Listed below are the issues raised by the Stakeholders during the backward mapping process. Each of these issues was "scoped" by checking with agencies on the probability of success as a pilot.

Air:

• Upgrading/changing equipment without revising permits;
• Decreasing costs for stack compliance at small facilities;
• Establish de minimus threshold for process equipment;
• New NESHAP rule at wastewater treatment plants;
• VOCs for mobile vs. stationary sources;
• Accidental releases under NJ TCPA and CAA Section 112;
• Potential-to-emit calculations;
• Bubble air permit.

Water:

• Pharmaceutical effluent guidelines;
• Pretreatment of organics discharged to sewer;
• NJPDES Stormwater permit revisions;
• Reduced treatment of organics discharged to sewer;
• Reduced frequency of lab analysis of effluent;
• Trading pollution limits for copper;
• Trading acidic/alkaline wastes across facilities;
• Waste minimization instead of double containment.

Hazardous waste:

• "Out of process" recycling as pollution prevention;
• "Out of process" recycling of hazardous waste without TSDF;
• Reprocess/recycle materials across facilities;
• Reuse of aqueous alcohols;
• Listing dye production waste as hazardous;
• Reusing wastewater as cooling water;
• Site remediation for small companies;
• Definition of solid/hazardous waste.

Multi-Media:

• Flexible track (reduced requirements for superior performance) for reporting;
• Flexible track for inspections;
• Flexible track for permitting;
• Consolidating similar reporting schemes;
• Minimized waiting period for permit modifications;
• Simplified registration for storage tanks;
• Notification of regulatory changes;
• Compliance assistance guidebook;
• Partnership with schools for chemical use, storage, and waste disposal;
• Amnesty for voluntary audits;
• International "TSCA" registration;
• TRI expansion;
• Label requirements for containers;
• Reducing overlap between agencies;
• Mentor small facilities for batch permitting;
• Recognition for good performance;
• Shift to performance-based standards and goals;
• Conflicting list requirements;
• Supplier/customer relationships;
• Product testing procedures;
• Permitting on a site-wide basis.

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Last Revision: March 13, 2000
http://www.epa.gov/emergingstrategies/njcip/is.htm