Macomb, Director Watershed Management Div., TNRCC G. Region 9 California - Office of Environmental Technology: California's Environmental Protection Agency (Cal/EPA) is proposing the formation of an Office of Environmental Technology which will manage a process for the evaluation and certification of environmental technology. The concept has been piloted in the Department of Toxic Substances Control for several hazardous waste technologies. Status: Authorizing legislation will be sought. Contact: Michael Kahoe, Deputy Secretary, Cal/EPA, 916-322- 5844 California - Permit and Regulatory Reform: Efforts began in 1992 to reform permitting processes by examining the requirements for a permit, how permits are processed, recordkeeping and paperwork requirements and interaction among permitting, data reporting, enforcement and planning functions. Recommendations developed in 1992 and implemented in 1993-1994 cover: regulatory assistance; one-stop permit centers; establishment of permit teams to coordinate permitting on major projects; regulatory reform task forces for specific industries; programmatic reviews; reducing the number of activities needing individual permits; consolidating monitoring data report requirements; developing a uniform permit tracking system; and legislative reform. A February 1995 report summarizes the status of these reforms. Status: Varies Contact: Patrick Dorais, Cal/EPA, 916-322-2858 California - Permit Relief Communities: Environmental regulation in California is complicated by the array of implementing agencies at the state and local levels. California is proposing the formation of "Permit Relief Communities," each of which would develop a single compliance assurance plan representing all state and local environmental requirements for its community. Companies would be required to comply with the community compliance assurance plan. The initial stage will be development of pilot "Permit Relief Communities" to test the concept. Authorizing legislation is required. Status: Cal/EPA is working with its regulatory agencies to organize a work plan; consultation with interest groups will also be initiated soon. Contact: Michael Kahoe, Deputy Secretary, Cal/EPA, 916-322- 5844 California - Reduce Individual Permits Through More Registration Processes: Promote the use of general permits in each of the media programs; in addition, share with EPA toxicology information that California develops as part of its pesticide registration process, so that EPA's registration of pesticides is also accelerated. Status: General permitting has been implemented in the hazardous waste and solid waste programs and will be more fully expanded within the water program in FY95. Legislation is needed to authorize the State Board to issue general permits for land application of treated effluents. Contact: Paul Blais, Special Assistant to the Secretary, Cal/EPA, 916-324-7584 California - Unified Environmental Statute: A comprehensive organic environmental statute that would address air and water quality, solid and hazardous wastes, pesticides and scientific risk assessment will be proposed by Cal/EPA. Status: A commission has been formed that will put forth a proposal early in 1995. Contact: Micheal Kahoe, Deputy Secretary, Cal/EPA, 916-322- 5844 H. Region 10 Alaska - Assistance Project: Alaska has established an assistance project to consolidate services to the business community in permits, compliance and pollution prevention. This project will serve as an initial "one-stop shopping" opportunity for the regulated community, and includes providing information on pollution prevention as a cost-effective way to achieve compliance and reduce the need for permits. This project will also encourage inclusion of P2 in permits and examine multi-media coordination. Status: Ongoing Contact: David Wigglesworth, 907-563-6529 Oregon - Cross-Media Risk Assessment Model: OR's Department of Environmental Quality (DEQ) has developed, with assistance from EPA, a cross-media risk assessment model to be used during permit application review and development. The model evaluates the long-term fate and transport of toxic chemicals discharged to the environment and evaluates alternative approaches during permit review. Status: Implementation has been initiated. Contact: Marianne Fitzgerald, DEQ, 503-229-5946 Oregon - Permits Handbook: DEQ has issued a new permits handbook which provides guidance on obtaining environmental permits and includes a policy statement on pollution prevention. Readers are encouraged to contact regional offices for assistance. Status: Handbook is available at all DEQ offices. Contact: Carolyn Young, DEQ, 503-229-6271 Washington - Governor's Task Force on Regulatory Reform: External task force preparing reports on various activities across state government. Draft reports prepared on alternative approaches, with a focus on voluntary compliance, and on rules review, focusing on a procedure for reviewing priority rules and establishing a streamlined rules repeal procedure. Status: Final report issued 1/95 Contact: Phil Miller, 360-407-6985 Washington - Joint Aquatic Resources Permit Application: Piloting use of a new single application form for six different types of federal state and local permits related to projects in shoreline areas. Status: Ongoing Contact: Bonnie Shorin, 360-407-7297 Washington - Land use Planning and Permitting Reform: Integrate and Streamline state land use planning and permitting by: integrating the procedures for comprehensive land use planning and development regulations with procedures for environmental impact review and the procedures for shoreline planning under three different statutes; "front-load" the analysis and mitigation of environmental impacts of land use development during preparation and adoption of comprehensive plans and development regulations by local government; streamline project permit review procedures and create more certainty at the permitting stage by relying on those "front-end" plan and regulatory decisions and eliminating duplicative reconsideration of decisions. Status: Recommendation developed as part of Task Force on Regulatory Reform Contact: Phil Miller, 360-407-6985 Washington State - Single Permit Feasibility Study: Determining the feasibility of combining air, water quality, and hazardous waste permits for a single facility into one permit. Piloting with one or more volunteer facilities. Status: Ongoing Contact: Hugh O'Neill, 360-407-6118 Washington - State and Local Permit Coordination: Proposed legislation to create a procedure for coordinating all required state and local permits through designation of a lead permit manger and active management of an agreed-upon permit processing timeline. Coordination procedure would be made available at an applicant's option. Status: Recommendation developed as part of Task Force on Regulatory Reform Contact: Keith Phillips, 360-407-6907 II. Pollution Prevention (P2) See also; Section III.A; Air Permitting Improvements, and Flexible Permitting Section IV. A; Permitting Subcommittee Section IV. G; Alaska Permitting