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RCRA Box 1883 

Prepped by Ollie Stewart 

Document Number: 

95) ll-B-257 

Docket Number: 

A-90-19 

Printed 12/3/2008 10:42:16 AM Sheet 95 of 171 
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I t, ' * 

vvEPA 

A-90-19 

ll-B-257 

United States • Office of Air Quality 

Environmental Protection Planning and Stand: 

Agency Research Triangle F 

Prevention and Toxii 

National Air Pollution 

Control Techniques 

Advisory Committee 

Minutes of Meeting 

November 19-21,1991 

Volume 1 of 2 ljU_iBJiL,[j 

n SEP UI992 '.'';" 

EPA AIR DOCKE" 

Printed on Recycled Paper 
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Two Volume Set: Volume 1 (Section I - X) 

Volume 2 (Section I, XI - XVIII, and Appendix) 

TABLE OF CONTENTS 

PAGE 

I. ' INTRODUCTION AND OPENING REMARKS 

Bruce C. Jordan, Committee Chairman 1 

Director, Emission Standards Division (ESD) 

Office of Air Quality Planning and Standards, EPA 

II. GENERAL PROVISIONS 

A. EPA Presentation 

Michele Dubow, ESD 5 

B. Industry Presentation 

Chemical Manufacturers Association 19 

Danny Anderson 

Vice President of Environmental Affairs 

First Chemical Corporation 

a. Supplemental Comments 22. 

C. Discussion 28 

III. HAZARDOUS ORGANIC NATIONAL EMISSION STANDARDS FOR 

HAZARDOUS AIR POLLUTANTS (NESHAP) 

A. EPA Presentation 

Daphne McMurrer, ESD 33 

B. Industry Presentation 

Chemical Manufacturers Association 4 3 

Thomas Robinson 

Manager of Regulatory Affairs 

Vulcan Chemicals Corporation 

C. Discussion 48 

IV. COKE OVEN NESHAP 

A. EPA Presentation 

Amanda Agnew, ESD 53 

B. Discussion 66 

V. DRY CLEANING NESHAP 

A. EPA Presentation 

Linda Herring, ESD 67 
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PAGE 

B. Industry Presentation 

. r.hricare Institute * 

l. international Fafcri presiden t William Fisher, Vice «r 

............. . 83 

C. Discussion 

VI. CHROMIUM ELECTROPLATING NESHAP 

A EPA presentation 

Lalit Banker, ESD 87 

B. Discussion 99 

VII. SECTION 112g 

A. EPA Presentation 

Tim Smith, ESD 105 

B. Industry Presentations 

• 1. Motor Vehicle Manufacturers Association . . 119 

Richard Paul 

Manager, Environmental Health 

2. American Petroleum Institute . 125 

F. Dan Gealy 

Director, Public Relations 

Atlantic Richfield Company 

3. Pharmaceutical Manufacturers Association . 131 

Richard Vetter 

Associate Counsel 

Burroughs Wellcome 

4. Chemical Manufacturers Association . . . . 140 

Joe Woolbert 

Principal Chemical Engineer 

Texas Eastman Chemical Company 

C. Discussion ........... . 145 

VIII. SOURCE CATEGORY SCHEDULE FOR STANDARDS 

A. EPA Presentation 

David Svendsgaard and Chuck French, ESD ... . 155 

* Did not provide a copy of presentation for inclusion in the 

minutes. 

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A: EPA PRESENTATION 

Daphne McMurrer of the Standards Development Branch, 

presenter, opened by reminding everyone that the Hazardous 

Organic NESHAP (HON) is scheduled to be proposed in.late February 

or early March 1992, and promulgated in November 1992. It is 

expected that 110 of the 189 hazardous air pollutants (HAP) 

listed in the Clean Air Act Amendments (CAAA) of 1990 will be 

regulated by the HON. 

The HON will be applicable to all Synthetic Organic Chemical 

Manufacturing Industry (SOCMI) processes which produce a HAP as a 

product, by-product, co-product, intermediate, or use a HAP as a 

reactant or raw material. Only major sources, as defined by the 

CAAA, will be regulated. The EPA will be seeking comment on the 

existence of SOCMI area sources and the applicability of the HON 

to area sources in the proposed standard. The remainder, and 

majority, of the presentation addressed the concept of emissions 

averaging. 

