Project XL | US EPA ARCHIVE DOCUMENT · and other regulated entities to achieve those goals in a...

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��Executive Summary .......................................................ix

Introduction .................................................................... 1

Learning from Experiments ........................................... 3

Innovations in Core Functions ...................................... 9

Ongoing Innovations .................................................... 13

Emerging Innovations .................................................. 83

Building a National Laboratory for Innovation .......... 95

Information Sources and Methodology ....................... 99

Glossary ...................................................................... 101

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Project XL 2000 Comprehensive Report compiles availableinformation on Project XL. It follows up the work started in theProject XL 1999 Comprehensive Report (October 1999).

This report has two volumes. Volume 1: Directory of Regulatory,Policy, and Technology Innovations describes more than 70innovations being explored by Project XL. These innovations arecatalogued by the core functions that are the fundamental processesand operations the U.S. Environmental Protection Agency must use inorder to perform its mission to protect human health and theenvironment. Volume 1 presents technical and policy informationrelevant to each innovation.

Volume 2: Directory of Project Experiments and Resultssummarizes the more than 50 projects and project proposals ProjectXL has produced to date. The 16 projects that have been underwayfor a year or more are described in some detail, including, back-ground, progress in meeting commitments, benefits for the environ-ment, benefits for stakeholders, benefits for the project sponsor,spin-off benefits (where applicable), key issues needing resolution,lessons learned, and information resources. For the 37 projects inimplementation for less than one year or still under development, onlybackground information is given.

For a short overview of program accomplishments please see Encour-aging Innovation, Delivering Results (September 2000) @ http://www.epa.gov/projectxl/.

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Projects in Implementation December 1999 orEarlier1. Andersen Corporation, Bayport, MN2. Atlantic Steel Redevelopment, Atlanta, GA3. Crompton Corporation Sistersville Facility (formerly

Witco), Sistersville, WV4. DOD: Elmendorf Air Force Base, Anchorage, AK5. DOD: Vandenberg Air Force Base, Santa Barbara

County, CA6. ExxonMobil Corporation, Fairmont, WV7. HADCO Corporation, Derry, and Hudson, NH; Owego,

NY8. Intel Corporation, Chandler, AZ9. Jack M. Berry Corporation, LaBelle, FL10. Lucent Technologies, Allentown, and Reading, PA;

Orlando, FL11. Massachusetts Dept. of Environmental Protection-ERP,

Commonwealth of Massachusetts12. Merck & Co. Inc., Elkton, VA13. Molex Incorporated, Lincoln, NE14. New England Universities Laboratories, Boston College,

University of Massachusetts-Boston, University ofVermont

15. NY State Dept. of Environmental Conservation, State ofNew York

16. Weyerhaeuser Company, Ogelthorpe, GA

Projects Underway or Under Development SinceDecember 199917. Anne Arundel County Bioreactor, Severn, MD18. Autoliv Automotive Safety Devices, Promontory, UT19. Buncombe County Landfill, Buncombe County, NC20. Chicago Regional Air Quality and Economic

Development Strategy, Chicago, IL21. City of Albuquerque, Albuquerque, NM22. City of Columbus (XLC), Columbus, OH23. City of Denton, Denton, TX24. City of Fort Worth, Forth Worth, TX

25. Clermont County Watershed Management Program,(XLC) Clermont, OH

26. Crompton Corporation TBT Project, Greenwich, CT27. DOD: Naval Station Mayport, Jacksonville, FL28. DOD: Puget Sound Naval Shipyard, Bremerton, WA29. Eastman Kodak Corporation, Rochester, NY; Windsor,

CO; Peabody, MA; White City, OR30. Georgia-Pacific, Big Island, VA31. IBM East Fishkill Facility, Hopewell Junction, NY32. IBM Semiconductor Manufacturing Facility, Essex

Junction, VT33. Imation Corporation, Camarillo, CA34. International Paper- Effluent Improvements, Jay, ME35. International Paper- Emissions Monitoring, Jay, ME36. Labs21, Nationwide37. Lead Safe Boston, Boston, MA38. Louisville and Jefferson Counties Metropolitan Sewer

Districts, Louisville and Jefferson Counties, KY39. Metropolitan Water Reclamation District of Greater

Chicago, Chicago, IL40. Naragansett Bay Commission POTW, Providence, RI41. National Aeronautic Space Administration White Sands

Test Facility, Las Cruces, NM42. New Jersey Department of Environmental Protection

Gold Track Program, State of New Jersey43. Ortho-McNeil Pharmaceutical, Spring House, PA44. Pennsylvania Department of Environmental Protection,

State of Pennsylvania45. Port of Houston Authority, Houston, TX46. PPG Industries, Inc., Pittsburgh, PA47. Progressive Auto Insurance Company, Nationwide48. Steele County, Minnesota (XLC), Steele County, MN49. United Egg Producers, Nationwide50. USFilter Recovery Systems, Inc., Roseville, MN51. U.S. Postal Service Denver, Denver, CO52. Waste Management, Inc. Virginia Landfill Bioreactors

Project, King George and Amelia Counties, VA53. Yolo County Bioreactor, Yolo County, CA

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Project Innovation Affected Media Featured onpage

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Regulations 15

Weyerhaeuser Company Integrated Pulp & Paper NESHAP Air, 16& Effluent Guidelines Water

3M Proposal NESHAP for Magnetic Tape Manufacturing Air, 17Operations Water

Crompton Corporation NESHAP for Miscellaneous Organic Air 18(formerly Witco) Processes

Atlantic Steel Clean Air Act Flexibility During Air 19Conformity Lapse

New York State DEC RCRA Waste Handling Waiver Hazardous Waste 21

New England Universities Performance-based Environmental Hazardous Waste 22Laboratories Management Standard

HADCO Corporation RCRA Conditional Delistings and Hazardous Waste 23Molex Incorporated Solid Waste Variances

IBM Vermont Process Exemption for Copper Plating Hazardous Waste 25Process

City of Albuquerque Integrating Pollution Prevention into Water 27POTW Pretreatment

City of Denton Remote Monitoring and Watershed Water 27Protection

Louisville-Jefferson Watershed-based Pretreatment Water 28County MSD Management

Steele County Mass-Based Compliance Standard for Water 28Pretreatment Industrial Users

Steele County Reduced Monitoring for Regulated Water 30Pollutants not Present

ExxonMobil Corporation CERCLA Streamlining to Recycle Hazardous Site 31Superfund Site Remediation

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Permitting 33

Intel Corporation Facility-wide Permit Air Emission Caps Air 34Weyerhaeuser CompanyMerck & CompanyImation Corporation

Andersen Corporation Performance-Based Permitting Air 36

Elmendorf AFB Pollution Prevention Incentives Through Air 38Title V Streamlining

International Paper-EI NPDES Effluent Improvements Water 39

Weyerhaeuser Company Water Effluent Limits Water 40

Berry Corporation The Consolidated Multimedia Operating Multimedia 40Permit (COP)

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Information Management and Access 42

Steele County Alternative Reporting on Web site Water 43for POTWs

Intel Corporation Enhancing Public Access: Internet Reporting Multimedia 43and Stakeholder Input

Merck & Company Tiered Reporting: Building Incentives into Multimedia 45Data Collection Requirements

Intel Corporation Consolidated Reporting: Streamlining the Multimedia 45Merck & Company Reporting BurdenWeyerhaeuser Company

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Enforcement and Compliance Assurance 48

Massachusetts DEP, Business Self-certification Multimedia 49Weyerhaeuser Company

International Paper-PEM Predictive Emissions Monitoring Air 51

Massachusetts DEP Environmental Business Practice Multimedia 52Indicators (EBPIs)

Merck & Company Alternative Compliance Mechanism Air 53

Weyerhaeuser Company Tiered Compliance Testing Air 54

Georgia Pacific Gasification of Pulping Liquor under Air 55Corporation MACT II


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Environmental Stewardship 57

Weyerhaeuser Company Link EMSs to Facility Standard Operating Multimedia 58Berry Corporation Procedures

Lucent Technologies An EMS Model That Can Be Used at Multimedia 59Multi-facilities

Crompton Facility-based Reviews That Inventory Multimedia 60(formerly Witco) and Suggest Process-level Pollution

Prevention Approaches

Weyerhaeuser Company Timberland Resource Strategies Multimedia 61Multi-Agency

New England Universities Institutional Recycling by Managing Hazardous Waste 63Laboratories All Laboratory Chemicals

Intel Corporation Process Modifications and Solid and 64Waste Minimization Hazardous Waste

Vandenberg AFB Reduce Permit Burdens Through Air 65Pollution Prevention

U.S. Postal Service Denver Transition to Lower-emitting Flexible Air 66Fuel Vehicles

Progressive Insurance Base Automobile Insurance Rates upon Air 67Specific Driving Factors

Intel Corporation Water Reclamation and Reuse Water 68

Naval Station Mayport Reuse Dredged Material Water 70

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Stakeholder Involvement 72

ExxonMobil Corporation Public Participation Hazardous Site 73Remediation

Weyerhaeuser Company Public Participation Multimedia 74Intel CorporationMerck & CompanyHADCO CorporationAndersenNew England UniversitiesLaboratoriesVandenburg AFBAtlantic SteelCromptonExxonMobil

Program wide Manual for EPA Project XL Teams, Multimedia 75Project XL Stakeholder Involvement Guide,and Project XL: Best Practices for ProposalDevelopment

Program wide Project XL Stakeholder Involvement Guide Multimedia 76

Program wide Build Stakeholder Capacity Multimedia 78

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Agency Culture Change 79

Program wide Senior Management Support and Multimedia 79Involvement through the ReinventionAction Council

Program wide Managing Experiments in Partnership with Multimedia 80State and Tribal Governments

Program wide Effective Cross-Agency Teams for Multimedia 81Multimedia Experimentation

Program wide Compliance Screening for XL’s Multimedia 82Voluntary Project Sponsors

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Emerging Innovations 83

RegulationsAnne Arundel Testing Bioreactor Method: Recirculating Solid Waste 85Buncombe County Leachate over Alternative Liners

AutolivAutomotive Enabling Metals Recovery from Hazardous Waste 85Safety Devices Pyrotechnic Material

City of Chicago Regional Air Quality and Economic Air 86Development Project

IBM Fishkill Using F006 Wastes as an Ingredient in Hazardous Waste 86Cement Production

Lead Safe Boston Lead-based Paint Debris Disposal Flexibility Hazardous Waste 86

Chicago POTW Alternative Effluent Discharge Monitoring Water 86

Narragansett Bay Enhancing the Metal Finishing 2000 Program Water 87Commission POTW

USFilter Recovery Encouraging Metals Recycling and Recovery Hazardous Waste 87Services

Virginia Landfills (Amelia Bioreactor Method: Comparing a Leachate Solid Waste 88and King George County) Recirculation System to the Introduction of

Additional Liquid Amendments in SanitaryLandfills

Yolo County Bioreactor Method: Aerobic versus Solid Waste 88Anaerobic Technology

PermittingPennsylvania DEP Investigating an Alternative Approach to Water 89

Promoting Coal Remining

United Egg Producers Environmental Management Systems/ Water 89Third-Party Certification

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Emerging Innovations (Continued)

Enforcement and Compliance AssurancePuget Sound Naval Integrated Marine Environmental Water 90Shipyard Compliance Program

New Jersey Gold Track Performance-based Approaches to Multimedia 90Environmental Management

Port of Houston Authority Port/Tenant Environmental Management Multimedia 90Programs

Environmental StewardshipClermont County Community-based Watershed Protection Water 91

City of Columbus Enhancing a Local Lead Hazard Program Hazardous Waste 91

Crompton TBT Flexibility in the Tributyltin Monitoring Water 92Program

Kodak Pollution Prevention Assessment Chemical Management/ 92PPG Framework (Developing Environmentally Hazardous Waste

Preferable Products in the ChemicalIndustry Through Technology Transfer)

City of Fort Worth Proactive Demolition of Structures Air 92Containing Asbestos

Labs21 Increased Efficiency in Lab Operations Water 93

Ortho-McNeil Catalytic Oxidation of “Mixed Waste” Hazardous Waste 93Pharmaceutical

Information Management and AccessNASA Real Time Web-Based Information Multimedia 94

Management


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In 1995, the U.S. Environmental Protection Agency (EPA) launchedan unprecedented new initiative known as Project XL to test innova-tive ideas that demonstrate environmental eXcellence and Leadershipby those who must comply with Agency regulations and policies.Project XL is one of several high-priority initiatives that challengedEPA to think about new ways to fulfill America’s environmental andhuman health protection goals, while simultaneously allowing businessesand other regulated entities to achieve those goals in a smarter, cleaner,and cheaper way.

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Project XL solicits ideas from privateand public sector facilities,states, trade associations, and com-

munities that propose solutions to difficultregulatory or technical problems and ex-plore new approaches to protecting humanhealth and the environment, usually at a lower cost or lessened regula-tory burden for the sponsor. In opening the door to experimentation,EPA has sent the message that it values innovation and, above all,wants superior environmental results.

The experiments being conducted under Project XL are in variousstages: some are just getting started, others have been underway forseveral years. In the 1999 Comprehensive Report, we identified 14projects with signed Final Project Agreements; as of November 2000,there are 48. What we are learning from these experiments has growndramatically in thepast year. Last year,we identified 35 in-novations withinprojects, this yearmore than 70 inno-vations have beenidentified. The 2000Comprehensive Re-port, Volumes 1 and2 are intended to bea reference guidefor those interested

Innovation – Anaction that starts orintroduces somethingnew or creative.

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RegulationsPermit Reform

Environmental Information ManagementEnforcement and Compliance Assurance

Environmental StewardshipStakeholder Involvement

Culture Change○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

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of Regulatory, Policy, and Technology Innova-tions presents the innovations and lessons learnedorganized by how they relate to the seven corefunctions that the Agency typically performs tocarry out its mission to protect human health andthe environment. Specifically, it discusses the:

• Experiment—characterizing the innovation be-ing tested and the regulatory flexibility beingsought;

• Results/anticipated outcomes—outlining theexpected advantage of the innovation over thecurrent approach and the results to date; and

• Transferability—detailing the efficacy of theinnovation and its suitability for application be-yond the pilot scale.

Volume 2: Directory of Project Experiments andResults provides a status report of the more than50 projects and proposals Project XL has supportedto date. Volume 2 highlights overall program ac-complishments, such as cumulative environmentalbenefits as exhibited below.

Then each project is described including a discus-sion of the achieved and expected environmentalperformance, achieved or expected financial andother benefits to the businesses and communitiessponsoring projects, achieved or expected benefitsto the other stakeholders involved, legal flexibilitythat allows the project to work, and barriers con-fronted and lessons learned.

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��.�� Today, EPA has experiments with a variety of part-ners: Fortune 500 companies and small businesses,state and local government agencies, and commu-nities. Each project has been designed to produceimportant benefits for the sponsor and the environ-ment. Companies are cutting costs, communitiesare addressing priority concerns, and regulatoryagencies are targeting their resources more effec-tively. Each of these benefits must meet the stan-dards of superior environmental performance andenhanced environmental protection.

But the intent of the program is not to serve only aselect few. The goal of Project XL continues to bemuch broader—to find solutions that can be inte-grated into our environmental protection system foreveryone’s benefit. This goal is being achieved intwo ways: first, by creating more options for envi-ronmental management and second, by taking amore comprehensive approach to environmentalmanagement.

Creating More Options for Environmental Man-agement. Through Project XL, EPA provides com-panies and other project sponsors with a forum todemonstrate their abilities to find innovative ap-

* This summary is based on results reported by Crompton Sisterville (formerlyWitco), Intel, Molex, Vandenberg AFB, and Weyerhaeuser.

** Eliminations in emissions are calculated by subtracting reported actualemissions from established baselines for the environmental parameters for eachproject.

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1997-1999 1997-2000

emissions eliminated (criteria air 20,853 tons 31,775 tonspollutants - nitrogen oxides, sulfurdioxide, particulate matter, carbonmonoxide)**

solid waste recycled 2,089 tons 10,855 tons

water reused 1,069 million 1,846 milliongallons gallons

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proaches to environmental protection. For example,Project XL provides a way to move state-of-the-art environmental technology from the fringes intothe mainstream. It does so by providing companieswith the incentives they need to make the requisitetesting and evaluation worth their time and invest-ment. We can see in the following examples how,over time, if a technology proves successful andothers become more receptive to its use, betterresults will be achieved for a growing number ofpeople.

• Georgia-Pacific Corporation. At its Big Is-land, Virginia, pulp and paper mill, George-Pa-cific is testing a new “gasification” technologyto control emissions of hazardous pollutants.One of the byproducts of their manufacturingis a “black liquor,” which contains a mix ofchemicals used in pulp production. With con-ventional technology, these chemicals are re-covered through combustion evaporation.Preliminary testing shows the new gasificationtechnology uses less energy and significantlylowers emissions of hazardous pollutants. How-ever, the Georgia-Pacific test is the first com-mercial-scale demonstration and there is somepotential that the technology may not work aswell as expected. In order for testing of thispromising new technology can proceed, EPAwill temporarily exempt the company from newhazardous waste emission requirements thatare expected to become effective during theexperiment.

• Molex Incorporated. At its electroplating fa-cility in Lincoln, Nebraska, Molex is using newtechnology to reduce the metal loadings in itswastewater. The new technology separates thewastewater streams from individual metal plat-ing processes, enabling the company to recoverdifferent metal contaminants, such as lead andcopper, from its wastewater. Molex had ex-pected this new technology to reduce metalloadings to the community’s wastewater treat-ment plant by 50 percent. Molex estimates thatthe new technology has resulted in an average65 percent reduction in the concentration ofcopper, tin and lead, and nickel in the effluentdischarged by the wastewater treatment plantin 1999 and 2000.

For the past decade, EPA has been building greaterflexibility into regulatory programs through tradingof emission “allowances” and other approaches.As the following examples show, in Project XL wecontinue to find that a little flexibility can go a longway toward getting better results.

• Denton, Texas. Rather than spend its resourcesmonitoring and inspecting wastewater treat-ment facilities that have excellent performancehistories, officials in Denton requested regula-tory flexibility to redirect these resources todevelop a comprehensive watershed protec-tion program. This approach will support site-specific watershed protection activities, suchas developing buffer zones along underdevel-oped areas, that are expected to result in bet-ter water quality.

• New England Universities Laboratories. Inthe Northeast, a consortium of university labo-ratories proposed a new approach for manag-ing hazardous wastes in laboratory settings. Theproject enables laboratories to integrate someEPA hazardous waste requirements with Oc-cupational Safety and Health Administration(OSHA) standards for managing chemicals.This approach will potentially lead to bettermanagement of the chemicals, which shouldhelp prevent pollution and improve worker andstudent safety.

Taking a More Comprehensive Approach toEnvironmental Management. Despite strong en-vironmental progress over the past three decades,gaps in environmental protection remain. Commu-nities and facility operators are considering how tomeet multiple environmental challenges and socio-economic objectives. The examples below showhow in using Project XL, communities and busi-nesses alike are finding that taking a more com-prehensive view often leads to better results.

• Lead Safe Boston. Local communities’ envi-ronmental priorities play an increasingly impor-tant role in decisions about environmental andhuman health protection. In Boston, Massa-chusetts, a federally funded program that re-moves lead from residential homes andapartments asked for approval to use a less

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expensive method for handling and disposingof lead-based paint debris. Massachusetts andEPA regulations currently require extensive leadtesting on architectural debris and disposal incostly hazardous waste landfills. ThroughProject XL, Lead Safe Boston identified a po-tentially more cost-effective option of using ahousehold hazardous waste exception to allowsuch debris to be disposed of in a municipalsolid waste landfill that meets certain perfor-mance criteria. With this project, Lead SafeBoston expects to substantially reduce disposalcosts, remove lead from more homes, and pro-tect up to 30 more children from lead expo-sure.

• Atlantic Steel Redevelopment. In Atlanta,Georgia, a unique public/private partnership hasthe potential to serve as a national model forcreative problem-solving. This redevelopmentproject expects to demonstrate that the appli-cation of “smart growth” concepts can makea difference in addressing transportation andenvironmental issues. Real estate developers,neighborhood groups, the City of Atlanta, Geor-gia Department of Transportation, GeorgiaEnvironmental Protection Division, and othergovernment agencies are working toward re-development of a 138-acre site formerly ownedby Atlantic Steel. This project, proposed byJacoby Development Corporation, includes amultimodal (automobile, pedestrian, bicycle, rail)bridge that would cross and provide accessramps to the adjacent highway as well as con-nect the site to a nearby MARTA (mass tran-sit) station.

• Intel Corporation. With the advent of e-com-merce and an increasingly global economy,businesses need to be more flexible to changeproduct lines and processes than ever before.First to market is no longer measured in monthsbut days. EPA and the Arizona Department ofEnvironmental Quality approved a facility-wideemissions cap for Intel’s semiconductor manu-facturing plant in Chandler, Arizona. The newlimits allow Intel to make equipment and pro-cess changes and to expand production capac-ity, without regulatory reviews, as long as thetotal emissions stay below the specified cap.

Since the project began, the company has re-mained well under its emission limits for allapplicable pollutants. Intel also has avoidedmillions of dollars in production delays by elimi-nating 30 to 50 new source permit reviews ayear. The company has found the emissioncaps so successful that it will invest $2 billionto build a new wafer fabrication facility (Fab22) at the site. So long as it remains under theexisting cap, Intel can proceed with expansionwithout first going through regulatory review.

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�� As a vehicle for testing new ideas in environmen-tal protection, Project XL is unprecedented. Pre-dictably for an experimental program, it hasexperienced some conflict and controversy. But italso has brought important discoveries and insightsabout ways to improve environmental results. Ofthe many lessons EPA has learned from this uniqueprogram, the following are some of the most im-portant:

• It is possible to experiment with new ap-proaches outside the traditional regulatory sys-tem as long as strong, reliable safeguards arein place.

• Some businesses and communities are not onlywilling, but eager, to take greater responsibilityfor environmental results if they are given flex-ibility in meeting the goals.

• If given an opportunity, citizens and other stake-holders can play an active, creative role in find-ing solutions to problems.

• The opportunities to improve become more vis-ible, and the results potentially more significant,when you step back and look at communitiesor facilities as a whole, rather than as a set ofseparate, unrelated components.

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With experiments now underway, we have beguncataloging and evaluating the results. This is animportant step if we are to progress toward ourultimate goal: bringing successful concepts and ap-proaches to broader application. To realize the truepotential of these experiments, we must use whatwe learn to make improvements in our national pro-grams. In some cases, existing policies and regula-tions may have to be adapted to reflect moreup-to-date knowledge and technology. Alreadysome Project XL innovations have been appliedbeyond their original experiment. For example, us-ing information from projects that have includedplant-wide applicability limits (PALs)—Intel,Merck, Weyerhaeuser, Imation, and Andersen––EPA expects to publish a rule in six months thatestablishes PALs as a way for facilities to estab-lish emission caps on their total air emissions. Thisaction will allow facilities to make process or manu-facturing changes without the need for reoccur-ring permit modifications and will give greatercertainty to community members of the emissionsbeing discharged into the local air. In another ex-ample, the Lead Safe Boston project has resultedin a new policy issued by EPA this summer allow-ing residential lead-based paint debris to be dis-posed of in municipal landfills, thus enablingcontractors across the country to perform leadabatement more quickly and cost-effectively.

We believe that the type of experimentation allowedunder Project XL is fundamental to continued ad-vances in environmental protection. Indeed, webelieve that sustaining our strong national legacyof environmental progress depends on innovation—at EPA, in state and tribal environmental programs,in local governments, in businesses, in communi-ties—in all parts of our society. That is why EPAlaunched Project XL, and it is why we will con-tinue supporting and encouraging those that arewilling to search for a better way of achieving en-vironmental goals. �

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�� In the last decade environmental protection has become more com-plex. We face challenges, like global warming and urban sprawl, thatare not addressed through traditional regulatory approaches. To en-sure progress on these and other issues, we need strategies that takeinto account all the factors affecting the quality of our air, land, andwater, that respect natural ecosystems, and that reflect the prioritiesof local stakeholders. We also need to improve regulatory proceduresso businesses and communities can focus on problems, not paper-work.

In 1995, the EPA launched a portfolio of high-priority initiativeswhich challenged us to think of new ways to fulfill America’senvironmental and human health protection goals. Since then, busi-

nesses, communities and other federal agencies have responded tothis challenge by participating in these initiatives, including Project XL(which stands for eXcellence and Leadership).

Project XL solicits ideas from private and public sector facilities, othergovernment agencies, trade associations and communities that pro-pose solutions to difficult regulatory or technical problems and thatexplore new approaches to protecting human health and the environ-ment, usually at a lower cost or lessened regulatory burden for theproject sponsor. EPA and these project sponsors formalize the detailsof these experiments in a document called a Final Project Agreement(FPA) which outlines responsibilities of the project sponsor and de-scribes any regulatory flexibility that EPA or the appropriate state,tribal, and local agency is granting in order to conduct the experiment.

These experiments are leading to improvements in well-establishedprograms and exploration of fundamentally new approaches to pro-tect human health and the environment. By testing sensible, flexiblesolutions to specific obstacles faced by a facility, a sector, a state or alocal community, Project XL champions ideas that yield broader con-cepts for enhancing our environmental protection system.

This type of flexibility is unprecedented, but it is an offer we havebeen able to make because we set high goals for environmental per-formance and insist on public accountability for results. And yet, be-cause we have been breaking new ground, we faced difficult issues inthe early stages. We wrestled with questions such as: What kind offlexibility should be allowed? How do you define “better results” and“superior environmental performance”? What can we do within theexisting laws? Who needs to be involved in the discussions? We learned

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ways to be more responsive to stakeholder needs.As a result, projects are underway throughout thecountry.

The experiments being conducted under ProjectXL are in various stages: 16 projects have beenunderway for a year or more and 37 projects havebeen in implementation for less than one year orstill are under development. Early evaluation re-sults show benefits to the environment, projectsponsors, and the communities. Data from severalprojects give us some indication of the great poten-tial their innovative approaches have for signifi-cantly improving our system for managing ourenvironment. In fact, Project XL’s greatest oppor-tunity, and its greatest challenge, is taking success-ful ideas from individual pilot projects and movingthese ideas to their appropriate system-wide prac-tice and into EPA’s everyday way of doing busi-ness. Through experimentation and evaluation,Project XL can add to an ever diversifying set oftools to protect the environment by identifying newapproaches, learning about the keys to their effec-tive use, and better enabling EPA to match the righttools to the right problems.

This volume, Directory of Regulatory, Policy, andTechnology Innovations, describes early resultsand how lessons learned from these efforts mightbe incorporated in EPA’s everyday work, such asregulation development, permitting, informationmanagement and access, enforcement and com-pliance assurance, environmental stewardship,stakeholder involvement, and Agency culturechange. In order to better understand the detailedinformation contained in this volume, please referto the Innovations in Core Functions by ProjectTable on page 14. For summaries of the progressand results of individual projects, please see thesecond volume, Directory of Project Experimentsand Results.