A. EPA HQ Pollution Prevention Information Clearinghouse (PPIC): The PPIC is dedicated to reducing or eliminating pollutants through technology transfer, education, and public awareness. It is operated by EPA's OPPTS. The Clearinghouse is a free, non-regulatory service that consists of a telephone reference and referral service, a distribution center for selected EPA documents, and a special collection available for interlibrary loan. Status: On-Line Contact: Labat-Anderson, Incorporated, under contract for EPA, 202-260-1023 Pollution Prevention Integration Initiative (P2IN): The Office of Prevention, Pesticides and Toxic Substances (OPPTS) has organized and is expanding its electronic, Agency-wide network of pollution prevention contacts. The goal of this network is to: (1) exchange information that can serve as a "road map" in identifying what prevention activities are occurring and where and who the experts or points of contact are; (2) identify how prevention is being institutionalized into EPA's mainstream activities; (3) put the Agency in a position to facilitate proactive inter- office and cross-program communication and information sharing so as to further pollution prevention opportunities and integration; (4) generate projects and initiatives -- e.g., the Common Sense Initiative and Environmental Technology Initiative. Status: Ongoing Contacts: John Shoaff, OPPTS 202-260-1831, or Julie Lynch, OPPTS, 202-260-4000 Pollution Prevention (P2): State Efforts to Integrate P2 into Their Activities: USEPA report summarizes efforts of 41 states concerning P2. One of the program elements discussed is permitting, both multimedia permitting and the integration of P2 into individual media permits. Twenty-five states have a section describing their permitting efforts. Other topics covered are legislation, inspections, enforcement, data integration and organization. Status: Report dated 9/93, EPA/742/B-93-002 - "Ongoing Efforts by State Regulatory Agencies to Integrate Pollution Prevention into Their Activities" Contact: Lena Ferris-Hann, Pollution Prevention Div., OPPTs, 202-260-2237 Source Reduction Review Project (SRRP): In the SRRP, the Office of Pollution Prevention and Toxics (OPPT) has taken the lead in working with other program offices to incorporate pollution prevention into regulations the Agency is developing, specifically Clean Water Act effluent guidelines, Resource Conservation and Recovery Act (RCRA) hazardous waste listings, and Clean Air Act Maximum Achievable Control Technology (MACT) standards. During the three years of this project, changes have occurred in the way information is collected for rulemaking, analysis is done and standards are set. Status: Ongoing for individual rulemakings. A white paper on SRRP opportunities, barriers and options for overcoming these barriers is being prepared. Contact: Kathy Davey, Pollution Prevention Div., OPPT, 202- 260-4164 B. Region 1. Connecticut - Publishing & Printing Pollution Prevention Process: Develop outreach material to promote pollution prevention in the Publishing and Printing Industry. Status: Ongoing Contact: Mary Sherwin, 203-566-5217 C. Region 2. New Jersey - Solvents Emissions at Automobile Plants: Incorporating pollution prevention planning requirements targeted at solvent emissions into permits for automobile manufacturing plants. The permits require the facility to conduct a waste minimization assessment for solvents, and contain specific suggestions for actions that should be taken in the waste minimization assessment. As a condition of the permit, the facility must also document annual emissions of solvents and show trends in solvent use per unit product. Status: Ongoing Contact: Louis Mikolajczyk, Chief Bureau of NSR, 609-292- 9258 New York - Waste Reduction for Electronics Industry: Waste reduction guidance, re: opportunities, assessments, methods included, four workshops for technical assistance and outreach. Status: Completed Contact: John Iannotti, 518-457-7267 D. Region 3. Maryland - Pollution Prevention: With support from EPA's Office of Pollution Prevention, Maryland has undertaken several projects aimed at integrating pollution prevention with the regulatory programs. Included are such things as training for Departmental staff, exploring opportunities with banking institutions for financial incentives through loan programs with industry, and expanding on existing efforts to employ pollution prevention credits during negotiated settlement processes. Status: Ongoing Contact: Dana Bauer, MDE Water Management Division, 410- 631-3512 E. Region 5 Illinois - "Top of the Pile" Review for Voluntary Pollution Prevention Proposals: Illinois EPA conducts expedited or "top of the pile" review for permit applications, variance petitions, site specific standard or rule petitions that address voluntary pollution or recycling proposals. The proposal can be a new process employing pollution prevention/recycling technology or can be a modification to an existing process. The environmental benefits of the proposal must be quantified relative to the status quo; the proposal must be a "significant departure from previous practice at he facility" and the facility must justify why it needs special processing by Illinois EPA. A statutory modification was passed to enable the agency to conduct these expedited reviews. Status: Ongoing Contact: Tom Wallin, Office of Pollution Prevention, 217- 782-8700 Ohio - Automotive Pollution Prevention Project: Reduce the generation and release of persistent toxic chemicals by the automotive industry in the Great Lakes Basin. Status: Ongoing Contact: Michael Kelly, 614-644-2980 F. Region 9 Arizona - Environmental Leadership Program: Pollution prevention with emphasis on streamlining permitting, inspections and self-audits. Status: Formative Contact: Beverly Westgard, 602-207-2203 G. Region 10 Alaska - Facility Planning: Alaska has begun a process to determine the future of pollution prevention facility planning. As a first step, Alaska is reviewing P2 facility planning efforts in Alaska and the nation. Upon completion of this review, Alaska will convene a partnership of public and private entities to determine what will work best for Alaska, and to make formal recommendations to the Commissioner and the legislature. Status: Ongoing Contact: David Croxton, 907-563-6529 Alaska - Permit Fees: Alaska is examining incentives to foster P2 through reductions in permit fees for facilities that implement P2 planning. Status: Ongoing Contact: David Wigglesworth, 907-563-6529 Oregon - Regulatory Guidance: The Handbook of Regulatory Guidance for Oregon Construction Contractors was developed to compile the myriad of environmental regulations the construction industry is guided by. The document sets the stage for a companion document entitled "Environmental Handbook for Oregon Construction Contractors: Best Pollution Prevention Practices", that highlights best pollution prevention practices for the construction industry. Status: Completed Contact: Sandy Gerkowitz, 503-229-5918 Washington - "Snapshots" Program: Modelled after "Shopsweeps" (see Section III.G. below) for the printing industry, but multi-media (air, hazardous waste and water) with a focus on pollution prevention. Educational materials on compliance and P2 were developed in conjunction with the industry and 1200 facilities are currently being visited by state and local government personnel. Status: Ongoing Contact: Darin Rice, 360-407-6743 III. Air A. EPA HQ Air Permitting Improvements: The Office of Air Quality Planning and Standards (OAQPS) is working with a contractor (RTI) to survey what pollution prevention initiatives are being utilized in the states and what next steps the Air program should focus on. Status: Ongoing - draft report due to be completed 8/95, final report by 9/95 Contacts: Leo Stander, OAQPS, 919-541-5589; Melissa Malkin, RTI, 919-541-6154 Compliance Assurance Monitoring Rule: Office of Air and Radiation will be proposing a flexible approach to Clean Air Act monitoring requirements. Rules would be written to address differences among regulated facilities instead of a blanket rule for all permittees. Sources would have to comply with the monitoring requirements only after regulatory guidance is issued. Status: Proposal due by 12/95, final rule due 6/96 Contact: Peter Westlin, OAR, 919-541-1058 Flexible Permitting: Projects with Intel facility in Region 10 and Merck facility with state of Virginia. Office of Air Quality Planning and Standards (OAQPS) has work assignment with RTI to look at examples of innovative air permits in the Regions/states, with emphasis on pollution prevention. (See Section II.G. below for more detail on Intel permit.) Status: Intel permit complete; Merck permit ongoing Contact: Intel permit: Dave Dellarco, Region 10, 206-553- 5973; Merck permit: Mike Trutna, OAQPS, 919-541- 5345 or Jesse Baskir, RTI, 919-541-5882 New Source Review (NSR) Reform: Subcommittee of industry, environmental organizations, and state and local agencies developed draft recommendations to reduce the complexity and perceived impediments to speedy review of the current systems, while maintaining the environmental goals and benefits. Recommendations have been drafted in the following areas: NSR permitting issues associated with near Class 1 areas, procedures and coordination, determination of adverse impacts, and mitigation of source impacts; Best Available Control Technology/Lowest Achievable Emission Rate (BACT/LAER), BACT/LAER clearinghouse and presumptive BACT, BACT/LAER criteria and innovative control technologies and pollution prevention; impact of existing sources in Class 1 areas; and NSR applicability. Regulations being proposed to incorporate the recommendations. Status: Recommendations from subgroup completed July 1994; Regulatory proposal under development. Contact: David Solomon, 919-541-5375 B. Region 1 Region 1 - Air Permitting Improvements: Working on a number of state initiatives: With CT to develop general permits establishing technical standards to "keep small sources small"; with MA to put technical standards into state Implementation Plans (SIPs) - so that as long as a source fits within a category described, a small source stays small; with MA on a rulemaking regarding operating permits -- to issue small-scale operating permits with restrictions to keep companies out of the full-blown permitting process -- and considering the use of this process for toxics as well as criteria pollutants; and with MA on pollution prevention guidance, to implement the concept of comparing actual to future predicted actual emissions when evaluating pollution prevention changes (vs. the traditional rule in the Prevention of Significant Deterioration (PSD) and New Source Review (NSR) programs of comparing actual to potential emissions, which may discourage pollution prevention). Status: Ongoing Contact: Lynne Hamjian, 617-565-4181 C. Region 2 New Jersey - Air Permitting Program: Seeking to use facility-wide pollution permit as the air operating permit for the first 5-year term of the facility- wide permit. Other initiatives include: technical manuals that provide a comprehensive list of requirements that are applicable to a specific type of equipment; permit application checklists to provide a comprehensive list of items that must be included in an application; holding public hearings when an application is received; categorizing permit applications into levels with different procedures based on complexity; and permit workshops to provide guidance, training and information to applicants. Status: Complete Contact: William O'Sullivan, NJ DEP, 609-984-1484 New Jersey - Asphalt Manufacturers Good Operating Practice Requirements in Permits: New Jersey has been incorporating good operating practice requirements targeted at air pollution control into both New Source Review and other New Jersey air permits for asphalt manufacturers. The permittees must report to the state quarterly on the good operating practices they have undertaken. Examples of effective practices are listed in the permit (e.g., adjusting burner systems to optimize fuel atomization and fuel/air mixing). The facility is not limited to these measures, but they must show that they have taken some measures. The program was developed in conjunction with the industry which helped identify the good operating practices. Status: Program has been successfully in place 5 years Contact: Louis Mikolajczyk, Chief, Bureau of NSR, 609-292- 9258 New Jersey - Reasonable Available Control Technology (RACT) for VOCs and NOx: Two RACT rules in New Jersey contain pollution prevention provisions: a. Sources at major facilities that are required to show compliance with the requirement to collect greater than 90% of VOC emissions are explicitly allowed to use pollution prevention measures in their demonstrations of compliance. Use of compliant surface coatings with low VOC content is considered to meet RACT and no control devices are then required. Use of low VOC volume percentage solutions meet RACT in graphic arts operations except for screen printing operations, and no control devices are required. b. The NOx RACT standard for non-utility boilers with heat input of between 20-50 million BTUs per hour requires facilities to annually adjust the combustion process of the boiler. This is a pollution prevention measure to reduce emissions that also saves fuel. Status: Ongoing Contact: Louis Mikolajczyk, Chief, Bureau of NSR, 609-292- 9258 D. Region 3 See "Flexible Permitting" under Section II.A. above. E. Region 5 Region 5 - Data Management: The implementation of the Title V operating permits programs will require the transfer of enormous amounts of information between the states and Region, including draft, proposed and final permits, applications, amendments and technical support documents. The ability to effectively transfer and manage this information in an electronic format is critical to the success of the state programs and Federal oversight (which must occur on strict timelines). Region 5's Air and Radiation Division (ARD) has formed a data management workgroup to concentrate on the issue of permit