1. Storm Water P2 1 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WELCOME INTRODUCTION TO STORM WATER POLLUTION PREVENTION CUSTOMIZED ENVIRONMENTAL TRAINING

2. Storm Water P2 2 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC INSTRUCTOR Insert Instructor Name Here

3. Storm Water P2 3 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC  Define Storm Water.  Discuss Storm Water Pollution.  Discuss Regulations Applicable to Storm Water Pollution.  Discuss General Storm Water Program Requirements.  Discuss Storm Drains and Discharge Points.  Discuss Industrial Sources of Pollution and Associated Best Management Practices (BMPs).  Discuss Parking Lots and Road Pollution and Associate BMPs.  Discuss Land Use Management Practices.  Discuss Source and Treatment Controls  Discuss Use of Contractors. OBJECTIVES

4. Storm Water P2 4 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC  Understand the Definition of Storm Water.  Understand Why Storm Water Pollution Prevention is Important.  Understand the Need for Implementing Best Management Practices (BMPs).  Be Familiar With the BMPs Preventing Storm Water Pollution.  Understand Source Controls for Preventing Storm Water Pollution Prevention.  Understand Treatment Controls for Preventing Storm Water Pollution Prevention. GOALS

5. Storm Water P2 5 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BACKGROUND  Storm water discharges are often the #1 source of ocean, bay, lake, and river pollution in the U.S.  It is estimated that storm water contributes as much as 80 percent of the total water pollution in the U.S.  One quart of oil can contaminate 250,000 gallons of water.  One pint of motor oil can produce an oil slick one acre in size.  This training helps improve environmental compliance with the Clean Waster Act.

6. Storm Water P2 6 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC  Supervisors  Facility Engineers  Maintenance Personnel  Department Managers  Building Occupants  Process Specialists  Environmental Committees LEARNERS

7. Storm Water P2 7 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC The goal of this course is to provide supervisors with the tools needed to help prevent storm water pollution from the work done in their building or work area’s. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate storm water pollution prevention activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities. OVERVIEW

8. Storm Water P2 8 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WHAT THIS COURSE DOES NOT DO The course is not intended to provide in-depth training in the technical aspects of water treatment, product substitution or land use management. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.

9. Storm Water P2 9 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WHAT IS STORM WATER? STORM WATER: Rain, Snow or Ice Melt Water that DOES NOT SEEP Into the Ground but is Channeled by Storm Sewers. Final Destination of Storm Water is Streams, Rivers, Lakes or the Ocean.

10. Storm Water P2 10 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WHAT CAUSES STORM WATER POLLUTION? STORM WATER POLLUTION: Rain, Snow or Ice Melt Carries Pollution. Oil, Antifreeze, Detergents, Pesticides, and Other Pollutants. Water Flows into Storm Drains. Storm Drains Channel Water Directly into Streams, Rivers, Lakes or the Ocean.

11. Storm Water P2 11 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORM DRAINS STORM DRAINS: Found Near Businesses, Homes and Street Corners. Called Storms Sewers, BUT Are Different from Sanitary Sewer System. Water Flowing in Storm Sewers is Untreated.

12. Storm Water P2 12 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC THE CLEAN WATER ACT CLEAN WATER ACT Section 402(p) - Establishes Framework for Regulating Storm Water Discharges Under National Pollutant Discharge Elimination System (NPDES) Program. FEDERAL REGULATIONS: 40 CFR Parts 122-125 - NPDES regulations 40 CFR Part 122.26 - Storm Water Discharges (subject to NPDES program) 40 CFR Subchapter N - National effluent limitations guidelines.

13. Storm Water P2 13 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC NPDES PROGRAM The following eleven categories are defined in federal regulations 40 CFR 122.26(b)(14)(i)-(xi) as sources of "storm water discharge associated with industrial activity:“ Facilities with Effluent Limitations Manufacturing Mineral, Metal, Oil and Gas Hazardous Waste Treatment, Storage, or Disposal Facilities Landfills Recycling Facilities Steam Electric Plants Transportation Facilities Treatment Works Construction Activity Light Industry

14. Storm Water P2 14 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC NPDES PROGRAM All Municipalities with population over 100,000 Require a NPDES Permit. Even if Your Business Does Not Require Its Own NPDES Permit, If the Business is in a Municipality Requiring a Permit, the Business is Required to be in Compliance with the Municipality’s NPDES Permit. MUNICIPAL NPDES PERMITS

15. Storm Water P2 15 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC POLLUTION PREVENTION STRATEGIES Best Management Practices (BMPs) – The Easiest Method to Implement Source Controls Treatment Controls