Project XL is one of many initiatives that EPA na-tional and regional programs are conducting to ad-dress environmental problems that have yet to besolved through the current system. For more infor-mation on these initiatives, please see A Decadeof Progress: Innovation at the EnvironmentalProtection Agency (April 2000) available at

http://www.epa.gov/opeihome/decade/ and the1999 EPA Innovations Task Force report Aimingfor Excellence: Actions to Encourage Steward-ship and Accelerate Environmental Progress(July 1999) available at http://www.epa.gov/rein-vent/taskforce/report99/. �

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�� )�� %"!�� EPA’s innovation initiatives aim to improve an already strong systemof environmental protection while building commonsense, cost-effec-tive ways to “identify important problems and fix them”.1 The UnitedStates has one of the strongest systems of environmental protection inthe world, but it is neither perfect nor complete. Everyday, conditionsare changing: new technology is entering the market, better informa-tion is becoming available, and environmental professionals are gain-ing more understanding and experience in managing theirresponsibilities. These and other developments mean the system mustchange too. By giving sponsors a chance to identify problems andpotential solutions, Project XL is learning how to adapt environmentalprotection to the emerging challenges of the new economy.

Project XL emphasizes more comprehensive, integrated ap-proaches to environmental protection, helping to optimize envi-ronmental, community, and business outcomes by stepping back

and considering all the issues affecting environmental quality. By lookingat facilities, sectors, and communities as a whole, we are finding thata broader view often leads to better results. States are actively ex-perimenting with new tools to improve the performance of industrysectors and promoting pollution prevention. Businesses increasinglyview environmental management as a fundamental part of a smartbusiness strategy. They recognize that they can realize a competitiveadvantage while addressing environmental problems. Project XL pro-vides a forum for communities and businesses to step forward withinnovations that have improved results, cut costs, and opened the doorto fundamentally new ways of doing business—the new tools of en-vironmental protection.

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In a development that could revolutionize computing, in EssexJunction, Vermont, IBM is testing a way to make computer chipswith copper rather than aluminum—an approach that promisescheaper computers and faster calculations. The new process,which is approximately 30 to 40 percent more efficient than theprevious one, enables IBM to deposit a layer of metal on itswafers much more efficiently, maximizing metal use in manu-facturing and minimizing releases into the plant’s wastewatersystem.

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1Sparrow, Malcom, The Regulatory Craft, Washington, DC: Brookings, 20001

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EPA has embraced innovation as a way to facili-tate environmental gains. But clearly, EPA is notalone in pursuing innovative environmental ap-proaches—it has to happen through partnershipswith others. Other government agencies, particu-larly the states, are active players, and local com-munities play an increasingly important role inenvironmental and human health protection. Theyare developing strategies that address their ownpriorities and concerns and that help sustain thebaseline of environmental protection all our citizenshave come to expect. These cleaner, cheaper,smarter ways of protecting the environment havechallenged EPA to diversify the role it plays inenvironmental protection—from that of Federalcommand and control regulator to a co-regulatorwith states, a convener of public discourse, andpartner with business and community in pollutionprevention.

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�� 2��America’s industrial sectors face new problems intoday’s economy. International competition gener-ates continuously changing market demands, whichmeans that companies who can design and developnew products quickly can be more strategic in themarketplace. Under the Clean Air Act, companiesmust obtain permit approvals from EPA or delegatedstate agencies when they install new equipment orchange a manufacturing process. Each process ortype of equipment may have its own permit re-quirements. Yet some industries, such as pharma-ceutical or semiconductor manufacturers, mustchange their processes frequently to meet customerdemands for new products. The paperwork andtime required to obtain permit approvals are costly,both for the companies and the government agen-cies charged with permit review. At the same time,local communities also have an increased aware-ness and concerns with industry impacts on humanhealth and the environment and are demanding agreater degree of access to facility information andgovernment decision making about permit actions.

Some companies have developed projects underProject XL to make the permitting process moreefficient and predictable for their quick-to-marketmanufacturing needs. These projects are based onfacility-wide air emission caps, which prevent thefacility from increasing its emissions, but allow pro-cess or equipment changes without regulatory ap-proval. Under this approach, facilities must offsetany emission increases with a reduction somewhereelse within the facility. EPA generally sets the capbelow the facility’s regulatory threshold for com-pliance, thus ensuring that the project achieves bet-ter environmental results than would otherwise beachieved under current regulatory requirements.This allows the company flexibility (e.g., usingpollution prevention instead of treatment when thatis a better option) in meeting pollution goals. At thesame time, it provides certainty to the public bycreating an enforceable regulatory cap on total airemissions and to the regulated facility by telling themwhat they can emit, what they can change quickly,and what limited number of major changes will re-

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Both self certification and self audit ap-proaches for small businesses (MassachusettsEnvironmental Results Program) offer en-hanced business accountability with enhancedcompliance. Per unit of production emissionlimits (Andersen and Intel projects) providean incentive to increase efficiency while main-taining flexibility; and the predictive emissionsmonitoring system (International Paperproject) offers improved environmental per-formance with reduced capital expenditures.

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Project XL supports new roles for EPA as aco-regulator— supporting new local govern-ment water pretreatment operations in theSteele County project, and helping communi-ties link their economic and environmentalgoals through the Atlantic Steel project.

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The following section highlights some of the prom-ising innovations achieved through Project XL todate. It shows preliminary results and takes on thebroader task of Project XL—describing better ap-proaches that are being adopted into our nationalsystem of environmental protection.

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quire new public review. These permit caps willprovide accountability to the public by improvingtheir ability to gain a overall picture of a facility’sperformance and ensuring that emissions will notexceed permitted levels without giving them a newchance to become involved.

EPA and the Arizona Department of Environmen-tal Quality approved a facility-wide emissions capfor Intel Corporation’s semiconductor manufactur-ing plant in Chandler, Arizona. The new limits al-low Intel to make equipment and process changesand to expand production capacity, without regula-tory reviews, as long as the total emissions staybelow the specified cap. Since the project began,the company has remained well under its emissionlimits for all applicable pollutants. Intel also hasavoided millions of dollars in production delays byeliminating 30 to 50 new source permit reviews a

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Implementing Site Specific Caps for Determining Major New Source Review (PAL Rule): Thisforthcoming rule will establish plant-wide applicability limits (PALs) as a way for plants to establishcapped limits on their total emissions, providing communities with certainty that emissions will notincrease above permitted levels, in exchange for increased flexibility to add and subtract productionunits without having to go through new source review (NSR) and the associated permitting. ProjectXL has served as a test bed for several ideas of an alternative major NSR applicability system thatallows PALs instead of traditional NSR netting for determining whether modifications are subject tomajor NSR. Projects that have included PALs as key innovations include Merck, Intel, Weyerhaeuser,Imation, and Andersen.

Part 70 Revisions (Permit Revision Process Rulemaking): This rule will provide industry withthe flexibility to make quick operational changes while providing the public and EPA with moreefficient and meaningful review of significant actions that could effect air quality. Instead of thecurrent “one size fits all” process, which is paperwork intensive and time consuming for everyoneinvolved, EPA will establish a new five-tiered system, which will provide increased flexibility forsimple changes and increased accountability for important ones. The Part 70 changes will allow foran expedited review process for all facilities and will incorporate the flexibility used by the Intelproject.

White Paper #3 Guidance: This guidance will provide guidance to states, tribes, and local govern-ments on how to design flexible operating permits, within the scope of Title V of Clean Air Act andthe operating permit regulations promulgated at 40 CFR Part 70. The White Paper focuses primarilyon “advance approvals” since this is the most versatile and potentially useful approach. This guid-ance discusses the many considerations and factors relevant to designing a permit that allow foradvance approvals of modifications or new emissions units so changes may be made without apermit revision. It also encourages pollution prevention, promotes active public participation, and theachievement of equal or better environmental protection. Projects supporting the development offlexible permitting approaches in White Paper #3 include Merck, Intel, and Imation.

year. The company has found the emission caps sosuccessful that it will invest $2 billion to build anew wafer fabrication facility (Fab 22) at the site.Under the existing cap, Intel can proceed with ex-pansion without first going through regulatory re-view. In announcing this decision, Intel noted that“the new facility will help us maintain our leader-ship in the extremely competitive world of semi-conductors. Fab 22 will give us more manufacturingcapacity in order to help us better address our cus-tomers’ growing need for high-performance mi-croprocessors.”

A significant part of Project XL’s influence on sys-tem change comes from the combined impact ofseveral projects tackling a problem area. New regu-lations and policy guidance for air permitting thathave been heavily influenced by Project XL inno-vations are described in the following box.

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�� !� ��Project XL is providing new ways for manufactur-ers to address existing compliance problems. Atthe facility level, manufacturers can find potentialopportunities for improving environmental perfor-mance, yet these options may require that greaterflexibility be added to federal regulations’ technol-ogy requirements. In a move similar to that of theIntel project, EPA and the Virginia Department ofEnvironmental Quality created a facility-wide emis-sions cap for Merck’s Stonewall pharmaceuticalmanufacturing plant in Elkton, Virginia. Developedunder a Clean Air Act permit that prevents signifi-cant deterioration of air quality, Merck’s cap alsoeliminates regulatory review for equipment or pro-cess changes as long as the facility’s emissions staybelow the specified cap. With this approach, Merckis reducing the plant’s total emissions of criteria airpollutants by 20 percent, sulfur dioxide emissionsby 25 percent, and nitrogen oxides emissions by 10percent, thus ensuring better environmental results.In addition, Merck will have flexibility under futureregulations to lower its cap instead of implement-ing specific control technologies that might be re-quired for other facilities. When a new criteriapollutant regulation is promulgated and becomesapplicable to the site, or when an existing regula-tion becomes newly applicable to the equipment atthe site, Merck has two options. (1) It can complywith the regulation(s) as written and install newcontrol equipment. (2) Alternatively, it can adjustthe facility’s site-wide emissions cap(s) by theamount of emission reductions that would have re-sulted from direct compliance with the rule (e.g.,reducing the cap by the amount of emissions re-ductions the new control equipment would haveachieved, if it was installed at the site).

Project XL has also allowed manufacturers to useinnovative approaches and a wider variety of tech-nologies to control hazardous air pollutants (HAPs).The affect this has had on creating new regulatoryoptions under HAP-related regulations is describedbelow.

1. The 3M Hutchinson XL proposal did not reachfinal agreement, however, one of the flexibilities3M requested in their proposal was incorpo-rated in the mid-1999 direct final rule for HAPemissions from magnetic tape manufacturingoperations. Based on the 3M proposal andother industry input, EPA determined that itwould be useful to offer regulated entities analternative compliance option for balancingHAP emissions from solvent storage tanks withemissions from other pieces of magnetic tapemanufacturing equipment.

2. In 2001, EPA plans to promulgate NationalEmission Standards for HAPs (NESHAPs) for“miscellaneous organic processes.” Thesestandards are referred to as the miscellaneousorganic NESHAPs or “the MON.” Produc-tion activities at Crompton Sistersville, WestVirginia, facility are classified as one type ofthese miscellaneous organic processes. It isexpected that the MON will require a level ofprocess vent controls similar to the level re-quired for the vent incinerator installed byCrompton as part of its project. Thus, this projectis providing some preliminary data for theMON on the effectiveness of this type of airpollution control technology in satisfying HAPcompliance requirements.

3. Innovations being tested as part of theWeyerhaeuser project helped shape severalcompliance options in the Integrated Pulp andPaper NESHAP and Effluent LimitationsGuidelines Rule promulgated in 1998. Threespecific regulatory flexibilities undergoing test-ing include using: alternative compliance re-gimes for HAP emission reductions, advancedtechnologies to reduce effluent discharges, andpollution prevention technologies to reduce airemissions in kraft-pulping operations.

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�� 7��Local communities and businesses are concernedwith the impact that the handling and disposal ofwastes can have on both quality of life for theircitizens and the community’s economy. Designingmethods that increase safety and reduce costlyhazardous waste generation are critical to theseconcerns. As described below, changes to Re-source Conservation and Recovery Act (RCRA)policies are underway or under consideration as aresult of information learned from Project XL.

• EPA is releasing a national RCRA policy de-termination that will allow the use of an alter-native disposal technique for lead-based paintarchitectural debris from residential sources.Under Project XL, Lead Safe Boston (a Bos-ton, Massachusetts, city government entity) istesting the use of a RCRA Household Haz-ardous Waste Provision exclusion that wouldallow the disposal of residential-generated,lead-based paint debris in RCRA-certifiedmunicipal waste landfills. Lead Safe Bostonbelieves that lead-based paint debris can besafely managed in municipal solid waste land-fills that meet RCRA requirements for landfillliners, leachate collection systems, groundwa-ter monitoring, and corrective action provisions.It is expected that this decision will enhancethe cleanup of more lead-contaminated siteswithin urban areas because of the lower costsassociated with handling and disposal of non-hazardous designated wastes. In addition, it isexpected to facilitate additional residentialabatement, renovation and remodeling, and re-habilitation activities, thus protecting childrenfrom continued exposure to lead paint in homesand making residential dwellings lead safe forchildren and adults. Specifically, Lead SafeBoston expects to substantially reduce disposal

costs, remove lead from more homes, and pro-tect up to 30 more children from lead expo-sure. EPA has used data generated during thedevelopment of the Lead Safe Boston projectand other sources to support its recent policydetermination.

• Every day many products containing economi-cally valuable metals are being disposed of ashazardous waste because few alternatives forresource recovery exist. The USFilter projectproposes to eliminate or substantially reducethe need for electroplators (i.e., metal finish-ers, printed wiring board manufacturers) to treatand/or dispose of their F006 hazardous wastestreams. USFilter proposes to offer “portableexchange deionization systems” (ion exchangecanister) to electroplators in lieu of on-sitephysical-chemical treatment and off-site dis-posal requirements. Once their resins becomespent, these canisters can be recharged byUSFilter who regenerates the resins. The re-claimed metals then can be sold rather thanland disposed. EPA is considering altering itsRCRA manifest and waste treatment require-ments for electroplators who elect to use ionexchange canisters for some or all of their F006waste handling requirements.

• RCRA hazardous waste manifest and wasteaccumulation requirements often entail hightransportation and collection costs associatedwith low volume waste disposal. The New YorkState Department of Environmental Conser-vation (NYSDEC) project is testing a solutionto this problem by allowing utilities (primarilyelectric and gas companies) located in the stateto consolidate their hazardous waste generatedat remote locations at central collection facili-ties (utility owned) before the waste is sent toa commercial RCRA permitted treatment, stor-age, and disposal facility (TSDF). Currently,utility hazardous waste generators must havetheir wastes collected individually at remotesites and transported directly to a TSDF. Inmany instances, this results in a large numberof vehicle trips to transport small waste loads.As a result of the data generated from thisproject, EPA is considering the modification ofits RCRA waste accumulation and manifest

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tion of the New York-based system.2

• Municipal solid waste landfill capacity is dwin-dling in United States and there is a great dealof interest in how to design and manage land-fills to extend their useful life. There are fourproject proposals currently being reviewed thatexplore various options for using leachate re-circulation systems (bioreactors) to extend thelife of existing sanitary landfills by speeding upthe decomposition process of organic materi-als, thereby creating more space in the landfilland extending its life. Each project—BuncombeCounty, Virginia Landfills, Yolo County, andAnne Arundel County—will be exploring dif-ferent aspects of a bioreactor system. Collec-tively, the various engineering and technicalparameters being investigated among theseprojects will provide EPA with background datato determine if it is appropriate to modify exist-ing RCRA municipal landfill design require-ments.

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�� !� ��In February 1999, the Administration unveiled acomprehensive Clean Water Action Plan, highlight-ing the public’s concern for protecting the nations’waters. In a July 1999 proposed rule affecting theNational Pretreatment Regulations, EPA sought tostreamline the procedures for measuring pollutantloadings for industrial waste water dischargers.Under the proposed rules, publicly owned treat-ment works (POTWs) have the option of usingmass-based limits in lieu of concentration limits forindustrial users if these users meet certain criteria.

The rule proposes that potential users (dischargersto the POTW) must install the best available tech-nology (BAT) or have equivalent BAT installed, andthey must use some form of water conservationmethods that substantially reduce their water us-age.

The Steele County project is referenced in the pro-posed Pretreatment rule as one example of a mass-based compliance experiment. Under Project XL,the POTW of Steele County, Minnesota, will allowparticipating industrial users to use mass-based limitsin lieu of concentration limits for discharges to thewastewater treatment facility. These industrial us-ers are primarily metal finishing facilities inOwatonna, Minnesota. Using a mass-based limitwill allow industrial dischargers to minimize theirwater usage while maintaining compliance withtheir POTW requirements. Using a concentrationlimit would not allow this to occur. Steele Countyalso is testing other alternative compliance ap-proaches such as reduced monitoring for regulatedpollutants not present and alternative significant non-compliance reporting. Collectively these approachestoward complying with pretreatment regulations canhelp establish a benchmark against which EPA andother regulators will determine whether these as-pects of the regulations should be permanentlymodified. �

2On October 7, 1999, the Atlantic States Legal Foundationand other parties filed a Petition for Review of EPA’s finalProject XL Rule for New York State Public Utilities in theU.S. Court of Appeals for the District of Columbia Circuit.EPA is currently exploring the option of settlement withthese petitioners.

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Asignificant portion of EPA’s work concerns developing regu-lations that define for businesses, municipalities, other regu-lated entities, and the public the actions, technologies, and

standards required to meet federal environmental laws passed by Con-gress. Under Project XL, EPA seeks to explore new and flexible ap-proaches to implementing existing and future environmental regulations.Projects have provided Agency regulation writers with experientialdata and results that influence the options available in new regulations.Project XL has been particularly successful at exploring specific regu-latory and policy options under the Clean Air Act (CAA), the Re-source Conservation and Recovery Act (RCRA), and the Clean WaterAct (CWA).

�� A permit is an authorization, license, or equivalent control documentissued by EPA or a state or tribal agency to implement the require-ments of environmental standards for a specific facility or group ofsimilar facilities. Federal permitting requirements are very importantenvironmental protection tools, but they can pose a burden for regu-lated entities and regulators alike. The alternative permitting approachestested in Project XL fit into a national reform effort to shift permittingtoward measuring performance while providing more flexibility in howstandards are met, strengthen the role of the public in important deci-sions, focus on results instead of procedures, reduce unnecessary bur-dens, and improve environmental performance.

The more than 70 innovations tested under Project XL are sorted byEPA’s core functions—the processes and operations that EPA typi-cally performs to carry out its mission to protect human health andsafeguard the natural environment—(1) regulations, (2) permitting, (3)information management and access, (4) enforcement and compli-ance assurance, (5) environmental stewardship, (6) stakeholder in-volvement, and (7) Agency culture change. These core functions aredefined briefly below.

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(��EPA has national information policy and manage-ment responsibilities which stem from the nation’senvironmental laws and include collecting, main-taining, and ensuring the quality of data used forboth internal decision-making and public purposes.EPA’s regulations and permits have data collectionand reporting requirements that can be burdensomefor facilities to prepare and for regulators to col-lect, when publicly presenting environmental infor-mation and results. In many cases, state and tribalgovernments are the primary collectors and man-agers for this information. The required data areoften in a specified format that is difficult for thegeneral public to access and understand. ProjectXL explores different approaches that seek to im-prove government systems for managing environ-mental information. These approaches includegaining more stakeholder input on data presenta-tion, building performance-based incentives intoreporting requirements, and eliminating duplicativeor unnecessary information requirements.

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(��EPA, tribal governments, and authorized states areresponsible for ensuring that the regulated com-munity complies with the laws and regulations thatprotect human health and safeguard the natural en-vironment. To do so, an array of approaches areemployed, including EPA’s traditional regulatory en-forcement program and compliance assistance sup-port and incentives. In recent years, national effortshave centered around identifying and addressingenvironmental problems using innovative, integratedinitiatives that combine compliance assistance, in-centives, monitoring, and enforcement. These com-pliance incentives include self-certification,compliance measurement and management pro-

grams, tiered compliance testing requirements, andoptions to use new technologies that will ensurecompliance by preventing pollution. Complianceincentives encourage improved environmental per-formance and have been explored by states, tribes,local governments, and EPA. Project XL providesanother platform for testing these new activities aswell as innovative approaches for measuring com-pliance on a facility and sector level.

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&��'�� !Environmental stewardship is a way of identifyingand pursing good business strategies that are con-sistent with environmental protection. Environmen-tal management systems (EMS), pollutionprevention, and recycling are pathways to environ-mental stewardship that help organizations improvetheir environmental performance and potentially gobeyond regulatory compliance. An EMS allows anorganization to systematically integrate environmen-tal concerns into business and operations decisions,address environmental decisions and focus on im-provements in compliance rates, while boostingefficiency, compliance rates, and improving workersafety. Pollution prevention, or “source reduction”as defined by the 1990 Pollution Prevention Actand EPA guidance, involves protecting natural re-sources through conservation or increased effi-ciency in the use of energy, water, and materials.Recycling shares many of the advantages of pollu-tion prevention: they both reduce the need for treat-ment or disposal by conserving energy and naturalresources. Project XL is a platform for testing dif-ferent EMS approaches, and many projects haveincorporated pollution prevention and recycling ac-tivities into their agreements.

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�� The American people have demanded active in-volvement in decisions that affect their health andthe quality of their environment. In response, EPAhas worked to increase stakeholder involvement

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by providing them opportunities to participate in thedevelopment and implementation of projects thatmay affect them. A stakeholder may be a civicorganization, particular interest group, governmen-tal entity, or individual. Past, present, and potentialparticipants in Project XL have identified the stake-holder involvement process as an area in which allgroups (e.g., project sponsors, government staff,and public participants) will benefit from additionalexperience and better guidance. These projects areproducing important insights into the site-specific,multi-stakeholder involvement process and its rolein Agency experimentation and innovation.

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��The emphasis on innovation has changed the wayEPA thinks and operates, leading to real environ-mental improvements and cost reductions. Thechallenge ahead is to make these innovative ideasa permanent part of EPA’s culture and reinforcethose Agency processes and behaviors that willaddress constantly changing conditions—environ-mental, technical, socioeconomic, and political—through new, creative solutions. Project XL hasserved as a laboratory for creating a work envi-ronment that supports cross-Agency multimediainnovation. While designing and testing potentialinnovations, the Agency has also undertaken man-agement, team-building, and experimentationchallenges. �

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This section catalogues 50 ongoing innovative ideas being testedunder Project XL. These innovations are generally from themore mature projects underway. The catalogue uses the fol-

lowing structure to describe these innovations:

• Experiment(s): What is the innovative idea being tested? Whichprojects are testing the innovation? What regulatory flexibility isrequired to test the idea?

• Results/Anticipated Outcome(s): What is the potential advan-tage of the innovation over the current system of environmentalprotection? Included are data that document results and data forthose projects that are “more mature.” For those projects still earlyin implementation, this section provides the operating context forthe innovation and anticipated results of the experimental approach.

• Transferability: What is the efficacy of the innovation? Is it suit-able for application beyond the pilot scale? For the more matureinnovations, the transferability section describes those innovativeconcepts that have been, or are in the process of being, incorpo-rated into Agency functions or programs. For the relatively newinnovations, this section describes potential opportunities for inte-grating the experimental ideas into the national environmental pro-tection system.

The table below is a summary of the types of ongoing innovationssorted by EPA’s core functions. This table is designed to give the readera “roadmap” for this section. It is not intended to be used as a check-list for future projects.

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Regulations Permitting Information Enforcement Environmental Stakeholder CultureManagement Compliance Stewardship Involvement Change

Andersen X

Atlantic Steel X

Berry X X X

AlbuquerquePOTW X

Denton POTW X

Crompton(formerly Witco) X X

Elmendorf AFB X

NS Mayport X

Vandenberg AFB X

ExxonMobil X X

Georgia Pacific X

HADCO X X

IBM Vermont X

Imation X

Intel X X X X

InternationalPaper-EI X

InternationalPaper-PEM X X

Louisville POTW X

Lucent X

MassachusettsDEP X

Merck X X X X

Molex X

New EnglandUniversitiesLaboratories X X

New York StateDEC X X

Progressive X

Steele County X X

USPS Denver X

Weyerhaeuser X X X X X X

Programwide X X

3M (Proposal) X

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�� Project XL has helped to identify and test new,flexible options under federal regulations. To date,project proposals have focused on hazardous airpollution and conformity issues under CAA regu-lations, process streamlining for RCRA hazardouswaste compliance, promoting metals recoverywithin RCRA hazardous waste requirements, im-proving the effectiveness of CWA pretreatmentoperations, and streamlining cleanups underCERCLA (known as Superfund). Project XL willcontinue collecting data about new regulatory pro-posals and will influence how well-established rulesare interpreted and implemented. New projects areproposing to explore regulatory changes that canenhance our solutions for increasing the capacityof sanitary landfills, reducing urban air toxic emis-sions, and decreasing persistent, bioaccumulative,and toxic pollutants.

Because of the large number of regulatory innova-tions underway, these innovations have been orga-nized according to media—air, hazardous waste,water, and site cleanup. Under each sub-section,Tables 2 through 5 identify the regulatory innova-tions being tested in current projects and illustratethe adaptability that is possible in complying withexisting regulatory requirements.

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Project(s) Affected InnovationMedia

Weyerhaeuser Water Pulp and Paper Cluster Rule: Voluntary effluent discharge limitations—allows additional time for MACT standards compliance; testingalternative compliance approaches for HAPs; using pollution preventiontechnologies to reduce HAP emissions across the facility providesadditional time to comply with MACT standards.

3M Proposal Water NESHAP for Magnetic Tape Manufacturing Operations MACT: Modificationto NESHAP based on data submitted in proposal regarding balancingHAP emissions between controlled and uncontrolled sources.

Crompton N/A RCRA Organic Emission Standards/ Miscellaneous Organic Processes(formerly Witco) MACT: Early compliance with NESHAP and air emission control

flexibility; use of alternative control technology, reducing organic airemissions and potential compliance with a new MACT standard.

Atlantic Steel Site Cleanup CAA Transportation Control Measure (TCM): Flexibility and smart growthapplications of a TCM for a brownfield redevelopment project movingforward in area previously out of conformity with CAA.

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A large proportion of EPA’s rulemaking activitieshave involved the ongoing development of NationalEmission Standards for Hazardous Air Pollutants(NESHAPs). These standards are required by Sec-tion 112(d) of the CAA, which dictates that EPAregulate the emissions of 189 hazardous air pollut-ants (HAPs). The intent of Section 112 is to pro-tect public health by requiring new and existing“major sources” of these HAPs to reduce theirgeneration through pollution prevention or to con-trol their emissions to the level possible through theuse of Maximum Achievable Control Technology(MACT). This technology-based requirement musttake into account cost, non-air quality impacts, andenergy requirements. NESHAPs are generallystructured in terms of numerical emissions limits,although under certain conditions they can specifya design, equipment, work practice, or operationalstandard.

