DIVISION OF SURFACE WATER
P2 Excerpts from SFY 99 Environmental Performance Partnership Agreement (EnPPA), June,1998

Storm Water Program (page 53)

The basis of the Storm Water program is the application of best management practices (BMPs) and pollution prevention concepts to minimize the introduction of pollutants into point source discharges of storm water with the goal of improving water quality. Industrial and construction Storm water discharges are primarily regulated with general NPDES permits described above. Storm water discharges from municipalities with populations greater than 100,000 are regulated by individual NPDES permits.

Pollution Prevention Initiatives (pages 58-59)

Listed below are pollution prevention activities underway or planned in DSW:

Enforcement - DSW will continue to include pollution prevention components in enforcement actions in the past (Supplemental Enforcement Projects).

P2 in regulations - DSW may require pollution prevention evaluations as a criterion for approval of stream mixing studies. The Agency's antidegradation rules and water quality standards also contain some P2 components.

P2 in RAPs and LaMP - DSW has included language to emphasize pollution prevention in RAPs and the LaMP.

P2 in Great Lakes Binational Toxics Strategy - Provide federal technical assistance and funding for P2 projects, especially pertaining to the implementation of the Great Lakes Binational Toxics Strategy.

Multimedia Pollution Prevention (M2P2) - This program has been used to varying degrees in district inspections. Representatives of all of the media perform a coordinated inspection of a facility and identify P2 options that would help bring the facility into compliance or reduce its regulatory burden.

Education of regulated community - DSW has provided fact sheets to the regulated community during inspections or in mass mailings, provide specific guidance for categorical industries, and held public meetings and seminars to educate the regulated community. DSW also established a pollution prevention training program for POTWs and industrial wastewater treatment plant personnel.

P2 in N.S. programs - DSW has promoted source reduction through its own activities and through grants to implement nonpoint source control programs. It has also encouraged regional water quality management agencies to include pollution prevention in their activities. The N.S. group has participated on the Ohio Department of Agriculture's statewide pesticide management plan workgroup and has worked with USDA, NRCS, and OSU Extension to evaluate a whole farm planning project.

P2 in grants - DSW has used pollution prevention as a project selection criterion for grants distributed by Ohio EPA. The "Toledo CSO" grant, State #W596, has industrial pretreatment P2 provisions. A grant with IAMS in the Lake Erie Basin, State #W288, has providing P2 training. An OEEF grant, #93P021, has been used for Cincinnati MSD P2 training.

MCMP program - P2 was included as a component of the Municipal Compliance Maintenance Program described above.