The averaging scheme for the HON is being developed to 

address the complexity and diversity within the source category. 

Because of this complexity and diversity, there can be a 

significant cost incurred for individual sources using point-bypoint compliance. Emissions averaging is intended to provide 

flexibility and allow equal or greater emission reductions at 

lower costs. This concept differs from bubbling since no 

emission caps will be set. The setting of emission caps under 

previous bubbling policies did not account for decreases in 

production or dismantling of equipment. As a result, when one or 

more of these events occurred, the remaining emission points were 

free to emit more than originally intended without exceeding the 

emission cap. Emissions averaging will take into account changes 

to the source and keep emissions from individual emission points 

at the intended level. 

-ft 
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The scope of the HON emissions averaging will be determined 

by the definition of "source." The current definition includes 

all product process units regulated by the HON, in a contiguous 

area, that are under common control. Emissions averaging will 

not be allowed with any product process units which are not 

regulated by the HON (outside the definition of source). 

Emissions averaging may include emissions from eligible process 

vents, storage tanks, wastewater streams, and transfer loading 

racks. Emissions from equipment leaks will be excluded from 

emissions averaging due to the uncertainty involved in 

quantifying emissions, the inability to assign a known, nominal 

emissions control efficiency rating, and because the equipment, 

leaks standard was developed through the regulatory negotiation 

process and including it would nullify the agreement reached. 

The form and compliance plans being developed will indicate 

what requirements are presented and described in the regulation. 

Compliance requirements will include quarterly emissions limits 

to allow more flexibility in administrating and enforcing 

emissions averaging. Compliance requirements will also include 

point-by-point commitments for the application of control devices 

on emission points involved in an average. Mass emission 

estimates will be required for all emission points included in 

the averages. All compliance commitments will be part of the 

Title V permits. Any change made by a source to the structure of 

the emissions average will be reviewed by the State as part of 

administering the Title V permits. Alternative operating 

scenarios can be planned and included in the permit so that a 

source has the flexibility to make changes without automatically 

violating the emissions average. 

For emissions averaging, under-controlling an emission point 

will be regarded as a debit, while over-controlling an emission 

point will be regarded as a credit. The three ways to obtain 

credits are discussed below. First, credits may be generated by 

controlling eligible emission points that are not required to 

apply control. For example, credits would be given for 

controlling a small storage tank that may be below the size 

applicability criteria for the HON, and would not be required to 
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apply emission controls. Second, credits can be generated by 

using higher efficiency controls than required by the standard. 

The higher efficiency must be achieved by using a different 

control technology than that required by the regulation, and not 

by using the same control technology at increased efficiency. 

For example, the standard may require 98 percent control 

efficiency on a process vent and if the source used a different 

control technology which had an EPA nominal efficiency rating of 

99 percent, it would receive credit for the 1 percent additional 

control. The third way to generate credits is to use approved 

pollution prevention methods. This can be used on points for 

which control is or is not required. As with the above methods 

to generate a credit, the emission reduction must be greater than 

that required by the standard for the relevant emissions points. 

Credits cannot be generated by production cutbacks or any 

controls applied before promulgation of the standard, except 

controls applied as part of the Early Reductions program and 

pollution prevention measures taken since 1987. These allowances 

are provided to encourage participation in the Early Reductions 

program and reward innovative emission reductions made before the 

standard is promulgated. 

The final topic discussed was the use and value of a 

discounting factor. A discounting factor reduces the value of 

emission credits generated as part of an emissions average, 

thereby ensuring greater emission reductions than would be 

achieved using point-by-point compliance. It is judged by EPA 

that the use of a discounting factor is fair and reasonable 

because of cost savings achieved using emissions averaging. The 

discounting factor chosen will reflect uncertainties in emissions 

estimation procedures. The states feel that there is great 

uncertainty for some of the emission estimation procedures 

currently being used, and the discounting factor should 

compensate for those uncertainties. The factor will only be 

applied to the emission points generating credits to be used in 

emissions averaging. 

i J 
f 

HAZARDOUS ORGANIC NESHAP 

(HON) 

(V? 

