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October, 1997
Table of Contents:Executive Summary Introduction Why did Ohio EPA decide to do this pilot project? Project description Goals and objectives Planning and conducting inspections Summary of facilities and inspections Analysis of 1996 M2P2 inspections What do facility representatives think about M2P2 inspections? What do Ohio EPA employees think about M2P2 inspections? Southeast District Office comments OPP compilation of Ohio EPA employee opinions Effect of M2P2 inspections on environmental regulatory compliance May, 1997 pollution prevention survey of facility representatives Specific pollution prevention projects Quantitative measures of reduced waste generation Benefits of pollution prevention Compliance benefits of pollution prevention Barriers to pollution prevention M2P2 inspection influence on pollution prevention behavior Recommendations for revising and improving M2P2 inspections Choosing facilities Selecting an inspection team and determining an agenda Cross training Promoting pollution prevention Including M2P2 inspections and other M2P2 activities in planning and grants Measuring the success of M2P2 inspections Different models for M2P2 inspections Recommendations from the Southeast District Office M2P2 activities from October, 1996 to September, 1997 Conclusions and planning for future M2P2 activities at Ohio EPA References Executive SummaryIn August, 1995, Ohio EPA began a pilot project to test the feasibility of combining a multi- media focus and pollution prevention in environmental compliance inspections. Using funding from a U.S. EPA Pollution Prevention Incentives for States (PPIS) grant, the Office of Pollution Prevention reviewed compliance and pollution progress of inspected facilities and wrote this report to evaluate the pilot project. The goals of Ohio EPA's pilot project include determining if M2P2 inspections improve compliance, avoid cross-media transfers, and increase the use of pollution prevention to achieve and maintain compliance. The Ohio EPA's five District Offices and the Office of Pollution Prevention (OPP) coordinated the multi-media, pollution prevention (M2P2) inspection pilot project. Each of the District Offices completed four M2P2 inspections between October, 1995 and September, 1996. A team of inspectors for each relevant media program and a specialist from the Office of Pollution Prevention conducted compliance inspections using a process based approach and emphasizing pollution prevention options for compliance. Following each M2P2 inspection, the team wrote one letter to the facility summarizing compliance issues covering each program area, and included pollution prevention options for the facility to consider as a means to return to compliance, reduce waste generation, and/or achieve environmental improvement beyond compliance. Inspected facilities were also asked to complete a survey about their experience with the pilot project. Ohio EPA employees' opinions about M2P2 inspections were mixed and covered a wide range of opinions from definite interest in continuation to negative opinions on usefulness of the inspection approach. Most staff were very willing to offer positive and negative comments, as well as suggestions for improving multi-media, pollution prevention inspections. Facility representative opinions were also mixed; however, 13 of 17 representatives who completed a survey would prefer to see this type of inspection continued at their facilities. M2P2 inspections require more time from Ohio EPA staff for preparation and coordination; however, M2P2 inspections save time for some facilities because several inspections are completed in one day. M2P2 inspections provided good cross training in other environmental regulations for some Ohio EPA staff. Facility representatives liked being able to discuss all the regulatory requirements at the same time. In their responses to a May, 1997 survey, facilities indicated M2P2 inspections emphasize Ohio EPA's interest in pollution prevention to facilities and encourage pollution prevention activities and projects. Some facilities have reduced waste generation and are no longer subject to some environmental regulations. Several companies provided case studies of pollution prevention projects and provided quantitative measures of waste reduction; however, only a few of the projects were directly related to compliance and/or pollution prevention information discussed in the M2P2 inspections. The effect of these M2P2 inspections on environmental regulatory compliance is inconclusive. During and after M2P2 inspections, 12 facilities were not in compliance with environmental regulations. As of July, 1997, three facilities have not returned to compliance and/or new violations have been discovered. This report provides the following recommendations for revising and improving M2P2 inspections:
The Director's Office stated that formal multi-media activities will continue to be a part of Ohio EPA's work in Federal Fiscal Year 1998 and Federal Fiscal Year 1999. The Director's Office has asked the Assistant District Chiefs and the Office of Pollution Prevention to develop plans for future multi-media activities. IntroductionIn August, 1995, Ohio EPA began planning a pilot project to test the feasibility of combining a multi-media focus and pollution prevention in environmental compliance inspections. The Ohio EPA's five District Offices and the Office of Pollution Prevention (OPP) coordinated the multi- media, pollution prevention (M2P2) inspection pilot project. Each of the District Offices completed four M2P2 inspections. Using funding from a U.S. EPA Pollution Prevention Incentives for States (PPIS) grant, the Office of Pollution Prevention reviewed compliance and pollution progress of facilities inspected in Federal Fiscal Year (FFY) 1996. OPP reviewed Ohio EPA's pilot project to determine if M2P2 inspections improve compliance, avoid cross-media transfers, and increase the use of pollution prevention to achieve and maintain compliance. This report describes the M2P2 pilot project, including how the project got started, goals and objectives, and a summary of inspections. We analyze the facility representatives' and Ohio EPA employees' opinions and comments about the project. By looking at the current compliance status of facilities and their pollution prevention activities, we begin to answer questions about M2P2 inspections ability to improve compliance, avoid cross media transfer and increase the use of pollution prevention for compliance. We also make recommendations for revising and improving M2P2 inspections based on comments from all participants. District Offices also conducted M2P2 inspections from October, 1996 through September, 1997. Districts modified their approach to M2P2 based on their experiences in 1995 and 1996. The OPP plans to summarize the results of Ohio EPA's M2P2 inspections at least once per year. Ohio EPA plans to continue to develop and perform multi-media activities. Why did Ohio EPA decide to do this pilot project?When trying to coordinate criminal investigations of environmental activities for the Divisions of Emergency and Remedial Response, Section Manager Kevin Clouse recognized Ohio EPA's need to approach the investigations from a multi-media perspective. He suggested to the Director's Office that Ohio EPA should try to do more Agency work using a multi-media approach. Ohio EPA's Office of Pollution Prevention develops and implements pollution prevention initiatives that reduce pollutants in Ohio. OPP works with all Ohio EPA Divisions and Districts and approaches all projects from a multi-media perspective. OPP was aware of multi-media, pollution prevention efforts in other state environmental agencies and supported all Ohio EPA's activities that promote a multi-media, pollution prevention perspective, especially in Agency regulatory activities. Ohio EPA's District Offices had also started some multi-media activities before this pilot project. Many Districts investigated complaints about possible environmental violations using a multi- media approach. The Northeast District Office started a pilot project using multi-media inspections checklists. The Division of Surface Water, the Division of Air Pollution Control, and the Division of Hazardous Waste Management developed a multi-media checklist with 17 questions. Inspectors from the Divisions received training on how to use the checklist. Inspectors voluntarily completed these checklists during their regularly scheduled inspections. The Southeast District Office had a quality improvement group that developed procedures for handling multi-media complaints. The Southwest District Office had a quality improvement group that looked at all inspections to determine appropriate times for communications between Divisions during the inspection process. The Northwest District Office started a pollution prevention workgroup that is interested in working on multi-media issues. As Deputy Director for Programs, Jenny Tiell was also interested in a multi-media approach. She works with all regulatory programs at Ohio EPA and understands the many benefits of a multi-media approach to environmental protection. At Jenny Tiell's request, Ohio EPA chose to voluntarily implement the M2P2 inspection pilot project; there were no federal or state requirements that mandated this project. Project descriptionIn August, 1995, the Director's Office, the Assistant District Chiefs and the Office of Pollution Prevention met to begin planning a pilot project to test the feasibility of combining a multi-media focus and pollution prevention in environmental compliance inspections. The group discussed goals and objectives, M2P2 work in other states, and how Ohio EPA might do M2P2 activities (Ohio EPA, 1995). Goals and objectivesTo provide guidance for the M2P2 pilot project, Ohio EPA developed the following goals in August, 