information transfer and management. The workgroup is reviewing software options for internal permit review and management purposes and is also working with each state to develop complimentary systems which will allow for electronic transfer of information among offices. In addition, the workgroup is developing an electronic database fact sheet to be used as a cover sheet by the states which will highlight various criteria and assist the Regional permit reviewer in identifying permits of concern; this database could also be used as a management tool for sorting and compiling statistics. The workgroup is developing options for the near term as some of our states are close to Title V approval, and long term solutions which involve applying for various resource assistance grants to fully computerize and integrate the entire process. Status: Ongoing Contact: Genevieve Nearmyer, 312-353-4761 Region 5 - Differential Oversight: Beyond trying to ensure individual permits meet all Clean Air Act requirements, the goal of the Air and Radiation Division (ARD) is to develop competent, self-sustaining state permit programs. To further this goal, ARD developed a system which utilizes the Section 105 grant process and differential oversight to encourage states to improve and/or maintain high quality permit programs. Specifically, a portion of the ARD workload model which allocates Section 105 grant resources among the states is performance-based, and one of the areas of review is NSR permitting. Criteria were developed which evaluate the state permitting programs in five categories, including notification, applicability, permit drafting issue resolution and improvements. Each year, states are evaluated and the portion of available NSR grant monies awarded to each state is dependent on its score. In addition to the resource benefit, states which achieved excellent ratings in all categories receive less real time individual permit review in the next year by the ARD permit review staff. For future years, since Title V permit fees will cover the costs of state permitting, the resource portion of the differential oversight incentive will no longer be applicable. However, ARD will continue to evaluate state permitting programs, including Title V, using this performance-based approach. The reward for quality programs will continue to be a reduction in real time Federal oversight of individual draft permits. Status: Ongoing Contact: Cheryl Newton, 312-353-6730 Region 5 - Permit Review Priorities: In recognition of the enormous numbers of draft permits which are sent to the Region for review under the state New Source Review construction permit programs, the Air and Radiation Division (ARD) developed a priority scheme which classifies permits into three categories. The categories represent three levels of review priority and cover issues such as geographic area (attainment versus nonattainment, proximity to Class I areas or Native American lands, etc.), synthetic minors, and industry type (e.g., power plants and waste management facilities). This procedure helps individual permit reviewers prioritize their workload to concentrate on issues of concern and best assess overall state permitting. Currently, the ARD is developing a similar priority scheme to help evaluate and prioritize the influx of state operating permit drafts expected in the near future. Status: Ongoing Contact: Ronald Van Mersbergen, 312-886-6056 Minnesota - Improvements to Air Emission Permitting Process: The following streamlining initiatives are being worked on by the MN Pollution Control Agency (MPCA) and Office of the Attorney General: 1) Registration permits/control equipment rule. New rules effective on December 26, 1994 are designed to allow small sources to obtain a very streamlined registration permit instead of the more detailed and time-consuming individual source permits. It is expected that this rule will cover half of the sources that need air emission permits; these sources account for less than ten percent of Minnesota's emissions. The rule is designed to impose needed emission requirements on these sources without engaging in a long permit issuance process. The new rule also imposes standards of performance for use of control equipment that would allow sources to take credit for emission reductions caused by control equipment in determining what type of permit is required. These enforceable emission reductions allow sources to obtain less complicated permits by establishing limits on the source through the control equipment rule. 2) Emphasis on general permits. Minnesota is emphasizing general permits to handle most of the sources not handled by the registration permit rule. For example, general permits are being developed for asphalt plants and sand and gravel facilities. These permits spell out the typical requirements for sources in these categories. Individual sources that need special conditions not present in the general permit would need an individual permit, but the general permit would cover almost all sources in a particular category. Minnesota is increasing the usefulness of the general permit by including typical alternative operating scenarios that a source category might want to use. That way, certain common changes at a source do not require a new permit; the general permit includes the new limitations that apply to the new activity as an alternative scenario. 3) 3M flexible permit. For sources too complex or large to include in the registration permit or general permit categories, Minnesota is gaining experience at permitting a source in a way that allows flexibility in operations to be authorized in the permit rather than through numerous amendments over time as the facility changes. One permit of this type has been issued to 3M. In exchange for voluntarily lowering its overall emission limit for the facility, 3M received authorization for a great deal of flexibility in changing its operations as long as it remains below the lower emission limit. Once such flexibility is allowed, the hardest issue is how the changes and resulting emissions will be monitored and recorded. The permit deals extensively with the monitoring and recordkeeping required for the various changes 3M is authorized to make. 4) Streamlining the permit template. Minnesota is trying to reduce the size and complexity of its air emission permits by creating a more streamlined permit template. The intent is to present emission limits, reporting requirements and compliance schedules in table format, and to reduce the paraphrasing of rule text in the permit by simply referring the permittee to the rule (i.e. the permit does not restate the performance test procedures but refers the permittee to the proper rule which sets out those procedures). Status: Complete/Ongoing Contact: Ann Seha, Assistant Attorney General, 612-297-8755 F. Region 6 Texas - Air Preconstruction Permit Process: The TX Natural Resource Conservation Commission (TNRCC) has adopted new rules that provide for a new, more flexible type of permit for new facilities and modifications to comply with air