November 19,1991 

00 
f 1 

Structure of the HON 

Applicability 

-SOCMI 

- "Major Sources" 

Requirements for Vents, Tanks, 

Transfer & Waste Water 

- point by point compliance 

- emissions averaging 

Requirements for Equipment Leaks 

CO 
EMISSIONS AVERAGING 

for the 

HON 

GOAL: 

Equal or Greater Emissions 

Reductions 

at a Lower Cost 
1 

SCOPE 

Set by definition of "Source" 

* 

- SOCMI product process units 

- regulated by HON 

- in a contiguous area 

- under common control 

Equipment leaks excluded due 

to uncertainty of emissions 
•P 

FORM & COMPLIANCE PLANS 

Quarterly Emissions Limit 

Compliance 

- point by point committments 

- emissions accounting for points in 

averages 

Title V Permits 

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CREDITS 

3 Ways to generate credits: 

- controlling points without control requirements 

- using higher efficiency controls than required 

- pollution prevention 

Cannot generate credits with: 

- production cutbacks 

- pre-existing controls, except 

Early Reduction Controls 

Pollution Prevention since 1987 

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1 

Discounting Factor 

> Only applied to points 

generating credits 

Used to reflect 

- cost savings 

- uncertainties in emissions estimates 

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CM 

STATEMENT OF 

THOMAS ROBINSON 

ON BEHALF OF 

THE CHEMICAL MANUFACTURERS ASSOCIATION 

BEFORE THE 

NATIONAL AIR POLLUTION CONTROL TECHNIQUES 

ADVISORY COMMITTEE 

ON 

EPA'S DEVELOPMENT OF NATIONAL EMISSION STANDARDS 

FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 

FOR HAZARDOUS ORGANICS 

NOVEMBER 19, 1991 

J2501 M Street, NW 202-887-1100 

Washington, D.C. 20037 Telex 89617 (CMA WSH) 
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CHEMICAL MANUFACTURERS ASSOCIATION 

TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL 

TECHNIQUES ADVISORY COMMITTEE ON 

EPA'S DEVELOPMENT OF NATIONAL EMISSION STANDARDS 

FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 

FOR HAZARDOUS ORGANICS 

Good morning. I'm Thomas Robinson. I'm Manager of Regulatory 

Affairs at Vulcan Chemicals Corporation. I appreciate the opportunity 

to testify today on behalf of the Chemical Manufacturers Association. 

CMA is a non-profit trade association- whose members make up more 

than 90 percent of the productive capacity for basic industrial 

chemicals in the United States. 

In my presentation today, I will touch briefly on the HON issues 

that are most important to members of CMA. As you might well imagine, 

the impact of these regulations will be significant for CMA's member 

companies. 

One of the most important issues is emissions trading. It's a 

cost-effective and efficient way to achieve the regulation's pollution 

control objectives. At the same time, averaging will help our industry 

stay competitive in an increasingly competitive world economy. 

In our view, every effort should be made to make the averaging 

program as straightforward as possible, as effective as possible, and 

as simple to manage as possible—for both the regulators and the 

regulated. 

Point-by-point trading will keep administration of the program 

simple. Having the flexibility to trade across emission types and 

between process units will be key, in the long run, to achieving a 

successful averaging program. 

Based on our experience, trading should be allowed between all 

units in a source category; between all units with the same MACT 

standards; and between all source categories regulated on a single 

promulgation date.As the scope of emissions trading expands, there are 

more opportunities for environmental benefits. 

Another important issue for a successful averaging program 

involves credits. In our view, sources should receive credit for 

emissions controls that are more stringent than MACT and for emissions 
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controls that aren't covered by the standard—regardless of when the 

controls were installed. 

Not allowing credit for controls applied before an artificial 

baseline date is counterproductive. It punishes companies which have 

taken the initiative--voluntarily--to reduce emissions. It also 

directly conflicts with other EPA programs, most notably the agency's 

Industrial Toxics Program, also known as the "33/50" program. 

Denying credit will simply delay the installation of non-required 

control devices and technologies. The result of that will be a net 

loss to the environment. 

When measuring credits, a discounting factor is not necessary when 

calculating credits for emissions averaging because EPA's control 

efficiencies and the emissions averaging program conservatively 

estimate actual emissions. 

Another key element of the HON is de minimis cutoffs. We see them 

as an integral part of the standard-setting procedure—in large measure 

because they achieve the most environmental benefit per implementation 

dollar. Put another way, de minimis cutoffs will return the most 

environmental benefit for each dollar spent. 