1995. Goal of M2P2 pilot project: Coordinate, develop and implement a multi-media pollution prevention (M2P2) project to determine the feasibility of conducting multi-media inspections and emphasizing pollution prevention in the effort. General goal of multi-media inspections: Increase the effectiveness of inspections, both environmentally and administratively. General goal of prevention-based inspections: Agency interaction with the regulated entity should result in the implementation of pollution prevention options whenever feasible. The regulated entity should move toward less need for regulation because of prevention-based environmental improvements, and Agency regulatory workload should be less and should avoid cross-media transfers. Planning and conducting inspectionsAll District Offices chose to conduct team inspections of four different facilities in their respective Districts. Districts chose to inspect facilities that have compliance requirements for air, water and hazardous waste regulations at a minimum. Some facilities also have compliance requirements for solid waste, storm water, and drinking and ground water. Divisions participating in the inspections included Air Pollution Control, Hazardous Waste Management, Surface Water, Solid and Infectious Waste Management, Drinking and Ground Water, and Emergency and Remedial Response. Local air agencies, local health departments and local pretreatment authorities also participated in some inspections. Each District formed an inspection team for every facility. Team members included an inspector for each relevant media program and a specialist from the Office of Pollution Prevention. Assistant District Chiefs met with each team to discuss the pilot project and help the team to begin to plan their inspection. In the Southeast District Office the Assistant District Chief also participated in the inspections. Each team chose a leader to coordinate logistics, the inspection agenda, and correspondence and communication with the facility. Teams met before inspections to discuss the facility's processes, compliance requirements for all media programs, and pollution prevention opportunities. Teams tried to develop inspection agendas focussed on processes instead of waste generation. Specific agendas were needed to coordinate the activities of several inspectors and to help the inspectors to effectively use the new M2P2 approach. The Office of Pollution Prevention provided pollution prevention information to facilities and inspectors, and accompanied inspectors on each site visit. The main goals of an inspection are to ensure compliance and to identify violations, but these M2P2 inspections also provided technical assistance to facilities in their pollution prevention efforts. The M2P2 approach also helped inspectors learn to recognize transfers of pollutants from one medium to another (e.g., from water to air), and to recognize possible pollution prevention options for compliance problems. Following each M2P2 inspection, the team wrote one letter to the facility summarizing compliance issues covering each program area, or one inspection report if no violations were found. The letter also included pollution prevention options for the facility to consider as a means to return to compliance, reduce waste generation, and/or achieve environmental improvement beyond compliance. Inspected facilities were also asked to complete a survey about their experience with the pilot project. Summary of facilities and inspectionsEach District Office conducted four M2P2 inspections in FFY 1996 for a total of 20 inspections. Facility profiles, including location, products manufactured, and number of employees are provided in Table 1. The majority of facilities manufacture goods in SIC codes representing primary metals industries, fabricated metal products, rubber and plastics, and industrial and commercial machinery. Facility size by number of employees ranges from 8 to 5000. Eight companies had less than 400 employees, six had between 500 and 850 employees, and five had more than 1600 employees. One facility, inspected as a result of a complaint investigation, is not included in this report's analysis. Table 1. Profiles of facilities inspected in Ohio EPA's M2P2 inspection pilot project
Compliance-related communication is completed and the Agency plans no further action at 15 facilities; compliance issues are pending at the others. Some of the pending cases have only minor issues. A tabular presentation of the M2P2 inspections and results is found in Table 2. Table 2. Summary of M2P2 inspections and facility compliance
Analysis of 1996 M2P2 inspectionsOhio EPA analyzed the 1996 M2P2 inspections in several ways. Ohio EPA surveyed facility representatives and Ohio EPA employees to ask their opinions about the inspections. We also looked at the inspections' effect on environmental regulatory compliance and on implementation of pollution prevention activities.What do facility representatives think about M2P2 inspections?Immediately after inspections, Ohio EPA surveyed representatives from the inspected facilities to evaluate the project's quality and effectiveness and to ask for comments. Table 3 lists the survey questions and responses from 17 facility representatives. Three facilities did not respond to the survey. Of the 17 facilities completing the survey evaluations, thirteen facilities would prefer to see this type of inspection continued at their facilities. Twelve facilities indicated this type of inspection should be used more at other facilities in Ohio. Sixteen of the facilities have or were intending to use pollution prevention to address their compliance needs identified in the multi-media inspections. Fifteen facilities included comments written by the facility's contact person. Two favorably mentioned the efficiency of the single-day "multi-media" approach as opposed to many inspections on different days. However, one facility representative said the inspected facility was too large and complex to benefit from such an approach, and in order to better maintain compliance, would prefer more in-depth, media-specific inspections in the future. Most facilities indicated it was desirable to deal with all environmental compliance issues during a single inspection rather than dealing with the issues on different days. Also, most facilities indicated it was desirable to communicate with a group of inspectors rather than a single inspector, and they indicated a team approach was effective in determining their compliance needs. However, as noted previously, some larger facilities indicated the multi- media team approach was inappropriate due to the size and complexity of their facilities. Also, some smaller facilities indicated they may feel "intimidated" by a team of inspectors when only one facility spokesperson is available to escort the inspectors. Table 3. Results of survey of facility representativesBased on 17 facility surveys received by OPP. Surveys were completed after facilities received inspection correspondence, two to four weeks after the M2P2 inspections. Average and range scores in Questions 3 through 10 were compiled from a 1 (less desirable) to a 5 (more desirable) response scale.
* One facility left this question blank on the survey.
Table 3. Results of survey of facility representatives (continued)
What do Ohio EPA employees think about M2P2 inspections?Ohio EPA employees opinions about M2P2 inspections were mixed, ranging from definite interest in continuation to negative opinions of their usefulness. Most staff were very willing to offer comments and suggestions for improving M2P2 inspections. The following comments from the Southeast District Office employees provide an overview of these opinions. Southeast District Office commentsEach SEDO inspector was asked to complete a questionnaire concerning their M2P2 inspection. Table 4, "Summary of SEDO M2P2 inspector questionnaire results," summarizes their comments.A group consisting of team leaders from the four SEDO inspection teams, three OPP representatives and the SEDO Assistant District Chief reviewed the facility evaluation summary and the inspector questionnaire summary. Based on these reviews and their experience with these inspections, this group developed the following advantages and disadvantages of the M2P2 inspections. Main advantages
Main disadvantages
The SEDO group also had recommendations for improving M2P2 inspections. These are included in the last section of this report under "Recommendations for revising and improving M2P2 inspections." Table 4. Summary of SEDO M2P2 inspector questionnaire resultsThe questionnaire was given to all 25 inspectors involved in one of the four pilot multi-media team inspections in the Southeast district during FFY 96. Inspectors represented all six district program areas, OPP, a Local Air Agency and a Local Health Department. Twenty-four inspectors returned the questionnaire. The following is a summary of the questionnaire results:
OPP compilation of Ohio EPA employee opinionsFrom August, 1995 to May, 1996, OPP compiled opinions from several Ohio EPA employees participating in the M2P2 project. These representatives included inspectors, team leaders and managers. Specific comments are listed in Table 5, "Partial summary of Ohio EPA employee opinions about M2P2 inspections, May 24, 1996." These opinions are similar to the SEDO employees opinions.Table 5. Partial summary of Ohio EPA employee opinions about M2P2 inspections, May 24, 1996These comments are a compilation of some of the comments from Agency employees recorded by OPP during pre-meetings, inspections, post-meetings, and the DHWM Retreat. Comments have not yet been solicited from all staff participating in the M2P2 pilot project. Also, please note that most staff have been very willing to offer positive and negative comments, as well as suggestions for improving multi-media, pollution prevention inspections.