According to the CAA, no transportation activitycan be funded or supported by the Federal govern-ment unless it conforms to the purpose of a state’sair quality plan. Though conformity was includedin the 1977 CAA, it was not clearly defined untilthe 1990 CAA amendments. Conformity links trans-portation planning with air quality planning, and func-

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tions by means of reinforcing a state’s air qualityplan and keeping areas on track in meeting their airquality goals. It requires areas that have poor airquality now or had it in the past to examine thelong-term air quality impacts of their transportationsystem and ensure that it is compatible with cleanair goals. These areas must assess the impacts ofgrowth up front and decide how to manage it.

Pulp and Paper Cluster Rule

The Experiment(s): The Weyerhaeuser projecthas been in implementation since early 1997. Whilethe project will be using a site-specific rulemakingto authorize MACT compliance, it has helped toverify compliance options in the MACT standardprovisions of the Pulp and Paper Cluster Rule. Flex-ibility for Weyerhaeuser under Project XL paral-leled two major aspects of the Cluster Rule: bleachplant and kraft pulping operations.

The Pulp and Paper Cluster Rule was promulgatedin April 1998. The Water Effluent Limitations Guide-lines and Standards portion of the rule requires morestringent reductions for toxic pollutants in the waste-water discharges during the bleaching process andin the final discharge from the mill. The EffluentGuidelines Voluntary Advanced Technology Incen-tives Program, a compliance option incorporatedinto the Cluster Rule, encourages bleach plant op-erators to install advanced technologies or makeprocess changes that will reduce effluent dis-charges beyond the rule’s limits. If a pulp and pa-per mill enrolls in this program and can meet thestrict discharge limits through advanced technolo-gies, the facility receives reduced monitoring andinspection opportunities and additional time to com-ply with the air (e.g., NESHAP) portion of the rule.Although not required by the Cluster Rule,Weyerhaeuser has conducted a feasibility study ofplant-wide effluent reductions through innovativetechnologies. While Weyerhaeuser’s Flint Riverfacility is not participating in this program, it ex-pects to exceed the effluent requirements for thisCluster Rule option. In addition, the facility hashelped to confirm the usefulness of this incentiveprogram and its potential to achieve stronger envi-ronmental performance.

Voluntarily reducing hazardous air emissions fromprocess water streams is another compliance op-tion for kraft-pulping operations that was incorpo-rated under the Pulp and Paper Cluster Rule. TheClean Condensate Alternative Program focuses onreducing the HAP emissions throughout the pulpmill by reducing the HAP mass in process waterstreams. By lowering the HAP mass loading inwastewater streams, fewer HAPs will be volatil-ized to the atmosphere. Many of the pollutantsemitted from production vents originate in mill con-densates that circulate throughout the mill. If a millcan reduce these condensates instead of control-ling individual specified vents, they will achievegreater air emission reductions and reduce theircompliance costs. Although not participating in thisalternative program, Weyerhaeuser’s willingnessto redesign its mill to reduce vent condensatestreams throughout the facility was instrumental informalizing this opportunity within the Cluster Rulerequirements.

The Pulp and Paper Cluster Rule also provides in-centives for using pollution prevention technologiesin kraft pulping operations. The MACT standardsprovide for an extension of up to eight years frompromulgation for compliance if pollution preventionapproaches that otherwise would not have beenused are used. Pulp and paper facilities will havethe flexibility to demonstrate HAP emission reduc-tions using innovative pollution prevention ap-proaches in lieu of, or in addition to, end-of-pipeHAP controls. This extension is designed to en-courage mills to install pollution prevention tech-nology that will reduce HAP emissions from thepulping process as well as both air and water pol-lutant discharges from the bleaching process. Asidefrom the incentives offered to all pulp and papermanufactures in the Cluster Rule, theWeyerhaeuser project is demonstrating pollutionprevention approaches to reducing HAP emissions.These approaches include reducing process con-densate wash water HAP content, reducing bleachplant HAP emissions, reducing oxygendelignification HAP emissions, and reducing cylin-der mould decker and filtrate tank HAP emissions.

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Results/Anticipated Outcomes: The Cluster Rulewill have significant national environmental impactsas mills covered by the rules move to comply withits requirements. Compliance with the rule is ex-pected to result in elimination emissions of morethan 160,000 tons of toxic air pollutants (59 per-cent of current levels), reduced chloroform dis-charges to water by 99 percent from proposedlevels, reduced dioxin and furan discharges to wa-ter by 96 percent from proposed levels, and re-duced dioxin and furan loading to sludges by 96percent from proposed levels.

For this project, Weyerhaeuser has agreed to in-vestigate methods to reduce bleach plant flow to-ward a long-term goal of a 50 percent flowreduction to 10 cubic meters per air-dried metricton of finished product (fluff pulp used to makediapers). Weyerhaeuser conducted a feasibilitystudy to determine the effect of bleach plant efflu-ent reduction on product quality. Weyerhaeuserstated in its 1999 Project XL Annual Progress Re-port, “Based on the completed feasibility study, thecurrent path forward is not technologically and eco-nomically feasible. …Weyerhaeuser remains com-mitted to this MIM project and will seek alternateways to move toward the goal.” Projected envi-ronmental benefits include (1) a 2-million-gallon-a-day monthly average water use reduction (thebleach plant water requirements are approximately50 percent of the total plant water usage); (2) re-ductions in effluent biological oxygen demand, to-tal suspended solids, and adsorbable organic halides;and (3) HAP emission reductions. If the effluentreduction goal is determined to be feasible [deter-mined as part of the process to renew the facility’sNational Pollutant Discharge Elimination System(NPDES) permit in 2002], a schedule will be pre-pared to achieve flow reductions by the year 2006.

Weyerhaeuser has prepared a site-specific MACTcompliance plan. This plan documents HAP emis-sion reductions that have been realized at the FlintRiver Facility. A review of the data has shown thatthe facility is collecting and destroying more HAPsthan is required under the Cluster Rule. A draftsite-specific MACT rule has been prepared, and itis anticipated that this rule will be proposed soon.

Transferability: The Pulp and Paper Cluster Rulehas been promulgated and now regulates toxic airpollutants in 155 of the 565 pulp, paper, and paper-board mills in the United States. Ninety-six of those155 mills also have their toxic water dischargesregulated by the rule. Individual mills may choosethe control technologies and process change com-binations that are the most advantageous for themto meet these regulations. As noted earlier, dataand information from the development of theWeyerhaeuser project helped to inform many ofthe compliance options associated with the rule.

NESHAP for Magnetic Tape ManufacturingOperations MACT

The Proposal: The 3M Hutchinson XL proposaldid not reach final agreement. However, one ofthe flexibilities 3M had requested is being used inthe revised Magnetic Tape Manufacturing opera-tions MACT standard. This standard, a recentamendment to a 1994 industry-specific HAP rule,illustrates EPA’s willingness to amend regulatoryrequirements when the regulated community canprovide persuasive data suggesting new alterna-tives. Since the 1994 rule was issued, 3M providedEPA with data showing that the volume of HAPemissions from uncontrolled solvent storage tanksis very close to that of HAP emissions from un-controlled vessels of mix-preparation process equip-ment. By balancing emissions from theseuncontrolled sources against those sources in theprocess line that are controlled, 3M was able tosuggest alternative control options. EPA accepted3M and other industrial data and proceeded toamend the 1994 rule providing facility owners andoperators with 25 options for “undercontrolling”tanks and/or mix-equipment vessels based on thelevel of control they achieve on their coating lines.3M developed these data in conjunction with a regu-latory flexibility proposal the company submitted toProject XL.

Results/Anticipated Outcomes: The revised Mag-netic Tape rule was effective in June 1999 and isexpected to increase compliance with this regula-tion, enhance flexibility for affected entities and savecompanies money in compliance costs. EPA pub-

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lished this MACT rule amendment as a direct finalrule because it considers this a noncontroversialchange. EPA believes that this change to the pre-viously promulgated 1994 rule will increase com-pliance flexibility for affected sources without anyadverse environmental consequences.

Transferability: The MACT rule amendment isa permanent change to an earlier promulgated rule.It is expected that this amendment will increasecompliance with this regulation, enhance flexibilityfor affected entities, and reduce companies’ com-pliance costs.

RCRA Organic Emission Standards/Miscellaneous Organic Processes MACT

The Experiment(s): The Crompton (formerlyWitco) project aims to reduce air emissions througha combination of flexible air pollution control andwaste minimization/pollution prevention (WM/PP)activities. The polyether methyl capper unit atCrompton’s Sisterville, West Virginia, plant is thefocus of air emission control efforts. The capperunit is the site of a two-step reaction that results inone of Crompton’s products, methyl-cappedpolyether. Methyl chloride, dimethyl ether, andmethanol emissions generated in the capper unitduring production of the methyl-capped polyetherwill be collected and routed to a new process ventincinerator installed on the capper unit.

EPA and West Virginia Department of Environ-mental Protection (WVDEP) deferred the RCRASubpart CC organic air emission standards appli-cable to Crompton’s two surface impoundments.These surface impoundments are 1-million-gallonreservoirs that hold wastewater from the facility’spollution control equipment and other sources.Without the deferral, the Subpart CC standardswould have required Crompton to install air emis-sion controls on these impoundments. However,Crompton could have replaced the existing reser-voirs with open-top reservoirs that are not regu-lated under RCRA Subpart CC, and air emissionswould not have been reduced. With the deferral,Crompton will now install a vent incinerator on thecapper unit.

Based on an XL-generated site-specific rule,Crompton installed the vent incinerator in lieu ofcomplying with RCRA organic air emission stan-dards. In 2001, EPA plans to promulgate NESHAPsfor “miscellaneous organic processes,” called “theMON.” Production activities at Crompton’sSistersville facility are classified as one type of thesemiscellaneous organic processes. Based on cur-rent understanding, it is expected that the MONwill require a level of process vent controls similarto the level required for the vent incinerator installedby Crompton under the project. While theSistersville project will provide superior environ-mental performance only until the MON is in ef-fect, the Crompton project has provided a test bedfor experimenting with air emissions control tech-nology under RCRA. The project’s FPA requiresa reevaluation of the project following proposal ofthe MON. Crompton will prepare a project reevalu-ation report within 90 days following the close ofthe comment period for the MON. If EPA,WVDEP, and other stakeholders agree to continuethe project, the FPA will be amended to identifynew approaches to achieve superior environmen-tal performance beyond the MON requirements.

Results/Anticipated Outcomes: Installing a pro-cess vent incinerator on Crompton’s capper unit inreturn for a deferral of air emission standards forits surface impoundments will lead to air emissionreductions several years earlier than would havebeen obtained without undertaking the project. Asrequired by a site-specific rule, the vent incineratorhas destroyed at least 98 percent of the organiccompounds (about 271,000 pounds) in the ventstream. In 1998, the capper unit emitted a total of59,898 pounds of organic compounds. Since thevent incinerator was installed and put into opera-tion, air emissions of total organics have been re-duced by over 217,000 pounds per year as comparedwith 1995 baseline levels. Performance tests indi-cated that the oxidizer is reducing total organics inthe vent stream by 99.99 percent, versus the 98percent minimum required by the facility’s site-spe-cific rule. In addition, undertaking this project willallow Crompton to defer the expenditure of ap-proximately $2 million in environmental control costsfor several years.

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Transferability: The Crompton project demon-strates the potential benefits for allowing air emis-sion control technology flexibility under RCRAregulations in order to provide superior and morecost-effective environmental protection. Flexibilityin the control of air pollutants by Crompton’sSistersville plant demonstrates the adaptability thatis possible in complying with air regulatory require-ments. Similar adaptations may be applicable toother plants that are facing similar compliance prob-lems and should be investigated relative to existingand future air emissions issues.

CAA Transportation Control Measure (TCM)

The Experiment(s): The Atlantic Steel projectwill redevelop a 138-acre brownfield site in down-town Atlanta. The redevelopment will integrate resi-dential, office, retail, transportation, andentertainment functions near Atlanta’s central busi-ness district and incorporate many “smart growth”design principles in the project. In addition to re-turning a contaminated site to productive use, thisproject will examine how redevelopment can le-verage environmental benefits in air quality by re-ducing automobile use in the Atlanta region. UnderProject XL, this brownfield development will beconsidered a TCM. A TCM is defined as a mea-sure—an activity undertaken, a transportationproject built, or a program implemented—used toreduce motor vehicle emissions. Classification asa TCM will enable this project to proceed withFederal approval and use Federal funds during thetransportation conformity lapse in the Atlanta met-ropolitan region.

Although the State of Georgia is seeking to redes-ignate for attainment, at the time the Atlantic Steelfinal project agreement was being developed, theCity of Atlanta was out of compliance with Fed-eral CAA standards for ground-level ozone emis-sions. Between January 1998 and July 2000, theAtlanta Regional Commission had failed to dem-onstrate that new transportation activities will notfurther degrade or delay timely attainment of airquality standards for the region. The CAA gener-ally prohibits new transportation constructionprojects that use Federal funds or require Federalapproval in areas where conformity with CAA re-

quirements has lapsed. Under the CAA, a projectmust demonstrate an air quality benefit to be con-sidered a TCM. In a traditional sense, the AtlanticSteel project would not qualify as a TCM, but EPAviews the combination of transit linkages (17thStreet Bridge), site location, site design, and otherelements collectively as a TCM.

In order to evaluate the potential environmentalimpacts of the Atlantic Steel development project,EPA, in consultation with project stakeholders, per-formed three main analyses: (1) regional transpor-tation and air emissions impacts, (2) local COimpacts, and (3) site level travel and multimediaimpacts.

Results/Anticipated Outcomes: EPA completedan environmental assessment for the Atlantic Steelproject in compliance with the National Environ-mental Quality Policy Act. While the project is stillundergoing State Implementation Plan (SIP) ap-proval, it is proceeding based on the premise thatthe unique “livability” attributes and interconnecteddesign of this specific project will result in long-term air quality benefits for the region. EPA evalu-ated the air quality benefits of this project based onthe fact that (1) the Atlanta metropolitan region isprojected to continue to grow over the next 20 yearsand (2) if the Atlantic Steel site were not redevel-oped, more of this growth would occur in outlyingareas. By comparing this development of abrownfield to similar development of greenfield sites,the Atlantic Steel project and its associated trans-portation measures were linked to analyze the over-all air quality effects of the development. An analysisof regional transportation and air emissions impactsof the Atlantic Steel development showed that byabsorbing a larger portion of Atlanta’s growth, theAtlantic Steel project would create as many as 34percent fewer vehicle miles traveled (VMTs) andreduce associated NOx

emissions by 45 percentwhen compared to growth occurring at alternativegreenfield sites.

The impact that site design can have on transpor-tation patterns and air emissions was analyzed aswell. EPA examined measures such as density, mixof use, connectivity, and transit access to see howsite design implementation might affect travel be-havior and, ultimately, air emissions.

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Transferability: Urban growth has resulted in in-creased traffic congestion, continued encroach-ment on green spaces, and resultant air qualityconformity problems. The Atlantic Steel project—an integrated, mixed-use, multimodal project, lo-cated near the central business district—can serveas a model for future smart growth planning andredevelopment. As more cities struggle with urbandevelopment, transportation, and air quality prob-lems comparable to those in Atlanta, many aspectsof this project will have the potential to be trans-ferred to these locations. EPA is in the process ofdrafting policy guidance identifying methodologiesto help account for the air quality benefits ofbrownfield developments in the air quality and trans-portation planning process. As the Atlantic Steelproject proceeds, there will be a need to analyze ifthe regulatory flexibility that will enable the project’ssite design to positively impact transportation andair quality can provide opportunities to maximizeenvironmental performance at comparable rede-velopment sites.

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Project(s) Innovation

New York State DEC RCRA Streamlining—Waste Handling Waiver: Revisions to streamlineremote waste handling and transportation. Satellite waste consolidation.

New England RCRA Performance-based Environmental Management Standard: LaboratoryUniversities Laboratories environmental management standard to streamline RCRA and

OSHA regulatory programs.

Molex, HADCO RCRA Streamlining—Delistings and Variances: Conditional delistings andsolid waste variances to encourage metals recovery and recycling;optimizing the recovery of metals by operating a segregated treatmentsystem; testing F006 waste stream and copper dust recycling.

IBM Vermont Process Exemption—Innovative Copper Metallization: IBM-VT has introduceda new, innovative copper plating process to deposit a layer of metal on thewafer and is seeking a site specific process exemption from the F006 listingfor its copper plating process rinsewater.

3These wastes are listed according to waste categories, such aF, K, P, and U. Wastes from non-specific sources are F codes,wastes from specific sources are K codes, and wastes fromcommercial products are U and P codes. Wastes from non-specific sources include material-specific wastes generatedby a variety of processes. This category of wastes includesolvent wastes, electroplating wastes, metal heat treatingwastes, and dioxin-containing wastes.

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RCRA regulations classify hazardous waste as ei-ther characteristic or listed. Characteristic wasteshave measurable properties that indicate that awaste poses enough of a threat to require regula-tion. EPA established four hazardous waste char-acteristics: ignitability, reactivity, corrosivity, andtoxicity. Listed wastes come from generic indus-trial processes, certain sectors of industry, and un-used pure chemical products and formulations.3

F006 wastes—wastewater treatment sludges fromelectroplating operations—have been the subjectof several projects.

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RCRA Streamlining—Waste Handling Waiver

The Experiment(s): The New York State Depart-ment of Environmental Conservation (DEC) projectallows participating electric, telephone, oil, and gasutilities located in the state to consolidate the haz-ardous waste generated at remote locations at util-ity-owned central collection facilities (UCCFs)before the waste is sent to a permitted treatment,storage, and disposal facility (TSDF). Utilities main-tain right-of-ways, such as pipelines, phone lines,and power distribution systems that can extend forhundreds of miles. In the process of accessing thesesystems at remote locations, hazardous waste isgenerated in the form of contaminated sedimentsaccumulating at utility service access points. Ac-cess points for electric power and phone systemscan vary from manholes and street vaults to re-mote service boxes. RCRA regulations allow theaccumulation of hazardous waste at remote loca-tions for up to 90 days without a permit but gener-ally do not allow shipment to or consolidation ofhazardous waste at off-site locations other thanpermitted TSDFs.

Utilities are currently allowed to accumulate haz-ardous waste at remote locations for up to 90 dayswithout a RCRA permit prior to transporting thewaste to a permitted TSDF. Since remote loca-tions are often unstaffed, it can be difficult to ac-cumulate hazardous waste and secure it againstreleases resulting from accidents or vandalism.Additionally, in urban “remote” locations, waste leftat street access locations can disrupt normal traf-fic patterns. For these reasons, utilities would pre-fer to transport hazardous waste immediately fromremote locations. However, the waste must betransported directly to a TSDF, and arranging tobring the waste directly to the TSDF can take sev-eral days, especially if the event is unplanned. Un-der the New York State DEC project, these utilitieswill be able to transport remote location hazardouswaste as soon as it is collected and to consolidatewastes for up to 90 days at their designated UCCFsbefore it is transported to a permitted TSDF. Inaddition, utilities will be allowed to combine similarwastes at their UCCFs. Consolidation will result infewer vehicle trips, with each trip carrying a largerwaste load. The regulatory flexibility in this projectis expected to streamline the reporting process,

resulting in a reduction of duplicative paperwork,streamlined information for the public, and a cre-ation of direct cost savings for participating utili-ties, EPA, and New York State DEC.

Results/Anticipated Outcomes: EPA issued a fi-nal rule in July of 1999 providing regulatory flex-ibility under RCRA that will allow participating NewYork State utilities to consolidate the hazardouswaste generated at remote locations at designatedUCCFs. New York State has received authority toadminister most of the RCRA program and the rulewill not become effective until the state adoptsequivalent requirements as state law. New YorkState will be promulgating a specific state rule withequivalent provisions to the federal rule. The statewill review and approve UCCF participation. Thisrule change will provide superior environmentalperformance and protect public health by facilitat-ing the removal and consolidation of hazardouswastes at remote locations. Under the rule, haz-ardous waste will be transported to a UCCF withina utility right-of-way network immediately aftercollection or when the staff collecting the wasteleave the location, whichever occurs first.

Under the New York State DEC project, each par-ticipating utility is required to reinvest one-third ofits direct cost savings into environmental remediationor pollution prevention activities that go beyondwhat is legally required and that were not plannedprior to participation in the project. In their annualprogress reports, participating utilities will be re-quired to identify the monetary value of the directcost savings they have experienced as a result ofthe project as well as the environmental activitiesin which they are investing.

Transferability: The New York project seeks toenable innovative waste handling practices to safelyand effectively deal with the problems associatedwith the generation of hazardous wastes at remotelocations. These new practices can benefit utilitiesacross the country facing similar problems with theremote generation, transportation, and secure ac-cumulation of hazardous wastes. This project pro-vides the opportunity to examine (1) if immediatetransport of hazardous waste to central collectionfacilities reduces accidental releases and risks tohuman health and the environment, (2) whether the

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reinvestment of direct cost savings creates betterenvironmental protection than current regulations,(3) the effectiveness of a regulatory flexibility ap-proach that extends across industry sectors withina state, and (4) the realized time and cost benefitsof the consolidation approach. EPA is currentlyconsidering whether alternative manifest standardsfor consolidating wastes from remote utility gen-eration sites are appropriate on a national scale.This project is helping to inform that process.

RCRA Performance-based EnvironmentalManagement Standard

The Experiment(s): The New England Universi-ties Laboratories project proposes to test the ef-fectiveness of an integrated, flexible, per-formance-based system (i.e., an environmentalmanagement standard) for managing laboratorywaste, including RCRA hazardous wastes, in labo-ratories. This project will examine this alternativeapproach to hazardous waste management to dem-onstrate that it is more systematic, more central-ized, and more environmentally beneficial than theapproach currently being used by these universi-ties. At the same time, the project will try to inte-grate some of the current RCRA hazardous wasteregulations with current Occupational Safety andHealth Administration (OSHA) regulations. Thiswill be accomplished by developing a RCRA-basedEnvironmental Management Plan (EMP) similarto the OSHA-required Chemical Hygiene Plan(CHP) at each university. Three universities areparticipating: University of Massachusetts-Boston,Boston College, and University of Vermont-Burlington. The laboratory EMP will establish theparameters for meeting the minimum requirementsfor handling wastes at each individual laboratory.The EMP is the mechanism through which the moregeneral Environmental Management Standards(EMS) will be put into practice at each university.These laboratory EMSs include provisions similarto those required for compliance with the Interna-tional Organization of Standards (ISO) 14001 En-vironmental Management System.

The three New England universities’ laboratorieswant to experiment with a Laboratory EMS ap-proach because it provides a means for compre-hensively managing all laboratory hazardous wastes.

It is through the Laboratory EMP that the universi-ties will have the opportunity, and the obligation, tocreate a performance-based EMS. This compre-hensive environmental management approach willcomplement their OSHA requirements, encouragewaste minimization, and stimulate the redistribu-tion and reuse of laboratory waste within each uni-versity.

Results/Anticipated Outcomes: The New En-gland Universities Laboratories project provides theparticipating universities a temporary conditional de-ferral from two specific RCRA regulations (Haz-ardous Waste Determination and the SatelliteAccumulation Provisions). These RCRA regula-tions have been identified by the universities asimpediments to a more efficient and effective labo-ratory waste management system. This deferral isbased on the universities’ compliance with theLaboratory EMP and minimum performance cri-teria set forth in the site-specific RCRA rule.

This project is expected to achieve superior envi-ronmental performance by setting ambitious goalsfor the universities (i.e., 10 percent reduction inhazardous waste generation and a 20 percent in-crease in the reuse of laboratory wastes). This ef-fort will include the creation of a comprehensivemanagement system for achieving these goalsthrough better tracking and control of the hazard-ous waste, improved coordination of RCRA andOSHA regulatory compliance, and a streamlinedprocess for increasing regulatory compliance withinthe universities. In this project, the requirement todefine and implement laboratory waste manage-ment policies and procedures will effectively man-age laboratory waste at every stage of its handlingand disposition. Full compliance with RCRA re-quirements is required once laboratory waste isreceived at the on-site hazardous waste accumu-lation area(s).

Environmental benefits also will result from in-creased environmental awareness. Training, de-fined policies and procedures, enhanced auditprograms, and pollution prevention strategies arekey management elements. One element of theLaboratory EMP requires each university to de-fine a list of “hazardous chemicals of concern” andannually conduct a risk assessment survey of these

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chemicals in the laboratory. This documented as-sessment will enhance both waste and risk minimi-zation efforts and move laboratory personnel/inspectors away from discussions over whether ahazardous material on the shelf is a RCRA haz-ardous waste.

Transferability: The Laboratory EMS is designedto offer a potential RCRA waste management ap-proach for research and teaching institutions. Thelong-term vision of the participating universities inproposing the laboratory standard is that, by stream-lining and coordinating the RCRA and OSHA regu-latory programs, an integrated and transferableLaboratory EMS will allow scientists and research-ers who move from one institution to another (ortemporarily perform research on a sabbatical at adifferent institution) to be subject to and familiarwith a consistent approach. The search for an al-ternative regulatory system for managing hazard-ous wastes in laboratories is currently beingdiscussed in California, North Carolina, and otherstates and regions of the country. Minnesota hasexpressed interest in testing this Laboratory EMSand other research organizations have expressedinterest in becoming “second-tier adopters.”

Since Massachusetts and Vermont have been au-thorized to administer most of the RCRA programin lieu of the Federal program, this rule will nottake effect until both states adopt the requirementsas state law. Each state has begun the process ofincorporating this new regulation into their autho-rized programs while the universities are in the pro-cess of developing their EMPs.

All three New England universities participating inthis project and implementing Laboratory EMPsare members of the Campus Consortium for Envi-ronmental Excellence (C2E2), which originated inthe New England geographic region. The lessonslearned from these pilots could be transferable toother C2E2 members. If results indicate success,the sharing of information and resources from thesepilots will not be limited to the New England geo-graphic area, however, and are expected to betransferable to other academic institutions, hospi-tals, and corporations with extensive laboratoryefforts. The types of information and resource shar-ing that is envisioned include (1) developing educa-

tional and training materials for laboratory work-ers, (2) sharing information about managing andenvironmental performance monitoring for labora-tories, and (3) integrating environmental manage-ment with laboratory health and safety practices.

RCRA Streamlining—Delistings andVariances

The Experiment(s): Under RCRA regulations,regulated entities may petition the Agency to ex-empt or exclude materials from being classified asa solid or hazardous waste. Two of the RCRA pro-cedures being tested in the HADCO and Molexprojects are, respectively, conditional delistings andsolid waste variances. Delisting is a form of relieffor generators and handlers of listed wastes withlow concentrations of hazardous constituents.Through a site-specific process, a waste handlercan submit to an EPA region or state a petitiondemonstrating that even though a particular wastestream (generated at its facility) is a listed hazard-ous waste, it does not pose a sufficient hazard tomerit RCRA regulation.

