Internal IDEM Pollution Prevention Integration Projects
Each of the 10 pollution prevention integration projects went through screening and review at the IDEM office level and by the senior management steering committee. Once the steering committee approved projects, senior managers identified project leaders and staff, and the project teams prepared detailed project work plans that included task descriptions, staffing requirements, performance measures, timelines and training needs.
IDEM began implementing the projects in 2001, with some beginning in the spring and others in the summer and fall.
- Test P2 Integration in Mercury Policy and Rules
- Improve Office of Air Quality (OAQ)/OPPTA Rule Development and Outreach Coordination
- Develop P2 in OAQ Rules and Permits Guidebook
- P2 in Enforcement
- P2 in Waste Inspections
- P2 in Water Inspections
- P2 in Air Inspections
- P2 in Remediation
- Energy Efficiency and Alternative P2 Technologies for Drinking Water Supply
- P2 in Wastewater Treatment Operator Certification
Test P2 Integration in Mercury Policy and Rules
OPPTA and other IDEM offices continue to work on mercury rulemaking activities. Mercury rules have been adopted including the Mercury and Mercury Products Law. IDEM is currently undergoing Triennual Review of its mercury rules related to water quality. OPPTA is working with POTWs to develop a mercury outreach program to sources that may release mercury in wastewater. The OPPTA/POTW workgroup is also drafting a model Mercury Pollutant Minimization Plan.
Improve Office of Air Quality (OAQ)/OPPTA Rule Development and Outreach Coordination
The goal of this project was to develop and implement a systematic approach to include pollution prevention opportunities using OPPTA expertise in the Air Office rule development process. The approach must be efficient and effective without slowing down the process and builds on successful prior OAQ/OPPTA collaborations on styrene and methylene chloride rules. The approach includes the following:
- OAQ and OPPTA sharing work plans.
- OAQ and OPPTA identifying rules that provide P2 opportunities.
- Coordination meetings between OAQ and OPPTA.
- OPPTA and OAQ reviewing rule projects to decide which rules provide P2 opportunities.
OPPTA has begun compiling for public distribution, the monthly Indiana Register summaries related to environmental documents. OPPTA reviews the first notices and contacts the OAQ or other affected office when P2 opportunities are available for potential incorporation in the rule. OAQ notifies OPPTA of upcoming rules and invites OPPTAs feedback. OPPTA also works with the Partners for Pollution Prevention to review potential P2 opportunities in upcoming rules.
Develop P2 in OAQ Rules and Permits Guidebook
To assist permit and rule writers with finding examples of how other states have incorporated pollution prevention into rulemaking activities and into permits, the Office of Air Quality developed a permitting/rule writing repository of current information that includes web links to tools, examples, and case studies laying out various ways to incorporate P2 in permits and into a rule. The information is compiled in a dynamic electronic document with information on sectors/processes/pollutants.
P2 in Enforcement
The purpose of this project is to place more emphasis on promoting pollution prevention during enforcement actions-specifically through a number of steps to encourage the proposal and implementation of P2 supplemental environmental projects (SEPs). There were several components to this project:
- Revised IDEM's policy for SEPs to encourage the development of P2-based SEP proposals
- Developed guidance for respondents on the requirements for a P2 SEP proposal.
- Developed internal guidance for IDEM staff on how to evaluate P2 SEP proposals.
- Developed a process defining both the process and timing for involving OPPTA in assessing P2 SEP proposals, and the role of OPPTA in assisting enforcement staff in evaluating P2 SEP proposals and/or providing technical assistance to facilities which are trying to develop O2 SEP proposals.
This was a very successful project. IDEM's Office of Environment agreed to change the offset of the gravity portion of a penalty for P2 SEPs from 80% to 90%, further encouraging respondents to consider P2 SEPs as an option during enforcement actions.
P2 in Waste Inspections
This project involves incorporating pollution prevention into land quality inspections. The effort is focused on a subgroup of EPA's list of persistent bioaccumulative and toxic chemicals (PBTs). Inspectors will identify and track pollution prevention opportunities by industrial waste generators, mainly focusing on hazardous waste Small Quantity Generators and PBT handlers. The project will also include pre-inspection and post-inspection activities. Key aspects of the project are listed below.
- Tracking use of PBTs at inspected facilities.
- Training inspectors on P2 opportunities for reducing PBT chemicals.
- Sharing information/fact sheets with inspected facilities.
- Revising current forms used in P2 tracking, P2 guidance, and P2 opportunities.
- Referring facilities for technical assistance to OPPTA and CMTI.
OPPTA monitors PBT releases through the Toxic Release Inventory and shares this information annually and as requested with each IDEM office.
Waste inspection staff have attended various pollution prevention training opportunities including through conferences and workshops and by accompanying EPA inspectors. Inspectors refer facilities to OPPTA and the Clean Manufacturing Technology Institute for pollution prevention assistance and distribute P2 instructional materials during compliance inspections.