Effect of M2P2 inspections on environmental regulatory complianceAssistant District Chiefs, teams leaders, and inspectors checked the current (July, 1997) compliance status of M2P2 facilities. They reviewed the facilities compliance with regulations and permits for air pollution, water pollution (including storm water), hazardous waste, solid waste, and drinking and groundwater. Central Office contacts reviewed the facilities compliance with regulations for Toxic Release Inventory reporting, Spill Prevention Control and Countermeasures plans, and polychlorinated biphenyls (PCBs), and Community Right to Know reporting. The facilities compliance status is current to July, 1997, and/or to the date of the last inspection for each set of regulations (note this date has a wide variation from July, 1997 to 1983).During and after M2P2 inspections, 12 facilities were not in compliance with environmental regulations. As of July, 1997, three facilities have not returned to compliance and/or new violations have been discovered. One facility has a solid waste landfill that requires closure; one facility had a lengthy workers' strike and compliance issues were not resolved; and one facility installed new air emission units after the M2P2 inspection and did not submit permits to install before installation. The effect of M2P2 inspections on environmental regulatory compliance is inconclusive. Some inspectors and some facility representatives thought the M2P2 inspection format was not as thorough as a traditional single medium inspection. If this perception is correct, some compliance violations might not have been cited. When inspectors determined facility compliance in July, 1997, they used whatever information was readily available. Facilities were not re-inspected to determine their current compliance status, although some have been inspected after their initial M2P2 inspection. Some Districts chose facilities that the Assistant District Chiefs thought would probably be in compliance to reduce the complexity of trying a new inspection approach. Some inspectors thought the M2P2 inspections improved their understanding of other regulatory programs and that this knowledge might allow them to assist facilities in overall environmental compliance in the future. This knowledge might also allow the inspectors to make better referrals to other programs in the future. The facility representatives thought they had a better understanding of their own facility's overall environmental compliance, although this might not affect their compliance status. For an overview of facility representatives opinions on the compliance benefits of pollution prevention, refer to the section, "Compliance benefits of pollution prevention." May, 1997 pollution prevention survey of facility representativesThe Office of Pollution Prevention surveyed 17 facilities in May, 1997 about the facilities' environmental compliance and pollution prevention activities after M2P2 inspections were completed. Facilities were inspected from 8 to 19 months before they received the survey. Survey questions are listed in Table 6. Sixteen of the seventeen facilities responded to the survey. From facility responses to the survey, the Office of Pollution Prevention was trying to measure compliance activity, pollution prevention activity, and actual pollution reduction at each facility. Table 6. Evaluation of Ohio EPA's M2P2 Pilot Project Questions for participating companies, May, 1997
Specific pollution prevention projectsThe survey asked facilities about pollution prevention projects they had implemented in the last two years. Many facilities had active pollution prevention programs and/or projects before their M2P2 inspections. However, a few projects were implemented as a result of the inspections and several companies thought the inspections pollution prevention emphasis helped to stimulate their pollution prevention programs. Some facilities have not had enough time after the inspections and before completing the survey to research, approve and implement pollution prevention projects. Also, note that activities listed here might not represent all pollution prevention activities at a facility. AEP, GavinAEP has installed baffles in the sewage treatment plant to trap solids. This also protects sand filters and reduces the number of times filters must be cleaned. Solid waste generation has decreased from 80 tons/year in 1995 to 20 tons per year in 1996. AEP estimates 1997 clean outs will generate only 5 tons. Bayer Corporation, NewarkBayer conducted an optimization program to regulate the face velocities at particulate pick up points in ventilation equipment to prevent unnecessary loss of raw materials. They also redesigned the particulate collection system to segregate and capture the two largest contributors to this waste stream. In new process lines, in-line particulate filters capture particulates and return them to the process. Chrysler Dayton Thermal Products Dayco, Bucyrus Glacier Daido America, BellefontaineGlacier Daido worked to reduce fresh water consumption and generation of electroplating sludge from wastewater treatment. Three evaporative separators were installed to recover lead plating bath from rinse waters. Seven cooling towers were installed, recycling 5.3 million gallons of water per day. A computer controlled cascade rinse water system was installed to conserve water and optimize the rinse process. A new computerized system was installed in the pretreatment system to control and minimize chemical addition and monitor performance. Goodyear Tire and Rubber Company, St. Mary'sGoodyear converted three high volume chemicals to semi-bulk, returnable containers, reducing scrap paper used in packaging by 30,000 pounds/year. They are expanding their packaging reduction program by working with material suppliers. Goodyear also changed from wood pallets to returnable containers for shipping, decreasing wood waste generation by 200,000 pounds in 1995 and 820,000 pounds in 1996. Gould Electronics, McConnelsvilleGould uses plating baths in one step of manufacturing copper foil. Some rinsing steps have been eliminated, and rinse water that is generated now feeds process baths. Gould reduced rinse water generation by 100,000 gallons/month and saves copper, a raw material, by 15,000 pounds/month. Holophane, NewarkHolophane's Energy Conservation Team has broadened its scope to include in-house recycling opportunities. Holophane now uses wire baskets (returnable containers) to transport materials to and from their satellite plants and a few select customers. By installing several closed loop systems, Holophane has reduced water use from 524,000 gallons/day in 1995 to 127,000 gallons/day. ITT Automotive, ArchboldIn 1996, a consultant conducted a waste minimization assessment for ITT Automotive. The consultant assessed annual waste streams by cost and quantity, and found ways to reduce discharges of water and raw material to the sewer by evaluating appropriate methods and technologies to reduce, treat and reuse wastewater. ITT reduced wastewater generation by installing drain boards and flow restrictors increasing the use of counter current flow rinses, and fixing leaks. Mead, ChillicotheMead has converted 31 parts washers from solvent to aqueous based cleaners, reducing hazardous waste generation by 31,000 pounds/year. Mead is trying to reduce their hazardous waste generation status from large quantity generator to small quantity generator. The parts washers were the largest source of hazardous waste. Pro-Tec, LeipsicPro-Tec started operation in Leipsic in January, 1993. The facility was designed with state of the art equipment and process design that also minimizes waste generation. Pro-Tec installed a cardboard baler in 1996 and reduced solid waste generation by 33%. Republic Engineered Steels, CantonRepublic has started 40 new pollution prevention and energy reduction projects in 1997, with a potential cost savings of $170,000. One project recovers boiler flue gas heat and preheats the boiler feed water. The boilers use less natural gas and less chemical additives, and generate less blowdown and less air pollutants. Republic is considering a different style of refractory ladle lining that will double the life of the lining. Republic partners with East Ohio Gas to reduce energy use through numerous energy efficiency projects. Other projects include energy efficient lighting and using graphite burners to heat pickle liquor. Roxane Laboratories, ColumbusRoxane implemented a maintenance program to determine when oil in machines needs to be changed. The oil is sampled and analyzed. Oil changes have been reduced from once every 3 months to once every 6 months, reducing waste oil generation by 50%. Senco Products, CincinnatiSenco Products is a manufacturer of collated staples and nails. Senco Producst has had a strategic plan for pollution prevention since 1987 with the objective to reduce all air emissions to zero. For several years Senco has been working to modify one of its staple processes to replace an adhesive containing VOC's of 5.63 pounds per gallon with technology utilizing 0.5 pounds VOC per gallon. Despite technical problems, this technology is being implemented. Once this technology has been fully implemented, the next objective is to incorporate zero VOC technology. All nails are currently manufactured with processes utilizing 0.5 pounds of VOC per gallon or less which replaced 5.63 pounds of VOC per gallon in the early 1990's. Another part of the strategy is to reduce hazardous air pollutant (HAP) usage to zero, and currently an 80% reduction has been achieved. Numerous solvent cleaning tanks have been replaced by water based systems. The remaining methyl ethyl ketone cleaning tanks have been replaced with an n- methylpyrrolidone based system that not only resulted in a 95% emissions reduction but extended floor usage from two weeks to eight months. Stolle Products, Sidney Benefits of pollution preventionThe survey asked the facilities, "What benefits has your company realized from implementing pollution prevention? Many facilities cited reduced operating costs as the most important benefit of implementing pollution prevention projects. The following list describes reported benefits and includes quotes illustrating benefits.