emission standards. Under these rules, the applicant must submit information that demonstrates that the following criteria are met: protection of public health and welfare; measurements of emissions; Best Available Control Technology (BACT); Federal New Source Performance Standards (NSPS); National Emission Standards for Hazardous Air Pollutants (NESHAPS) and Maximum Achievable Control Technology (MACT); performance demonstration; air dispersion modeling or ambient monitoring; and proposed control technology and compliance demonstration. Status: Rules adopted November 25, 1994 Contact: Mary Ruth Holder, TNRCC, 512-239-1966 Texas - Flexible Air Permit Based on Emissions Cap: Flexible air permits based on emissions cap are used as an alternative to current preconstruction requirements. One permit is issued for a given plant or site, but it can contain multiple emissions caps or multiple individual emissions limits. Status: Program began this year and at least one permit has been written. Contact: Victoria Shu, TNRCC, NSR, 512-239-1230 G. Region 10 Region 10 and Oregon - Air Permitting Improvements: In 1993, Intel Corporation, EPA and the Oregon Department of Environmental Quality (DEQ) joined in a partnership to evaluate opportunities to incorporate flexibility and pollution prevention into permits issued under Title V of the Clean Air Act as amended in 1990. The project created a Title V permit that will demonstrate the ability of P2 to perform equally as well as traditional end-of-pipe controls. The permit contains the following requirements: * Emission limits and performance standards * Plant Site Emission Limits * Reasonably Achievable control Technology (RACT) standards * Aggregate Hazardous Air Pollutant emission limits * Pollution Prevention condition * Pre-approved changes * Monitoring requirements * Reporting requirements * General conditions Status: Final permit issued Contact: David Dellarco, Region 10, 206-553-4978 Oregon - Title V Permits: Oregon DEQ instituted a pilot program for a select group of affected sources in an effort to detect and resolve problems in the Title V application and permitting process. Status: Ongoing Contact: Shelly McIntyre, Oregon Department of Justice, 503-229-5725 IV. Hazardous Waste A. EPA HQ Innovative Approaches to Resource Conservation and Recovery Act (RCRA) Permitting: Evaluating past and present suggestions for innovative RCRA permitting. Developing, in accordance with the RCRA Implementation Study and National Performance Review, recommendations for improving the RCRA permitting process. Current initiatives include: updating and compiling permit writer "part B" checklists; examining ways to simplify modification and renewal processes; and submitting an Environmental Technology Initiative proposal for the development of permitting software and innovative inspector tools. Status: Options Paper 5/24/94, ETI proposal 9/22/94 Contact: Ken Amaditz, OSW, 703-308-7056 RCRA Expanded Public Participation Rule: Proposed rule (June 94) to provide for earlier and more meaningful public participation. Status: Final Rule expected late summer 1995 Contact: Tricia Buzzell, OSW, 703-308-8632 RCRA Post Closure Rule: Proposal to allow permitting agency to substitute enforcement or other authority in lieu of a post-closure permit. Status: Anticipated final rule early 1996 Contact: Barbara Foster, OSW, 703-308-7057 RCRA Siting Workgroup: Develop options and recommendations for RCRA policy on facility siting issues, examining both technical and environmental justice concerns. Status: Ongoing - recommendations expected to be developed for consideration by AA in Fall of 1995. Contact: Vernon Myers, OSW, 703-308-8660 Authorization of Indian Tribes Hazardous Waste Programs under RCRA Subtitle C: Rule would give Tribes the authority to implement Subtitle C in whole or in part. This is different than current requirements for states, which must adopt the entire program. Status: To be proposed in early 1995. Contact: Felicia Wright, OSW, 703-308-8634 RCRA Waste Minimization National Plan Steering Committee: Four subcommittees have been established, one of which is the permitting subcommittee as described below. Status: Developing a broad strategy for minimizing all hazardous waste. Contact: Donna Perla, 703-308-8402 Permitting Subcommittee: Examine approaches used to incorporate waste minimization/pollution prevention into RCRA permits; develop national guidance and training to promote waste minimization in RCRA permits; identify and resolve crosscutting and multi-media pollution prevention permit, inspection and enforcement issues. Status: Ongoing Contact: Jim Lounsbury, 703-308-8463 B. Region 1 Region 1 - RCRA Permitting Improvements: Working with CT on a permit streamlining project to develop a guidance manual for implementing contingency plans for treatment, storage and disposal facilities. The guidance will try to differentiate between highly hazardous substances vs. more "routine" hazardous wastes - then have permit requirements to better reflect the real risks. Status: Ongoing Contact: John Podgurski, 617-573-9680 C. Region 2 Region 2 - RCRA Prioritization System - Inclusion of Environmental Justice (EJ) Factors: Incorporate EJ factors into environmental benefits ranking. The inclusion of EJ factors will ensure that the Agency properly evaluates human health and environmental issues for minority and low-income populations in proximity to RCRA regulated facilities. The environmental benefits ranking along with the NCAPS ranking determines the overall facility priority in RCRA permitting and corrective action program activities. Status: Ongoing Contact: Andrew Bellina, EPA Region 2, 212-637-4110 Region 2 - RCRA Public Involvement: Begin public involvement process at the planning stage (e.g., at time of permit application) in order to give the public enough time for comments. For Environmental Justice facilities, submit a Citizen's Participation Plan in RCRA permit applications and corrective action tasks. This plan would include a list of organizations and concerned citizens in the community and describe a proactive approach to be taken by the facility to inform the community of the proposed actions and how community members can voice their opinions. Status: Ongoing Contact: Andrew Bellina, EPA Region 2, 212-637-4110 Region 2 - Training Waste Program Personnel in Environmental Justice: Environmental justice training plan developed for all waste program staff and management. The training includes Regional and state RCRA permitting and corrective action personnel and covers revised public notification outreach procedures which will incorporate environmental justice concerns. Status: Training began 12/94; continuing Contact: Wilfredo Palomino, EPA Region 2, 212-637-4179 New York - Hazardous Waste Management for Printers: Survey printing industry on product processes, waste management methods, regulatory compliance, six workshops, and technical assistance. Status: Completed Contact: John Iannotti, 518-457-7267 D. Region 5 Minnesota - Improvements to Hazardous Waste Permitting Program: The following permit improvement initiatives have been implemented by the MN Pollution Control Agency (MPCA): 1. Conduct annual facility roundtable for all facility owners and operators to discuss issues of importance to hazardous waste facilities. Facility/state workgroups are dealing with term of permits, incident reporting and agency/county issues. 