Hmm.. Replacing P with DIV might have some issues with simple substitution, because many P tags aren't closed.
Yet, there are apparently 2042 cases of P open tag and 1260 of P closed tag, using this awkward grep:
grep -R "</p" acs-* | grep -v resources | grep -v "www/doc/" | grep -v "www/xml/" | grep -v "acs-core-docs" | wc -l