Compliance benefits of pollution preventionReducing waste generation through pollution prevention projects has the potential to help companies maintain compliance with environmental regulations. In some cases the requirements no longer apply to the company because they have reduced their waste generation. Refer to the section, "M2P2 inspection influence on pollution prevention behavior" for additional other benefits of pollution prevention projects. The following examples illustrate some compliance benefits of implementing pollution prevention. The facilities completed these projects before their M2P2 inspections. However, some facilities have not had enough time after the inspections and before completing the survey to research, approve and implement additional pollution prevention projects that could reduce waste generation and improve compliance. The hazardous waste inspector asked AEP Gavin to have a more specific contingency plan, especially to include the specific hazardous waste, paint, on site. AEP has reduced their hazardous waste generation of paint by better inventory control and reduced their generator status to small quantity generator. Small quantity generators are not required to have a detailed contingency plan. Mead has converted 31 parts washers from solvent to aqueous based cleaners, reducing hazardous waste generation by 31,000 pounds/year. Mead is trying to reduce their hazardous waste generation status from large quantity generator to small quantity generator. The parts washers were the largest source of hazardous waste. Because Gould completed several pollution prevention projects, they did not have to install a new wastewater treatment plant. Chrysler Dayton Thermal Products had these comments: "The M2P2 inspection did provide DTP with a more heightened awareness about using pollution prevention as a means of environmental compliance. During the wrap-up meeting and during the inspection, the inspectors provided DTP with suggestions concerning additional processes within the plant that should be investigated for pollution prevention initiatives. DTP realizes that any method to reduce pollution similarly reduces the potential for exceeding compliance requirements." Barriers to pollution preventionThe survey also asked the facilities, "Over the past two years, have you experienced any barriers or obstacles to implementing pollution prevention projects?" Some facilities report they had no barriers to implementing pollution prevention projects in the last two years. Other facilities reported the following barriers.
M2P2 inspection influence on pollution prevention behaviorSome facilities have had an active pollution prevention program for many years. Because they have been active in pollution prevention and implemented waste reduction projects, these facilities did not think the M2P2 inspections substantially influenced their pollution prevention activities. Other facilities implemented pollution prevention activities suggested during the M2P2 inspection or suggested in compliance letters. One facility broadened the scope of the plant's energy conservation team to include in-house recycling opportunities. The following quotes provide an overview of facility representatives comments. "The M2P2 inspection made us place more environmental importance on the use of pollution prevention, and as such all environmental activities are being reviewed with this in mind." "The M2P2 inspection emphasized that Ohio EPA is pushing pollution prevention more than pollution control." "The M2P2 inspection was very informative in terms of compliance help and pollution prevention efforts. We will continue to look at ways to reduce waste and recycle and will call on the Ohio EPA for information and/or assistance." "The M2P2 inspection caused us to formalize our pollution prevention program and to follow through on past commitments to reduce waste and energy use." "It was helpful to have an extra set of eyes specifically looking for pollution prevention possibilities and asking if we had ever considered changes to reduce waste. Some compliance inspectors are very busy looking for compliance issues and we don't talk about pollution prevention." "This type of inspection heightens our awareness about using pollution prevention to help our company. Also, this type of inspection involves upper management which helps to implement pollution prevention projects." "Having someone from the Ohio EPA's Office of Pollution Prevention provided valuable insight into the large amount of information available regarding pollution prevention throughout industry. Some of this information involving solvent replacement is being used in our TRI emission reduction program." "Bayer's charter and goals have always included being an environmentally friendly organization. Our primary goal is compliance, but beyond that we recognize that sound operating principles and pollution prevention go "hand-in-hand." It's not only good for the environment, it's good for business. The multi-media audit gave us an opportunity to evaluate ourselves using the expertise of Ohio EPA. Given the fact that we are a small site with limited resources, this sort of inspection was very helpful to us. We were able to focus our efforts in a precise time frame." Recommendations for revising and improving M2P2 inspectionsOhio EPA's initial goals for the M2P2 inspections were to see if conducting the inspections was feasible, to improve the environmental and administrative effectiveness of inspections, and to convince facilities to implement pollution prevention activities. The following recommendations for revising and improving M2P2 inspections should help future inspections attain the original goals. Choosing facilitiesWhat facilities are good candidates for M2P2 inspections? This is probably one of the most difficult issues to address. Assistant District Chiefs and staff used their best professional judgement to try to choose facilities for M2P2 inspections. Here are some suggestions for selecting facilities. Size - Consider the physical size of the facility, the number of employees, and the complexity and number of plant processes. M2P2 inspections seem to be most successful at facilities in the middle range of each of these factors. At large facilities inspections might not be thorough, it is more difficult to completely understand all the processes (for compliance evaluation and pollution prevention opportunities), and it is hard to complete an inspection in one day. Small facilities can be overwhelmed by several inspectors, and may not have compliance and pollution prevention issues in more than one medium. Multiple compliance requirements - Try to choose facilities that have compliance requirements in air, water and hazardous waste regulations. Look for facilities that also have compliance requirements for solid waste, storm water, and drinking and ground water regulations. Pollution prevention opportunities - Choose facilities that have the potential for reducing waste generation through pollution prevention. Look at the size of the facility, the number of compliance requirements, and the processes at the facility. Determine if the facility has been active in pollution prevention and/or seems willing to accept suggestions about waste reduction. Selecting an inspection team and determining an agendaAsk inspectors that address each compliance area at the facility to participate in the inspection. Ask someone from the Office of Pollution Prevention to participate. However, limit the total number of Ohio EPA employees to no more than four people. Both facilities and inspectors have stated that the entire M2P2 inspection process is more effective when team size is limited. If possible, one person should have previously participated in an M2P2 inspection. Inspectors should meet at least once before the inspection to talk about facility processes, waste generation, pollution prevention opportunities, and logistics. The group should try to develop a specific agenda for the inspection. Cross trainingIn the pilot project model, inspectors can informally provide cross training for each other during the pre-meeting, during the inspection, and through discussion of the correspondence to the facility. During the pre-meeting, each inspector can discuss compliance requirements for the facility and what the inspector normally looks for and does during their inspection. To do cross training during the inspection, inspectors will need to actively include everyone in discussions and ask questions of other inspectors. Inspectors can also review the post-inspection correspondence and discuss issues with other inspectors. Ohio EPA could consider conducting additional cross media for inspectors, similar in concept to training provided at Massachusetts Department of Environmental Protection and New York Department of Environmental Conservation. Washington Department of Ecology provided cross program, multi-media training to field staff covering the basic regulatory structure and top five common violations, compliance issues, and jurisdictional framework of air, water, hazardous waste regulations and underground storage tanks. Ohio EPA could consider including multi-media activities in new employees' position descriptions. If managers define multi-media activities as an important part of job duties, new staff will be more likely to participate in these activities. If M2P2 activities are not included in job descriptions, the Director's Office could consider formally defining all employees' roles for implementing M2P2 activities, possibly through a memo from the Director. Division and District Chiefs could encourage staff to conduct joint inspections with other programs more frequently. Currently, some individual staff routinely perform inspections with other programs. Ohio EPA could explore ways to have one Agency staff person carry two program messages. Ohio EPA could also consider conducting a formal evaluation of joint inspections. Promoting pollution preventionAn environmental specialist from the Office of Pollution Prevention provided pollution prevention training and information to inspectors in pre-meetings, during the inspection, and during the drafting of facility correspondence. OPP discussed general and process specific pollution prevention information. Although the OPP person usually actively participates, inspectors are encouraged to discuss pollution prevention and offer ideas to the facilities during the inspections. OPP plans to complete a pollution prevention training plan in September, 1997. The plan will outline Agency-wide and Division specific pollution prevention needs and provide details on how Ohio EPA staff might be trained. Training about multi-media pollution prevention inspections could be included in the training plan. For example, DHWM is currently training inspectors on how to conduct industrial pollution prevention assessments. The training also has a multi-media focus. Although inspectors will not be expected to conduct assessments, DHWM plans to require more pollution prevention activities as regular job duties