2. Publish a semiannual newsletter updating all treatment, storage and disposal facilities (TSDFs) on new informational items such as proposed new rules affecting facilities, etc. 3. Use reminder letters sent out one year in advance of the permit expiration date. 4. Revise the public notice to make it more user- friendly by replacing legal jargon with more understandable language. 5. Make permit conditions more facility-specific. 6. Include compliance schedules in permits to expedite permit issuance. 7. Re-draft modified permits to include the modified text with the most current revision date on each page. A summary is also included at the beginning of the permit listing each modification and the effective date. This eliminates confusion regarding "current" permit. 8. Provide facilities with a "tip" sheet listing useful information for preparing permit applications, and meet with permittees prior to reissuance to review necessary changes to the permit. 9. Update MPCA permit review checklists as needed. 10. Schedule and coordinate permit drafting and public noticing to avoid a "crunch" with clerical staff tasks. 11. Use computer aided permit boilerplates and public notice documents to save time in permit drafting. 12. Use combined completeness and technical review to reduce the number of iterations required on permit applications. 13. Provide permittees with a "pre-review" of current permit application so as to improve the quality of permit reissuance application submittals and expedite application review. 14. Allow permittee to review draft permit prior to placing public notice so as to resolve any issues they may have well before the permit document is finalized. Status: Complete/Ongoing Contact: Bruce Brott, Hazardous Waste Division, 612-297- 8380 E. Region 6 Region 6 - Customer Service Questionnaire: A questionnaire is being developed that will be sent to citizens who have participated in the public outreach/comment aspects of the RCRA permit process. The questionnaire is being designed to provide customer feedback on the public's involvement efforts over time. Status: Piloted in early 1995, results under analysis Contact: Arnold Ondarza, 214-665-6790 Region 6 - RCRA "Paperless Permit" Initiative: A LAN-based computerized permit system developed to reduce processing time. After implementation, the average time lag between state signature and EPA signature of jointly-issued permits dropped from 69 days to 8 days. The system also improved the consistency of RCRA permits and has been exported to states as they have become authorized to run the program. Status: Completed 1991 Contact: Arnold Ondarza, 214-665-6790 Texas - Hazardous Waste Facility Permit Streamlining: The TX Natural Resource Conservation Commission (TNRCC) has proposed regulations to expand public awareness through published notice of intended applications; requiring more balanced and representative makeup of local review committees; requiring professional facilitators to coordinate the activities of the review committees; and directing prospective applicants to defray the reasonable expenses of committees and facilitators. Status: Rule proposal 9/30/94. Contact: 512-239-6087 F. Region 9 Region 9 - Environmental Justice Support: The Region is providing support to their RCRA staff in addressing environmental justice issues they encounter in permitting decisions. This is done through presentations to permits staff to familiarize them with issues and options, as well as to provide proactive support in identifying potential areas of EJ concern. Grant guidance for states also includes environmental justice work that may be applied in their RCRA permitting programs. Status: Ongoing Contact: Karen Scheuermann, Hazardous Waste Management Division, 415-744-2057 Region 9 - RCRA California Multi-Year Permit Strategy: A strategy is being developed for addressing remaining permit and closure activities in priority. The goal is to create a multi-year plan which can be used as the grant workplan. This will reduce the level of review required each year when the grant is negotiated. Status: Ongoing. Expected completion date: July 1, 1995 Contact: John McCarroll, Hazardous Waste Management Division, 415-744-2057 Region 9 - RCRA Permit Grant Streamlining: The Region is developing a pool of activities from which the state of California can choose projects (as opposed to approving a site-specific, activity-specific grant workplan). The Region is also developing a set of substitution criteria for the state to follow. This will provide flexibility for the state to manage its program and will reduce or eliminate the need for grant workplan amendments. Status: Ongoing (To be included in the FY96 grant) Contact: Paula Bisson, Hazardous Waste Management Division, 415- 744-2064 California - Recycling Requirements for Hazardous Wastes: Cal/EPA has revised requirements for addressing hazardous wastes that are being recycled. Recyclable material will not be classified as a waste if it is: (1) used or reused as an ingredient in an industrial process to make a product, (2) used or reused as a safe and effective substitute for commercial products, (3) returned to the original process from which the material is returned as a substitute for raw material feedstock, and the process uses raw materials as principal feedstocks. Status: Effective 1/1/93 Contact: Department of Toxic Substance Control, 916-323- 6042 California - Tiered Permitting of Hazardous Wastestreams: Tiered permitting system developed for non-RCRA hazardous waste, including: conditionally exempt small quantity treatment; conditionally exempt; conditionally authorized; and permit-by-rule. Fifteen different wastestreams are addressed by the tiered system based on type of treatment employed and quantity and concentration of the waste. Status: Effective 1/93 Contact: Department of Toxic Substance Control, 916-323- 5871 G. Region 10 Alaska - Permitting: Alaska regularly incorporates pollution prevention planning conditions in its Resource Conservation and Recovery Act permits and is piloting P2 language in wastewater and solid waste permits. As appropriate, local governments seeking new landfills are being required to demonstrate that they have considered all waste management options and are following a prescribed hierarchy of waste management alternatives. Status: Ongoing Contact: David Croxton, 907-563-6529 Washington State - Refinery Hazardous Waste Incineration: Examine and develop options for managing combustible wastes from refineries other than incineration in hazardous waste incinerators. Status: Formative Contact: Kim Anderson, 206-407-6931 or Stan Springer, 206- 407-6723 Washington State - "Shopsweeps" Program: "Shopsweeps" was a voluntary program providing