P2 in Water Inspections
The goal of this project is to increase NPDES compliance of rural schools through pollution prevention. Rural schools often have a small sewage treatment system to treat their waste. They are often in non-compliance due to interference from cleaning/custodial operations, especially when flows are low when schools are out of session. The Office of Water Quality believes P2 modifications such as changing cleaning chemicals and procedures will decrease the sector's rate of non-compliance.
Project activities include identifying of alternative cleaners and cleaning practices, handouts and training for inspectors, and targeting inspections and modifying inspection activities. This project has been on hold due to lack of staff to manage it. But plans are in place to begin work toward completion in 2004.
P2 in Air Inspections
This project involves incorporating pollution prevention into air inspections. The effort includes a series of training and other capability building measures to train air inspectors, track their efforts, and give them resources to use in the field. This initiative builds on prior joint OAQ/OPPTA coordination with CMTI and includes the development of handouts and modification of the inspection protocol to emphasize P2. These modifications include changes to pre-inspection activities (e.g., researching P2 opportunities for the processes at the facility where the inspection will occur), inspection activities (e.g., emphasizing P2 technologies and referring the facility to P2 technical assistance activities), and post inspection (e.g., summarizing P2 activities in the inspection report).
Two handouts were developed and made available to inspectors for use: "Pollution Prevention: The Basics" and "Pollution Prevention: Indiana's Preferred Alternative for Environmental Protection and Economic Success" The inspection report format was changed to include a Pollution Prevention element. The Clean Manufacturing Technology Institute trained inspectors on pollution prevention measures for fiberglass/surface coating processes. Additional training on surface coating/pollution prevention was also conducted. In addition, each staff meeting now includes a pollution prevention element and Section Chiefs and Deputy Directors have added P2 to job descriptions.
P2 in Remediation
The objective of the P2 in remediation project was to educate staff, consultants, communities and responsible parties on pollution prevention as it relates to remediation and redevelopment projects. Due to lack of staff, this project has not been implemented. The project also planned to look at providing incentives and/or awards for successful implementation of P2 in remediation projects. The following were the planned components of the project:
- Develop P2 in remediation orientation training for staff remediation team.
- Develop P2 remediation educational materials for interested parties.
- Develop a P2 opportunities in remediation web page for public outreach.
- Provide P2 in remediation awareness training for internal and external workgroups.
- Initiate an awareness program for P2 in the voluntary remediation program.
- Initiate an awareness program for P2 in the brownfields program.
- Devise recognition programs for successful implementation of P2 in remediation and redevelopment projects.
No future timeframe has been set to implement this project.
Energy Efficiency and Alternative P2 Technologies for Drinking Water Supply
The objective of this project is to develop a resource list of pollution prevention opportunities for public water supply systems, and to provide education to the drinking water industry and providers on how P2 approaches can reduce both expenses and pollution.
This project was recently reinvigorated. It is expected this project will primarily emphasize energy-savings approaches and equipment, such as high-efficiency pumps, variable drive controls, and energy-efficient lighting. The program will first put together information on energy-efficiency and P2 opportunities for drinking water providers, and then develop presentations and handouts for use, initially, with the engineering and provider community. The project plan calls for convening a workgroup of relevant association representatives to assist IDEM in developing the P2 resource list. OPPTA is currently working with OWQ to consider adding P2 questions to the Drinking Water Certification Program.
P2 in Wastewater Treatment Operator Certification
Wastewater treatment plants are responsible for a variety of activities that could affect the environment, including treatment, analysis and discharge. Pollution prevention opportunities exist in the day-to-day processes at the plant, and there are also many educational opportunities for plant officials to teach their peers about pollution prevention. To encourage plants to implement these ideas, IDEM incorporated the concepts of pollution prevention into the Wastewater Treatment Plant Operator Certification Program.
All wastewater treatment plants must have at least one certified operator in charge of supervising the plant's operations. Certification is also required for pretreatment operators at facilities discharging to Publicly Owned Treatment Works. In addition, some wastewater treatment plants require all operators to pass the certification exam to retain their jobs. Because less than half of those taking the exam pass on their first attempt, the exam is a major training component for wastewater treatment operators.
Several steps were taken to implement this project, including dedicating a portion of each certification exam to pollution prevention questions. The level of expected understanding is graduated to be consistent with the various levels of professional certification. Pollution prevention reference materials are provided to those studying for the certification exam, and a portion of the Wastewater Operators Certification Manual now contains pollution prevention information. To date, more than 1,500 wastewater treatment plant operators have received the pollution prevention training. This project was also recognized by the National Pollution Prevention Roundtable and will appear in the P2 Regulatory Integration Case Study resource tool commissioned by U.S. EPA's Office of Pollution Prevention and Toxics. For additional information, visit IDEM's Web site.