Generators, owners, and operators of hazardouswaste management facilities also may petition EPAfor a variance from their wastes being classifiedas a solid and hazardous waste. The Agency maydetermine on a case-by-case basis that certainmaterials should not be classified as a solid or haz-ardous waste.

HADCO is examining ways to overcome barriersto the recovery of metals that are associated withsludge waste. There are three HADCO facilitiesin two different states—New York and NewHampshire—currently involved in the project. TheHADCO project tests various aspects of hazard-ous materials recycling. Transporting hazardouswaste sludges off-site is costly and there are risksinherent in their long-distance transport. On-siterecycling of some of these materials may be eco-nomically feasible. The HADCO project addressesthree different waste recycling and reduction ques-tions: (1) Can F006 RCRA wastes be safely re-cycled by primary metals smelters or otherappropriate metal reclamation facilities? (2) Is itpossible to recycle copper dusts, a current by-prod-uct of HADCO operations that is being sent to a

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landfill? (3) Does the installation of sludge dryerssafely and economically reduce the volume ofsludge wastes? The HADCO project hopes to dem-onstrate that new regulatory approaches to safelyhandling sludge can favor recycling certain wastesthroughout the printed wiring board industry.

Molex has upgraded the wastewater treatmentsystem at its Lincoln, Nebraska, facility to optimizethe recovery of metals used in its electroplatingprocesses. This is being accomplished through useof a segregated treatment system for nickel, cop-per, and tin/lead wastestreams. EPA and Nebraskaissued Molex a temporary variance from hazard-ous waste regulations based on the company’sagreement to (1) routinely collect environmentaldata on the waste sludges and wastewater efflu-ent and (2) collect appropriate cost informationassociated with the operation of the segregatedtreatment system and sludge handling activities.Obtaining the temporary variance classifies its seg-regated process sludge as a “commodity-like” ma-terial rather than as a hazardous waste, allowingMolex to change not only the method of shipping(to common carriers from hazardous waste haul-ers subject to RCRA regulations), but also the ship-ping frequency (on an as-needed basis rather thanevery 90 days as required for hazardous waste).

Results/Anticipated Outcomes: HADCO willmeasure the benefits of its copper recycling ex-periments by estimating the reduction of air emis-sions associated with their truck shipments of sludgewastes. The company hopes to reduce annual fuelusage by 75 percent once regulatory relief is pro-vided. In its 2000 annual report, HADCO submit-ted data developed from F006 sludge shipmentsfrom 1995 through 1999, in addition to data analy-ses and estimates of additional parameters for thesame period. Once regulatory relief is provided,HADCO will begin documenting progress in meet-ing its fuel reduction goal in its annual reports. Thecompany’s annual goal is to reduce by 75 percentits air emissions based on F006 sludge shipmentrecords from 1995 through 1999. HADCO’s fu-ture annual reports will describe its progress onmeeting this goal once regulatory relief is secured.Similarly, HADCO expects to include in future an-nual reports the project-related savings from thereclamation of its copper drilling, sawing, and edg-

ing dusts, as well as from the reduction in copperuse throughout the facility. HADCO installed onesludge dryer in its Derry, New Hampshire, facility,and the company’s goal is to reduce the sludge fromthis facility by 40 percent. HADCO will describethe utility of the sludge dryer installation in futureannual reports and discuss the feasibility of install-ing dryers in other New Hampshire facilities.

The Molex project has been in implementation sinceAugust 1998. Molex intends to document superiorenvironmental performance by demonstrating that(1) its segregated waste treatment system is tech-nically feasible, (2) through greater metals recov-ery the environment will benefit from a reductionof the amount of metals discharged to thecommunity’s publicly owned treatment works(POTW), and (3) a greater quantity of wastewa-ter treatment sludges can be recycled or reclaimed.

In its baseline report, Molex estimated that it wouldbe able to recycle 71,328 pounds of metals sludgesin a year. However, in the first three quarters of2000, a total of 86,302 pounds of sludge have beensent to the recycler, a 21 percent increase over thebaseline estimate. Based on the 2000 quarterly re-ports, the segregated treatment system has re-sulted in:

• a 65 percent reduction in the concentration oftotal metals in the effluent discharged by thePOTW;

• decreased copper concentrations in thePOTW’s effluent by 81 percent;

• decreased nickel concentrations in the POTW’seffluent by 80 percent; and

• decreased concentrations of tin (98 percent)and lead (3 percent) in the effluent being dis-charged.

Transferability: By offering regulatory flexibilityto HADCO and Molex, EPA and the states of NewYork, New Hampshire, and Nebraska are able toevaluate the effectiveness of offering a conditionaldelisting or solid waste variance for RCRA-listedwastes so as to encourage metals recycling andreduce solid waste generation. Many printing wir-ing board manufacturers face environmental prob-

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lems similar to HADCO, and the results of thisexperiment may offer some data on how these prob-lems may be addressed at other facilities.

The Molex project expects to reduce metals’ load-ings in its effluent discharges to the Lincoln, Ne-braska, POTW by at least 50 percent. This goalshould provide a benchmark against which otherpotential requests for temporary variances may bemeasured. Fundamental to both of these projectswill be the environmental and economic feasibilityof these alternative compliance strategies. It mustbe demonstrated that these regulatory flexibilitiesnot only cause no adverse environmental impactbut also, in fact, offer significant environmentalbenefits.

Process Exemption—Innovative CopperMetallization

The Experiment(s): The technologically dynamiclife cycle of semiconductor chip manufacturing hasled to a rapid evolution of manufacturing processtechnologies. IBM’s semiconductor manufacturingfacility in Burlington, Vermont, has developed andintroduced a new, innovative copper metallizationstep into the chip manufacturing process that usesa copper plating process to deposit a layer of metalon the wafer. This process replaces the AluminumChemical Vapor Deposition process, a dry processused for the current generation of semiconductordevice technologies. IBM’s new metallization stepadds 400 gallons per day of copper platingrinsewater (present generation rate, rising to ap-proximately 3,000 gallons per day in 2002) to allother process wastewaters (approximately 4.1 mil-lion gallons) generated at the Burlington facility.Prior to implementation of this new metallizationstep, these other process wastewaters were notregulated as a hazardous waste under RCRA.

Commingling of the copper plating rinsewater withall other wastewaters has required that theBurlington facility classify all sludge generated bythe wastewater treatment process (3 tons per day)as an F006 hazardous waste, even though the cop-per plating rinsewater negligibly changes pollutantconcentrations in the sludge. Additionally, copperis not one of the materials listed as the basis forF006 classification. Current RCRA regulations state

that wastewater treatment sludges from electro-plating operations are F006 wastes, and this newplating process meets the narrative description ofelectroplating. Rather than pursue delisting of thewastewater treatment sludge, IBM Vermont soughta site-specific process exemption from a F006 list-ing for its copper plating rinsewater and resultanttreatment sludge. This exemption removes an “up-stream” manufacturing process (copper metalliza-tion) from EPA’s definition of an electroplatingoperation as the newer process is considerably dif-ferent from the electroplating that was performedwhen the regulation was conceived. Specifically,this process does not involve plating baths of thou-sands of gallons of water that can result in largeamounts of toxic metals in wastewater treatmentsludges, but instead uses only 40 gallons of platingbath for several wafers.

Results/Anticipated Outcomes: While the IBMVermont project is early in implementation, this newplating process has been developed to maximizeefficient use of copper while minimizing the releaseof copper into the wastewater treatment system.IBM Vermont has conducted analyses of the plat-ing bath and rinsewater that showed no presenceof any RCRA materials of concern. The coppermetallization process is approximately 30 to 40 per-cent more energy efficient than the previous gen-eration process, producing a chip that isapproximately 25 percent more efficient than itspredecessor. In addition, by replacing the alumi-num chemical deposition vapor process, use ofperfluorinated compounds (PFCs)—greenhousegases—will be greatly reduced, eliminating theemission of 10,000 metric tons of carbon equiva-lent. (Use of PFC will not be completely eliminatedhowever; the nature of semiconductor manufac-turing still creates a need for some vapor deposi-tion of aluminum.) IBM has also committed toadditional, voluntary greenhouse gas emission re-ductions of 40 percent from the 1995 baseline aspart of this project.

Due to reclassification of its wastewater treatmentsludge, IBM’s reported hazardous waste produc-tion has increased by 170 percent per year, from2.14 million pounds to 5.78 million pounds (1999totals), and waste management costs have in-creased by approximately $3,500 per year. The

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State of Vermont has also waived its hazardouswaste tax, saving IBM $225,000 per year. Thiswaiver will be made permanent by a rule change.In addition, conversion to the copper metallizationprocess is expected to result in operational savingsup to $200,000 per year. As the classification ofthe wastewater treatment sludge as an F006 haz-ardous waste has created only limited additionalcosts, the facility has been provided with little eco-nomic incentive to install a cost-prohibitive segre-gated treatment system that would prevent mixingof plating rinsewaters with general treatment sys-tem influent. However, removal of F006 listing fromthe wastewater sludge for this project will affordIBM Vermont the potential to investigate opportu-nities to recycle the sludge for other uses.

Transferability: IBM’s copper metallization pro-cess could have application in other chip manufac-turing facilities that are seeking to attain moreefficient production methods while reducing wastegeneration per unit output. By focusing on the pro-duction (copper metallization process) side, thisproject also offers EPA an opportunity to test adifferent approach in determining whether “down-stream” treatment waste resulting from a new “up-stream” process should be subject to hazardouswaste listings.

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Albuquerque POTW Integrating Pollution Prevention into Pretreatment: Resource reapportionmenttoward pollution prevention outreach and implementation at 25 newindustrial users a year; reduce or stabilize 13 water pollutants of concern aswell as mass and concentration loadings of influent, effluent, and biosolids.

Denton POTW Remote Monitoring and Watershed Protection: Reduced monitoring andannual inspections while having greater focus on pollutants in urbanstormwater drainage. Resource savings from regulatory flexibilityreapportioned to watershed protection activities.

Louisville-Jefferson Watershed-based Pretreatment Management: Three-phase project that willCounty POTW reallocate pretreatment resources to develop a more holistic watershed

protection approach. The FPA describes project Phases I and II and willallow implementation of a third phase.

Steele County Mass-based Compliance Standard: Replace concentration-based categoricallimits with mass-based limits to help achieve overall industrial water reduction goals.

Steele County Reduced Monitoring for Regulated Pollutants Not Present: Reduced or eliminatedmonitoring for regulated categorical pollutants not present in a facility’s discharge.

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Publicly owned treatment works (POTWs) thathave mastered the programmatic aspects of theindustrial pretreatment program (identifying users,permitting, monitoring) are seeking to move towardmore performance-based environmental processes.Some POTWs want to make decisions on allocat-ing resources based on the risk associated with theindustrial contributions they receive along with otherfactors. Others want to be able to focus more re-sources on ambient monitoring in their receivingwaters and/or to integrate their pretreatment pro-grams with other environmental monitoring pro-grams. In general, POTWs want the opportunityto redirect limited resources toward activities thatthey believe can produce greater environmentalbenefits. A performance-based pretreatment pro-gram pilot can allow experimentation with certainprogrammatic requirements of POTWs’ approvedPretreatment Program. This flexibility will enablePOTWs to shift resources toward innovative ac-tivities likely to yield superior environmental results.

Project XL is sponsoring a series of projects in-volving POTWs. While each project investigatesunique innovations, they all offer EPA the prospectfor improving the pretreatment program as a whole.

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They all test alternative methods for protecting theenvironment and better ways to maintain healthywaterways.

Integrating Pollution Prevention intoPretreatment

The Experiment(s): The City of Albuquerque (NewMexico) POTW project aims to reduce the amountof water pollutant loadings from business and in-dustry in the city by integrating pollution preventionactivities with Albuquerque POTW’s existing In-dustrial Pretreatment Program (IPP). This will beachieved by shifting resources from currently re-quired IPP activities and requirements. Albuquer-que POTW’s current pollution prevention outreachefforts will be expanded through various methodsand will be guided by new sampling and monitoringof sewer system sub-basin manhole locations. Sub-basin monitoring will investigate the feasibility ofdetecting where in the city certain pollutants ofconcern are most prevalent. The AlbuquerquePOTW project will create a baseline from which apollution prevention program can be customized tomeet the requirements of an area. Sub-basin moni-toring is a change from the current system of sam-pling influent at the POTW and deducing theupstream source(s). The monitoring information willbe used to target the development and promotionof pollution prevention outreach material at appro-priate locations and businesses within the sub-basin(s) of the city.

Results/Anticipated Outcomes: The AlbuquerquePOTW project seeks to optimize its resources toachieve institutional integration of pollution preven-tion into its National Pollutant Discharge Elimina-tion System (NPDES) pretreatment program. Theproject commits Albuquerque POTW to pursuingreduction or stabilization of 13 water pollutants ofconcern. To achieve these goals, AlbuquerquePOTW will look to implement pollution preventionat a targeted 25 new businesses a year.

Pollutant reductions will be guided by sewer sub-basin monitoring to determine where certain pol-lutants of concern predominate. Actual pollutantlevels will be monitored in the sub-basins beforepollution prevention outreach and implementationoccurs. Once the monitoring baseline is established,

certain sub-basins could receive more focused andintense pollution prevention outreach efforts de-pending on the type and amount of pollutants iden-tified. This is expected to result in an eventualstabilization and/or decline of targeted pollutants ofconcern, reducing targeted pollutants by 10 to 20percent over time.

Transferability: The materials, methods, and les-sons learned from pollution prevention approachesin the Albuquerque POTW project could be trans-ferable and serve as a model for other cities. Giventhe ability to shift resources to support such activi-ties, sewer sub-basin monitoring could also be trans-ferred to other POTWs. Sub-basin monitoring hasthe potential to provide focus to broader commer-cial and residential sectors. This project providesan opportunity to evaluate the benefits and obstaclesof directing pollution prevention outreach materialsat specific locations and businesses.

Remote Monitoring and WatershedProtection

The Experiment(s): The Denton POTW projectis using regulatory flexibility to begin developmentof a watershed protection program for the PecanCreek. The City of Denton, Texas, (Denton POTW)will receive flexibility from the Pretreatment Pro-gram to modify its annual industrial user inspectionand monitoring schedule for individually approvedfacilities and focus on pollutants in urban stormwaterdrainage. Saved resources due to this flexibility willbe reapportioned to site-specific watershed pro-tection activities, including developing buffer zonesalong underdeveloped areas in the watershed andestablishing a remote creek monitoring networkintegrated with a local flash flood warning system.This remote monitoring network, being developedin partnership with the University of North Texas,will transmit real-time water quality data from au-tomated, remote monitoring stations located up- anddownstream from the POTW.

Denton POTW plans to create an administrativemechanism to allow buffer zone creation in under-developed drainage basins of watersheds lyingwithin the Denton boundary. These easements,which Denton POTW hopes to establish at a mini-mum of 50 feet, will create a network of vegeta-

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tion that should result in the reduction of suspendedsolids, nitrogen and phosphorous fertilizers, pesti-cides, and herbicides.

Results/Anticipated Outcomes: The DentonPOTW project tests the application and develop-ment of technological methods to achievestormwater and watershed monitoring requirementswith minimal personnel demand. The project willfocus on establishing baseline ambient conditionsof Pecan Creek with monitoring designed to as-sess the impact of pollution control measures.

The Denton POTW will assess the impact of itsefforts to control stormwater runoff and pollutionusing elements of the State of Texas’ ReceivingWater Assessment and Clean Rivers Program.Water quality and aesthetic indicators will be usedto measure the effectiveness of all proposed wa-tershed protection activities.

Transferability: This project will test the appli-cation and development of technological methodsto monitor a watershed that creates minimal de-mand on personnel. The use of technology (remotemonitoring) to accomplish tasks that would other-wise require extensive staff demand could serveas a model for other POTWs looking for innova-tive watershed protection approaches.

Watershed-based Pretreatment Management

The Experiment(s): The Louisville and JeffersonCounty Metropolitan Sewer District (MSD) wantsto more effectively manage its local pretreatmentprogram and establish links between other Districtwastewater programs (e.g., stormwater). This willmove MSD toward a more holistic watershed pro-tection strategy for the Chenoweth Run watershed.The MSD project will move forward in threephases: (1) data collection and development of pre-treatment performance measures, (2) pretreatmentprogram redesign to reduce key pollutants and iden-tify areas of resource inefficiency, and (3) newprogram implementation to reduce mass loadings.Phase I of the project was cemented in a Phase Iagreement. Phase II is described in greater detailin the FPA. Phase III is intended to result in re-source savings that MSD can shift to pollution pre-vention outreach activities, first within thepretreatment program and then in other watershedbased programs.

Results/Anticipated Outcomes: The MSD projecthas proposed to better manage the JeffersontownPOTW’s pretreatment program through a holisticwatershed approach. In Phase I, MSD collectedsupplemental and improved data from “strategic”points in the sewer collection system. These data,combined with existing pollutant data, enabled MSDto establish a baseline for pollutant loadings. Withthis baseline established, MSD will develop loadingprojections and reductions, performance measures,and new pretreatment program elements.

MSD has already realized benefits from meaning-ful data and better coordination of information. MSDexpects to realize further benefits through enhancedresponse to wastewater treatment plant upsets,reapportioning monies that would have been spenton permitting and monitoring to pollution preven-tion projects within the watershed. These projectsare intended to maintain or decrease loadings ofcertain pollutants within the watershed.

MSD is also committing to continue its monitoringof the Chenoweth Run watershed for pollutants ofconcern, developing agreements with eligible in-dustry for pollution prevention projects, and con-ducting assessments of pretreatment programperformance against performance measures. TheFPA specifies performance measures for pollut-ants of concern to be a percentage reduction be-low water quality criteria, local NPDES permitslimits, and biosolids disposal criteria.

Transferability: Once this new program is fullyunderway, other municipalities could draw impor-tant lessons from MSD’s experience in developingand implementing a performance-based, and ulti-mately holistic watershed protection strategy. Also,co-regulators (states, tribes, and EPA) have theopportunity to analyze the challenges posed by aregulatory structure that does not integrate pro-grams and to find solutions with more holistic ap-proaches.

Mass-based Compliance Standard

The Experiment(s): The Steele County projectsponsors are pursuing a community-wide projectto address industrial wastewater effluent reduc-tions in two municipalities, Owatonna and Bloom-ing Prairie, Minnesota. The project sponsors are acollection of local industrial users, primarily metal

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finishing facilities, that will commit to a cumulativereduction of some regulated wastewater effluentswhile reducing overall water usage.

One project goal is to facilitate water conservationmeasures at sponsor facilities. To effectively insti-tute such measures, sponsors in Owatonna soughtregulatory flexibility to express concentration-basedpretreatment categorical limits with mass-based lim-its. The CWA’s National Pretreatment Standardsestablish limits on pollutants in specific industrialcategories. The standards establish pollutant limi-tations in different ways for different categories.The Owatonna sponsor facilities are currently op-erating under concentration-based standards. Cur-rent regulations do not allow alternative mass-basedlimits to be substituted for a concentration-basedlimit when the applicable standard is expressed interms of concentration. This lack of flexibility cancause obstacles for industrial users that are attempt-ing to reduce or minimize water use. By reducingvolume, water conservation can increase the con-centration of pollutants, even if the total mass ofpollutants has decreased. A facility that has cut itswater use might exceed its concentration-basedlimit despite having reduced pollutants in its dis-charge. By complying with a mass-based limit thatis equivalent to or less than the total pollutant loadfrom a concentration limit, pollutant loading wouldbe unchanged or reduced, even though effluentconcentration might have increased. Through theSteele County project, the local POTW is able toallow sponsor facilities in Owatonna to use mass-based limits in lieu of concentration limits for dis-charges to the wastewater treatment facility.

Sponsor facilities will also pursue wastewater ef-fluent reductions that are greater than what isachieved under current regulations. The sponsorsin Owatonna, a group of small-to-medium sizedfacilities, have made a voluntary commitment to a20 percent reduction in the discharge of each offour priority metals (chromium, copper, nickel, zinc).The sponsor facility in Blooming Prairie has madea voluntary commitment to a 20 percent reductionin biological oxygen demand (BOD), total sus-pended solids (TSS), and total Kjeldahl Nitrogen(TKN) that flow to the local POTW. If these dis-charge reductions goals are met, sponsor facilitiescould receive flexibility in the form of reducedmonitoring frequency.

Results/Anticipated Outcomes: In return for theequivalent mass-based limit flexibility, Owatonnasponsor facilities have committed to a goal of re-ducing the total amount of water flowing from spon-sor facilities to the wastewater treatment facilityby 10 percent over the course of the project. Regu-latory limits for industrial discharges from the spon-sor facilities will remain in effect, but these limitswill be changed from concentration-based toequivalent mass-based limits. Any exceedance ofa mass-based limit could result in the use of a tra-ditional enforcement tool. To ensure the appropri-ateness of the mass-based limits, sponsor facilitieswill be required to notify the POTW in the eventthat production rates vary, impacting mass loading.

For the Owatonna sponsor facilities, if the metaldischarge goals are met, the POTW would havethe option to reduce the frequency of monitoringfrom quarterly to biannual monitoring for facilitieswith satisfactory compliance records. For theBlooming Prairie sponsor facility, if the effluent dis-charge goals are met, the frequency of monitoringfor BOD, TSS, and TKN could change from aweekly requirement to a bimonthly schedule.

Transferability: The Steele County project willserve as a test case for the use of equivalent mass-based limits as an alternative to concentration-basedlimits. As more industries and municipalities insti-tute water conservation practices due to supplyconstraints, environmental conditions, or costs, themass-based limit option has the potential to be trans-ferred to facilities heavily dependent on water whoare operating under a concentration-based categori-cal pretreatment standard.

EPA is currently considering allowing POTWs toset equivalent mass-based limits as an alternativeto concentration limits to meet concentration-basedcategorical pretreatment standards on a nationalscale through the proposed rule Streamlining theGeneral Pretreatment Regulations for Existing andNew Sources of Pollution (July 22, 199964FR39564). The Steele County project is helpingto provide information. It is also helping to deter-mine whether providing mass-based limit flexibilityprior to implementation of water conservation ef-forts will encourage more widespread adoption ofsuch practices.

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Reduced or Eliminated Monitoring forRegulated Pollutants Not Present

The Experiment(s): Steele County project spon-sors in Owatonna may be provided flexibility bythe local POTW to allow them to reduce or elimi-nate monitoring for any pollutant regulated by acategorical pretreatment standard if that pollutantis not present in the facility’s discharge. Under cur-rent regulations, industrial users subject to categori-cal pretreatment standards are required to submitreports at least twice a year to their Control Au-thority indicating the nature and concentration ofall pollutants limited by the standards. (For mostmunicipalities, as for Owatonna, the Control Au-thority is the local POTW). In addition, the localPOTWs must sample facility sponsors at least an-nually for all regulated pollutants. This sampling isrequired for all pollutants limited by a categoricalstandard, even if the pollutants are not reasonablyexpected to be present in the effluent.

Under the Steele County project, the local POTWwill be able to modify an industrial user’s permit toreduce or eliminate sampling for regulated pollut-ants not discharged by the sponsor facility basedon three years of sponsor effluent data. This flex-ibility will apply to any categorical pollutants thatare not expected to be present in the waste streamat levels greater than background in the water sup-ply, with no increase in the pollutant due to the in-dustrial user’s activities.4

Results/Anticipated Outcomes: The SteeleCounty project gives the participating POTWs theflexibility to allow facility sponsors to eliminate orreduce monitoring. This determination will be basedon both sampling data and other technical data (rawmaterial usage, industrial processes and potentialprocess byproducts). Existing data on pollutant con-centrations in the local public water supply will helpcharacterize background concentrations. If a spon-sor facility uses an alternative water supply, repre-sentative sampling will be needed to characterizebackground pollutant concentrations from the al-ternative influent. At least three years of facility

sponsor effluent data will then be compared to thebackground data in making the determination thata given pollutant is not expected to be present. Thisdetermination will also be based on raw materialsused, industrial processes and potential processbyproducts. It will not consider the capability orefficiency of the sponsor facility’s pretreatmentsystem. Once the POTW determines that one ormore regulated pollutants are not expected to bepresent at a sponsor facility, it can modify thatsponsor’s permit to reduce or eliminate monitoringrequirements for those pollutants.

The POTW will sample and analyze the applicablesponsor for all pollutants limited by the categoricalstandard at least once during the term of the spon-sor facility’s permit. Sponsor facilities will remainsubject to the categorical standards for pollutantsdetermined not to be present and will need to re-sume sampling if the pollutant is found to be presentat levels greater than background in the water sup-ply. As a condition of the revised permit, sponsorfacilities will be required to submit a brief certifica-tion statement that there has not been an increaseof the pollutant(s) due to activities along with thestandard semiannual monitoring reports.

Transferability: By testing the flexibility to waiveor reduce monitoring for categorical standard pol-lutants not expected to be present in the wastestream, the Steele County project approach couldbe applied broadly by POTWs. This reduced moni-toring approach was proposed as part of the July22, 1999, proposed rule affecting the National Pre-treatment Regulations.

4 This flexibility will not apply to industrial users subject tothe Categorical Standards for the Organic Chemicals Plasticsand Synthetic Fibers point source category, 40 CFR Part414.

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In response to growing concern over health andenvironmental risks posed by hazardous waste sites,Congress established CERCLA, commonly knownas Superfund, on December 11, 1980. This law cre-ated a tax on the chemical and petroleum indus-tries and provided Federal authority to responddirectly to releases or threatened releases of haz-ardous substances that may endanger public healthor the environment. By April 2000, more than 100Superfund sites (many thought to be unusable) hadalready been recycled without an organized effort

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ExxonMobil CERCLA Streamlining to Recycle Superfund Site: Streamlined strategy for Superfund siteremediation; early consideration and planning in remediation process for siteredevelopment and reuse.

on the part of EPA. The Agency is now embarkingon a coordinated effort called the Superfund SiteRedevelopment Initiative, begun in July, 1999, tofacilitate the return of these sites to productive use.Through partnerships with states, tribes, other Fed-eral agencies, local governments, communities, land-owners, developers, and parties potentiallyresponsible for contamination, EPA has achievedsubstantial results protecting public health and theenvironment, while piloting and experimenting withimprovements to the cleanup process.

CERCLA Streamlining to Recycle SuperfundSite

The Experiment(s): Proposed in September 1998,the ExxonMobil project implements a streamlinedstrategy to the traditional Superfund remediationapproach to expedite the cleanup of the Fairmont(West Virginia) Coke Works Superfund Site (Site).To clean up the Site, ExxonMobil will be adminis-tering a series of changes to the traditional Superfundprocess that will affect site characterization, riskassessment, management of on-site landfills, andmitigation requirements for on-site wetlands. Al-though many of the administrative procedures be-ing used in this project are available throughCERCLA, concurrent use of them represents adeparture from conventional cleanup actions. Thesechanges are intended to minimize the impact of theSuperfund site on human health and the environ-ment, enabling the Site to be cleaned up in approxi-mately half the time a normal Superfund responsemight take.