technical assistance on the proper management of hazardous wastes to automotive repair shops, conducted in cooperation with the industry. Over 1700 shops were visited in a six month period and of the total compliance recommendations made during the visits, 61% had been complied with by the shops, based on follow-up visits to 5% of the shops. Status: Completed in 1993 Contact: Darin Rice, 360-407-6743 Washington State - Underground Storage Tank Permit Streamlining: Reduce permit instructions from 30 pages to one and combine the permit and fee invoice into one form. Beginning to issue permits and fees as part of a master business licensing program. Status: Ongoing Contact: Ron Moyer, 360-407-7217 V. Water A. EPA HQ General National Pollutant Discharge Elimination System (NPDES) Permits Clearinghouse: The Permits Division in the Office of Water maintains a clearinghouse of NPDES general permits issued by EPA and states. Permits for stormwater discharges are not included. The clearinghouse contains information on the permit conditions of each general permit. The purpose of the clearinghouse is to transfer information on existing general permits to permit writers interested in writing new general permits. Status: Complete and updated periodically Contact: Brian Bell, 202-260-6057 NPDES Permit Streamlining Activities: Encourage use of general permits. Thirty-nine states have approved general permits programs. Nineteen states have issued general permits since 1/1/91 for non-stormwater discharges, and all 39 states have issued general permits for stormwater discharges associated with industrial activities. There are about 250 general permits that cover about 82,000 facilities. States or EPA have issued general permits for: stormwater from industrial activities; non- contact cooling water; concentrated animal feeding operations; groundwater cleanup dewatering; underground storage tanks; and hydrostatic testing of oil and gas lines. A national database of general permits and their conditions has been established and is updated quarterly. Status: Complete and ongoing Contact: Jim Pendergast, OW, 202-260-9537 NPDES Pretreatment Streamlining: Straw proposal developed to streamline the procedures associated with developing and maintaining approved pretreatment programs. The proposed streamlining allows incorporating only significant elements of the approved program, and requires a formal modification only where the pretreatment program is made less restrictive or where the Approval Authority so requests. Status: Straw proposal issued May 1994, results of stakeholder meetings being studied Contact: Elaine Brenner, OW, 202-260-4933 NPDES Rulemaking: Revising the basic NPDES permit regulations to expand the list of allowable minor permit modifications (those that do not require public notice) and reduce the administrative requirements for general permits. Status: Temporarily on hold Contact: Tom Charlton, OW, 202-260-6960 NPDES Watershed Strategy: The Permits Division in the Office of Water developed a strategy for integrating NPDES permit issuance into an overall watershed framework. This strategy provides examples for permitting programs in EPA Regions on how they assist states in focusing on true environmental problems in critical watersheds. The strategy has 6 elements: state-wide coordination, NPDES permit issuance, monitoring and assessment, programmatic measures including environmental indicators, public participation, and enforcement. Status: Completed March 1994 Contact: Deborah Nagle, 202-260-2656 NPDES Watershed Successes: The Permits Division in the Office of Water issued a report on the status of EPA Regions in assisting states in integrating NPDES activities into a watershed context. The report includes many examples of successes; these provide states/Regions with examples of what might be applicable to their jurisdictions. Status: Completed October 1994 Contact: Deborah Nagle, 202-260-2656 National Water Program Agenda for the Future: The USEPA Office of Water has issued an agenda for the future (1995). The agenda includes: polling the states and tribes to identify specific items in day-to-day implementation that do not make sense; providing implementation choices when developing programs, guidance and regulations; and identifying reporting that will be simplified or eliminated to achieve a 25% reduction in the reporting burden. This agenda lays out the overall operating strategy for the Office of Water. Status: Memorandum issued December 30, 1994 by Robert Perciasepe Contact: Mark Luttner, 202-260-5700 Watershed Policy Committee: Developing an action plan that includes: enhanced federal agency coordination; integration of EPA initiatives -- NPDES watershed strategy, Comprehensive State Groundwater Protection Programs, state nonpoint source programs -- into state comprehensive programs; expanded use of the tools needed to carry out watershed management such as new methods, models, and monitoring techniques; improved internal EPA coordination; and an aggressive outreach effort to watershed stakeholders. Status: Announced in 10/7/94 memo from AA Perciasepe; ongoing. Contact: Janet Pawlukiewicz, 202-260-2194 B. Region 1 Region 1 - Water Program Improvements: Quality Action Team (QAT) recommendations implemented to improve the permitting process. A focus was to establish procedures to better address the backlog of permit appeals. Status: Ongoing Contact: Dianne Chabot-O'Malley, 617-565-3430 Connecticut - General Permit for Wastewater Discharges Generated by Publishing and Printing Activities: Develop a simplified permitting process for the Publishing and Printing Industry. Status: Ongoing Contact: CT DEP, 203-566-7167 C. Region 2 New Jersey - Pollution Discharge Elimination System Improvements: Report prepared describing evaluation of program, identification of problems and proposed actions to improve the program. Status: Report dated 11/2/93; implementation ongoing. Contact: John Laurita, NJ DEP, 609-292-4543 D. Region 3 Maryland - General Permits: At MD Department of the Environment (MDE), a number of general permits are being written, including: seafood processors, well pump tests, hydrostatic pipe and tank tests, marina facilities, surface coal mines, vehicle car washes, sand and gravel operations, stormwater, heat pumps, animal feed lots, cooling water, and swimming pool backwash water. Status: Ongoing Contact: Dana Bauer, Water Management Division, 410-631- 3512 Maryland - NPDES Data Base Enhancements: In FY 94 and 95 Region III EPA provided grant funds to Virginia to develop a new software program specifically tailored to NPDES permit writing and tracking. A copy of this prototype has been provided to Maryland and other Region III states in order to facilitate their efforts to improve upon their own databases. In FY 95 Maryland received a $10,000 grant to focus on a better computer application for permit writing. Status: Ongoing Contact: Dana Bauer, Water Management Division, 410-631- 3512 Maryland - Permit Backlog Elimination Plans: Over the last year the MDE Water Management Division has aggressively