for inspectors. Discussing pollution prevention in the inspection and in correspondence with the facility provides additional emphasis about the importance of pollution prevention to Ohio EPA. Facilities that are active in this area were glad to see Ohio EPA recognizing their efforts, and some facilities used Ohio EPA's emphasis to revive or begin pollution prevention activities. Some inspectors and facilities recognize that achieving or maintaining compliance by doing pollution prevention activities has many benefits. OPP staff noted the M2P2 model limited their ability to do extensive discussions or research on pollution prevention options for the facility. Because inspectors determine facility compliance with numerous environmental regulations during these inspections, less time is available to discuss pollution prevention. Including M2P2 inspections and other M2P2 activities in planning and grantsOhio EPA's FY 97 Environmental Performance Partnership Agreement (EnPPA), December, 1996, states that multi-media activities are the main focus of the Agreement. "The purpose of this EnPPA is to lay out a basic framework for changing the existing regime focused on media specific environmental programs where success is measured by the number of activities completed, to a multi-media system where success is measured by improvements in environmental quality." Ohio EPA could consider including more specific language and commitments to multi-media activities in future agreements. Ohio EPA has developed a Strategic Management Plan to direct all Agency activities. The plan defines Ohio EPA's vision, mission and long term goals. Each Division, District and Office developed its own plan to achieve the Agency's goals. Many Divisions, Districts and Offices mentioned multi-media and pollution prevention activities in their plans. Ohio EPA could consider including specific language in all Division and District strategic plans about multi-media, pollution prevention activities, and could consider including specific language in Accountability Agreements that discuss how the work will actually be accomplished. The Assistant District Chiefs and the Office of Pollution Prevention could draft this language when planning for FFY 1998 multi-media activities. This is especially important because M2P2 activities are not mandated or required by federal or state requirements. The language could identify the separate and complementary roles and responsibilities of the Director's Office, Assistant District Chiefs, Office of Pollution Prevention, and the Divisions. If multi-media activities are included in grants and strategic plans, Ohio EPA could also consider adding some measure of these activities in the Agency's new time accounting system.. Measuring the success of M2P2 inspectionsOhio EPA, U.S. EPA, and the inspected facilities would like to be able to measure the success of Ohio EPA's multi-media, pollution prevention inspections pilot project. However, the Assistant District Chiefs and the Office of Pollution Prevention did not design specific measurements for compliance and pollution prevention for the FFY 1996 M2P2 inspections before the project began. Some measures that we did develop included a facility survey immediately after inspections, soliciting comments from Ohio EPA employees, and a facility survey in May 1997 to determine compliance, pollution prevention implementation and waste reduction. To try to determine additional measures for future M2P2 inspections, Ohio EPA could review the work and results of compliance assistance projects in the Division of Hazardous Waste Management (DHWM). DHWM has measured the effectiveness of their projects with dry cleaners (Central Office) and hazardous waste generators in specific counties (DHWM, Southwest District Office). Ohio EPA could also compare M2P2 inspection results to similar facilities that were not inspected using M2P2 model, and review compliance rates, number of cross-media transfers, pollution prevention activities, and amount of waste reduction. Some specific measures for future M2P2 inspections could include: opinions of facility representatives and inspectors; number of unpermitted waste streams discovered; time to complete different activities; number of pollution prevention referrals; number of referrals from one program to another; compliance rate of facilities determined by follow-up inspections; decrease in compliance requirements (e.g., change from large quantity generator to small quantity generator of hazardous waste; change from Title V air permit to non-Title V permit); and changes in waste generation. Different models for M2P2 inspectionsWhen planning for future M2P2 activities, Ohio EPA could consider other models for inspections, such as sector based inspections, geographic based inspections, specialized inspectors, and M2P2 checklists (see "Planning for future M2P2 activities" below). Sector based inspections could target specific industries such as electroplating, dry cleaning, plastics manufacturing, etc. Geographic based inspections could target specific cities and counties, and/or specific watersheds. Specialized inspectors could inspect certain industrial sectors and/or be familiar with two or more regulatory programs. M2P2 checklists can be developed for one inspector to determine compliance with several regulatory programs during a single inspection. Recommendations from the Southeast District OfficeSteve Skinner, Assistant District Chief at SEDO, met with SEDO managers and staff and OPP after SEDO completed their first year of M2P2 inspections. The group discussed many aspects of the inspection process and developed the following recommendations for revising and improving the inspections.
M2P2 activities from October, 1996 to September, 1997Inspectors and OPP staff have continued to conduct multi-media pollution prevention inspections in FFY 1997. SEDO, CDO, NWDO and NEDO chose to perform inspections using the FFY 1996 pilot project model. SWDO created a multi-media checklist for inspectors to use in conjunction with regular single medium inspections. Their effort targeted small and medium size facilities. Some recommendations listed in this report for revising and improving M2P2 inspections were used in FFY 97 inspections. For example, fewer inspectors participated in each inspection. Conclusions and planning for future M2P2 activities at Ohio EPAThe goals of Ohio EPA's pilot project include determining if M2P2 inspections improve compliance, avoid cross-media transfers, and increase the use of pollution prevention to achieve and maintain compliance. Ohio EPA employees' opinions about M2P2 inspections were mixed and covered a wide range of opinions from definite interest in continuation to negative opinions on usefulness of the inspection approach. Facility representative opinions were also mixed; however, 13 of 17 representatives who completed a survey would prefer to see this type of inspection continued at their facilities. M2P2 inspections require more time from Ohio EPA staff for preparation and coordination; however, M2P2 inspections save time for some facilities because several inspections are completed in one day. M2P2 inspections provided good cross training in other environmental regulations for some Ohio EPA staff. Facility representatives liked being able to discuss all the regulatory requirements at the same time. Facilities indicated M2P2 inspections emphasize Ohio EPA's interest in pollution prevention to facilities and encourage pollution prevention activities and projects. Some facilities have reduced waste generation and are no longer subject to some environmental regulations. Several companies provided case studies of pollution prevention projects and provided quantitative measures of waste reduction; however, only a few of the projects were directly related to compliance and/or pollution prevention information discussed in the M2P2 inspections. The effect of these M2P2 inspections on environmental regulatory compliance is inconclusive. The Director's Office stated that formal multi-media activities will continue to be a part of Ohio EPA's work in Federal Fiscal Year 1998 and Federal Fiscal Year 1999. The Director's Office has asked the Assistant District Chiefs and the Office of Pollution Prevention to develop plans for multi-media activities. The Director's Office and the Division Chiefs would like the M2P2 planning activities to include the development of a list of inspection alternatives. These alternatives should focus on multi- media and pollution prevention, and allow the District to decide what alternative is most appropriate for the facility being inspected. Some Chiefs would also like the Districts to pilot and evaluate M2P2 approaches other than the FFY 1996 pilot project model of multiple inspectors in one inspection (see "Different models for M2P2 inspections" above). ReferencesOhio EPA. 1997. M2P2 Update: Ohio EPA pilot project to develop multi-media, prevention- based inspections: Summary of 1996 activities and 1997 M2P2 plans. Office of Pollution Prevention, Ohio EPA. March 31, 1997. Ohio EPA. 1997. SEDO FFY 97 multi-media pollution prevention inspection program. Steve Skinner, Southeast District Office, Ohio EPA. March 12, 1997 Ohio EPA. 1996. M2P2 Update: Ohio EPA pilot project to develop multi-media, prevention- based inspections: FFY '96 Summary. Office of Pollution Prevention, Ohio EPA. October 18, 1996. Ohio EPA. 1996. M2P2 Update: Ohio EPA pilot project to develop multi-media, prevention- based inspections. Office of Pollution Prevention, Ohio EPA. May 28, 1996. Ohio EPA. 1995. DRAFT: M2P2: Ohio EPA pilot project to develop multi-media, prevention- based inspections. Division of Emergency and Remedial Response and the Office of Pollution Prevention, Ohio EPA. August 21, 1995. AcknowledgmentsWe acknowledge and thank these organizations and individuals for their contribution to the multi-media pollution prevention inspection pilot project: U.S. EPA provided funding through the Pollution Prevention Incentives for States (PPIS) grant to the Office of Pollution Prevention, Ohio EPA, to evaluate and revise Ohio EPA's multi-media, pollution prevention inspection pilot project. Jenny Tiell, Deputy Director of Programs, Ohio EPA, asked Districts and Divisions to develop the pilot project. Kevin Clouse, Division of Emergency and Remedial Response, formally requested the Director's Office to consider multi-media activities. Jeff Hines, Rod Mehlhop, Steve Skinner, Jeff Steers, and Bob Wysenski, Assistant District Chiefs, made it happen! They coordinated all aspects of their respective Districts activities, including planning, inspections, and follow up with facilities and Ohio EPA staff. Special thanks to all of the inspectors and team leaders for taking the extra time to try a different approach to traditional environmental compliance inspections. |
For printed copies of this or other pollution prevention publications distributed by the Ohio Environmental Protection Agency, Office of Pollution Prevention, please call the Office of Pollution Prevention at (614) 644-3469.