Site Mitigation: While maintaining protection ofhuman health and the environment, ExxonMobil isseeking to reduce the total time involved in clean-ing up the Site. Due to the specific nature of con-tamination at the Site, it was recommended that anon-time critical (NTC) removal action frameworkbe used to address the remediation of process ar-

eas and waste management units at the Site. Re-moval actions are short-term responses to mitigateimminent threats to the public or the environmentwhile remedial actions are longer-term cleanupactions to permanently remedy problems at a site.The NTC action will be consistent with any long-term remedial action at the Site. Other potentialcleanup issues at the Site (e.g., groundwater con-tamination) will be addressed by the remedial ac-tion process. EPA site managers have estimatedthat this use of a NTC removal action will result ina faster, more efficient cleanup. ExxonMobil plansto use removal and remedial actions in a coordi-nated manner to reduce the total time involved incleaning up the Site.

Site Characterization: ExxonMobil and EPA ne-gotiated the use of an engineering evaluation/costanalysis (EE/CA) to temporarily replace a reme-dial investigation/ feasibility study (RI/FS).5 TheEE/CA is a flexible document tailored to identifyand analyze the scope, goals, and effectiveness ofthe NTC removal action. The detail of the EE/CAis determined by the scope of the NTC action. Al-though not required by EE/CA guidance, an eco-logical risk assessment is being conducted on theSite.

Risk Assessment: A baseline human health riskassessment will be conducted as a required part ofthe EE/CA. Human health risk assessments con-

5 Under a traditional Superfund remedial action, once a site islisted on the National Priorities List (NPL), a remedial inves-tigation (RI) is performed to characterize the site and deter-mine nature of the contamination. As part of the RI, a riskassessment is performed to determine baseline risk to humanand environmental receptors. A feasibility study (FS) is con-ducted concurrently with an RI to establish remedial actionobjectives and evaluate all remedial alternatives in detail. Inconsultation with the appropriate state agency, a remediationplan is selected and documented in a Record of Decision(ROD). Remedial design (RD) technical specifications areselected based on the ROD and then the remedial action (RA)phase implements the cleanup.

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ducted as part of Superfund programs have gener-ally included an evaluation of potential risks asso-ciated with residential exposure scenarios, unlessthe future use of the site is commercial/industrial.The assessment of potential risk associated withdirect exposure to contamination at the Site waslimited to commercial/industrial exposure scenarios.The scope of risk evaluation conducted as part ofthe NTC removal action was between the limitedrisk evaluation undertaken for a time-critical re-moval action and the conventional risk assessmentconducted for remedial actions. ExxonMobil hasownership of the property, thus it can limit the re-development options for the site to commercial orindustrial uses through institutional controls suchas deed restrictions.

Site Management: A specific area in the north-ern part of the Site will be designated as an area ofcontamination (AOC)6 to avoid triggering a RCRAland disposal restriction (LDR) during remediationactivities. Under RCRA, land disposal or place-ment of RCRA classified hazardous wastes with-out previous treatment is generally restricted. Underthe AOC concept, EPA has designated activitiesnot considered land disposal or placement. All wastemanagement units in the northeast area of the Sitewill be designated as a single AOC so that on-sitewaste management can proceed in a regulatorycompliant and efficient manner without being con-strued as placement or invoking an LDR. This des-ignation is justified due to the close proximity of thewaste management units.

Wetlands Mitigation: Some wetland areas (e.g.,drainage channels) were formed during interim re-moval actions on the Site between 1993 and 1996.ExxonMobil has prepared a map identifying poten-tial wetland areas created by the removal actionsand EPA will evaluate the mapped areas and de-termine flexible mitigation requirements for the Sitebased on the following: (1) If any of the mapped

wetland areas are part of existing treatment ofdrainage systems, no mitigation will be required.(2) In addition, if, in the process of anticipated Sitecleanup, these wetland areas will be improved dueto grading or reconstruction, such actions could beconsidered mitigation. Wetlands created during the1993-1996 EPA removal actions not fitting the abovecriteria will be evaluated on a case-by-case basis.

Results/Anticipated Outcomes: ExxonMobil hasmapped wetland areas created during the earlierremoval actions. The mapped areas are being re-viewed by EPA and the State of West Virginia.Completion of the EE/CA and NTC removal ac-tions is expected in the coming months.

This project has been designed to achieve acceler-ated remediation and improved environmental pro-tection. Coordination of removal and remedialactions by ExxonMobil will result in a more rapidprogression through site characterization, remedyselection, and remediation phases without compro-mising the technical aspects of the Superfund pro-gram. This approach will allow the Site to becleaned up in approximately half the time a normalSuperfund response might take. As a direct resultof an accelerated cleanup, control and manage-ment measures will be implemented sooner to miti-gate the extent of migration of contamination. Risksto human health and the environment will be mini-mized or eliminated sooner due to the shortercleanup time frame. In addition, ExxonMobil willexperience a reduced administrative burden throughthe use of streamlined risk assessment, site char-acterization processes, and data submissions.

Transferability: At this stage in the project, it istoo early to measure changes in environmental per-formance, but by examining options for streamlin-ing the Superfund cleanup response timeline, thisproject can serve as a model for expeditiously andeffectively cleaning up a Superfund site and facili-tating its return to productive use. As the projectproceeds, there will be an opportunity to analyzehow streamlined risk assessment and focused sitecharacterization can provide benefits to the com-munity and environment and how expedited cleanupschedules can help mitigate migration of contami-nation and reduce or eliminate potential risks tohuman health and the environment.

6 EPA defines an AOC as a non-discrete land area on whichthere is generally dispersed contamination. The AOC con-cept arose out of the EPA’s definition of “land disposal” andwas introduced as a tool for the management of remediationwastes. Land disposal is broadly defined to include virtuallyany placement of hazardous waste on the land, includingtemporary placement.

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�� EPA, state, and tribal programs require industrialand municipal facilities to obtain permits that limittheir emissions and discharges to the air, land, andwater. Permits, which contain detailed descriptionsof proposed activity and operating procedures, arethe chief vehicles through which statutes and regu-lations are translated into facility-level ordinances.They have been one of our most effective environ-mental protection tools and are the nexus at whichmost people first encounter the regulatory process.Permit provisions may include any combination ofrequirements addressing (1) limits on emissions oreffluents; (2) monitoring, reporting, andrecordkeeping; (3) pollution treatment or controltechnologies; (4) management practices; and (5)pollution prevention requirements. Permits are typi-cally issued by states, tribes, or EPA (when a co-regulator permitting program has not yet beenapproved by EPA). Interested stakeholders areencouraged to provide input into the permitting pro-cess during the mandated public commentopportunities.

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Project(s) Media Innovation

Intel Air Facility-wide Permit Air Emission Caps: Flexible use of plant site emissionWeyerhaeuser limits (PSEL), prevention of significant deterioration (PSD) permit, orMerck plant-wide applicability limits (PALs); facility-wide emissions caps allowImation preapproval of production changes without recurring permit revisions.

Andersen Air Performance-based Permitting: Incentive-based approach to reduce VOCemissions based on per unit of production emissions limit.

Elmendorf AFB Air Pollution Prevention Incentives through Title V Streamlining: New approachto streamline Title V permit process leading to cost savings that can beapplied to currently non-funded pollution prevention projects.

International Water Tailoring NPDES Effluent Improvements: Through use of a collaborativePaper—EI process, IP will replace a set of qualitative regulatory requirements—best

management practices (BMPs) from the water portion of EPA’s Pulp andPaper Cluster Rules—with targeted, enforceable, and quantitative NPDESpermit limits

Weyerhaeuser Water Water Effluent Limits: A revised NPDES permit reflecting more stringentlimits on BOD, TSS, and adsorbable organic halogens (AOX). Voluntaryreductions below permit limits resulted in no fish tissue sampling or waterbody assimilative capacity studies.

Jack M. Berry Multi-media Comprehensive Operating Permit: Consolidate individual media permits intoCorporation a multimedia all-permit reporting requirements for a facility.

The present system has developed into a sophisti-cated one that controls significant sources of pollu-tion from industrial and municipal facilities.However, government permitting regulations reflectthe single media, “command-and-control” focus ofour environmental statutes. Industry, government,and community partners recognize the need to de-sign flexible permitting approaches that are funda-mentally performance-based. The essence of theperformance-based approach is to shift the focusof environmental permitting toward measurementand assurance of performance, while providing flex-ibility in how a regulated entity meets performancestandards. In theory, a system that focuses moreon a facility’s overall environmental impacts, andless on narrow decisions about particular technolo-gies or process changes, should be more beneficialto the public as well as less prescriptive for thefacility. Project XL experiments with approachesthat apply this theory, as briefly described in Table 6.

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Facility-wide Permit Air Emission Caps

The Experiment(s): The complexities of air regu-lations require a considerable effort by both regu-lators and facilities in their preparation and reviewof permit applications for many process modifica-tions. Project XL is testing how innovations in theair permitting systems can reduce a facility’s envi-ronmental impact, while streamlining the permit-ting process and reducing paperwork. Usingfacility-wide emission caps is a way to bring about

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Project/Permit Type Approach Emission Caps

Intel

New SourceReview(Minor)

Weyerhaeuser

New SourceReview

Merck

Prevention ofSignificantAir QualityDeterioration

Emissions for the entire facility arecapped as follows: VOCs at 40tons per year; NOx and CO2 at 49tons per year; SO2 and particulatematter at 5 tons per year; phos-phine at 4 tons per year; sulfuricacid at 9 tons per year; organicHAPs and inorganic HAPs at 10tons per year.

The caps reduce allowable airemissions by 60 percent. The dualemission caps apply to particulatematter, SO2, NOx , CO , VOCs, andtotal reduced sulfur (odor-causingpollutant).

The facility-wide cap limits totalemissions of criteria air pollutantsto levels 20 percent below baseline(i.e., prior actual emissions): SO2emissions to levels 25 percentbelow baseline levels, NOxemissions to levels 10 percentbelow baseline levels, andparticulate matter to levelsapproximately equal to baselinelevels.

EPA and the State of Arizona have provided Intel withthe flexibility to make equipment and process changesand construct new facilities at the site without airquality permit reviews, as long as the PSELs are notexceeded and all other FPA and permit limits are met.To provide an additional safety factor, Arizona Ambi-ent Air Quality Guideline limits for HAPs will not beexceeded at the Intel facility property line or elsewhereon the site.

EPA and the State of Georgia have modified thefacility’s existing air quality permit to include dualemission caps for air pollutants. The dual emission capsare (1) a cap that allows the recovery furnace, smeltdissolving tank, calciner, and combination boiler (thefacility’s major sources emissions) to be operated totheir design capacity without triggering permit review;and (2) a cap covering all facility sources except thosefour major sources. The modified air quality permitstreamlines the permit renewal process, includesalternate excess emission reporting protocols, andincludes a protocol for conducting manufacturingprocess experiments without triggering a permitreview.

EPA and the State of Virginia issued a new PSD airquality permit for a facility wide air emissions cap atthe Merck Stonewall Plant. Under the new permit,changes or additions to facility operations that result inemission increases will no longer require prior ap-proval under either Federal or state regulations. Thenew permit provides the flexibility to implement achange in operations that increases emissions withinthe constraints of the emission caps. In addition, Merckwill have the option of reducing the facility-wide capsinstead of implementing specific control technologiesprescribed by certain future regulations.

such changes. Facility-wide emission caps are de-signed to prevent growth in discharges from bothexisting and future stationary sources. In general,such provisions require that any emission increasefrom equipment at a facility be offset by emissionreductions from other equipment under the samecap. Table 7 includes the Project XL experimentswith facility-wide air emission caps under the fol-lowing permits: Prevention of Significant Air Qual-ity Deterioration (PSD), New Source Review(NSR), and Title V of the Clean Air Act (CAA).

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Project/Permit Type Approach Emission Caps

Imation Camarillo will be subjectto a PAL (a voluntary emissioncap) for VOC emissions of 150tons per year. While providing noNSR flexibility, facility emissioncaps for other pollutants include:CO, 30 tons per year, NOx, 8 tonsper year; particulate matter andSO2, less than 15 tons per yeareach; any individual HAP less than10 tons per year.

Imation will use the concept of a pollutant-specific, PALfor new source review (NSR) purposes. The PALconcept is intended to allow major sources to avoidcase-by-case NSR applicability determinations. Instead,under the PAL concept, sources are allowed to makefacility modifications without triggering major orminor NSR so long as their actual emissions do notexceed the PAL, which is set at a level representative ofactual emissions. The existing preconstruction airpermitting regulations that govern modifications at thefacility, specifically the CAA minor NSR and majornonattainment NSR regulations, require that changesto Imation’s manufacturing processes must be re-viewed and approved in advance by the VenturaCounty (California) Air Pollution Control District(VCAPCD)

Imation

New SourceReview

Results/Anticipated Outcomes: Under ProjectXL’s flexible approach to permitting, businesseshave avoided costly production delays. They alsohave improved their worker health and safety stan-dards, increased the public’s access to useful envi-ronmental information, and reduced their facility’semissions to the environment:

• Since 1997, Intel’s Chandler facility has re-mained well under its air emission caps. Thefacility continues to avoid millions of dollarsworth of production delays by eliminating 30 to50 permit reviews a year. Early this year, Intelannounced it will build its first 300-millimeter,high-volume production manufacturing facilityat Chandler. The company said it will invest$2.0 billion to build and equip the wafer fabri-cation facility. The company will seek this ex-pansion under its existing air emissions capestablished by Project XL in 1996.

• Merck anticipates being able to avoid millionsof dollars worth of potential production delaysby eliminating redundant permit reviews.

• Since 1997, the Weyerhaeuser Flint River fa-cility has remained under its caps. In 1999Weyerhaeuser was 33 percent under its capfor particulate matter (PM), 44 percent for to-tal reduced sulfur, 66 percent for sulfur dioxide(SO

2), 37 percent for nitrogen oxides (NO

x),

36 percent for carbon monoxide (CO), and 61percent for volatile organic compounds(VOCs).

• The site-specific air permit will allow Imationto avoid potentially costly delays in makingchanges in their existing magnetic tape manu-facturing equipment and processes providedthat all of their air permit conditions are satis-fied and their air emissions remain below thecaps. In addition to the 150 tons per year capon VOC emissions, Imation must meet a mini-mum of 95 percent and 100 percent captureefficiency for organic compounds (VOCs andHAPs) emitted from coating manufacturingoperations at the facility. While providing noNSR flexibility, Imation has committed to emis-sion caps for other criteria pollutants, includingNO

x, 8.34 tons per year; and CO and SO

2, less

than 5 tons per year, respectively.

Transferability: By focusing on the total emis-sions of a facility, Project XL is testing and con-firming flexible emission reduction strategies thatmay be both duplicated at similar facilities acrossthe country and integrated into EPA’s existing regu-latory regime. These concepts have already begunto be integrated into the national regulatory sys-tem. The recent pharmaceutical MACT regulationspromulgated in April 1998 have incorporated les-sons learned from the Merck project, allowing the

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limited preapproval of certain types of productionchanges without requiring permit revision for eachmodification. The Agency is formally consideringfurther expanding this use of preapproval and “cappermits.”

In addition, these projects are testing alternativemajor new source review (NSR) applicability sys-tems that allow plantwide applicability limits (PALs)instead of traditional NSR netting for determiningwhether modifications are subject to major NSR.Through a proposed NSR rule, EPA would makePALs more broadly available, enabling plants toestablish capped limits on their total emissions inexchange for increased flexibility to add and sub-tract production units without having to go throughNSR and the associated permitting. This wouldprovide communities with certainty that emissionswill not increase above permitted levels. EPA isalso developing guidance on flexible permitting ap-proaches that will allow a facility to permit alterna-tive operating scenarios, establish limits onemissions, and use other techniques to provide themwith operational flexibility for the life of the permit.

Performance-based Permitting

The Experiment(s): The Andersen project estab-lishes an innovative, incentive-based per unit emis-sion measure intended to reduce Andersen’s VOCemissions at the Bayport, Minnesota, facility. Un-like traditional permitting, the Andersen project willreceive a permit that uses a combination of aplantwide VOC emissions cap and a performanceratio based on VOCs emitted per cubic feet ofproduct shipped. Traditional regulatory approachesimpose penalties for poor environmental perfor-mance but have not focused on encouraging im-proved performance once a facility is in compliance.The performance ratio approach will have conse-quences for poor performance like the current regu-latory system and will include rewards for beyondcompliance performance. This will provide an in-centive for Andersen to continue to improve theenvironmental performance of its Bayport facility.

One of the means Andersen will use to achieve itsreduced VOC and particulate matter emissions lev-els will be through the expanded use of Fibrexmaterial. The Fibrex composite material is a com-

bination of reclaimed sawdust and vinyl. The manu-facture of Fibrex composite allows for the use ofwood byproduct materials rather than virgin wood.The use of Fibrex materials is beneficial since itreduces the need for raw material and requires nowood preservation treatment, which accounts fora substantial amount of VOC air emissions fromthe Bayport facility. Expanded use of Fibrex com-posite will result in substantial reductions in theemissions of VOCs per unit of production.

In addition, Andersen wants to increase the use ofits in-line waterborne treatment systems and re-duce the use of solvent-based wood preservatives.The current regulatory system discourages the useof the waterborne treatment systems such thatAndersen has to use a greater amount of solvent-based wood treatment. Because solvent-basedtreatment emits substantially more VOCs thanwaterborne treatment, current regulations actuallycause Andersen to have greater VOC emissionsat it facility. This project removes the limits onAndersen’s use of its in-line waterborne treatmentsystems so that Andersen can make greater use ofthis environmentally beneficial process.

Andersen may also experiment with recycling win-dows as feedstock for the Fibrex process. Thisentails collecting old window components frombuildings where replacement windows are beinginstalled, removing the paint (some of which maycontain lead), processing the lead for reuse, andusing the wood as feedstock for the Fibrex pro-cesses. Andersen’s goal is to manage its windowtake-back program without invoking RCRA treat-ment, storage, and disposal facility requirements.

Results/Anticipated Outcomes: The Andersenproject emphasizes an incentive-based system forthe reduction of Andersen’s VOC emissions perunit of product produced. The cap on per unit VOCemissions will ensure that Andersen’s per unit VOCemission rate does not significantly exceed theirrange of current actual VOC emissions per unit.The penalty limit will be set at two standard devia-tions above Andersen’s five-year average per unitemission rate. The reason for setting the rate attwo standard deviations is that the emission ratefluctuates on a daily basis depending on productionneed: Fibrex demand, use of waterborne treatment,

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use of solvent- based treatment, and the number ofpainted windows ordered. This approach, which isnot available under existing regulatory schemes, isintended to “lock-in” existing efficient manufac-turing methods and processes while encouragingenvironmental efficiency and rewarding continuedimprovement. Andersen will use as a baseline thepenalty limit (an enforceable pound per unit limitfor its VOC emissions); the other performance limitsand thus the performance ratio will be based onthe penalty limit. Table 8 describes the various per-formance limits used.

Transferability: The Andersen project testswhether a tiered air emission ratio system with bothrewards and penalties can provide a better incen-

tive than traditional approaches for reducing airemissions. Specifically, EPA will gain reference dataas to whether emission rates per unit of productioncan be used to effectively limit VOC emissions andencourage environmental efficiency.

In addition, the project will provide information onwhether RCRA treatment, storage, and disposalrequirements can be eliminated for companies thatplan to reuse materials. This could be useful to otherwindow manufacturing and production facilities aswell as other manufacturers who are interested inreuse or product “take back.”

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Community The CAC limit serves as the main limit for evaluating Andersen’s ongoingAdvisory Council performance. The CAC limit is the average of the prior five years’ performance(CAC) Limit ratios and will be recalculated once every three years. It will decline if appropriate,

and will increase only if the changes are approved, with concurrence of EPA andMinnesota Pollution Control Agency. If its annual performance ratio exceeds theCAC limit, Andersen will be required to provide a specific explanation of theexceedance to the CAC as well as establish an approved corrective action plan tobring the performance ratio below the limit. The CAC—a group of individualsrepresenting local residents, employees, environmental groups, and governmentofficials—was formed to assist Andersen in development and implementation ofthis project.

Enforcement Limit A static enforcement limit for the ten-year duration of the project will beestablished using the initial CAC limit plus two standard deviations.

Project Limit The project limit will be set at two standard deviations above the CAC limit. Itwill be the same as the enforcement limit for the first three years, but will beadjusted with the CAC limit. The project limit will never exceed theenforcement limit.

Reward Limit This limit will be two standard deviations below the CAC limit. The reward limitwill not increase and will only decline if Andersen remains below it for threeconsecutive years. In addition to the per unit VOC limits described above,Andersen plans to make enforceable commitments to keep its overall VOCemissions for both its Bayport facilities below 2,397 tons per year. Andersen alsowill maintain a VOC emission sub-limit of 96 tons per year at its as yetundeveloped West facility.

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Pollution Prevention Incentives throughTitle V Streamlining

The Experiment(s): The Elmendorf Air ForceBase (Elmendorf AFB) XL/ENVVEST7 projecttests an approach to air pollutant source permittingand administrative management for military instal-lations. Elmendorf AFB is looking to (1) reduce airpollution through prevention at the source and (2)demonstrate the feasibility of alternative-fuel ve-hicles in the Anchorage, Alaska, area. ElmendorfAFB is seeking regulatory relief from its monitor-ing and recordkeeping requirements by streamlin-ing its CAA Title V permit process.

Under Title V, military installations are treated as asingle major emissions source, with accountabilityfor all emission sources at the installation. The CAArequires that each installation permit not only largepollutant sources, but also a significant number ofsmaller sources. For Elmendorf AFB, this wouldinvolve the permitting of 106 separate sources un-der a Title V permit, which would create costlyadministrative burdens for Elmendorf and regula-tory agencies. Elmendorf AFB has proposed to usethe Project XL/ENVVEST process to help reduceCO emissions and to reallocate money, currentlyearmarked for Title V permitting requirements, intoother currently non-funded pollution preventionprojects. Elmendorf AFB intends to demonstratesuperior environmental performance in part throughthe introduction of a compressed natural gas (CNG)fleet and fueling program.

Results/Anticipated Outcomes: The ElmendorfAFB project seeks to reduce air pollution loadingsof CO and NO

x through pollution prevention ap-

proaches. Although the base is in CAA attainment,Anchorage, which the base borders, is currentlyclassified as a nonattainment area for CO. The basewill pursue its pollution prevention efforts througha two-fold process of regulatory flexibility.

• First, Elmendorf AFB and EPA will use theEPA policy document entitled “Major SourceDeterminations for Military Installations underthe Air Toxics, New Source Review, and TitleV Operating Permit Programs for the CleanAir Act” (Major Source Guidance). This policydocument recognizes that many military instal-lations possess characteristics warranting flex-ibility in CAA major source determinations.Major Source Guidance allows military instal-lations to divide themselves into functionallydistinct emitting activities. Based on a poten-tial to emit (PTE), a select number of emis-sions sources on a given installation couldpotentially be considered major stationarysources. For Elmendorf AFB, only the centralheating and power plant (CH&PP) is a majorstationary source based on actual emissions ofCO and NO

x.

• The second part of the regulatory flexibility willbe limiting the PTE of other emissions sourceson the base so they will not be considered ma-jor sources. Actual emissions from thesesources are currently below major sourcethresholds, and the base will obtain limits onthe emissions from these sources. These al-ternative emissions standards create enforce-able standards and are a critical part of theproject’s permitting scheme.

These flexibilities will streamline Elmendorf AFB’sTitle V permit process, placing the CH&PP (and anumber of other sources subject to new sourceperformance standards) in the revised permit. Thischange will simplify monitoring and recordkeepingrequirements and result in cost savings that will beapplied to pollution prevention projects. By beingable to target specific emission sources, ElmendorfAFB will be able to make more cost-effective useof its resources. Through reduced monitoring andrecordkeeping, Elmendorf AFB estimates that itspermit management costs will decrease by 80 per-cent, saving the base $1.5 million over six years.These cost savings will be redirected toward pollu-tion prevention opportunities on the base.

One of the pollution prevention projects will be theinstallation of a CNG fueling station, the conver-sion of certain base fleet vehicles to be able to use

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7As part of the Administration’s reinvention initiative, EPAand DoD signed a Memorandum of Agreement in 1995 thatestablished how the two agencies will interact during imple-mentation of DoD’s Environmental Investment (ENVVEST)program. The ENVVEST program emphasizes regulatorycompliance through pollution prevention and provides analternative to prescriptive regulatory requirements through aperformance-based environmental management system de-signed to attain superior environmental results.

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CNG, as well as the procurement of dedicatedCNG fuel vehicles. The CNG fleet should help toreduce the levels of CO on the base and bolsterAnchorage’s efforts to reduce CO levels.

Transferability: The Elmendorf AFB project ex-plores ways to alleviate regulatory burdens at fed-eral facilities and could serve as a model for otherDepartment of Defense (DoD) installations deal-ing with emissions from multiple major sources. Ademonstration of achievable and superior environ-mental benefits could spur the transfer of similaractivities to other DoD installations. In addition, theconversion to alternative fuel vehicles will assist indemonstrating the feasibility of CNG technology inAnchorage as well as the potential to transfer thistechnology to other installations.

Tailoring NPDES Effluent Improvements

Experiment(s): The International Paper effluentimprovement (IP-EI) project in Jay, Maine, is imple-menting process changes to improve effluent qual-ity at its Androscoggin mill. The IP-EI projectreplaces a set of qualitative regulatory requirements[best management practices (BMPs) from thewater portion of EPA’s Pulp and Paper ClusterRules] with targeted, enforceable, and quantitativeNational Pollutant Discharge Elimination System(NPDES) permit limits for key environmental pa-rameters. The Pulp and Paper Cluster Rules re-quire pulp and paper facilities to develop BMPs toprevent, capture, and recover spent pulping liquorand other materials that might otherwise be dis-charged into the wastewater treatment process andeventually into the final effluent.

IP considers its existing practices—including ex-isting spill prevention procedures and process con-trol technologies—to be advanced enough to befunctionally equivalent to the BMPs. In exchangefor a waiver of the BMP requirements, IP is imple-menting a series of effluent improvement projectstailored to its Androscoggin mill operations. Theimprovement projects will be specifically designedto improve the mills’ effluent quality for chemicaloxygen demand (COD) and color. IP will also ac-cept new NPDES permit limits for effluent dis-charge once the effluent improvement projects arecompleted. The regulatory flexibility of the IP-EI

project will enable IP to reallocate estimated costsavings to select and implement effluent improve-ment projects at the facility.