The de minimis concept is already embodied in individual state 

regulations, existing NSPS standards, the federal concept of Total 

Resource Effectiveness, and the recently negotiated regulation on 

equipment leaks. 

Without de minimis cutoffs MACT would apply to all emissions 

points with little or no net positive effect on the environment. 

Requiring the application of technology beyond the point of diminishing 

benefits will be counter-productive. 

A third key issue will be the definition of "source" and "major 

source". EPA should define major source broadly, including contiguous 

facilities in its definition. 

A broad definition satisfies the fundamental purpose of the new 

regulatory regime for air toxics, focusing on efficient application of 

technology based standards. A broad definition of "source" will allow 

the Agency to mandate controls for individual emission points. At the 

same time, it will maximize the impact of these controls to reduce a 

plant's overall emissions. This, of course, is the intent of the Act. 

HON applicability is very important to our members. Sources need 

a simple system to determine applicability clearly and conclusively. 

If each process is regulated once under a single set of applicable 

regulations, industry will be most effectively and efficiently 

regulated under the Act. 

The HON MACT is a source category based standard. Consequently, 

applicability criteria must determine whether a source "resides within" 

a source category regulated by the HON MACT. Units regulated by the HON 

should not be subject to later, possibly incompatible MACT standards. 
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Once a source has been "assigned" to a source category, it will 

know exactly which regulations it must follow, and when it must 

comply. All hazardous emissions will be effectively regulated by the 

standard covering that category. This approach will alleviate much of 

industry's uncertainty, and ease EPA's administrative burden. 

Without clearly defined applicability criteria, the limits of 

the regulated population will continue to expand and it will become 

more difficult to define. Potentially, the HON could expand to cover 

all units that create trace amounts of a stated chemical, stretching 

far beyond the synthetic organic chemical manufacturing industry and 

becoming an administrative nightmare. . 

The last general HON issue I want to raise is timing and 

compliance. If EPA promulgates a single HON encompassing all of SOCMI 

at one time, it will be difficult, perhaps impossible, for industry to 

meet required compliance deadlines. Equipment shortages, delayed 

deliveries, overburdened agencies facing new levels of permit 

applications, and a scarcity of internal resources are all formidable 

obstacles to compliance. 

Under this scenario, a source may find itself unable to comply due 

to events beyond its control, such as delays in construction permits. 

The Agency must provide for these possibilities in its compliance 

timeline. 

Furthermore, EPA should consider, in its development of lower 

quantity threshold regulations, the impact such regulations will have 

on the HON. The scope of the HON is already broad, covering over half 

of the listed source categories. A significant lowering of lesser 

quantity thresholds, and a subsequent increase in the number of sources 

trying to comply within the next few years, will further increase the 

burden on overloaded agencies. It will also increase the difficulty of 

obtaining control equipment in a reasonable time frame. 

EPA should consider the net environmental benefits of control 

technologies when considering alternative technologies and setting MACT 

standards. Increased NOx emissions and fuel consumption are both 

by-products of familiar control technologies. In areas of 

non-attainment, the maximum environmental improvement may be achieved 

by using a marginally less efficient technology to achieve a balance 

between toxics, NOx, SOx, and energy consumption. 

I would like to spend my remaining time discussing a specific area 

of the HON - secondary emissions from wastewater. 

The HON includes industrial wastewater because volatile air toxics 

from wastewater collection and treatment systems can be released to the 

atmosphere. CMA supports the regulation of wastewater emissions. 

However, there are ways to maximize overall controls and minimize 

costs. 

Not all HAP's can vaporize to the atmosphere. CMA encourages the 

Agency to implement a tiered approach to controlling wastewater 

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emissions based on physical chemistry. Only volatile Group 1 compounds 

-those which have the correct physical properties to actually enter the 

atmosphere - should be regulated. Non-volatile compounds which, by the 

laws of physics and chemistry, cannot leave the wastewater matrix 

should not be regulated. 

A clear applicability procedure for wastewater, including de 

minimis cutoffs, is also necessary. This insures that critical 

secondary emissions are regulated and non-volatile ones are excluded. 

CMA is concerned with the Agency's use of Reference Method 25D to 

analyze emissions from wastewater. This analytical method should not 

be used under the HON. It does not correctly identify the truly 

volatile constituent of total organics present in the wastewater 

matrix. Method 25D will result in the unnecessary and costly control 

of many wastewater streams which have no significant hazardous 

emissions. 