A printed copy of the Office of Pollution Prevention publications distribution list, "Pollution Prevention Information Available from Ohio EPA", may also be ordered by calling (614) 644-3469.
Office of Pollution Prevention
Ohio Environmental Protection Agency
P.O. Box 1049
Columbus, Ohio 43216-1049
Phone (614) 644-3469
Fax (614) 644-2807
E-mail: email@example.com
Back to the Ohio EPA, Office of Pollution Prevention Home Page
Back to the Ohio EPA Home Page


text:
Washington: The US Senate has unanimously approved a resolution calling for easing Haiti`s debt burden to help with reconstruction efforts in the wake of the devastating January 12 earthquake.
The measure directs US representatives to the International Monetary Fund (IMF) and other international lenders to act to relieve Haiti`s external debt obligations and calls for future aid to be in the form of grants, not loans.
The "Haiti Recovery Act" also urges President Barack Obama`s administration to support the creation of an international trust fund for Haiti to support investment in infrastructure including the development of electric grids, roads, water and sanitation facilities, and reforestation initiatives.
"The people of Haiti face a long and difficult road ahead," said Democratic Senator Christopher Dodd, a lead author of the measure. "But today, the United States Senate made it clear that they will not have to walk that road alone."
Dodd, chairman of the Senate Banking Committee, crafted the resolution with Senator Richard Lugar, the top Republican on the Senate Foreign Relations Committee.
"The Senate will continue to assess measures that will help Haiti and develop greater stability and hopefully new opportunities. Dealing with Haiti`s crippling debt burden is an important initial step," said Lugar.

subset: commoncrawl


text:
We didn't book ahead, but the warm and friendly staff didn't mind. They showed us the room first to see if it worked for our group of people. The room was incredibly clean and neat. Breakfast was included. Will stay again!
We didn't book ahead, but the warm and friendly staff didn't mind. They showed us the room first to see if it worked for our group of people. The room was incredibly clean and neat. Breakfast was included. Will stay again!
We just stayed at the Radium Chalet, and it was great. Hopefully they can get a new trip advisor page put up because the are a lot of bad reviews on the Chalet Europe page. New owners, and they have done a lot of upgrades to the rooms. We would definitely recommend people give it a try.
The big hotel on the top of the hill in Radium has just changed ownership and names. It used to be known as 'Chalet Europe' but is now named "Radium Chalet". The rooms have been updated with flat screen tvs, the bathrooms totally re-done, the beds seem new. The new Filipino front desk people seem very friendly and eager to... More
New management who are very nice and personable. Rooms come with small kitchenette. The couch even pulled out to turn into a bed and there was a fire place which helped make it a little more romantic. View is unbeatable and price is reasonable. Nice and close to the hot springs.Would stay here again!
We stayed there for 1 night on a motorbike trip. The views are fantastic. There were a few of us so the owner showed us a few rooms so we had a choice. Our room was an end room that was nice. It has a small kitchenette with a nice living room area with a fireplace. There were 2 balconies... More
So, let's start with the really good stuff -- the view! They really do have the best location for a hotel in Radium. I wish we had been here in the summer so we could have sat out on the balcony and enjoyed it more but it was far far too cold for that on this visit. I also appreciated... More
We have been going to Radium for number of years, and Europe Chalet is the best spot to stay, enjoy the view, rest and have the beficial effects of the Radium hot springs thermal waters. The place is clean, safe, and quite. Great for relaxing.
The hotel could do a better job running itself. The managers who actually WORK there do a good job, but the owners are kind of a joke. I gave my information over the phone to the wife of the owner(who was kind of rude) and have to give it again when I arrived(the managers had NO IDEA I already made... More
First of all, the hotel is under new management and all the things that people are complaining about are being fixed! This is not an overnight process and patience needs to be exercised. I have been going to Radium Hot Springs for over 30 years (was introduced to Radium by my grandparents as a little girl) and in that time... More
Our stay at Chalet Europe was an excellent experience. The room was complete with a walkout balcony,fireplace, kitchenette and living room. The rooms are not brand new, but they are more importantly clean. Our complimentary breakfast was amazing, it was a continental breakfast with a hot smorgasbord. The view was spectacular and more surprising was the amount of wildlife that... More


text:
Shootings In East New York And Crown Heights Leave At Least One Dead
NEW YORK(CBSNewYork) — Two people were shot in the East New York section of Brooklyn on Sunday afternoon, according to authorities.
Officers arrived at 768 Miller Ave to find an 18-year-old, black, male with a gunshot wound to the chest, he was immediately transported to Brookdale hospital where he was pronounced dead.
The second victim a 16-year-old, black, male was shot in the leg and taken to Brookdale in stable condition.
"I think there was a fight. Then when I looked closer over there I saw two boys on the floor," a witness told 1010 WINS reporter Gary Baumgarten.
One suspect was described as black male, dressed in all black, and wearing a ski mask. He allegedly stepped out of a tan or brown, four-door, sedan driven by a heavy-set black female and opened fire on the teens before getting back in the car and escaping in an unknown direction.
In a separate incident in Crown Heights a woman and three others were shot, the woman was hit in the leg, injuries to the other victims were not immediately clear. Two of the victims were taken to Brookdale Hospital, two others were taken to Kings County Hospital, according to authorities.
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Join OkCupid
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- White
- Height
- 5′ 11″ (1.80m)
- Body type
- Athletic
- Diet
- Mostly anything
- Smokes
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- Drinks
- Socially
- Drugs
- —
- Religion
- Catholicism, but not too serious about it
- Sign
- Pisces, but it doesn't matter
- Education
- Working on university
- Job
- Technology
- Income
- $50,000–$60,000
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My favorite shows right now are HIMYM, Big Bang Theory, Dexter, Breaking Bad, and things of that nature.
My favorite shows right now are HIMYM, Big Bang Theory, Dexter, Breaking Bad, and things of that nature.
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Think outside the box. Sometimes the little things can say a lot.
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Global warming, lunch, or your next vacation… it's all fair game.
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For a long time without anything.
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Enjoy now. http://www.newgrounds.com/art/view/cebola/white-
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Buy your fist tool from the mart. (I'd recommend a fishing rod :b)
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Be the Intruder in this brutal shooter with amazing physics and animation.
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text:
Find a copy in the library
Finding libraries that hold this item...
Document Type: | Book |
All Authors / Contributors: |
Francis R Nicosia; Jonathan Huener |
OCLC Number: | 48026439 |
Notes: | The Mazal Holocaust Collection. |
Description: | 160 pages |
Contents: | G. Allen, The Ideology of Elimination: American and German Eugenics, 1900-1945; R. Proctor, The Nazi Campaign Against Tobacco: Science in a Totalitarian State; H. Friedlander, Physicians as Killers in Nazi Germany: Hadamar, Treblinka, and Auschwitz; M. Kater, A Criminal Profession in the Third Reich: Toward a Group Portrait of Physicians; W. Seidelman, Pathology of Memory: German Medical Science and the Crimes of the Third Reich; M. Burleigh, The Legacy of Nazi Medicine in Context; Appendix: Speech given by the President of the Max Planck Society for the Advancement of Science Hubert Markl on the occasion of the opening of the symposium entitled "Biomedical Sciences and Human Experimentation at Kaiser Wilhelm Institutes - The Auschwitz Connection." |
Responsibility: | edited by Francis R. Nicosia and Jonathan Huener. |
Five of the six essays are based on lectures delivered at an April 2000 symposium arranged by the Center for Holocaust Studies at the University of Vermont. Historians discuss such topics as the ideology of elimination: American and German eugenics, 1900- 45; the Nazi campaign against tobacco: scien
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True benevolence, or compassion, extends itself through the whole of existence and sympathizes with the distress of every creature capable of sensation.
Joseph Addison
Medicine, the only profession that labors incessantly to destroy the reason for its existence
James Bryce
The best argument I know for an immortal life is the existence of a man who deserves one.