This project will be using a collaborative processinvolving IP, co-regulators, and other local stake-holders to design and implement effluent projectsthat have the potential to yield optimum environ-mental benefits. The collaborative process will alsobe used to estimate potential pollutant reductions.This stakeholder group would then map out a phasedplan for implementing projects. A list of potentialeffluent improvement projects to evaluate includes:

1. knot liquor recovery system;

2. pulp screening liquor recovery system;

3. pulp digester heater drains recovery;

4. complete recycle of “A” pulp mill washwaters;

5. alternative knot and screening conveyancefluid;

6. power house sump drains collection system;and

7. computerized mill sewer conductivity display.

Results/Anticipated Outcomes: At this stage inthe IP-EI project, it is too early to see changes inenvironmental performance, but it is anticipated thatimplementation of these effluent improvementprojects will yield greater environmental benefit forCOD and color reduction than compliance with thePulp and Paper Cluster Rule BMPs. Numeric lim-its will ultimately be placed in the facility-specificNPDES permit that is expected to reflect a 50 per-cent reduction of current discharges of several keypollutants [BOD, COD, AOX, TSS].

Transferability: The IP-EI project provides an op-portunity to explore how water quality improve-ment projects tailored to a mill’s specific operationscan achieve environmental results superior to whatwould be attained by adherence to existing regula-tions. It will serve as an opportunity to gain fasterfamiliarity with new effluent technologies that maybe transferable to other mills. This project may alsohelp to inform future Agency rulemaking as regu-lations are under consideration for COD and color.

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Water Effluent Limits

The Experiment(s): As part of its project,Weyerhaeuser revised its Flint River Plant’sNPDES permit to include more stringent effluentlimits on BOD, TSS, and AOX. Weyerhaeuser hasmodernized several components of the pulping pro-cess, which has reduced the BOD and TSS levelsin bleach plant wastewater, as well as maintainedthe AOX levels.

Results/Anticipated Outcomes: The company’s1998 NPDES permit was revised under theWeyerhaeuser project. Weyerhaeuser modernizedseveral components of the pulping process and hasmet the more stringent effluent limits on BOD, TSS,and AOX per air-dried metric ton (ADMT) of fin-ished product. Table 9 describes the Weyerhaeuserpermit limits.

Transferability: In Aiming for Excellence (July1999), EPA commits to identifying and implement-ing improvements within the NPDES permittingprogram. The Weyerhaeuser project’s piloting ofNPDES permit alternatives have the potential toinfluence Agency permitting initiatives. For ex-ample, case studies about these alternatives mightprove useful in the development of permit writertraining materials for any of the cross-agency per-mitting initiatives.

Comprehensive Operating Permit (COP)

The Experiment(s): The Berry citrus juice pro-cessing plant has been required to obtain multiplepermits from multiple regulatory agencies. Air qual-ity, water quality, and consumptive-use regulationsgovern the plant’s boilers, feed mill dryers, drinkingwater, industrial wastewater, and water use opera-tions. The Berry project intended to consolidatethese individual permitting requirements into a singlecomprehensive operating permit (COP). The COPwould have offered the opportunity for co-regula-tors (in this case EPA, the Florida Department ofEnvironmental Protection, and the South FloridaWater Management District) to eliminate Berry’sburdensome requirements for preparing multiplepermit applications on differing and sometimes con-flicting schedules.

The COP would have consolidated selected oper-ating permits and requirements, maintained all en-vironmental standards, and committed Berry tosuperior environmental performance. The stream-lined permitting approach was also expected to re-sult in cost savings to the facility operator byreducing administrative burdens. In turn, Berry hadagreed to invest these cost savings into the instal-lation of updated equipment and implementation ofupdated procedures used in citrus processing toreduce air emissions of VOCs, SO

2, and NO

x.

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Permit Limits Results

Discharge of 3.8 pounds of BOD Reduced the amount of BOD in its effluent from a 1997 level of 3.01per ADMT of finished product. pounds per ADMT to a 1998 level of 2.13 pounds per ADMT. In 1999,

BOD levels in facility effluent increased to 2.83 pounds per ADMT.

Discharge of 4.09 pounds of TSS per Reduced the amount of TSS in bleach plant wastewater. WeyerhaeuserADMT of finished product. reduced the amount of TSS in its effluent from a 1997 level of 3.13

pounds per ADMT to a 1998 level of 2.8 pounds per ADMT. In 1999,TSS levels in facility effluent increased to 3.87 pounds per ADMT.Unreliable operation of a facility process during 1999 caused increasedproduction of off-grade pulp, which is recycled through the pulpmanufacturing process. This increased the amount of water used,effluent produced, BOD levels per ton of finished product, and TSSlevels per ton of finished product.

Discharge of 0.15 kilograms of AOX The AOX limit under the project is 4 percent beyond the best availableper ADMT of finished product. technology standards proposed by EPA. AOX levels were 0.10 kilo-

grams per ADMT in 1996, 1997, and 1998. In 1999, levels of AOX infacility effluent remained at 0.10 kilograms per ADMT.

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Results/Anticipated Outcomes: During the initialphase of COP development Berry employees andthe State of Florida worked together on the devel-opment of detailed work procedures. However, afterthe Berry project had been underway for almost ayear, Cargill, Inc., (an international marketer, pro-cessor, and distributor of agricultural products) tookover as the operator but not as the owner of Berry’sLaBelle, Florida, facility. Although some projectcommitments had been met, EPA and the State ofFlorida chose to terminate the agreement after at-tempts to engage Cargill in the process failed. TheCOP was not submitted, and the project was ter-minated on June 2, 1999.

Transferability: Should an opportunity arise,Project XL could potentially test the COP conceptat another facility. In March 1999, EPA approveda detailed plan for “The Next Generation in Per-mitting.” The COP concept is an integral part ofthis plan and is expected to be a key concept in theAgency’s ongoing permit improvement process.

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Demands for high-quality and readily accessibleenvironmental information has never been greater.To meet these needs, EPA, like many other organi-zations, has worked to take advantage of the op-portunities created by new information technologies.This new capability brings new challenges, such aspublic access, information security, and protectionof proprietary business information. EPA’s newOffice of Environmental Information, working with

many different internal and external stakeholdersand partners, is working to develop information-related policies and procedures that reflect the con-cerns of EPA managers and staff; local, state, andfederal governments; tribes; the regulated commu-nity; interest groups; and the general public. Aspart of this national effort, Project XL is experi-menting with approaches that seek to (1) improvepublic access to information through the Internet,(2) gain more stakeholder input into data presenta-tion, (3) build performance-based incentives intoreporting requirements, and (4) eliminate obsolete,duplicative, and unnecessary monitoring,recordkeeping, and reporting requirements from thefederal, state, tribal, and local levels. Table 10 be-low describes the projects’ environmental informa-tion innovations.

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Steele County Water Alternative Reporting Strategy: Alternative significant noncompliancereporting for POTWs. Qualifying pretreatment violations may be postedon Minnesota Pollution Control Agency Web site in lieu of beingpublished in local newspaper.

Intel Multi-media Internet Reporting and Stakeholder Input: Improving public access toinformation; making community participation more meaningful; ProjectXL guide to project tracking and reporting.

Merck Air Tiered Reporting: Incentive-based reporting and record-keepingrequirements determined by levels of emissions control(through a PSD permit).

Intel Multi-media Consolidated Reporting: Reducing reporting burdens through reportMerck streamlining and consolidation; one-stop reporting.WeyerhaeuserNYSDECBerry

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Alternative Reporting Strategy

The Experiment(s): The first phase of the SteeleCounty project includes flexibility for the develop-ment and implementation of an alternative signifi-cant noncompliance (SNC) reporting approach,under which qualifying violations may be posted onthe Minnesota Pollution Control Agency (MPCA)Web site in lieu of being published in a local news-paper. Current pretreatment regulations requirePOTWs to annually publish a list of industrial usersthat, at any time in the previous 12 months, were inSNC. This list must be published in the largest dailynewspaper published in the municipality in whichthe POTW is located. The purpose of this provi-sion is to notify the public of violations and to serveas a deterrent for the industrial user to avoid non-compliance. Under the project, the OwatonnaPOTW will be granted the flexibility to use an al-ternative procedure for publishing SNC. This al-ternative approach would reserve annualnewspaper publication for cases where that for-mat is needed for its potentially greater effect.

Results/Anticipated Outcomes: The intent of thisWeb-based approach is to provide prompt and ap-propriate assistance for identifying and correctingviolations. Violations that qualify under this alter-native approach are available for a sponsor facilitythat is responsive, and where the violation(s) didnot cause a pass-through or interference violationat the POTW. For a SNC event qualifying underthis provision, a description of the event and thecorrective action taken will be published on theMPCA Web site as the violation is reported. AllSNC violations, whether published in a newspaperor not, would eventually be posted on the MPCAWeb site. The Web site will also explain how SNCis determined and will have contact informationabout violations which are not SNC.

All noncompliance events will be investigated by apeer review committee established under the SteeleCounty project. This committee would include twoor three sponsor facility representatives not con-nected to the noncompliance event under reviewalong with any stakeholder wishing to participate.The peer review committee would investigate non-compliance events, make recommendations andprovide assistance to expedite the return to com-

pliance. Peer review recommendations are not bind-ing, and the city will continue to implement its En-forcement Response Plan. Newspaper publicationof SNC will be used at the discretion of theOwatonna POTW, where the previously discussedcriteria are met. The Owatonna POTW would con-tinue to be required to provide newspaper publica-tion of any violation that is not corrected within 30calender days or that results in pass-through or in-terference. Sponsor facilities in Owatonna will takesteps to ensure that public outreach on the avail-ability of information regarding SNC events throughthis alternative publication approach is conducted.

Transferability: A Web-based, alternative SNCreporting approach could have application in othermunicipalities seeking to provide real-time and“meaningful” public notice of SNC events whilecontinuing to provide a deterrent for industrial us-ers. The Steele County project also provides anopportunity to test how a community-based ap-proach can provide prompt and appropriate assis-tance in identifying and correcting violations. EPAis already contemplating opportunities to furtherapply this innovation under the new PerformanceTrack program. Performance Track offers admin-istrative streamlining benefits in the major programareas such as air, water, and waste. In addition,EPA will propose a set of changes in its regula-tions to accommodate Performance Track facili-ties, including expanding the options for POTWs toreport certain compliance information through theInternet instead of through the newspaper. Thesechanges will be formally proposed by EPA for pub-lic review and comment later this year.

Internet Reporting and Stakeholder Input

The Experiment(s): The Intel project has two in-novations designed to improve public access to in-formation: (1) using stakeholder input to helpredesign the format and content of the reports onthe environmental performance of the Ocotillosemiconductor facility in Chandler, Arizona, and (2)making these reports available on the Internet. Thefacility’s new reporting format was designed inconjunction with the stakeholder team that includedEPA, the Arizona Department of EnvironmentalQuality, the Maricopa County Bureau of Air Pollu-tion Control, the City of Chandler, and members of

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the Community Advisory Panel (CAP). Based oninput from the stakeholder team, Intel agreed toput routine environmental reporting requirementsand accountability measures into a single, integratedreport that is publicly available on the Internet viaIntel’s Project XL Web site, http://www.intel.com/intel/other/ehs/projectxl/index.htm. Now citizens,as well as regulatory officials, can routinely moni-tor progress toward the facility’s environmentalcommitments. This approach tests the value ofgetting comprehensive environmental informationdirectly from the company. Currently, all data mustbe reentered, although the long-term goal is forIntel’s Internet form to be merged directly into thestate and local agency information systems.8

Results/Anticipated Outcomes: Intel establisheda precedent for making facility-based environmen-tal information publicly available on the Internet.Co-regulators and public stakeholders involved withthe Intel project have universally endorsed this ap-proach. Project regulators and public stakeholdershave described the report as citizen-friendly, con-cise, and easy to use.

However, while it is enhancing public access toenvironmental performance data and the timelyavailability of information to the public, public stake-holders have cautioned that the Internet is not apanacea for increasing public access to informa-tion. For example, the needs of public stakeholderswith limited or no access to computers must beaddressed. Other projects enhancing public accessin ways supported by public stakeholders includethe Crompton project, which both appointed aProject XL contact at the facility to serve as a re-source for the community and established publicfiles on the project at the local library. Also, underthe Weyerhaeuser project, in exchange for reduc-ing the number of reports filed with the State ofGeorgia, the facility now provides information di-rectly to the public upon request, and the facilityhas agreed to make even more data available thanwas previously reported.

Transferability: The multistakeholder input ap-proach and the Internet access to information haveproven so innovative that EPA has incorporatedIntel’s approach into the “Guide to Project Teams—Project Tracking and Reporting,” which stronglyencourages that all future projects develop similarInternet reporting formats with interested stake-holders. Also, new projects such as the SteeleCounty project, are featuring Internet reporting in-novations.

The demand for high-quality environmental data isincreasing rapidly. To respond to the demand, EPAis developing a prototype system to allow data tobe received and stored electronically for use byEPA, the states, and the public. This new systemwill allow electronic reporting instead of paper re-porting, saving companies and government agen-cies millions of dollars. It will also centralize andintegrate EPA’s largest environmental databases,making information more accessible and useful. Instep with the direction of this new system, the Intelproject can help facility-based electronic reportinggain acceptance by other companies and regula-tors. Also, the stakeholder involvement approachcan create an opportunity to make community par-ticipation more meaningful, e.g., by allowing firmsto redesign reporting mechanisms in ways that en-hance community understanding and trust.

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8“The current reporting system relies on a mix of paper formsand electronic information systems. Data originates at a facil-ity, where it is often entered into a computer for storage.Submission of that data to a government agency, however,requires transferring it to a paper form. The agency receivingthe paper report must then rekey the same data into its sys-tem to make use of it. If a state agency is the first recipient, itforwards the data to EPA, where it then must be rekeyed foruse in EPA systems.” From Reporting Reform: The Case forA Joint EPA/State Strategy, One Stop Reporting Program, April28, 1998.

Graph from Intel's 1999 Annual Report

1999 Recycled Non-Hazardous Chemical Waste

Per

cen

t

100%Intel Ocotillo Site

90%

80%

70%

60%

50%

40%

1999Goal - 50%

1997Goal - 25%

30%

20%

10%

0%

78%

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Tiered Reporting

The Experiment(s): The Merck project providesan innovative three-tiered approach to monitoring,recordkeeping, and reporting linked to its air qual-ity permit. A site-specific rule and new preventionof significant deterioration (PSD) permit providealternative methods for complying with applicablestate implementation plan air quality rules, NSR airemission regulations, and certain provisions ofRCRA relating to air emission controls on hazard-ous waste equipment. The new PSD permit includesa facility-wide cap for total criteria air pollutantsand subcaps for SO

2, NO

x, and PM with a diam-

eter of less than 10 microns. The requirements formonitoring, recordkeeping, and reporting increasein stringency as the facility’s actual total criteriaair emissions approach the sitewide emissions cap.Annual reporting is required when facility-wideemissions are less than 75 percent of the cap. Semi-annual reporting is required when facility-wideemissions are between 75 percent and 90 percentof the cap. Monthly reporting is required whenemissions are equal to or greater than 90 percentof the total emissions cap. In addition, as actualemissions approach the cap, more precise moni-toring methods for certain emission units, such asstack tests, must me used in place of emissionscalculations based on generalized emissions fac-tors. This provides an incentive for Merck to pur-chase the cleanest available technologies and tomaintain low air emission levels.

Results/Anticipated Outcomes: The three-tieredmonitoring, recordkeeping, and reporting require-ments will become effective no later than 12 monthsafter Merck completes the installation of new equip-ment that converts its coal-fired powerhouse tonatural gas. This lag time is due to the fact thatactual emissions will be measured using a 12-monthrolling total. This total will be larger at the outset,reflecting the coal burning prior to powerhouseconversion. Powerhouse conversion is required tobe completed no later than 30 months after thepermit’s effective date.

Transferability: Other facilities that face compa-rable circumstances or business issues could ben-efit from a similar tiered approach to monitoring,record keeping, and reporting designed to provideincentives for air pollutant emissions reductions.Once the Merck project is in full implementation,there will be a need to further evaluate (1) howuseful the data are for the local, state, and Federalusers; (2) what a facility must do to implement thisapproach; (3) whether it can be transferred into amultimedia approach; and (4) what the barriers areto broader potential implementation. This tieredprovision may also have the potential to influenceother Agency permitting initiatives.

Consolidated Reporting

The Experiment(s): A number of projects are test-ing new approaches for consolidated reporting ofthe environmental information required by Federal,state, and local regulations. The approaches aredetailed in Table 11.

Intel has consolidated recurring and routinereports into four quarterly reports and oneannual report. The consolidated reportingformat was designed in conjunction with theEPA, the Arizona Department of Environmen-tal Quality, the Maricopa County Bureau ofAir Pollution Control, the City of Chandler,and a CAP consisting of area residents.

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Description Programs Affected

Intel Internet reports cover air quality, waterquality, and solid and hazardous wastereporting requirements, with theexception of the Toxic Release Inven-tory (TRI) reports required under theEmergency Planning and CommunityRight-to-Know Act (EPCRA), whichmust be prepared and submittedseparately.

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Results/Anticipated Outcomes: The Intel andWeyerhaeuser projects’ reporting mechanismshave been underway since 1997. The companies,regulators, and stakeholders involved believe thatthe Intel and Weyerhaeuser projects have gener-ally resulted in detailed, value-added reporting.However, stakeholders’ comfort with this approach

Weyerhaeuser

NYSDEC

Berry

The requirements for monitoring, recordkeeping, and reporting become more strin-gent as the facility’s actual emissions approachthe facility-wide cap under Merck’s air qualitypermit. Monitoring, record keeping andreporting will be performed by Merckaccording to the reporting tier determined bythe current 12-month rolling total. Tier I hasthe least stringent requirements; morefrequent reporting is required when Tier II orTier III requirements are in effect.

The Weyerhaeuser project allows the facilityto consolidate reporting into two annualcomprehensive reports for some of theFederal, state, and local permitting andregulatory programs that apply to the facility.The reports eliminate some sampling require-ments and allow annual compliance self-certification in lieu of periodic dischargemonitoring reporting.

Participating utilities will produce one biennialreport on all the hazardous waste generatedat remote locations. Under the currentsystem, a separate EPA identification numberis assigned to each remote location reportinghazardous waste production and a biennialreport must be produced for each location.This change will bring about significantreduction in paperwork and savings in timeand labor, both for the public utilities andenvironmental regulatory agencies. Thechange will also provide the public withclearer and easier to use information aboutwaste generated at remote locations.

The Berry project had been designed to havea multimedia consolidated permit in place,and the State of Florida would have allowedBerry to use nonstandard forms in reportingenvironmental performance.

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Description Programs Affected

Merck The tiered reporting covers air qualityemissions specified by the innovativePSD permit.

The comprehensive, less frequentreports cover drinking water, waterquality discharges, groundwater andsurface water use, and air quality. Self-certification covers discharge monitor-ing reporting for the NPDES permit.

NYSDEC will receive fewer reportswith more information from participat-ing utilities, reducing the number ofreports that require separate trackingand review under the ResourceConservation and Recovery Informa-tion System.

The nonstandard forms would haveapplied to air quality, drinking water,industrial wastewater, groundwatermonitoring, and fresh water usereporting. Also, the State of Floridamay not have required Berry toprovide certification of environmentalreports by a professional engineer,because the COP would have beenmore extensive than a certifiedprofessional engineer’s application.

is not absolute; e.g., one stakeholder for the Intelproject wants more technical details to be avail-able to the public, as well as the technical assis-tance to interpret the information, so that thecommunity can better evaluate the potential im-pacts on health and the environment and then in-fluence the company’s decision-making process for

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choosing among different available technologies orchemicals. This desire has been echoed by othernational interests. The Merck project’s reportingmechanisms are projected to start in 2001. Berryhad not initiated the reporting mechanisms beforethat project was terminated in June 1999.

Transferability: EPA strives to reduce reportingburdens by authorizing specific reductions throughrecently issued rules and policies. However, themeasures that EPA seeks to adopt to reduce re-porting burden typically require state action in or-der for these reporting approaches to be achieved.A number of state programs are looking to transi-tion to a consolidated “one-stop” reporting system.In keeping with this trend, EPA plans to furtherexplore the Federal component of the consolidatedreporting and burden reduction opportunities pre-sented by the Intel, Merck, Weyerhaeuser,NYSDEC, and former Berry projects. EPA is al-ready contemplating opportunities to further applythis innovation under the new Performance Trackprogram. Performance Track offers administrativestreamlining benefits in the major program areassuch as air, water, and waste. In addition, EPA plansto propose a set of changes in its regulations toaccommodate Performance Track facilities, includ-ing consolidated environmental reporting under vari-ous environmental statutes into a single report.These changes will be formally proposed by EPAfor public review and comment later this year.

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(��One of EPA’s most important responsibilities ismaking sure that companies and other organiza-tions comply with the laws that protect humanhealth and the environment. EPA and state gov-ernments have typically relied on a strong enforce-ment program to do this. However, EPA and stateshave increasingly sought to identify creative toolsto help regulated entities improve day-to-day com-pliance and achieve performance at levels beyondcompliance. For example, EPA is helping compa-nies comply through the support of assistance cen-ters, as well as an audit policy that encourages themto complete their own environmental evaluations.

In recent years, national efforts have centeredaround identifying and addressing environmentalproblems using innovative and integrated initiativesthat combine compliance assistance, incentives,monitoring, and enforcement. These complianceincentives include incentives to self-disclose, includ-ing the audit and small business policies promotingsupplemental environmental projects and providing

compliance assistance through electronic centers.In particular, self-certification is being explored bystates as an opportunity to deliver better compli-ance assurance while EPA is exploring promotingEnvironmental Management Systems. Self-certifi-cation approaches vary, but they typically ask fa-cilities to report on a specified set of environmentalperformance measures (such as sampling actions,sampling results, regulatory compliance, and regu-latory violations). States have used self-certifica-tion strategies in a variety of ways: to reducereporting burdens, to reduce the need for resourceintensive individual permits for small sources, toreduce the amount of labor-intensive inspectionsand/or prioritize them to allow states to reinvestresources into higher priority problems, and to in-crease the number of facilities addressed by states’enforcement and compliance systems. Also, statesand EPA are trying new procedures to measurecompliance on a facility and sector level. The mea-sures may assist in identifying problem areas thatcould be improved through new technology or pol-lution prevention. Additionally, EPA is willing tooffer flexible options under regulations that encour-age facilities to choose compliance alternatives thatare better economically and environmentally.Project XL has been one venue for testing these

innovations, which are described below in Table 12.

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Massachusetts DEP Multi-media Business Self-Certification: In lieu of state permits, self-Weyerhaeuser certifications are used to comply with or exceed state performance

standards; Weyerhaeuser performs compliance self-certification inlieu of periodic discharge monitoring report for facility NPDESpermit based on 16 years of compliance.

IP-PEM Multi-media Predictive Emissions Monitoring: Reduce the frequency of stacktesting and replace a CEM system with a predictive computer-basedsystem that will correlate operating parameters with air emissions.

Massachusetts DEP Multi-media Environmental Business Practice Indicators (EBPIs): Use of EBPIs tosupplement or replace traditional measures of compliance allowsregulatory agencies to review compliance as well as encouragebeyond compliance techniques for industry leaders.

Merck Air Alternative Compliance Flexibility under Emissions Cap: Flexibility toreduce air emissions cap as an alternative to directly complyingwith newly applicable criteria pollutant regulations (through thePSD permit).

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Business Self-Certification

The Experiment(s): The Massachusetts Depart-ment of Environmental Protection (MassachusettsDEP) established its Environmental Results Pro-gram (ERP) on a basic premise—a primary rea-son for noncompliance is a lack of knowledge andunderstanding of the rules (including permit require-ments). ERP is a multimedia, whole sector-basedregulatory system that replaces case-by-case per-mits with industry-wide environmental performancestandards and an annual certification of compliance.The ERP approach offers a multimedia summaryof all applicable regulations and makes a facilitymanager personally responsible for compliance. Itprovides a simple but comprehensive checklist aspart of its self-certification package and encour-ages a facility manager to use the checklist as atool for maintaining compliance. ERP is a manda-tory program for the three identified small-businesssectors (printers, photo processors, dry cleaners)currently participating. ERP focuses in large parton corporate accountability and self-evaluation withcompanies required to meet and certify their com-pliance with industry-wide performance standardsmutually agreed upon by regulators and industry.These sector-specific performance standards em-phasize pollution prevention practices and principlesto yield environmental results superior to thoseachieved through conventional regulatory ap-proaches. ERP provides a period of outreach as-sistance and training for companies on complianceand other performance standards, after which thecompany submits a statement certifying compliancewith applicable performance standards and thatcompliance will be maintained for the coming year.

The ERP approach has also been designed with anemphasis on enforcement. Certification statementsare signed under penalty of perjury by a facility’sowner, president, CEO, or other high-ranking offi-cial. Under ERP, companies are accountable forreporting any releases or exceedances of dischargeor emission standards to Massachusetts DEP. Par-ticipating firms will need to provide evidence oftheir good faith efforts to meet and maintain com-pliance with ERP standards. Violations will be re-ported, and a “Return to Compliance Plan”submitted to Massachusetts DEP, if any such vio-lations are either outstanding at the time of certifi-cation or discovered thereafter. If a facility is notin compliance when it self-certifies, this Plan willidentify the existing violations and specify how andwhen compliance will be achieved.

The ERP approach will require annual self-certifi-cation, use clear performance standards written inplain language, target compliance assistance, andemphasize pollution prevention. Key to the processof confirming company compliance as well as mea-suring and evaluating the environmental results ofERP will be the use of environmental business prac-tice indicators (EBPIs). EBPIs (see page 52) areindustry-specific performance measures that pro-vide a snapshot of a facility’s environmental per-formance. EBPIs are unique in that they includemeasurement of adherence to traditional regula-tory standards (e.g., level of compliance with la-beling, record keeping, and monitoring), as well as“beyond compliance” measures (pollution preven-tion and reuse/recovery activities).

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Weyerhaeuser Air Major Source Emissions Tiered Compliance Testing: Modified NSR PSDpermit creates a tiered compliance testing schedule based on thecontrol of the facility’s major source emissions.

Georgia-Pacific Air Gasification of Pulping Liquor Under MACT II: Pulp and paper mill isseeking to demonstrate a new recovery technology under section112 of the CAA

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The Weyerhaeuser project allows the facility toeliminate some sampling activity and to provideannual compliance self-certification in lieu of peri-odic discharge monitoring reporting for the NPDESpermit. This limited self-certification process wasallowed due to the company’s 16-year history ofmeeting all required discharge levels combined withthe project’s commitment to superior environmen-tal performance. Weyerhaeuser is still required tomaintain required sampling and laboratory analysisrecords, and all upset, malfunction, or noncompli-ance reporting will continue as required by appli-cable regulations. These records are available uponrequest by regulators and the public. Weyerhaeuserwill remain subject to the State of Georgia’s stan-dard enforcement protocol, as required by the state’sNPDES permit program.

