Introduction

Welcome to the Wyoming Department of Environmental Quality (DEQ), Voluntary Remediation Program (VRP) Interactive Toolbox for help in developing Pollution Prevention Plans (P2 Plans). 

PURPOSE OF THIS ASSISTANCE
The VRP statute states that facilities must be implementing a Pollution Prevention Plan consistent with the promulgated VRP rule to be eligible to enter a contaminated site into the program.  In order to help facility owners and operators develop P2 Plans, the DEQ/VRP is offering this information only to provide some ideas and useful content to help develop P2 Plans and minimize generation of wastes and releases of contaminants.  A contaminant is any chemical, material, substance or waste which is regulated, classified as hazardous or toxic, or to which exposure is regulated, under any applicable federal, state, or local law or regulation. (see W.S. 35-11-103(g)(iii)). This information is primarily to assist owners and operators who are developing P2 plans to meet the Alternative Minimum Pollution Prevention Operating Standards.

The content provided does not cover the scope of regulatory requirements for management of many of the wastes or contaminants mentioned.  Implementing P2 practices does not modify or replace regulatory compliance responsibilities associated with a specific contaminant.  For example, Best Management Practices (BMPs) included in the Interactive Toolbox provide several suggestions to manage contaminants to reduce the toxicity and/or the potential to release these types of contaminants.  An owner/operator who generates, treats, stores and/or transports hazardous waste has the responsibility to meet specific regulatory requirements for the management of hazardous waste.  More complete regulatory citations and guidance are available from other, separate resources within DEQ.

DEVELOPING A P2 PLAN
This assistance includes suggestions designed to assist facility owners and operators, who may be potential future volunteers in the VRP, with developing P2 Plans appropriate for their facilities.  The Interactive Toolbox is part of this information, and it includes some suggested BMPs that can be used to help create customized P2 Plans for different types of contaminants and businesses. The DEQ/VRP is providing these suggested BMPs only as a courtesy to assist facility owners and operators; it is not intended to be an exhaustive list.  Owners/operators are encouraged to add other facility and industry specific BMPs.  The best P2 Plan will include BMPs and ideas that owners/operators have learned through their own operating experiences and knowledge.

Prior to using this interactive toolbox, the DEQ/VRP suggests that the P2 Plan developer:

• Reads the P2 Plan Rule;
• Conducts a site walk-through of the facility;
• Inventories all contaminants that are used, stored or generated; and
• Inventories all areas and processes where contaminants are used or stored and have the potential to release to the environment. 

This inventory can help owners/operators develop a customized P2 Plan by guiding them to relevant BMPs provided in this information, as well as other resources that pertain to specific contaminants and processes.  Keep in mind that incorporating ideas, experiences and knowledge gained from owning and operating a facility is primary to developing the best P2 Plan.  Every facility is different with respect to contaminants in use, size, layout, location, staffing, machinery, operations and many other parameters; therefore, each P2 Plan will be different and specific to a facility and site. Owners/operators of multiple, similar facilities may want to consider if it is appropriate to develop a single P2 Plan that can be used at all of their facilities.

By implementing an appropriate P2 Plan, a facility owner is fulfilling one of the criteria needed for a facility to be eligible for participation in the VRP. The requirement for facilities to implement a P2 Plan as a condition of eligibility for the VRP is included in the VRP statute [W.S. 35-11-1601 to 1613].  Details on how to meet this P2 Plan requirement are provided in the VRP rule titled "Chapter 1--Pollution Prevention Plan Requirements for Eligibility in the Voluntary Remediation Program."

BENEFITS
Why is it important to develop and implement your P2 Plan as soon as possible?
If facility owners/operators are not implementing P2 activities in accordance with the rule’s provisions, they will not be eligible to take advantage of the VRP and voluntarily clean up the contaminated site. There are important benefits available to facility owners/operators only when contaminated sites are cleaned up through the VRP; these benefits are not available through any other DEQ program, and include:

• Liability Assurance (see VRP Fact Sheet #15) issued by the DEQ both during and after successful site cleanup;
• The possibility for the volunteer to calculate site-specific, soil cleanup levels; and
• The ability of the volunteer to petition for a Use Control Area, under certain circumstances (see VRP Fact Sheet #23).

How can implementing a P2 Plan help owners/operators operationally at their facilities?
In addition to meeting one of the eligibility requirements for the VRP, owners/operators implementing a P2 plan can cut costs and improve profitability:

• Save money by not wasting materials.
• Save money that would otherwise be spent cleaning up the resulting contamination that can impact soils, surface water and groundwater. Cleanup can be VERY expensive and take months or years to accomplish.
• Help to prevent employees and the public from being exposed to potentially harmful chemicals that may spill.   
• Some insurance companies offer discounts to companies that proactively take measures to prevent pollution.

Certain industries must have written P2 Plans while other facilities must demonstrate that Alternative Minimum Pollution Prevention Operating Standards are being implemented in order to be considered for participation in the VRP.

REGULATION HIGHLIGHTS – WHAT TYPE OF P2 PLAN IS REQUIRED and WHEN DOES IT HAVE TO BE IMPLEMENTED?
What Type of P2 Plan?  The VRP rule divides all Wyoming facilities into two categories that determine whether the facility needs to implement a written P2 Plan [Chp. 1, Section 4.a.] or implement “alternative minimum pollution prevention operating standards” [Chp. 1, Section 4.b.] to remain eligible for the VRP.

When Does a P2 Plan Have to be Implemented?  A key provision of the new P2 Plan rule stipulates when a facility needs to begin implementing a P2 Plan with respect to a given contaminant release, should the owner/operator want to enter that site into the VRP [Chp. 1, Section 5]:

• If the contaminant release in question occurred between March 10, 2000 and December 31, 2010, a facility must be implementing an appropriate P2 Plan at the facility before it submits the VRP application for that release.
• If the contaminant release in question occurs on or after January 1, 2011, a facility must have been implementing an appropriate P2 Plan at the time the spill or release occurred to be eligible to enter that site into the VRP.

The BMPs in this Interactive Toolbox are meant mainly for the Alternative Minimum Pollution Prevention Operating Standards tier of operators; but, written P2 plans need to cover these same topics in addition to other requirements.  As such, some BMPs or ideas listed herein would be relevant to include in a written plan. No templates or examples of written P2 plans are provided as these must be specific to your facility.