William James
Men found that his absorbing egotism was deadly to all other men. It resembled the torpedo, which inflicts a succession of shocks on any one who takes hold of it, producing spasms which contract the muscles of the hand, so that the man can not open his fingers; and the animal inflicts new and more violent shocks, until he paralyzes and kills his victim. So, this exorbitant egotist narrowed, impoverished, and absorbed the power and existence of those who served him; and the universal cry of France, and of Europe, in 1814, was, "enough of him;" "assez de Bonaparte.
Ralph Waldo Emerson
Our very strength as lesbians lies in the fact that we are outside of patriarchy; our existence challenges its life
Charlotte Bunch
It is a lonely existence to be a child with a disability which no-one can see or understand, you exasperate your teachers, you disappoint your parents, and worst of all you know that you are not just stupid.
Susan Hampshire
Profound meditation in solitude and silence frequently exalts the mind above its natural tone, fires the imagination, produces the most refined and sublime conceptions. The soul then tastes the purest and most refined delight, and almost loses the idea of existence in the intellectual pleasure it receives. The mind on every motion darts through space into eternity; and raised, in its free enjoyment of its powers by its own enthusiasm, strengthens itself in the habitude of contemplating the noblest subjects, and of adopting the most heroic pursuits.
Johann Georg von Zimmermann
HOURI, n. A comely female inhabiting the Mohammedan Paradise to make things cheery for the good Mussulman, whose belief in her existence marks a noble discontent with his earthly spouse, whom he denies a soul. By that good lady the Houris are said to be held in deficient esteem.
Ambrose Bierce
Las Vegas marks itself out by nothingness. All the negative descriptions that can generally be used in labelling a city apply to it, for its absence of consistency actually makes its existence doubtful: no man's land, waste ground, non-place, ghost town, urban simulacrum, nowhere city, etc. For us it is Zeropolis, the non-city which is the very first city, just as zero is the very first number. The nothing that counts, the nothingness of neon
Sometimes people get the mistaken notion that spirituality is a separate department of life, the penthouse of existence. But rightly understood, it is a vital awareness that pervades all realms of our being.
David Steindl-Rast
I am confident that there truly is such a thing as living again, that the living spring from the dead, and that the souls of the dead are in existence.


text:
Pheromax For Men
We all want to be more sexually attractive to the opposite sex; to that end, manufacturers have jumped on board with a confusing plethora of pheromone products that claim to do just that.
The problem is, many of them are dubious at best and absolutely ineffective or even problematic with negative side effects (such as headaches, and bad mood, etc.) at worst. Is there really an effective pheromone product out there that REALLY works, such that it does what it says is going to do?
What is Pheromax For Men?
Pheromax For Men was created by German technology, such that it's an extremely concentrated formulation of two pheromones, androstenol and androstenone. Although users have found it to be very effective, they have one complaint — that it is unscented. Whether or not you think this is actually a drawback is up to you. That is, you can certainly simply add the product to your favorite cologne and have it work as well for you as any pheromone spray, without having to give up your favorite cologne.
The Specifics
The bottle contains 14 mL of solution, and specifically lists that it contains 2 mg of androstenol, and 3 mg of androstenone. The bottle itself is reusable and you can simply mix right with your favorite cologne or scent. The pheromones themselves last five to seven hours per application, which is a significant duration among pheromone products.
Does It Work?
The product states that when you wear this product, you feel superior, people think you're important, you're comfortable socially, and you give yourself an aura of class. And indeed, that seems to be tested out in real-life social situations. Users found that women responded positively to them when they wore it, and that they felt significantly more comfortable and confident overall.
The secret may be in the combination of the androstenol and the androstenone. If your natural personality is one that is more "laid-back," women are more attracted to you because the androstenone produces feelings of comfort and security. If your natural personality is one that is more assertive, the androstenone will attract them via the added confidence Pheromax For Men gives you. In addition, this combination of pheromones will give you all the benefits without any of the drawbacks adding "too much" of a pheromone, especially one like androstenone, can give you (headaches, negative feelings, etc.).
The Verdict
Pheromax For Men absolutely does work as it says it's going to. Although it has a hefty price tag ($79.95), it's certainly effective. The company also offers a 30-day moneyback guarantee so that you can get your money back if you want to — but chances are, you won't want to. This is one product that really does what it says it's going to.
Score | Product | Lab Certified | Guarantee | MG/bottle | Scent | Duration | Satisfaction | Full Review |
Visit Site | Price |
N/A | 5mg | 4-6 hours | 7.9/10 |
Read Review | $99.50 |
More advanced formulas from competing manufacturers are now sold in scented and unscented formulas delivering greater performance for your money.
Score | Product | Lab Certified | Guarantee | MG/bottle | Scent | Duration | Satisfaction | Full Review |
Visit Site | Price |
1. | 18mg | 6 hours | 9.4/10 |
Read Review | $89.95 | |||||
2. | 13.5mg | 4-6 hours | 8.5/10 | Read Review | $49.50 | |||||
3. | 10mg | 4-6 hours | 8.2/10 | Read Review | $69.95 | |||||
4. | N/A | 17mg | 4-6 hours | 8.1/10 | Read Review | $98.50 | ||||
5. | N/A | N/A | 4-6 hours | 8.0/10 | Read Review | $59.95 |
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text:
All GC controllers should work on Wii as far as I know. I'm sure they will work.
Hey all! I'm gonna be getting some 'cube games to play on my Wii.Has anyone tried the Logic3 controllers on their Wii yet? Has it been any success?
All GC controllers should work on Wii as far as I know. I'm sure they will work.
What are Logic3 controllers?Originally Posted by hoodedreeper
Inventory Thus Far:
Wii: Console, 2 Wiimotes/nunchuks, Wii Sports, Excite Truck, Rayman: Raving Rabbids!, Legend of Zelda: Twilight Princess, Call of Duty 3, and Metal Slug Anthology
DS: Old School DS, Super Mario 64 DS, The Urbz: Sims In The City, Tenchu Dark Secret, Trace Memory, Trauma Center, Warioware: Touched, Mario Kart, Lost Magic, Metroid Prime: Hunters, and New Super Mario Bros
A Logic3 controller looks like > THIS < I'm just trying to find cheaper alternatives than the proper controllers as i need 4 lol (1 official controller for me,3 un-official for my friends :P)
no reason why it shouldn't work try your local gamestation i picked up 2 official ngc controlers for £20.
i bought tht EXACT one for the wii and it works great. even been playing VC games with it.Originally Posted by hoodedreeper
The key to immortality is first living a life
worth remembering. - Bruce Lee
PSN ID: Byuakuya


text:
March 8, 1999 4:00 AM PST
War over the world's wireless future
- Related Stories
When will data change the wireless world?
February 10, 1999 -
Wireless CEOs target standards battle
January 26, 1999 -
New world order in wireless
January 25, 1999 -
Battle over wireless standards heats up
January 22, 1999
A meeting of the relatively obscure International Telecommunications Union (ITU) is attracting uncharacteristic attention from both government officials and industry executives. Preparations prompted an angry exchange of letters between the United States and Europe earlier this year.
At stake is the possibility of a single, worldwide standard for wireless phones, now divided among several largely incompatible technologies in various regions.
An ITU decision on a wireless standard could eventually allow consumers to use a single phone wherever they are in the world--instead of today's system, which often requires switching phones when traveling between U.S. states or overseas. The outcome also will affect what kinds of high-speed Internet and other services are available through a cell phone, and how much money consumers will pay for these services.
The ITU's goal of standardization sounds like a good thing, at least from a consumer's point of view. But the process has been controversial, with groups from the United States and Europe fighting hard to make sure their own standard--or something very close--comes out on top.
In today's wireless world, several incompatible versions of technology are currently in use. Most of Europe, Southeast Asia, and parts of the United States--or some 50 percent of the world's mobile phone users--use a technology called GSM.
But strong contingents in the States and elsewhere use opposing standards, alternately called CDMA or TDMA.
Each of these different technologies can be upgraded to a create a "third-generation" standard, allowing them to support high-speed Internet access and other new services.