Results/Anticipated Outcomes: MassachusettsDEP anticipates superior environmental perfor-mance by means of converting permit requirementsinto industry-wide performance standards that en-able facility managers to be aware of their envi-ronmental obligations before they make decisionsabout modifying equipment and operations. In 1995-1996, the Massachusetts DEP conducted a limitedevaluation of the usefulness of company participa-tion in the Massachusetts Printers Partnership(MP2)—a predecessor ERP program. DEP foundthat more than 50 percent of the participating (andcertifying) MP2 facilities exhibited higher environ-mental performance than non-participating print-ers.

The ERP project has been underway since late1996, and the results of the ERP approach and self-certification are still being evaluated. In May 2000,Massachusetts DEP presented its own preliminaryassessment of the ERP program to EPA. DEP isusing EBPIs, compliance inspection findings, anddata reported on the self-certification forms, as wellas statistical sampling techniques to measure andevaluate the environmental results of ERP. Feed-back from preliminary state evaluations has beenlargely positive. In the fall of 1997, participatingdry cleaners and photo processors completed theirfirst annual certification. Participating printers com-pleted their first certification in 1998. These certi-fication statements have increased the identificationand understanding of small businesses not other-

wise included in a regulatory framework. BeforeERP, only 10 percent of dry cleaning facilities were“in the system.” By 1999, that number had in-creased to 95 percent. Altogether, nearly 2,400companies representing three sectors have self-certified under the ERP since 1997. Massachu-setts DEP has begun expanding this approach totwo additional sectors—industrial wastewater andcombustion sources (boilers)—which will signifi-cantly increase the number of Massachusetts fa-cilities self-certifying under ERP.

Preliminary evaluation has also demonstrated thatconverting permit requirements into comprehensiveand stringent industry/sector-wide performancestandards has improved corporate accountabilitytoward annual compliance. For 1997, 80 percentof dry cleaners and photo processors completedtheir certifications accurately. Ten percent of sub-mitted certification statements have “Return toCompliance Plans” (a 10 percent compliance in-crease). Thirty-five percent of these Return toCompliance Plans will result in a decreased envi-ronmental impact. Massachusetts DEP has esti-mated that increased compliance will lead to aprogram-wide decrease in VOCs by 10 percent,an estimated 43 percent reduction in perchloroeth-ylene emissions (a total of 500 tons) from Massa-chusetts dry cleaners each year, and a reduction inwastewater discharges of silver by 99 percent fromphoto processors. Increased compliance is alsoanticipated to yield significant reductions in the useof smog-forming solvents and alcohol used by com-mercial printers.

The Weyerhaeuser project’s self-certification hasbeen underway since 1997, and the company re-ports that it continues to meet and exceed all of theenforceable discharge levels in the NPDES per-mit. Weyerhaeuser’s records on the required sam-pling and analysis are also more accessible to thepublic as all information is available upon requestdirectly from the facility.

Transferability: The Massachusetts DEP andWeyerhaeuser projects are testing alternativemechanisms that enhance accountability while pro-viding flexibility. In particular, Massachusetts DEP’sERP approach has been designed to increase sec-tor understanding while focusing limited resources

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where they will make the biggest difference (awayfrom permitting and toward outreach for compli-ance assurance and technical assistance and siteinspections targeted against non-reporters and vio-lators). With Massachusetts DEP expanding thisapproach to other sectors, the ERP approach willcontinue to serve as a test bed to explore opportu-nities for expanding self-certification and perfor-mance standards.

The extent to which the ERP approach will provetransferable in practice will depend in large part onthe ability to measure and document the anticipatedresults of the project. Three potential opportunitiesfor transferability are being investigated. (1) De-velopment of a “tool kit” and communications ma-terials could help expand the availability ofinformation about the benefits and limitations of theERP program as program data become available.(2) Sectors have already expressed an interest inparticipating in innovative programs and could beinterested in participating in a self certification pro-gram if it could provide them with reduced burdensor regulatory flexibility. (3) The concentration oflarge and small businesses in certain geographicregions may provide an opportunity to address sec-tor- or place-based issues on a local level.

Predictive Emissions Monitoring

The Experiment(s): The International Paper (IP)predictive emissions monitoring (IP-PEM) projectis seeking to develop, test, and implement a sophis-ticated, computer-based, alternative emissions moni-toring system that can accurately predict pollutantemissions on a continuous basis at IP’s Jay, Maine,pulp and paper mill. IP will replace stack testingand the continuous emissions monitoring (CEM)system on the mill’s waste fuel incinerator (WFI)with a predictive emissions monitoring (PEM) sys-tem. The PEM system would be a computer-gen-erated model that would predict air emissions (PM,SO

2, NO

x, CO

2, and CO) from WFI operations on

a continuous basis. A PEM system would providereal-time feedback and would allow IP to makeoperational adjustments when predicted pollutantemissions approach permitted limits. IP is alsomaking a voluntary commitment to maintain itsemissions from the WFI at a level equal to or less

than 90 percent of its license limit once the PEMsystem is implemented.

The IP waste fuel incinerator produces steam fromthe combustion of fossil fuel, wood residue,papermill sludge, and waste paper. CEM systemsare required for SO

2 and NO

x emissions from the

WFI, but currently, WFI PM emissions are subjectonly to annual stack tests. Development, testing,and implementation of a computer-generated PEMsystem will determine if IP can predict emissionsfrom a complex, saturated stack on a continuousbasis. Current stack testing and CEM systems aredesigned to record compliance and noncompliancewith permit limits when a violation occurs. Theydo not provide an opportunity to prevent or loweremissions at the time of measurement. A success-ful PEM system would allow IP to be proactive,correlating the relationship between operating pa-rameters and emissions, enabling the facility to pre-dict emissions in advance and adjust their operationsprior to exceedances actually occurring.

To fully develop the computer model, the IP-PEMproject has the flexibility to allow a number of short,controlled exceedances above the current WFIemission limits to formulate the model’s emissionprediction capabilities. The exceedances would beneeded for model development, since, unless themodel was programmed to identify the operatingconditions which caused an exceedance during atest, the PEM system would be unable to accu-rately predict such a situation should it arise duringregular operations.

Results/Anticipated Outcomes: The IP-PEMproject seeks to provide assurances of pollutantemissions compliance on a continuous basis. Anypermitted exceedance granted for computer modeldevelopment will be agreed upon beforehand andwill be limited to days when the potential to exceedambient air quality standards would be minimal.Successful development of a PEM model wouldprovide continuous information on particulate emis-sion rates for sources that, to date, have had nofederally approved methods to monitor PM on acontinuous basis from saturated stacks. If the PEMsystem is successful for PM, a State Implementa-tion Plan amendment could allow the system to be

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approved for continuous monitoring of all types ofemissions from the WFI. A successful PEM sys-tem will optimize operational efficiency while re-ducing facility emissions. Traditional monitoringtechniques measure emissions but do not provideinformation on the operational parameters that af-fect those emissions or information on how to re-duce those emissions. The PEM system would helpoperators better correlate emission rates and theoperational processes that effect them. The sys-tem would identify statistically significant operat-ing parameters and use them to predict emissionlimits. Data from the PEM will be made availableto the local public via IP’s Web site.

The accuracy and precision of the PEM systemwill be determined through a formal validation testdeveloped by the EPA Office of Air Quality Plan-ning and Standards. If preliminary estimates proveaccurate, transferability may prove to be no prob-lem. Due to improved efficiency, IP is anticipatingfuel savings that could surpass $200,000 per year.

Transferability: The IP-PEM project offers thepotential for technology transfer to other emissionsources at the IP facility as well as to other facili-ties. PEM systems have previously been developedfor simple stacks and gas-fired boilers, but havehad very limited application for complex stacks withhigh moisture content. This project will help dem-onstrate if this technology can be transferred to“complex” boilers, kilns, and incinerators. PEMsystems can provide a meaningful linkage betweenemission rates and the operational parameters thataffect them and could have application for othersources of pollution or operations seeking to opti-mize operation controls while reducing emissions.PEM systems-generated information can be usedby operators to decrease emissions while maximiz-ing production.

Environmental Business Practice Indicators

The Experiment(s): As part of its ERP, Massa-chusetts DEP has developed EBPIs, in collabora-tion with EPA and industry, to evaluate theperformance of three industry sectors—dry clean-ers, printers, and photo processors. EBPIs will playa key role in the evaluation of ERP. EBPIs areindustry-specific performance measures that pro-

vide a snapshot of a facility’s environmental per-formance. The concept is to “benchmark” facility/sector performance and potentially shift complianceassurance strategies based on how EBPIs trackcompliance and beyond compliance activities.

The use of EBPIs rather than traditional “singledimension” measures of compliance (e.g., in com-pliance, out of compliance, significant noncompli-ance) allows regulatory agencies not only to lookat compliance more comprehensively and on anannual basis, but also to recognize and potentiallyencourage “beyond compliance” strategies for in-dustry leaders. The number of EBPIs developedfor each sector is different. Printers have 16 EBPImeasures (including nine pollution prevention-spe-cific measures), dry cleaners have 16 EBPI mea-sures, and photo processors have eight EBPIs. Thenumber is based on the complexity of the industryand the number of multimedia discharges. Currently,beyond-compliance and pollution prevention oppor-tunities are being tracked only for printers.

Sector-specific EBPIs can serve as a validationmeasure for sector-wide environmental perfor-mance. Massachusetts DEP is using EBPIs, alongwith random inspection findings and data reportedon facility’s annual certification forms to measureand evaluate ERP results. In establishing a sector-specific program, Massachusetts DEP uses fielddata and statistical methodology to calculate an in-dustry-wide EBPI score “before” program startup,comparing this with “after” participation scores todetermine the accuracy of the certification dataand to calculate an industry-wide compliance rate.Rather than inspecting each ERP facility to estab-lish a baseline understanding of the regulated uni-verse, the Agency has used statistics to determinethe appropriate number of facilities to inspect. In-spection data from these facilities were also usedto compare information supplied by those firms’annual certification forms to determine overall cer-tification accuracy based on statistical analysis.

Results/Anticipated Outcomes: In a demonstra-tion program under MP2 (Massachusetts PrintersPartnership) in 1995-1996, Massachusetts DEPused EBPIs to evaluate the performance of theMP2. Together with key stakeholders, Massachu-setts DEP identified 19 different EBPIs, including

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regulatory requirements, pollution prevention tech-niques, and good environmental management prac-tices for MP2 participants. DEP staff performedinspections at randomly chosen facilities both be-fore and after program startup and used data fromthese inspections to calculate an industry-wide “be-fore” EBPI score as well as two “after” scores—one for printers that joined the MP2 by certifyingcompliance and one for those that did not. Massa-chusetts DEP used these data to determine if therewas a statistical difference between those printersenrolled in the MP2 as compared to those who werenot. Comparing EBPI scores, Massachusetts DEPfound that the scores—and hence the environmen-tal performance—of MP2 participants were 50percent higher than the score of the “before”sample as well as those printers not certifying forthe program.

For ERP, EBPI measures include using low VOCcleanup solutions (printers), degree of silver recov-ery (printers and photo processors), perc recovery(dry cleaners), and other pollution prevention mea-sures for printers. Massachusetts DEP is usingEBPIs to measure and evaluate the results of theERP approach, and while results are still forthcom-ing, preliminary findings have been positive.Baseline data collected during random inspectionsbefore the first round of certification has been com-pared to data collected during random inspectionsafter certification and outreach under ERP. Forphoto processors, preliminary EBPI evaluation hasrevealed an increase in aggregate EBPI score fromthe before baseline score (5.7 to 7.1), indicating anincrease in compliance for the sector. For dry clean-ers, the aggregate EBPI score remained constant,but there was a statistically significant increase.Additionally, the dry cleaning sector did exhibit asmall increase in aggregate score for all certifica-tion questions (not just EBPI questions) after pro-gram implementation. In addition to calculatingsector-side scores, DEP has sought to measure theoverall level of accuracy of the certification databy comparing data collected during random inspec-tions after ERP certification with data presentedon the certification forms of those facilities. Al-though compliance is a single point in time, initialanalysis of dry cleaners in ERP has revealed agree-ment between certification forms and state inspec-tions 76 percent of the time. By measuring

compliance rates by firm, sector, media, and com-pliance requirement, DEP anticipates being able tofocus its scarce resources for compliance assis-tance and inspections based on how EBPIs tracksector-specific performance measures.

Transferability: Given that the EBPIs are spe-cific to each industry, it is too early to determinebroader sector-wide applicability. Nevertheless, theuse of EBPIs rather than the traditional “single di-mension” measures of compliance (e.g., in compli-ance, out of compliance, or significantnoncompliance) not only allows regulatory agen-cies to look at compliance more comprehensivelybut it also offers the opportunity to recognize andpotentially encourage beyond compliance tech-niques for industry leaders. Massachusetts DEPhas already agreed to expand its ERP effort to twoadditional, cross-sector activities—firms discharg-ing industrial wastewater (the industrial wastewa-ter sector) and firms installing or modifying boilers(the combustion sector). Massachusetts DEP esti-mates that the addition of these new sectors couldquadruple the number of Massachusetts facilitiesthat ERP could impact. This would provide an evenmore comprehensive database of EBPIs and wouldenable further evaluation of this innovative perfor-mance measurement and tracking system.

It is important to recognize that in an effort to ex-pand the scope of measurement of sector and fa-cility performance characteristics, new informationon the sectors or facilities may be required to begenerated and/or collected. The potential exists forsuch efforts to conflict with simultaneous effortsto reduce the amount of recordkeeping and report-ing required by regulated entities. DEP’s experi-ence in this regard could prove helpful in futureefforts to balance these sometimes competing goals.

Alternative Compliance Flexibility underEmissions Cap

The Experiment(s): Emissions caps provide an in-centive for a site to minimize emissions to ensurecompliance and to preserve a sufficient marginunder the cap to accommodate growth. Merck’sStonewall Plant criteria pollutant cap has been con-structed so that the facility has the ability to makemany common changes at the site without prior

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approval from the permitting authority. A uniqueaspect of this project is that Merck also has theflexibility to reduce their emissions cap instead ofdirectly complying with a newly applicable criteriapollutant regulation. Specifically, when the Stone-wall Plant becomes newly subject to a regulation,they may choose to comply with the regulation di-rectly or reduce their criteria pollutant cap by theamount of emissions reduction expected from di-rect compliance. Thus, to achieve compliance witha new air pollutant regulation, the plant may installnew control equipment and maintain the existingfacility-wide criteria pollutant limit or they may keepthe existing equipment and establish a permanentreduction in their emissions cap. Figure 1 providesa graphic depiction of this alternative compliancemechanism. Only regulations addressing one ormore of the criteria pollutants covered by the emis-sions caps (i.e., CO, VOCs, SO

2, PM-10, and NO

x)

can qualify for this alternate compliance mecha-nism. For example, a new rule establishing emis-sion standards for VOCs from storage tanks wouldqualify; however, if the purpose of the rule was tocontrol HAPs, alternate compliance via cap ad-justment would not be available.

forts on finding emission reductions in the most cost-effective manner, rather than attempting to achievecompliance through a generic “one size fits all” ap-proach or the mandated installation of air pollutioncontrol equipment.

Transferability: The flexibility offered to Merckunder this emissions cap adjustment scenario isrelated to their site-specific prevention of signifi-cant deterioration permit. Similar opportunities forflexibility under an emissions cap are possible basedon site-specific conditions. Merck’s ability to oper-ate its Stonewall facility in this manner representsan approach that may be applied to other plantswho are facing similar business issues.

Major Source Emissions Tiered ComplianceTesting

The Experiment(s): The Weyerhaeuser projectprovides an alternative approach for tiered compli-ance testing of major source emissions under thefacility’s modified air quality permit. This modifiedpermit grants compliance testing flexibility for thefacility’s major source emissions (generated by thepower boiler, recovery boiler, smelt dissolving tank,and calciner). For these major sources at the facil-ity, the tiered compliance testing requirements be-come more rigid as the major source emissionsconverge on the emissions limit. The four tiers ofcompliance testing have been established, governedby the specifications shown in Table 13.

This tiered approach provides an incentive to con-trol major source emissions at the facility thus re-ducing compliance testing frequency.

Results/Anticipated Outcomes: Using this tieredperformance testing approach, Weyerhaeuser hasreduced costs and analyses by eliminating repeti-tive compliance tests for pollutants that are moni-tored continuously. Process improvements andenergy use savings may also help further curtailboiler usage and reduce emissions, leading to a re-duced compliance testing burden. Compliance test-ing is currently performed annually—this is due tothe need to conduct testing for other pollutant emis-sions under the Pulp and Paper Cluster Rule—butit is expected that increased control of future emis-sions could lead to compliance testing every threeyears.

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New criteriapollutantregulation

Reduction inemissions

Install newcontrol equipment

Keep existingequipment

Maintain facility-wide cap limits

Reduce facility-wide cap limits

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Results/Anticipated Outcomes: This cap adjust-ment and regulatory compliance scenario is basedon the premise that facilities operating under anemissions cap practice “up-front” compliance tofuture rules that would require emission reductions.Merck’s commitment, for example, to convert thesite powerhouse from burning coal to natural gasallows the facility to offer an environmental ben-efit in advance of any regulation. This is becausethe cap adjustment “locked in” a portion of the re-ductions from that project, preventing the site fromincreasing its emissions back to the cap level priorto adjustment. This approach focuses facility ef-

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Transferability: The opportunity to use this ma-jor source emissions compliance test flexibility wasprovided under the dual emission cap system in-corporated into the Flint River modified air qualitypermit. Other facilities that face comparable cir-cumstances could benefit from a similar compli-ance-based, tiered approach designed to achievecriteria pollutant emissions reductions. This provi-sion of a facility-wide permit modification may alsohave the potential to influence other Agency per-mitting initiatives. This project will also present anopportunity to analyze how state air pollution moni-toring and reporting requirements can be coordi-nated with federal compliance testing flexibility toensure compliance while achieving superior envi-ronmental performance.

Gasification of Pulping Liquor UnderMACT II

The Experiment(s): The Georgia-Pacific Big Is-land, Virginia, pulp and paper mill is seeking to dem-onstrate a new recovery technology under section112 of the CAA. The Big Island facility, a semi-chemical mill, is subject to the air emissions re-quirements of the Pulp and Paper Cluster Rule ofthe CAA, which requires the installation of maxi-mum achievable control technology (MACT). Asecond MACT standard (MACT II), applicable topulp and paper mills, was proposed in 1998 specifi-cally to address emissions from combustion sourcesassociated with the recovery of pulping chemicals.The recovery process is an integral component of

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Monitoring Results Testing Frequency

When parametric monitoring has shown that Major source compliance testing will be performed everycontrol of emissions are less than 25 four yearspercent of the allowable limit

When control of emissions are greater than 25 Major source compliance testing will be performed everypercent and less than 50 percent of the three yearsallowable limit

When control of emissions are greater than 50 Major source compliance testing will be performed everypercent and less than 75 percent of two years.the allowable limit

When control of emissions are greater than Major source compliance testing will be performed75 percent of the allowable limit annually

mill operations. Chemicals used in the pulping pro-cess are recovered and spent liquor organic solidsare converted to energy (process steam). Currently,the mill takes spent liquor (black liquor) from woodpulping, reduces its water content through an evapo-ration train, and combusts the resultant concentratedliquor in two smelters (type of recovery furnace).The smelters recover sodium carbonate from amolten smelt that is then dissolved in water to pro-duce new pulping liquor.

MACT II does not specify a particular technologyto meet the emission standard. However, to com-ply with the proposed standard, the current Geor-gia-Pacific system would require a substantialupgrade. Georgia-Pacific would have to either (1)upgrade these smelters and add additional controldevices or (2) replace the smelters with a new re-covery boiler that uses conventional technology. Asan alternative, Georgia-Pacific has proposed install-ing a black liquor gasification system to recoverpulping chemicals. The current smelter recoveryfurnace would be replaced with a PulseEnhancedTM

Steam-Reforming chemical recovery system.9

Under this alternative system, organics from theconcentrated spent liquor would be pyrolyzed to ahydrogen rich fuel. In turn, this fuel would be burnedas an energy source for the gasification unit and as

9The PulseEnhancedTM Steam-Reforming gasification systemwas developed by StoneChem, Inc. The process produces anendothermic reaction converting black liquor organics to a gasin the absence of air or oxygen at temperatures below thoserequired for smelt formation.

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elsewhere in the Big Island facility. Sodium bicar-bonate pellets would be recovered during this pro-cess for reuse in fresh pulping liquor.

Recognizing that the existing smelters would notmeet the performance standard of the proposedMACT II, Georgia-Pacific sought regulatory flex-ibility in working to bring the gasification technol-ogy on line. Given that this technology iscomparatively new, Georgia-Pacific pursued anextension to operate the existing smelters or con-ventional recovery boiler for a set period of timepast the MACT II compliance date (once that dateis established). This flexibility would provide thefacility with additional time for commissioning or,in a worst case scenario, replacing a failed gasifi-cation system with a conventional recovery boiler.Georgia-Pacific also requested flexibility to usesteam generated by the new process in place ofsteam currently generated from a natural gas boiler.

Results/Anticipated Outcomes: The final projectagreement for the Georgia-Pacific project wassigned on May 31, 2000. The Big Island black li-quor gasification system would be the first com-mercial application of this innovative technology inthe United States. General benefits of this gasifi-cation technology are expected to include increasedenergy conversion and chemical recovery effi-ciency, elimination of the smelt-water explosionhazard, and lower emissions of criteria pollutants(PM, SO

2, NO

x, VOCs, CO) and HAPs. Georgia-

Pacific believes that use of this system will allowthe Big Island facility to reduce HAP emissionsbelow the proposed MACT II standard. Criteriapollutant emissions would also be reduced sincethe gasification system does not require auxiliaryfuel to maintain a stable liquor combustion as op-posed to a conventional recovery boiler. Such emis-sions reductions are attractive to pulp mills such asBig Island that use a semi-chemical non-sulfur pro-cess requiring auxiliary fossil fuel to combust blackliquor.

Transferability: This project offers the opportu-nity to demonstrate and analyze the energy con-version, safety, and environmental performancebenefits of a new technology. The Big Island millwill test the effectiveness of the PulseEnhancedTM

Steam-Reforming gasification technology in pro-viding full chemical recovery capacity for a semi-chemical mill. Other pulping facilities that facecomparable circumstances could benefit from asimilar approach to make their energy conversionsystems more efficient and less capital intensivewhile achieving emissions reductions. With the BigIsland facility similar in characteristic to 12 othermills in the United States, successful demonstra-tion of this technology could contribute substan-tially to its transfer and implementation at a largernumber of kraft mills. This technology could alsohave applications for the conversion of non-woodliquors, sludges, and agricultural wastes to energy.

Additionally, as the project proceeds, there will bea need to analyze the energy efficiency potentialof this technology in producing steam as abyproduct of the chemical recovery process, whichcan be used to offset steam generated with fossilfuels.

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Environmental stewardship is a way of identifyingand pursuing good business strategies that are con-sistent with environmental protection: choosing en-vironmentally benign raw materials; improving thefinancial and environmental efficiency of manufac-turing processes; and employing effective environ-

mental management systems (EMSs). The ultimatevalue of stewardship is deriving economic valuefrom environmental excellence. Recognizing theneed to promote environmental stewardship, EPArecently announced the National EnvironmentalPerformance Track to motivate and reward topenvironmental performance. Several states havetheir own programs as well. Also through ProjectXL, regulated facilities can further their commit-ment to stewardship approaches with pollution pre-vention, recycling, and EMSs.

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Project Media Innovation

Weyerhaeuser Multi-media Linking EMSs to Standard Operating Procedures: Link EMSs to facilityBerry standard operating procedures improving environmental performance.

Lucent Multi-media Multi-facility EMSs: Develop a company-wide EMS model that could beused at multi-facilities and involves stakeholders in the developmentprocess.

Crompton Multi-media Waste Minimization and Pollution Prevention Assessment: Facility basedreviews that inventory and suggest process-level pollution preventionapproaches for reducing environmental impacts and costs.

Weyerhaeuser Multi-media Timberland Resource Strategies: Non-point BMP and pollution prevention;incorporate forestry management best practices into facility-wide EMS.

New England Hazardous University Laboratory Pollution Prevention and Recycling: Erase theUniversities Waste distinction between unused chemicals and waste chemicals in laboratories;Laboratories support institutional recycling by managing all laboratory chemicals under

an integrated approach.

Intel Solid and Process Modifications and Waste Minimization: Continuous improvement DfEHazardous approach to encourage pollution prevention and waste minimization;

Waste incorporation of voluntary measures into management plan.

Vandenberg AFB Air Alternative Technological Solutions for Preventing Air Emissions: Resourcereallocation; test ways to reduce permit burdens at Federal facilities toencourage the use of pollution prevention and innovative technologies.

USPS Denver Air Flexible Fuel Vehicle Replacement: USPS will eliminate 794 delivery vehiclesfrom the Denver area and replace them with lower-emitting flexible fuelvehicles. USPS Denver will earn mobile source emission credits.

Progressive Air Testing Incentives for Pollution Prevention in Mobile Sources: Unique voluntaryinsurance program that will base automobile insurance rates on specificdriving factors such as mileage driven, time of day, and geographiclocation. This should be an incentive to reduce car travel, and thereforereduce mobile source air emissions.

Intel Water Partnership for Water Reclamation and Reuse: Unique partnership with a localmunicipality to reuse treated city wastewater and reclaim manufacturingprocess wastewater and reinject into local aquifer.

NS Mayport Water Dredged Material Pollution Prevention Opportunities: The Naval StationMayport is seeking to examine and demonstrate innovative and beneficialreuse of dredged material.

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Pollution prevention and recycling provide multiplepathways to sustainable development and environ-mental stewardship. EPA has defined pollution pre-vention as “source reduction” (which is explainedunder the 1990 Pollution Prevention Act) and pro-tection of natural resources through conservationor increased efficiency in the use of energy, water,and other materials. Recycling shares many of theadvantages of pollution prevention; it can reducethe need for treatment or disposal and conserveenergy and natural resources. Many facilities usea broad definition of pollution prevention that in-cludes recycling.

An EMS applies standard business principles to themanagement of an organization’s environmentalissues. An EMS does not determine a company’slegal obligations; rather, it is a sophisticated toolused by companies to manage compliance andother environmental concerns. An EMS can help acompany boost efficiency, cut waste, and improveworker safety. It also can bring attention to envi-ronmental matters that are not directly addressedthrough regulation, such as energy use.

Table 14 identifies several projects that are testingEMS, pollution prevention, and recycling optionsthat demonstrate these facilities’ commitments tosustainable development.