16. Storm Water P2 16 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORM DRAINS AND DISCHARGE POINTS Keep Storm Drains and Other Discharge Points Clear. This Should Include a Regular Program to:  Remove Dirt, Oil, Grease, and Litter.  Grates Must Be Cleaned.  Inlets, Catch Basins, Clean-Out Access Points and Outlets Must Be Cleaned.  Perimeter Areas Must Be Cleaned. ALL BUSINESSES MUST:

17. Storm Water P2 17 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORM DRAINS AND DISCHARGE POINTS BMPs  Prevent Spills from Entering Storm Drains.  Eliminate Illegal Connections.  Routinely Inspect.  Routinely Clean Out All Storm Drains.  Control Litter by Sweeping and Picking Up Litter Regularly. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

18. Storm Water P2 18 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORM DRAINS AND DISCHARGE POINTS BMPs  Clean Mats.  Have All Wash Water Discharge to the Sanitary Sewer.  Use “Dry" Cleaning Methods.  Use Secondary Containment Measures for Waste Storage Areas. BMPs (continued): BMPs

19. Storm Water P2 19 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC STORM DRAINS AND DISCHARGE POINTS BMPs  Label All Storm Drain Inlets "No Dumping"  Practice Good Housekeeping.  Clean Up Spills Immediately to Minimize Safety Hazards and Deter Spreading.  Train all employees. BMPs (continued):

20. Storm Water P2 20 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MAINTENANCE AND CLEANING OF FLOORS AND OUTSIDE IMPERVIOUS SURFACES  Keep Floors and Impervious Surfaces Free of Contaminates.  Contaminants Can Contribute to Polluted Runoff When Floors and Outside Impervious Areas are not Maintained or Cleaned Properly. ALL BUSINESSES MUST:

21. Storm Water P2 21 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MAINTENANCE AND CLEANING OF FLOORS AND OUTSIDE IMPERVIOUS SURFACES BMPs  Practicing Good Housekeeping.  Keep Outside Areas Free of Trash.  Use Absorbent for Liquid Spills and Sweeping and Mopping to Clean Outside Areas.  Regularly Inspect and Clean Out Grease Traps. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

22. Storm Water P2 22 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MAINTENANCE AND CLEANING OF FLOORS AND OUTSIDE IMPERVIOUS SURFACES BMPs  Avoid Spilling Onto Floors.  Control Litter.  Never Dispose of Wash Water Into the Storm Drain.  Use “Dry" Cleaning Methods. BMPs (continued): BMPs

23. Storm Water P2 23 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MAINTENANCE AND CLEANING OF FLOORS AND OUTSIDE IMPERVIOUS SURFACES BMPs  Use a Damp Mop to Clean Floors.  Label All Storm Drain Inlets.  Clean Up Spills Immediately.  Train All Employees. BMPs (continued): BMPs

24. Storm Water P2 24 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT WASHING AND CLEANING  Wash or Clean Vehicles and Equipment Properly.  Contaminants can runoff if wash water is rinsed into gutters or storm drains. ALL BUSINESSES MUST:

25. Storm Water P2 25 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT WASHING AND CLEANING BMPs  If Possible Use Closed-Loop Washing.  Use Designated Wash Areas.  Use Alternative Washing and Cleaning Methods. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

26. Storm Water P2 26 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT WASHING AND CLEANING BMPs  Never Discharge Wash Water to the Storm Drain!  Properly Contain and Dispose of Cleanup Materials. BMPs (continued): BMPs

27. Storm Water P2 27 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT WASHING AND CLEANING BMPs  Label All Storm Drain Inlets “No Dumping”.  Clean Up Spills Immediately.  Educate employees on pollution prevention measures. BMPs (continued): BMPs

28. Storm Water P2 28 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT FUELING  Properly fuel vehicles and equipment to avoid contributing pollutants to runoff.  Store rags properly to avoid contamination of storm water. ALL BUSINESSES MUST:

29. Storm Water P2 29 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT FUELING BMPs  Cover Fueling Areas  Install Perimeter Drains.  Pave Fueling Areas with Concrete.  Install vapor recovery nozzles to control drips. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

30. Storm Water P2 30 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT FUELING BMPs  Discourage “Topping Off" Fuel Tanks.  Use Secondary Containment.  Use Absorbent Materials.  Use a rag cleaning service for contaminated rags. BMPs (continued): BMPs

31. Storm Water P2 31 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT FUELING BMPs  Transport Industrial Equipment to a Designated Fueling Area.  Clean Up Spills Immediately.  Train Employees on Proper Fueling and Cleanup Procedures. BMPs (continued): BMPs

32. Storm Water P2 32 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR  Properly Operate, Maintain and Repair Vehicles and Equipment.  Leaks and Worn Parts Can Result in Contamination of Storm Water. ALL BUSINESSES MUST:

33. Storm Water P2 33 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR BMPs  Use Berming and Drainage.  Inspect and Clean Equipment to Prevent Leaks and Excessive Buildup.  Move Activities Indoors or Cover Equipment Areas. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

34. Storm Water P2 34 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR BMPs  Never Pour Materials Down Storm Drains.  Avoid Hosing Down Work Areas.  Use Non-Toxic Substitutes for Chemicals When Possible. BMPs (continued): BMPs

35. Storm Water P2 35 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC VEHICLE AND EQUIPMENT MAINTENANCE AND REPAIR BMPs  Clean Storm Drains Regularly, and Stencil Inlets with "No Dumping".  Use Catch Basin Infiltration Inserts.  Cleanup Spills Immediately.  Train Employees. BMPs (continued): BMPs

36. Storm Water P2 36 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MATERIALS LOADING, UNLOADING AND STORAGE  Prevent Runoff from Contacting Pollutants and Avoid Spills in Areas Where Hazardous and Non-Hazardous Materials are Loaded or Unloaded.  Spills, Improper Storage and Sloppy Techniques May result in an Illegal Discharge. ALL BUSINESSES MUST:

37. Storm Water P2 37 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MATERIALS LOADING, UNLOADING AND STORAGE BMPs  Park Delivery Vehicles so that Spills or Leaks can be Contained.  Protect Materials from Rainfall.  Use Seals or Door Skirts Between Trailers and Buildings. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

38. Storm Water P2 38 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MATERIALS LOADING, UNLOADING AND STORAGE BMPs  Position Roof Downspouts to Direct Storm Water Away from Loading, Unloading and Storage Areas.  Use Drip Pans.  Sweep Parking Lots.  Store Liquids in a Designated Area on a Paved Impervious Surface Within a Secondary Containment. BMPs (continued): BMPs

39. Storm Water P2 39 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC MATERIALS LOADING, UNLOADING AND STORAGE BMPs  Clean Storm Drains Regularly, and Stencil Inlets with "No Dumping".  Use Catch Basin Infiltration Inserts.  Cleanup Spills Immediately.  Provide Employees Training. BMPs (continued): BMPs

40. Storm Water P2 40 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WASTE MANAGEMENT AND DISPOSAL  Properly Manage All Areas Where Solid, Liquid or Non- Hazardous Waste is Stored or Disposed.  Wastes Can Contribute to Storm Water Contamination if Not Properly Managed. ALL BUSINESSES MUST:

41. Storm Water P2 41 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WASTE MANAGEMENT AND DISPOSAL BMPs  Cover and Berm Waste Storage Areas.  Keep Outside Areas Free of Trash and Debris.  Store Wastes Indoors When Possible.  Keep Waste Containers Covered.  Regularly Inspect and Clean Grease Traps. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

42. Storm Water P2 42 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WASTE MANAGEMENT AND DISPOSAL BMPs  Use Non-Toxic Substitutes for Chemicals When Possible.  Recycle Food Grease, Cleaning Solutions, Oil, Antifreeze, Batteries and Fluids.  Sweep Parking Lots or Other Surfaces.  Store Liquids in a Designated Area on a Paved Impervious Surface Within a Secondary Containment. BMPs (continued): BMPs

43. Storm Water P2 43 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC WASTE MANAGEMENT AND DISPOSAL BMPs  Regularly Inspect and Clean Storm Drains, and Stencil Inlets with "No Dumping".  Cleanup Spills Immediately.  Regularly Control Litter by Sweeping.  Train Employees. BMPs (continued): BMPs

44. Storm Water P2 44 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING AND GROUNDS MAINTENANCE  Prevent Contamination of Storm Water Where Building or Ground Maintenance is Conducted.  Potential Sources of Contamination are the Overuse of Pesticides and Fertilizers and Over-Watering. ALL BUSINESSES MUST:

45. Storm Water P2 45 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING AND GROUNDS MAINTENANCE BMPs  Utilize Native Vegetation.  Use Landscaping Pesticides and Fertilizers Only as Needed.  Avoid Over-Water to Prevent Excess Runoff.  Use Integrated Pest Management (IPM) Where Appropriate. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

46. Storm Water P2 46 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING AND GROUNDS MAINTENANCE BMPs  Sweep Paved Surfaces, Rather Than Hosing Down or Using Blowers.  Properly Contain and Dispose of Wash Water, Sweepings and Sediments.  Use Non-Toxic Substitutes for Chemicals When Possible. BMPs (continued): BMPs

47. Storm Water P2 47 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING AND GROUNDS MAINTENANCE BMPs  Regularly Inspect and Clean Storm Drains, and Stencil Inlets with "No Dumping".  Cleanup Spills Immediately.  Regularly Control Litter by Sweeping.  Train Employees. BMPs (continued): BMPs

