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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

52) ll-C-10 

Docket Number: 

A-90-37 

Printed 11/4/200810:22:19 AM Sheet 52 of 147 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF AIR AMD RADIATION 

MEMORANDUM 

REDUCE OR ELIMINATE PQELOTION TODAY! 

May 20, 3 9-9.1 

SUBJECT: Transmittal of an Agenda for the May 21, 1993 "P2 

Partnership Feasibility" Mp.c=-.ting, and My Working 

Definition of Pollution Prevention 

FROM: 

TO; 

Louie R. Palay, National Air Compliance ^oy.ULion 

Prevention (P2) Coordinator *._>' /( -j'••/'/>,, 

Addressees < 

BACKGROUND: 

On May 5, 1993, many of you joined me in 

which continued our discussion-? about the fca 

a eerioe of P2 partnerships (EPA/State/indust 

group) for the primary purpocc of deraonstrati 

••approach fto cpinpllance witn air pol i iit-.lon re 

superior to "ond-of-pipc" approaches. Du ring 

possibility of Using a recent 3M Company (-T2 

NSR) permit as a starting point for industry 

implement enforceable P2-baead permits was ra 

it wao agreed that there was a need for all i 

ofctaln and review tho 3M permit, and to meet 

matter further. Friday, May' 21st, from 8:30 

selected as the best choice for this meeting. 

a conference call 

oibility of foriuing 

ry/community action 

ng that a P2 

gulationc) waa 

that discussion the 

based, flexible 

to develop and 

ised. At that time 

ntoroetod parties to 

to discuss this 

am EDT to Noon was 

*+** Note that I have scheduled the meeting to start 30 

-minutea earlier than some of you heard before, and I have 

moved-up the time when thp telephone conference lines ate 

available, in order to accommodate addition;--! n*---pnrata 

presentations. **** 

LOCATION. PURPOSE, and MEETING AGENDA: 

Location; Classroom "D", on the second floor of our building 

at 2800 Crystal Drive, Crystal city, VA. 

Determine whether the DM Company permit provides a 

suitable and appropriate basis for developing P2-

baeed "flexible" permits. Such permits (including 

NSR, Title III and Title V) .ire one of tht* decirecJ 

outputs of -such partnerships. 
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Meeting Agenda; 

8:30-8:45 

8:45-9:30 

EPA welcome and opening remarks 

Video on semiconductor manufacturing process, 

Intel's major emiosion pointa, and P2 

opportunities 

Texas Instruments* summary of its 

manufacturing process, major emission points, 

and P2 opportunities 

SSCD summary of the 3M Company permit 

Dupont Corporation summary of its 

manufacturing process, major emission points, 

and P2 opportunities 

Merck Corporation summary of its 

manufacturing process, major emission points, 

and P2 opportunities 

Discussion comparing the 3M operating and 

permit conditions with the potential 

partners' operating and permit conditions 

Decisions - (1) are the 3M conditions 

sufficiently comparable to those of the 

industrial partners? (2) Does the 3M permit 

provide an appropriate basis for developing 

P2-based permits for the partnerships? (3) 

What are the next steps and tentative 

schedule? 

For those of you who can not attend the meeting in person, I 

have arranged to have telephone conference lines available, from 

9:30 to Noon (only). The call-in number is (202) 260-4290. If 

you have any difficulty connecting or being heard, please seek 

assistance from EPA's teleconferencing staff by calling 

(202) 260-2001. 

MY WORKING DEFINITION OF P2: 

P2 means Whatever action one takes, often in a continuous or 

iterative manner, to: eliminate or reduce the formation of 

pollution or waste at the source or in the process; or the 

protection of a natural resource by conservation. P2 does not 

include recycling, except when it is done "in process", e.g., 

continuously and on-site. Pollution prevention is the strongly 

preferred first choice which one should make when selecting an 

appropriate emission reduction approach. Only after all 

opportunities for P2 have been exhausted, should one choose an 

9:30-9:45 

9:45-10:00 

10:00-10:15 

10:15-10:30 

10:30-11:30 

ll:30-Noon 
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alternate option which is lower in the hierarchy, namely: 

recycling, if P2 is not sufficient or feasible; proper controls, 

if P2 and recycling are not sufficient or feasible; and proper 

(safe) disposal, if P2, recycling, and controls are not 

sufficient or feasible. Furthermore, any action which results in 

or causes a negative impact upon another media is not P2. 

Some examples of P2 include: improving combustion 

efficiency, pre-cleaning coal to remove sulfur before combustion, 

use of low Nox burners, reducing leakage from valves and piping, 

reducing the flow of air over a volatile toxic chemical, and 

replacing or reducing a toxic chemical used in a process. 

Addressees 

Potential Agency and Industry T2 Partners: 

Intel, Jim Jewett 

Texas Instruments, Janet Ondricek 

Dupont, John Dege 

Merck, Bruce Wallington (% D. Bowers) 

Kirt COX, AQMD, OAQPS 

Jack Edwardson, ESD, OAQPS 

Gregory Foote, OGC 

,/Mike Trutna, OAQPS 

William Tyndall, OPAR 

Gil Wood, TSD, OAQPS 

SSCD (L. Paley, L. Lay, C. Poffenberger, J. Engert, 

P. Reinermann, C. Mixon, D. Lyons) 

AED (J. Berman, K. schapiro) 

David Kling, PPD, OPPTS 

Lynn Vendinello, P2 Staff office 

cc: 

J. Rasnic, SSCD 

R. Biondi, SSCD 

S. Hoover, SSCD 

M. Miller, SSCD 

MTG521PE.RMT, 5/20/93