This diversity, however, has created a field of landmines for the effort to create third-generation standards. European officials favor a technology that will boost local mobile giant Ericsson, but U.S. officials have complained about the European movement, in order to protect the interests of U.S. companies like Qualcomm.
Those conflicts heated up last year and early this year into an angry series of letters between European Union officials and U.S. regulators, including Federal Communications Committee chairman William Kennard, Secretary of State Madeline Albright, and Secretary of Commerce William Daley.
A bipartisan group of 14 influential U.S. Senators turned up the pressure late last week, sending a letter to President Clinton asking him to hold the line for multiple standards, rather than compromise for a single standard.
Meanwhile, a group of industry players last month agreed to support a proposal that backed multiple standards, with some new compatibility between the U.S. and European flavors of CDMA.
Brazilian face-off
The 11-day ITU meeting, which kicks off today in Fortaleza, Brazil, should settle some of the last year's debate.
The group has a deadline by the end of March to set the beginnings of technical specifications for the third-generation standard, with a final deadline by the end of 1999. This means that by the end of the 11-day meeting, it should be much clearer which one or which group of the competing technologies will drive future wireless investments.
Some close to the process say the group is likely to put off the decision further, however, to allow more time for the industry to develop its own convergence proposals.
"There is progress being made in the community," said Jim Tackesh, director of advanced programs for the U.S.-based CDMA Development Group. "The ITU wants to accommodate that."
Officials from the FCC and the Commerce Department are expected to be on hand to help keep U.S. interests up front. European officials will also be in attendance, and the new Secretary General of the ITU will meet privately with industry and government officials, in an attempt to smooth the waters.
But it's not yet clear whether one of the competing technologies, a "harmonized" combination, or a recommendation to allow several standards to coexist will come out of the meeting.
"Almost 50 percent of the mobile phone users in the world are using a phone based on GSM standards," said Ray Jodoin, senior wireless analyst for the Cahners In-Stat Group. "If I'm playing roulette, and almost half the wheel is black, and the rest is sprinkled with red and white, I know where I'm putting my money."
But ITU decisions are hard to predict, and very political, Jodoin cautioned. "They can walk into a room telling you white is white and come out saying black is white."


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Release Description:
Johnny Gat is on a mission to shoot the Devil in the face! In this standalone Saints Row action game Saints Row IV: Gat Out of Hell, players take on the role of Johnny Gat as he is sent into hell via a nefarious spirit board incident and left to combat demons, the horrors of the underworld (including prominent historical figures) and, of course, the Devil himself. Play as either Johnny Gat or Kinzie Kensington as you tear apart Hell in a quest to save the leader of the Saints' soul. Historical icons, old friends, older enemies, a talking gun, a full length musical number, and a whole lot of other shenanigans all await you in the open world expansion playground that is Saints Row: Gat Out Of Hell.
- Play as Johnny Gat or Kinzie Kensington - For the first time ever, play as the fan favorites Johnny Gat and Kinzie Kensington, alone or in 2-player online co-op.
- An Open World from Hell - Wage war against the Prince of Darkness through-out the 5 unique districts of hell any way you want: rescue allies, pick a fight with nightmarish Arch-Dukes, rob Satan's soul processing plants… dozens of options await you in an all new city unlike any that's been seen in Saints Row before.
- New Supernatural Powers - The acclaimed super powers of Saints Row 4 are back with a hellish twist – Soar through the air on fallen angel's wings, summon devilish imps to attack your foes, and surround yourself in a divine aura that forces all to worship you.
- Outrageous Weapons - Put the 7 deadly sins to good use with an arsenal of underworld themed arms: fire exploding frogs at enemies, shoot swarms of locusts, and even deal destruction from afterlife's most comfortable (and lethal) armchair.
- Kill Dex - We promise you can do it this time. Pinky swear.
Publisher: Deep Silver
Developer: Volition
Genre: Action
Region: FREE
Release Name: Saints.Row.Gat.out.of.Hell.XBOX360-COMPLEX
Size: 8.13 GB
Links: AMAZON | iGN | GameSpot | NFO | Torrent Search
Download: ViP FiLE – UPLOADED – RAPiDGATOR – Uploadable


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Currently at the Forum: Guess the movie from the image
Jet Li | |
Date of Birth: Apr 26, 1963 Country: China Biography: Li made his film debut in Shaolin Temple, the movie that launched the Hong Kong martial arts craze of the 1980s. A plethora of very popular Hong Kong action flicks followed; by the mid-'90s, Once Upon a Time in China, Black Mask and The Defender were getting release, and notice, in America. Li made his U.S. debut as a villain in Lethal Weapon 4. Li first u.s. starring role in Romeo Must Die. His American films include Kiss of the Dragon, The One and Cradle 2 the Grave. Total Films at Criticker: 46 - You've Seen 0 |
Biography last updated by dst7175
Find more information about Jet Li at The Internet Movie Database
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During the Yuan period, after the Mongol conquest of the Song dynasty, many of the leading landscape painters were literati who did not serve in office, either because offices were not as widely available as they had been under the Song, or because they did not want to serve the conquerors. Scholars' landscapes, like the paintings they did of other subjects, were designed for a restricted audience of like-minded individuals. It was not uncommon for scholars to use the allusive side of paintings to make political statements, especially statements of political protest. |
What would be the political appeal of depictions of scholars in caves? For the full handscroll, click here
Wang Meng (ca. 1308-1385), The Orchid Chamber, detail
The full handscroll: |
Huang Gongwang (1269-1354), Dwelling in the Fuchun Mountains, detail |
To see an overview of the entire scroll, click here [below in the Teacher's Guide]. | |
To see some more details, click here[ given below in the Teacher's Guide]. | |
An overview of the entire scroll:
Like other handscrolls, this one should be viewed from the right to the left. How is the painting organized? Does this look like a natural landscape to you, or did the artist alternate mountains and open spaces for aesthetic reasons? 1. 2. 3. 4. 5. 6.
Move on to Court Painting |


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Lodovico appears for the first time as an emissary to Cyprus from the Duke of Venice in Act IV, Scene 1. He inquires casually about the situation on the island, but immediately witnesses Othello strike Desdemona. Lodovico is shocked by Othello's behavior, asking the rhetorical question: "Is this the noble Moor whom our full Senate / Call all in all sufficient?" (IV.i.265-266). As a neutral observer, his comment highlights the dramatic devolution that Othello has suffered under Iago's spell. Lodovico cannot prevent the tangle of evil that occurs in the last two acts of the play. He does relieve Othello of his office and appoints Cassio as the governor of Cyprus before Othello's suicide. It is to Lodovico that the task of passing summary judgment upon Iago falls, as he pledges to go straight back to the state of Venice to report what has occurred. In this sense, Lodovico represents the return of civil order to Cyprus, albeit too late for Iago's victims.
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Resistance training is an essential workout that should be incorporated in any MMA fighter's workout. Strengthen up your arms, shoulders, chest, and abs by adding heavier weight resistance cables to your power walk handles. Resistance training is a great method to add low impact, high endurance, aerobic training to develop your strength and power.
Training Station weighs just over one pound. The Perfect Home Gym.
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Add resistance to sprinting and footwork drills to strengthen the lower body and build speed.
Increase your lower body strength and drive with the PER4M Leg Power Tube.
PER4M Jump Trainer includes four Power Tubes with Quick Release to easily add or remove resistance.
PER4M Juke 360 allows full range of motion for a large variety of drills to perform.
Resistance training with cardio.
Cables will work your arms, chest, back, and legs.
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Marketplace for Tuesday, May 21, 2013
Episode Teaser Image
Episode Description
After yesterday's tornado in Moore, Okla. -- where residents got about 15 minutes of warning -- we ask if tornado prediction has gotten better, and how it can continue to improve. What would it have taken to get more than 15 minutes? In tech-ish news, Apple's tax issue comes to the Hill with Tim Cook. But Apple isn't the only company that has funds beyond the reach of the IRS. Also, before you order dinner, news is out that Grubhub and Seamless, two online delivery services, are merging. Just how do these services make money and what about the restaurants?
Music from this show
Click below to purchase songs from this show through our Amazon affiliate.


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萨尔塔 Ferienhaus Hostel Salta
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