48. Storm Water P2 48 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING REPAIR, REMODELING AND CONSTRUCTION  Prevent Contaminants from Contributing to Polluted Storm Water Runoff in Areas Where Building Repair, Remodeling and Construction Activities are Conducted.  Contaminates can Include Paint, Finishes, and Other Hazardous and Non-Hazardous Material. ALL BUSINESSES MUST:

49. Storm Water P2 49 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING REPAIR, REMODELING AND CONSTRUCTION BMPs  Use Soil Erosion Control Techniques.  Enclose Painting Operations.  Properly Store and Dispose of Wastes.  Properly Store Materials That are Normally Used in Repair and Remodeling Such as Paints and Solvents. BEST MANAGEMENT PRACTICES INCLUDE: BMPs

50. Storm Water P2 50 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING REPAIR, REMODELING AND CONSTRUCTION BMPs  Sweep Paved Surfaces, rather than Hosing Down or Using blowers.  Properly Contain and Dispose of Wash Water, Sweepings and Sediments.  Use Non-Toxic Substitutes for Chemicals When Possible.  Regularly Inspect and Clean Storm Drains, also Stencil Inlets with "No Dumping". BMPs (continued): BMPs

51. Storm Water P2 51 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC BUILDING REPAIR, REMODELING AND CONSTRUCTION BMPs  Cleanup Spills Immediately.  Control Litter by Sweeping and Picking Up Trash on a Regular Basis.  Maintain Good Housekeeping Practices.  Train all employees. BMPs (continued): BMPs

52. Storm Water P2 52 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PARKING LOTS AND STREEET CLEANING  Prevent Contaminants from Contributing to Polluted Storm Water Runoff in Areas Where Vehicles travel or are parked.  Contaminates can Include Automotive Fluids, Paints, Waxes, and Other Hazardous and Non-Hazardous Material. ALL BUSINESSES MUST:

53. Storm Water P2 53 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PARKING LOTS AND STREEET CLEANING BMPs  After a Snow or Ice Storm, Don’t Use Salt. Use Sand as an Alternative.  Sweep Paved Surfaces, Rather Than Hosing Down or Using Blowers.  Properly Contain and Dispose of Wash Water, Sweepings and Sediments.  Regularly Inspect and Clean Storm Drains, also Stencil Inlets with "No Dumping". BEST MANAGEMENT PRACTICES INCLUDE: BMPs

54. Storm Water P2 54 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC PARKING LOTS AND STREEET CLEANING BMPs  Cleanup Spills Immediately.  Control Litter by Sweeping and Picking Up Trash on a Regular Basis.  Train all employees. BMPs (continued): BMPs

55. Storm Water P2 55 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC LAND USE MANAGEMENT  Planners Often Will Utilize Buffers, Easements, and Setbacks to Protect Bodies of Water.  Businesses Should Ensure that No Work is Done on These Types of Property and They are Regularly Cleaned.  Banks Along Bodies of Water Should be Stabilized to Prevent Erosion.

56. Storm Water P2 56 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC SOURCE CONTROLS  Source Controls Regulate the Amount and Rate of Runoff.  These Controls Consist Primarily of Infiltration Devices, and Minimizing the Amount of Directly Connected Impervious Areas.  Examples Include:  Minimize Impervious Area  Filter Strips and Swales  Oil Water Separators Source Controls:

57. Storm Water P2 57 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC SOURCE CONTROLS  Oil and Water Separators are Designed to Remove Some Contamination.

58. Storm Water P2 58 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC TREATMENT CONTROLS  Treatment Controls are Designed to Remove Pollutants from the Runoff.  Usually Applied to Drainage Areas Greater Than One Acre.  Some Examples of Treatment Controls:  Extended Detention  Retention or Wet Ponds  Wetlands  Filters Treatment Controls:

59. Storm Water P2 59 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC  Remember, You Control Your Facility or Area!  Review Procedures With Them Before Starting the Job!  Ensure They Are Properly Trained!  Determine Their Environmental Compliance Record!  Determine Who Is in Charge of Their People!  Determine How They Will Affect Your Facility’s Environmental Compliance! TIPS FOR USING CONTRACTORS

60. Storm Water P2 60 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC ELEMENTS OF A SUCCESSFUL STORM WATER POLLUTION PREVENTION PROGRAM 1. DETAILED WRITTEN STORM WATER POLLUTION PREVENTION ASSESSMENTS. 2. DETAILED WRITTEN STORM WATER POLLUTION PREVENTION BEST MANAGEMENT PRACTICES. 3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS 4. PERIODIC REINFORCEMENT OF TRAINING 5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION 6. PERIODIC FOLLOW-UP

61. Storm Water P2 61 / 61 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC THE IMPORTANCE OF A CLEAN ENVIRONMENT “I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.” Carol Browner Former EPA Administrator