CMA does not support steam stripping as the optimal control 

technology for wastewater emissions. Steam stripping is inappropriate 

for many HAP chemicals that are reactive with water, infinitively 

soluble, or form azeotropes. Steam stripping is prone to operational 

problems and it is difficult to dispose of the stripped residues. 

Steam stripping is also incompatible with recently upgraded biological 

treatment facilities required under Clean Water Act regulations. 

Finally, the agency should exempt those systems which are closed 

to atmosphere. To do this, the point of generation must be clearly 

defined as the first air-water interface with the potential for organic 

release to the atmosphere. 

In conclusion, CMA thanks the NAPCTAC committee for this 

opportunity to present some of our ideas and concerns regarding the 

HON. We look forward to working with with EPA as it moves forward in 

the rulemaking process. At this point I'll be pleased to answer any 

questions from the committee. 
Discussion 

Following the EPA presentation, Mr. Bruce Jordan, Director 

of the Emission Standards Division, discussed the four goals of 

the HON standard. The first goal was to provide flexibility to 

industry to help minimize the costs of meeting the standard. The 

second was to provide ease of implementation. Third was 

certainty in enforceability. And fourth was to prevent 

environmental damage. 

Committee member Mr. Donald Arkell (Lane Regional Air 

Pollution Authority) opened the question segment by asking how 

new and existing emission points would be distinguished for the 

purposes of emissions averaging. Ms. McMurrer replied that 

Section 112(g) of the CAAA determines new emission points within 

the boundaries of the existing source. She stated that new 

emission points are not available for averaging, and would be 

subject to the new source MACT. Existing points within a source 

may only be averaged with other existing points. Mr. Arkell 

asked if that meant new and existing sources could not be 

averaged together. Mr. Jordan replied that was indeed correct. 

Ms. McMurrer took this opportunity to reiterate the definition of 

the terms emission point and source. An emission point is an 

individual tank or process vent while a source (as defined in the 

presentation) is the collection of SOCMI process units subject to 

the HON in a contiguous area under common control. 

Mr. Arkell noted that the emissions averaging accounting 

process sounded difficult, specifically the calculation of 

quarterly emission estimates. Dr. Jan Meyer, Standards 

Development Branch, answered that while extra recordkeeping would 

be required, the rule will give explicit instructions on how to 

calculate emissions for the points included in emissions 

averages. The data used to estimate emissions will be sitespecific. To comply with the rule, sources must also show the 

parameters they use to demonstrate their proper use of control 

technology. 

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Committee member Mr. Brian Taranto (Exxon Chemical Americas) 

asked what activities could generate emission credits, 

specifically activities related to the application of early 

reduction controls covered under Section 112(i) of the Act. 

Ms. McMurrer replied that those sources that are part of the 

Early Reductions program would be given credit for their 

application of controls that are more stringent than the HON 

standard. Mr. Taranto asked if other emission reduction 

activities taken before promulgation would generate emission 

credits. Ms. McMurrer replied that only activities under the 

Early Reductions program and pollution prevention activities 

since 1987 would generate credits. 

At this time, Mr. Taranto asked whether emissions averaging 

would be applicable to other MACT standards besides HON. 

Mr. Jordan replied that emissions averaging is currently being 

considered only for the HON and that the EPA would review its 

applicability to other MACT standards on a case-by-case basis. 

Mr. Jordan stated that emissions averaging will be studied 

internally by the EPA and that comments will be collected and 

considered between proposal and promulgation and, if warranted, 

emissions averaging could be removed from the promulgated 

standard. 

Ms. Deborah Sheiman (Natural Resources Defense Council) 

asked whether a quantitative analysis of the averaging scheme had 

been done to determine the expected change in emissions. 

Ms. McMurrer answered that emissions are expected to be equal to 

those without averaging, or less using a discounting factor. The 

actual decrease depends on the discounting factor chosen. 

