Measuring P2 in Enforcement

To begin the process, staff developed a worksheet to track those facilities under enforcement action that returned to compliance using P2 techniques. The worksheet consisted of familiar P2 source reduction techniques taken from the TURA program along with conservation measures. The worksheet, also included a space to calculate actual reductions in hazardous waste generation, VOC emissions, and wastewater discharges.

Staff reviewed both high and low level enforcement documents and conducted interviews with inspectors and permitters to identify facilities that implemented P2 to return to compliance. A total of 38 facilities were included in a chart designating the facility, sector, type and amount of reduction (e.g., hazardous waste, VOCs, and wastewater), P2 method, the company's incentive to choose P2, and comments.

Preliminary results of the tracking system were analyzed. For instance, many minor corrections to operations and management procedures resulted in P2. Larger reductions came from input substitution and modernization of operations. An important aspect of the pilot survey is that it provided an indication of the value of inspecting specific industrial sectors. For instance, wood and metal coaters yielded substantial VOC reductions. It also identified the importance of including permitting staff in the process.