pursued the reduction of permit backlogs for both municipal and industrial facilities. This is being achieved through a combination of workload redistribution, application analysis and sorting and development of additional general permits. A key element of the analysis and sorting process and workload distribution includes the determination of which permits can be quickly processed using desktop computations and which will require in-stream surveys or more complicated models. Priorities are assigned accordingly and permits which can be issued more timely than others are moved through the work stream more quickly. This has yielded significant results with MDE having eliminated all of the municipal permit backlog in FY95. It is anticipated that similar results will occur with the industrial permit backlog, which is projected to be eliminated by July 1995. Status: Ongoing Contact: Dana Bauer, Water Management Division, 410-631- 3512 E. Region 5 Region 5 - Dredge and Fill Permitting: The Region 5 Water Program has: 1) Assisted in the development of general permits for states and counties so that certain sizes and classes of wetlands can be regulated at the local level. 2) Drafted position paper on how to handle wetland permit issues on tribal lands. The system is geared to educate tribes on their responsibilities and provide a framework for the Army Corps of Engineers and EPA to improve delivery of wetlands program to tribes. Status: 1) Complete; 2) Under review Contact: Doug Ehorn, Chief Wetlands and Watersheds Section, 312-886-0243. Region 5 - NPDES Permitting: In April 1992, a state/EPA quality action team was established to investigate and recommend opportunities for improvement in the NPDES permit process. Recommendations included: 1) Reducing the number of in-line permit reviews done by EPA. Minimum reduction of 50% with focus on high- priority discharges. 2) Periodic reviews of state permit programs by EPA to assess the overall effectiveness of the state program. 3) Joint establishment of priorities during program planning. 4) Establishment of a standing workgroup of EPA and state permits and standards program managers to reach resolution of issues and share information. 5) Preparation, by states, of their decision-making procedures and submission to EPA for review. Any issues identified will be addressed with the particular state or the workgroup if of Regional significance. 6) Identification in annual state program plans of permitting priorities, specific permits (issues or areas) that will be subject to in-line review and permit issuance commitments. Status: Implementation of recommendations began in FY94. Contact: Tim Henry, Chief Permits Section, 312-886-6107 Region 5 - Underground Injection Control (UIC) Permitting: The following actions have been implemented to improve UIC permitting: 1) Have permit writers prepare their own permits. 2) Have all correspondence related to permit issuance go through the permit writer. 3) Revise permit approval process to remove non-value added steps. 4) Issue Class I permits for 8-10 year lifespans to stagger the workload. 5) For Class V sites that would not be able to obtain a permit don't do the call-in. 6) Sign MOU's with other units that provide assistance. 7) Establish a tracking system to cover major workload items. 8) Handle requests for assistance from other units as formal requests, and include in the tracking system. Status: Implemented Contact: Rebecca Harvey, Chief Permit Unit, UIC Section, 312-886-6594 Indiana - NPDES Expert System: The Indiana Department of Environmental Management has started a project to develop a menu-driven expert system to help permit writers draft permits. This project was started in an effort to provide training to new permit writers in the state. The expert system takes permit writers through the process of writing a permit, cross references all appropriate state regulations and internal procedures, and results in a draft permit. Status: Ongoing Contact: Rod Thomson 317-233-8399 Wisconsin - Tiered Fee System for Stormwater Permits: General stormwater permits are divided into three tiers by SIC code (heavy industry, light industry, and everything else). Tier I permits come with a $200 annual fee and a requirement to develop a stormwater management plan and to do sampling and chemical analysis. Tier II permits have an $100 annual fee and require a management plan but no sampling or chemical analysis. Tier III carries no fee and not planning or testing requirements. If a Tier I or II facility takes measures (usually pollution prevention practices like covering a dumpster) to get to the point where runoff is not contaminated, then it can be classified as Tier III. Status: Ongoing Contact: Roger Larson, 608-266-2666 F. Region 6 Region 6 - NPDES Computerized Permit System: Computerized permit generation system developed which reduces permit development time and paper consumption. Status: Completed 1989 Contact: Jack Ferguson, 214-665-7170 G. Region 9 California - External Program Review Report of the State Water Resources Control Board and the Regional Water Quality Control Boards: Governor Wilson, in July 1993, requested an external review of mandates and programs of the State Water Board and the nine Regional Water Quality Control Boards. The goal was "... to identify how best the Boards can meet their mandates to protect the water resources of the state, while removing unnecessary red tape that hinders the economic resurgence in California." The review was conducted by members from the regulated community, environmental groups, and other stakeholders. Status: Final Report issued 6/17/94 Contacts: James Strock, Secretary Cal/EPA, 916-445-3846 or John Caffrey, Chairman, State Water Resources Control Board VI. PCBs A. EPA HQ PCB Disposal Rule: Proposal to reduce disposal costs by billions of dollars, through modifications to the disposal rule. Status: Proposed 12/6/94, analyzing comments Contact: Tony Baney, OPPTS, 202-260-3933 B. Region 5 Region 5 - PCB Permitting: Region 5 Pesticides and Toxic Substances Branch (PTSB) initiated a process in which Region 5 will issue a permit to a state which will allow the disposal of PCBs in facilities approved by that state. This was possible because the state's requirements for municipal landfills are equivalent to the requirements for PCB landfills under TSCA. PTSB has also modified the draft and final permit review process. A thorough peer review of draft and final permits is conducted, assuring all regulatory and technical requirements are included. Status: Ongoing Contact: Tony Martig, 312-353-2291 C. Region 9 Region 9 - PCB Permit Writers Guide: A guide is being prepared that will define all of the information, documentation and supporting materials needed for the review and processing of permit applications to engage in research and development, conduct storage or dispose of PCBs. The guide will serve to expedite the review of applications, identification of deficiencies, and final decision making. Status: Ongoing Contact: Yosh Tokiwa, Air and Toxics Division, Region 9, 415-744-1109