Ms. Sheiman then stated that the emission levels from which the 

sources are starting do not necessarily reflect MACT. Mr. Jordan 

reiterated the EPA's position that emissions averaging will 

achieve the same amount or greater emission reductions than would 

be achieved otherwise. Ms. McMurrer stated that credits can only 

be generated by controlling emissions above the levels set by the 

technical requirements. Mr. Jordan expounded on Ms. McMurrer's 

statement by saying that, for example, every process vent may not 

be controlled by the HON and this would provide a source 

opportunities to achieve emission credits. 
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Mr. Ralph Hise (Advanced Technologies Management, Inc.) 

questioned whether the use of more stringent controls (i.e., 

innovative technologies) for credits would change the 

determination of MACT. Dr. Jan Meyer and Mr. Jordan both 

emphasized that MACT must be universally applicable and that 

there may be individual cases where a more stringent control 

technology can be applied that would not be widely applicable to 

other similar emission points. 

Ms. Vivian Mclntire (Eastman Chemicals Company) discussed 

the subject of quarterly emission limits, specifically as they 

related to compliance. She asked the attendees to suppose there 

were two vents involved in an emissions average. One vent was in 

compliance while the other vent was not. She questioned whether, 

as a result, you would be out of compliance for the entire 

quarter. Ms. McMurrer responded that yes, you would be out of 

compliance for the entire quarter. She explained that a quarter 

consists of a three-month rolling average. Ms. Mclntire then 

asked what happens if you are out of compliance and whether the 

states will be given the authority to decide compliance status. 

Ms. McMurrer replied that enforcement action for an emissions 

averaging non-compliance would be similar to enforcement actions 

taken in the absence of emissions averaging and that states are 

given authority to determine compliance since they establish the 

permits. 

Mr. William Dennison (Dennison and Associates) asked whether 

the discounting factor of 20 percent is workable and whether or 

not it incorporates any safety factor. Ms. McMurrer replied that 

the proposed rule seeks comment on the need and value of the 

discounting factor. She stated that EPA welcomed feedback on 

this topic. 

Next, Mr. Dennison stated that the standard did not seem to 

allow a reduction in production to generate credits. 

Ms. McMurrer replied that the production changes resulting in 

different emissions are allowed. However, if any emission points 

associated with the equipment experiencing changes in production 

levels were involved in an emissions average, any unanticipated 

debits would need to be balanced with additional credits. Ms. 
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McMurrer further stated that Mr. Dennison was correct in saying 

that production reductions could not be credited. 

Dr. John Pinkerton (National Council of the Paper Industry 

for Air and Stream Improvement, Inc.) asked how wastewater air 

emissions fit into the emissions averaging concept. Dr. Meyer 

replied that emissions from HON wastewater are distinguishable 

from other wastewater because they are estimated at and 

controlled from the point of generation. Dr. Pinkerton went on 

to state that if he understood correctly, credits could not be 

received for controlling wastewater emissions from non-SOCMI 

processes. Ms. McMurrer stated that this was correct. 

Committee member Mr. William O'Sullivan (N. J. Department of 

Environmental Protection) commented that, as a representative of 

state agencies, he was opposed to emissions averaging, especially 

for new sources or new emission points. Mr. O'Sullivan then 

provided EPA with three recommendations. The first 

recommendation was to include enforceable short-term emission 

limits with point-by-point commitments. Second, Mr. O'Sullivan 

disagreed with the assignment of nominal control efficiency 

values. He noted the wide variations in performance and 

recommended that different efficiencies be assigned for different 

levels of control for a control technology. Third, 

Mr. O'Sullivan stated that under the Early Reductions program, 

credits can be generated through process shutdowns. Mr. 

O'Sullivan felt that shutdown credits should not be allowed 

within the emissions averaging program. 

Next, Ms. Sheiman asked how pollution prevention is being 

defined. Ms. McMurrer answered that the definition from the 

Pollution Prevention Act of 1990 was being used. Dr. Meyer added 

that since pollution prevention was being incorporated into the 

HON, the rule would give the definition as well. Ms. Sheiman 

added that she felt that pollution prevention could be used as a 

loophole. 

For the final question, committee member Dr. Patrick Atkins 

(Aluminum Company of America) asked why the Industrial Toxics 

Program (ITP) was not included as an activity for generating 
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emission credits. Mr. Jordan replied that many of the activities 

taken under this program are pollution prevention, measures and, 

therefore, would be creditable under the HON. Those actions that 

are part of the ITP, but are not pollution prevention, are not . 

creditable because the ITP is voluntary, and thus not enforceable 

like the Early Reductions program. 

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