Linking EMSs to Standard OperatingProcedures

The Experiment(s): Weyerhaeuser is striving tominimize the environmental impact of its manufac-turing processes on the surrounding environmentby pursuing a long-term vision of its Minimum Im-pact Mill. Weyerhaeuser has voluntarily institutedan EMS at the Flint River facility that conforms tothe International Standard Organization (ISO)14001 standard. The EMS will include operationalprocedures, record keeping, auditing, quality assur-ance, and permit requirements. Weyerhaeuser isalso developing a comprehensive manual of stan-dard operating procedures for plant employees. TheBerry project had also committed to using an EMSbased on ISO 14000. The project was designed totest the EMS approach as a means of promotingcontinuous improvement in environmental perfor-mance, pollution prevention, and source reductionstrategies.

Results/Anticipated Outcomes: For Weyer-haeuser, the overall process of developing ISO14001 documentation originally was scheduled forcompletion in mid-1997. Due to a company focuson other aspects of the Minimum Impact Mill vi-sion, documentation has proceeded slower thanexpected and is now scheduled for completion latein 2000. For Berry, the work on the EMS itself hadnot begun before the project ceased implementa-tion; the company had intended for the standardoperating procedures and work instructions devel-oped for the potential comprehensive operatingpermit to be compatible with ISO 14000. BothWeyerhaeuser and Berry believe that the strate-gies they have used to develop the EMSs have re-sulted in a more environmentally aware workforce.For example, in 1997 Berry reported that develop-ing the standard operating procedures and workinstructions helped the company reduce the cost oftraining and improved day-to-day compliance byfocusing on how employees should perform theirspecific job responsibilities. Weyerhaeuser reportedin 1998 that engaging their employees in the imple-mentation of the revised EMS had begun to increasestaff education and awareness of the environmen-tal aspects of their jobs.

Transferability: When the implementation of theWeyerhaeuser project is further along, EPA plansto evaluate the benefits and challenges of the EMSapproach. EPA will look to work with Weyerhaeuserpersonnel to collect data assessing the improve-ment in day-to-day compliance with environmentalregulations attributable to the EMS. This will assistEPA in meeting a charge by the 1999 InnovationsTask Force to report, by 2002, on the use and ef-fectiveness of EMSs in improving environmentalperformance and achieving results. Also, on March12, 1998, EPA issued a policy statement in the Fed-eral Register,10 describing a number of pilot projects,including Project XL, which will provide data onthe actual compliance and environmental benefitsof EMS approaches. The Federal Register Noticedescribes how a group of Federal and state offi-cials involved in EMS pilot projects have beenworking together to set up a common national da-tabase of information gathered through the pilotprojects. As part of that process, EPA and states

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10 Federal Register: March 12, 1998 (Volume 63, Number 48,Page 12094-12097).

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developed a series of data protocols that provideinstructions and survey instruments to guide theactual collection of data for the database. Futureanalysis of the Weyerhaeuser project also will bedesigned to support the EMS database.

Multi-facility EMSs

The Experiment(s): The Lucent project testswhether a corporate EMS can be the basis forstreamlining the implementation of state and Fed-eral regulations, consolidating permits, and improv-ing Lucent’s facilities’ day-to-day compliance. Thegoal is to have more cost-effective systems thatraise facility managers’ awareness of their envi-ronmental obligations before they make decisionsabout modifying equipment and operations (ratherthan at the end of a long, expensive regulatory orpermitting process) and allow regulators to focusmore on compliance assurance and technical as-sistance. Table 15 below describes the project ap-proach and goals.

Results/Anticipated Outcomes: Specific resultsfor the Lucent project are not yet available. TheFPA for the Lucent project is an “umbrella” agree-ment and is based on an existing, third-party-certi-fied ISO 14001 EMS for the entire, global

microelectronics business unit of Lucent Technolo-gies. The FPA contemplates the development ofspecific proposals for regulatory flexibility and su-perior environmental performance at individual fa-cilities. The umbrella FPA outlines a process thatallows Lucent to use its EMS as a framework fordeveloping facility-specific proposals to simplify per-mitting, recordkeeping, and reporting requirements,while driving continual improvement and pollutionprevention programs.

Transferability: The EMS Federal Register No-tice states that it is critical to measure any changein a facility’s environmental performance that mightbe attributable to implementation of an EMS. ProjectXL can collect information on types, amounts, andproperties of regulated and nonregulated pollutantsthat are reduced as a result of an EMS. In particu-lar, the Lucent project will be able to provide thisinformation on a multi-facility basis. EPA’s EMSFederal Register Notice also states that Federaland state regulators are interested in understand-ing the involvement of local communities and otherstakeholders in the EMS process. The Lucentproject can collect data to assess the amount anddegree of stakeholder and regulator participationin both the development and implementation of anorganization’s EMS, and the effect that participa-

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To develop site-specific flexibilities that would leadto superior environmental performance andimproved environmental management at eachLucent facility.

The ultimate goal is to use the EMS as a platformfrom which the company can, over time, consoli-date all Federal and state permits for its domesticfacilities into a single companywide multi-mediapermit. This permit would be based on objectivesand targets set annually and jointly by the companyand regulators. Involving regulators in this EMSapproach would result in a de facto annual review ofthe permit, eliminating multiyear renewals ofindividual permits.

Develop a third-party-certified, high-quality EMSframework that can be used to:

• identify significant, site-specific regulated andnon-regulated activities, substances, or processessuch as water usage, wastewater discharge, airemissions, energy usage, chemical consumption,raw material consumption, and land use thatinteract with the environment;

• set and achieve site-specific performance goalsfor reducing environmental impacts; and

• ultimately, integrate critical information andperformance goals into a single, companywidematrix that facilitates understanding andaccessibility for stakeholders, assists in measur-ing performance and accountability, and poten-tially serves as the core of a companywideconsolidated permit.

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Approach Goals

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tion has on the public credibility of the facility’sEMS implementation. EPA plans to evaluate thebenefits and challenges of these EMS approachesdesigned to support the Innovations Task Forcereport and the goals of the EMS database.

Waste Minimization and Pollution PreventionAssessment

The Experiment(s): The Crompton (formerlyWitco) project conducted a comprehensive wasteminimization/pollution prevention (WM/PP) studyfor its Sistersville, West Virginia, facility. The fol-lowing focuses on this WM/PP study andCrompton’s commitment to methanol recycling.

Instead of occurring as a single event outside thepurview of routine business operations, theCrompton WM/PP study was an employee-driveneffort that sought to identify and integrate pollutionprevention approaches into the company’s standardoperating practices using a third-party contractorto conduct the study. The WM/PP opportunity as-sessment facilitated employee involvement in theprocess and implemented an approach tailored tothe specific needs of the facility. Crompton used amultiphased process to conduct the study: (1) iden-tifying and characterizing plantwide wastes andemissions, (2) screening and prioritizing thesewastes and emissions, (3) identifying pollution pre-vention options, (4) screening and prioritizing pollu-tion prevention options, (5) examining the technical

and economic feasibility of these options, and (6)developing an implementation plan.

A WM/PP study team (made up of Cromptonmanagement and employees and an independentcontractor, STV Incorporated) was established toguide and conduct the daily activities of the WM/PP Study. Employee brainstorming sessions werea key component of this process. These sessionsincluded representatives from a cross-section ofthe plant’s technical and operating staffs. In addi-tion, an advisory committee was established to of-fer comments and suggestions throughout the studyprocess. Through the use of this advisory commit-tee, Crompton involved EPA, West Virginia DEP,the International Chemical Workers Union Coun-cil, and other stakeholders in the study phase of theWM/PP Project.

Another aspect of the Crompton project is the com-mitment to recycle methanol. Previously, excessmethanol produced in Crompton’s Sistersville fa-cility was condensed, collected, and either disposedof in the facility’s wastewater treatment unit or in-cinerated. Under the project, Crompton is reusing,recycling, or thermally treating 95 percent of thecollected methanol. This will minimize thebiotreatment of methanol in the facility’s waste-water treatment units and reduce sludge genera-tion. Table 16 describes the project approach andpotential savings from the Crompton project.

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Crompton Waste Minimization/Pollution Prevention Study Potential Cost Potential WasteSavings Emission Reductions

One-time pollution prevention $ 42,000 26,000 poundsoptions—completed in 1998

Project air emissions reduction and $ 16,000 per year 1,100,000methanol recycle (excludes capital savings). pounds per year

Other pollution prevention options in $620,000 per year 730,000progress or put in place July 1998–June 1999. pounds per year

Total savings $640,000 per year 1,830,000pounds per year

Expected

recurring/

ongoing

savings

*Crompton has not yet assigned the expense of implementing these projects, and when it does the net cost savings will be less.

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Results/Anticipated Outcomes: A final reportwas published in December 1998 as a result of theWM/PP study. This report laid out 330 pollutionprevention options that were determined to be tech-nologically and economically feasible. Crompton’sAnnual Project XL Report (July 31, 2000) lists atotal of 370 pollution prevention opportunities thathave been identified. Of these, 26 are at some stageof study and 67 have been implemented. Table 16is a summary of some of the potential cost savingsand potential waste or emissions reductions to begained by the pollution prevention options identi-fied by the Crompton WM/PP study.

The most promising identified opportunities are re-viewed and selected by an internal Pollution Pre-vention Council, which was established in 1998 asa result of the WM/PP study. The Pollution Pre-vention Council, representing many plant functions,meets monthly. Council members choose the mostpromising opportunities identified in the final reportto pursue, including options originally deemed notfeasible, as well as offering other ideas. The Pollu-tion Prevention Council maintains an “evergreen”list of ideas—a list of prioritized waste problemsalong with a list of pollution prevention projects thathave been proposed to resolve those problems—which are reviewed at each monthly meeting.

As a result of the Crompton methanol recyclingeffort, the amount of sludge generated by the waste-water treatment system and disposed of in an on-site hazardous waste landfill will be decreased byabout 815,000 pounds per year.

Transferability: The Crompton project approachtoward pollution prevention and recycling may of-fer an innovative model for other chemical inter-mediate-product manufacturers. Some pollutionprevention approaches can be implemented throughmodifications to existing standard operating proce-dures combined with careful training on the newprocedures and follow up to ensure those proce-dures are carried out. Involving facility-level per-sonnel “up-front,” even in the development of theprocess itself, has proven valuable and could haveapplication at other facilities. Including a broadspectrum of employees representing many plantfunctions has helped to instill a facility-level culturein which individual employees are trained and em-

powered to continuously identify and implementnew pollution prevention opportunities and strate-gies. This approach has required a clear manage-ment commitment on the part of Crompton tocommit resources and institute technically and eco-nomically feasible pollution prevention measures.

Timberland Resource Strategies

The Experiment(s): Weyerhaeuser manages over300,000 acres of timberland in Georgia, with im-pacts on more than half of the river basins in thestate. As a component of the Weyerhaeuserproject’s Minimum Impact Mill vision and as ameans to further protect the Flint River, neighbor-ing wildlife habitats, and unique parcels on its for-est land, Weyerhaeuser has undertakenmanagement changes to enhance its Forestry Man-agement System. These methods are expected toimprove water quality and wildlife habitat, soil sta-bility and increase soil productivity while sustainablyproducing wood and forest products. Weyerhaeuserhas incorporated its forestry management strate-gies into the Flint River facility-wide EMS.Weyerhaeuser is also engaging in cooperative ef-forts to ascertain how company forest lands cancontribute to the conservation of threatened andendangered species.

Results/Anticipated Outcomes: The modified For-estry Management System has produced a moreholistic view of the forest management approachesapplied to the forest lands serving the Flint Riverfacility. It has shifted forest management from aremediation, reactionary approach to a more pro-active, continuous improvement one (see Table 17).Time formerly spent on remediation of roads andstreams and other impact abatement activities isnow spent on process improvements and preven-tive measures.

Transferability: Weyerhaeuser’s Forestry Man-agement System offers a framework for other fa-cilities that are seeking to integrate their forestrymanagement strategies into a facility-wide EMS.It also offers an effective model for the incorpora-tion of responsible practices and a continuous im-provement approach into forest management forthose facilities that rely on a consistent, high-qual-ity source of wood and wood-related products. In

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addition, the project provides the opportunity toexplore how performance and management objec-tives and principles can serve as leverage pointswith vendors and contractors.

Variability in environmental performance in the for-est products industry could serve as a potential bar-rier to broader scale transfer and application of anenhanced forestry management system.Weyerhaeuser manages its operations to reduce

the ecological footprint of the Flint River facility.Compared to similar pulp and paper operations, theFlint River facility produces only 10 percent of theair emissions and uses only 20 percent of the for-est land needed for an equivalent unit of produc-tion. Diversity of forest types and growth ratesacross the country and differing forest land man-agement desires and systems could also impact theapplicability of a timberland resources strategy.

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Improvements have been seen in:

Water quality—through reduced sediment loading and enhancement and establish-ment of riparian zones (aquatic habitat benefits as well).

Soil stability—through better management and planning of roads, site preparationprior to harvesting. There are approximately 500 miles of roads managed by thisfacility; historically approximately 20 miles of road a year needed repair. With carefulplanning of new roads and retirement of older roads, less remediation has beenneeded, thus soil erosion into streams has been reduced.

Identification and management of forestland wildlife habitats.

Weyerhaeuser has worked to integrate the forestry management system into thefacility-wide EMS. The Flint River facility’s total quality management system is ISO9000 certified and the facility has implemented an EMS that complies with the ISO14001 standard, although the facility is not ISO 14001certified at this point.

Weyerhaeuser supports and applies principles of the Sustainable Forestry Initiative(SFI) and expects that its contractors meet SFI principles and objectives as well toensure timber coming to the plant has been grown and harvested using responsibleforestry practices.

The forestry EMS has been significant from a forest stewardship and sustainabilityperspective and has created economic benefits as well.

To broaden the application of responsible practices and sustainable forestry,Weyerhaeuser has taken a lead role in updating the forestry best managementpractices (BMPs) for the State of Georgia. Under the direction of the Georgia ForestryCommission, work was conducted with nonprofit organizations, governmentagencies and private landowners to develop comprehensive guidelines designed toimprove wildlife habitat and water quality in the state’s private forests.

Weyerhaeuser has undertaken other cooperative, outreach, and public educationactivities to empower landowners and other forest managers with the tools toadvance responsible forestry practices.

Weyerhaeuser’s forestry practices lead to forests that produce two to three times asmuch wood per acre as unmanaged forests. In addition to increased productivity,harvested sites are prepared for prompt reforestation. In 1998, over 78 percent of itsharvested lands were replanted within one year.

Forest strategies also seek to minimize waste during harvesting and to encourage theuse of other products from the forest.

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Forestry Management System

EnvironmentalPerformance

Internal Process

CommunityOutreach

ResourceManagementPractices

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University Laboratory Pollution Preventionand Recycling

The Experiment(s): The New England Universi-ties Laboratories project includes several provisionsdesigned to result in increased pollution prevention.One of the objectives of the laboratory environ-mental management plan (EMP) and the overallproject is to erase the distinction between unusedchemicals and waste chemicals in the laboratorysetting so that the value in reusing chemicals canbe realized. Thus, all laboratory waste in this projectwill be managed under a single standard in the labo-ratory. The determination whether a laboratorywaste can be reused within the university will bemade at a central accumulation facility within theuniversity by environmental health and safety pro-fessionals.

According to a 1996 survey of about 100 academicinstitutions by the Campus, Safety, Health, andEnvironmental Management Association, less than1 percent of the hazardous chemical waste other-wise destined for disposal was reportedly redis-tributed or reused on-site. Under this project, theparticipating universities will be able to more easilyfacilitate the reuse of chemicals on a university-wide basis. For example, chemicals that are nolonger of sufficient purity for use in a research labo-ratory could be used by teaching laboratories, or ifa researcher in one department no longer needscertain raw material chemicals, rather than dispos-ing of them as waste, these chemicals could beavailable to other departments in the university foruse. Waste reduction will be encouraged as a re-sult of the more comprehensive waste exchangesystems throughout the institution.

Results/Anticipated Outcomes: The New EnglandUniversities Laboratories project is expected toresult in increased pollution prevention. The par-ticipating universities have set specific pollutionprevention goals including a 10 percent reductionin the overall amount of hazardous waste gener-ated from participating laboratories (from thebaseline), and a 20 percent increase (from thebaseline) in reuse of laboratory waste over the lifeof the project. The universities will report each yearon their progress in meeting these goals.

One element of the Laboratory EMP is a require-ment to define a list of “hazardous chemicals ofconcern” and annually conduct a risk assessmentsurvey of these chemicals in the laboratory. Thislist will be developed on an institution-by-institutionbasis because the types of hazardous chemicals ata particular institution will vary with the type ofwork done there. This list will be reviewed on anannual basis and adjusted to ensure that it coversan adequate breadth of hazardous materials. Thisdocumented assessment will enhance both wasteand risk minimization efforts and move laboratorypersonnel/inspectors away from discussions as towhether a hazardous material on the shelf is aRCRA hazardous waste.

The proposed surveys will support institutionalchemical reuse and/or the timely disposal of haz-ardous chemicals that are approaching or haveexceeded their shelf life. The surveys will also docu-ment that hazardous chemicals of concern that re-main on the shelf have been assessed for productintegrity and risk to human health and the environ-ment.

Transferability: Laboratory waste managementcurrently accounts for the most substantial expensefor environmental, health, and safety (EHS) pro-grams at the participating universities. This projectis intended to allow these institutions to more ef-fectively promote and implement pollution preven-tion programs in their laboratories. It is intended toreduce waste disposal costs and reduce chemicalpurchasing costs without diminishing the level ofenvironmental protection associated with the properhandling and/or disposal of hazardous laboratorywastes.

The three participating universities are membersof the Campus Consortium for Environmental Ex-cellence (C2E2) originating in the New Englandgeographic region. As members of that Consor-tium, each participant strives to promote pollutionprevention and environmental performance moni-toring for laboratories. In addition, the participantsare seeking to continuously improve their labora-tory EHS programs. The lessons learned from thesepilots may be transferable to other C2E2 members,as well as other academic institutions, hospitals, andcorporations with extensive laboratory efforts.

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Sharing information about managing and minimiz-ing laboratory wastes and other environmental im-pacts will result in economic and social values forthe participants and distinguish them as leaders inthe EHS field.

Process Modifications and WasteMinimization

The Experiment(s): The Intel project seeks to mini-mize the use and generation of hazardous wastewhile exploring the value of incorporating non-regu-lated (voluntary) items into its EMP. While Intel isnot legally required to recycle the solid, hazardousand non-hazardous wastes generated at its Fab-12facility, it has committed itself to specific recyclinggoals. Notwithstanding its voluntary recycling tar-gets, Intel’s goal is to reduce the total amount ofhazardous waste generated and used at the facilityand to shift as much hazardous waste as possibleinto the non-hazardous waste category. To affectthis switch, Intel is applying a design for the envi-ronment (DfE) approach to its manufacturing pro-cess development. Intel develops new chip-makingprocesses every two years and incorporates envi-ronmental improvement into manufacturing pro-cesses through process and technology design andchemical screening. These process design and tech-nology improvements enable Intel to continuouslyrefine the management of its waste resources.Intel’s waste management goals will also reducethe impact of the Ocotillo facility on waste treat-ment or disposal facilities. Intel has committed toreport its waste recycling activities in its consoli-dated report to equip stakeholders with informa-tion to evaluate Intel’s progress toward attainmentof these recycling goals.

Results/Anticipated Outcomes: Through its de-velopment and implementation of more environmen-tally compatible manufacturing processes, Intel hasintegrated environmental considerations into itsdecision-making process to lessen the environmentalburden of waste generation at its Ocotillo facility.Intel is seeking to spur source reduction of hazard-ous waste use with an front-end manufacturingprocess design approach based on the DfE modelof continuous process improvement. This modelincorporates environmental improvement into pro-cess development before these manufacturing pro-

cesses are implemented at Intel facilities. The DfEapproach will (1) reduce the total amount of haz-ardous wastes used and generated during manu-facturing processes and (2) employ chemicalscreening to shift manufacturing processes towardsincreased use of non-hazardous materials. Thesematerials shifts complement one another, and Intelexpects that they will lead to a decrease in the per-centage of hazardous waste available for recyclingwhile increasing the percentage of non-hazardouswaste available for recycling. Intel is increasingthe amount of solid waste recycled by looking out-side the scope of typical solid waste streams at itsfacility. Intel’s progress towards attaining its recy-cling goals is outlined in Table 18 on the followingpage.

Transferability: Intel’s focus on using processdesign and development to drive source reductionand improve environmental management could haveapplications for other technologically dynamic firmsfacing comparable rapid evolution of manufactur-ing process technologies. The continuous improve-ment DfE approach offers a model of how up-frontconsideration of environmental goals can be incor-porated into traditional business decisions and prod-uct/process development cycles to achieve superiorenvironmental performance. The Intel project of-fers the opportunity to analyze (1) the value of in-corporating voluntary targets into an environmentalmanagement strategy, (2) barriers to effectivelyinterfacing environmental goals and process devel-opment to create environmentally compatible prod-ucts and processes, and (3) how chemical selectionprotocols might affect process design and reducethe amounts and toxicity of hazardous materialsused in manufacturing processes.

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Alternative Technological Solutions forPreventing Air Emissions

The Experiment(s): The Vandenberg AFB projectis testing new budgetary approaches that will al-low the DoD to spend resources on pollution pre-vention programs, innovative technologies, andother approaches that will cost-effectively reduceenvironmental impacts. The Memorandum ofAgreement established a framework for develop-ing ENVVEST11 pilot programs at three to fiveDoD facilities. The Vandenberg AFB in SantaBarbara County, California, was selected as thefirst DoD facility to pilot the ENVVEST programand implement cost-effective environmental pro-tection.

Through this XL/ENVVEST project, VandenbergAFB committed to upgrade ozone-precursor emis-

sion controls using resources that would otherwisebe spent complying with Title V of the CAA re-quirements, such as permitting, record keeping,monitoring, and training. When Vandenberg AFBreduces ozone-precursor emissions to agreed-uponlevels, its designation under Title V as a majorsource of ozone-precursor emissions (primarilyNO

x) will be reduced to a designation as a minor

source, resulting in a substantial reduction in airemissions and compliance costs for VandenbergAFB. Near term, obtaining reductions has focusedon boilers, furnaces, and process heaters.

Result(s): Vandenberg AFB has committed to re-ducing annual emissions of ozone precursors bytwo tons per year by April 30, 2000, and by ten ormore tons per year by November 30, 2002. NO

x

reductions will be accomplished by retrofitting orreplacing those boilers with the highest potentialfor emission reductions, and VOC reductions willbe accomplished by assessing the emission reduc-tion potential from solvents, surface coatings, andother VOC emission sources. To date, actual NO

x

emission data has been collected from nearly 30preselected candidate boilers to determine baselineemission levels and the potential emission reduc-tion resulting from a boiler retrofit/replacement

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Waste Minimization

Intel Goals Intel Progress

Hazardous 1997— recycle 60% of hazardous 1997—67% of hazardous waste recycledWaste waste generated

1999—recycle 50% of hazardous 1998—53% of hazardous waste recycledwaste generated2001—recycle 40% of hazardous 1999—65% of hazardous waste recycledwaste generated

Non- 1997—recycle 25% of non- 1997—58% of non-hazardoushazardous hazardous waste generated waste recycledChemical 1999—recycle 50% of non- 1998—49% of non-hazardousWaste hazardous waste generated waste recycled

2001—recycle 70% of non- 1999—78% of non-hazardoushazardous waste generated waste recycled

Solid 1997—recycle 40% of solid 1997—42% of solid waste recycledWaste waste generated

1999—recycle 55% of solid 1998—67% of solid waste recycledwaste generated2001—recycle 60% of solid 1999—67% of solid waste recycledwaste generated

11As part of the Administration’s reinvention initiative, EPAand DoD signed a Memorandum of Agreement in 1995 thatestablished how the two agencies would interact during imple-mentation of DoD’s Environmental Investment (ENVVEST)program. The ENVVEST program emphasizes regulatorycompliance through pollution prevention and provides analternative to prescriptive regulatory requirements through aperformance-based environmental management system de-signed to attain superior environmental results.

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project. Similarly, targeted VOC reductions willentail the application of low, and zero-VOC coat-ing substitutions for both architectural and corro-sion-control operations.

While the emissions reductions achieved by con-trolling emissions from the candidate boilers fellshort of the 10-ton goal, Vandenberg AFB hasevaluated alternative activities to help achieve thegoal. Activities include:

• using internal combustion engine control tech-nologies to reduce NO

x emissions from aero-

space ground equipment;

• replacing lawn mowers and other ground main-tenance and irrigation equipment that use in-ternal combustion engines with electricequipment;

• using zero-VOC paints and coatings in corro-sion control, industrial facility painting, and ar-chitectural interior and exterior coatingoperations;

• consolidating paint booth operations to includeapplication of corrosion control coatings to re-duce VOC emissions; and

• implementing an electric vehicle (EV) fleet pro-gram.

On August 25, 1999, Vandenberg AFB presenteda proposal to the Santa Barbara County Air Pollu-tion Control District for investing the balance ofENVVEST funds in an EV fleet pilot program. Thisprogram will help achieve the remaining reductionrequirements.

Transferability: The Vandenberg AFB project istesting ways to reduce regulatory burdens at Fed-eral facilities. Likewise, the Vandenberg AFB couldbe a model and benchmark for other DoD facili-ties. This innovative approach in applying resourcestoward high-priority environmental problems that,in turn, will result in lower costs and reduced envi-ronmental emissions from the facility, should offeruseful data for other DoD applications.

Flexible Fuel Vehicle Replacement

The Experiment(s): The United States Postal Ser-vice (USPS) Denver project will reduce its impacton air emissions in the Denver, Colorado, area byreplacing high-emission vehicles with low-emissionones. USPS has committed to (1) using at least794 new, alternative fuel vehicles in Denver and(2) helping support the development of an infra-structure to support these vehicles. As part of theColorado Environmental Leadership Program andProject XL, USPS will remove 794 delivery ve-hicles used in Denver and replace them with tran-sitional low-emitting vehicles (TLEVs). In exchangefor these commitments, the USPS will receive cred-its from the State of Colorado that can be used tosatisfy the vehicle purchase requirements of theColorado Clean Fuel Fleet Program (CFFP).

This delivery vehicle replacement project will re-duce the USPS’s contribution to mobile sourceemissions in the Denver area. While it is in theprocess of redesignating for CAA attainment, theDenver metropolitan area is currently innonattainment for CO. The CAA requires stateswith ozone and CO nonattainment areas to revisetheir State Implementation Plans (SIPs) to incor-porate a CFFP. Section 246 of the CAA providesthat a SIP submission must require fleet operatorswith ten or more vehicles that are or are capableof being centrally fueled, to include a specified per-centage of clean-fuel vehicles in their new vehiclepurchases each year. In the Denver area, compli-ance with the Colorado CFFP requires 50 percentof the new vehicle purchases to be low-emittingvehicles (LEVs).

USPS sought partial relief from Colorado’s CFFPrequirements. The State of Colorado is using theUSPS’s vehicle replacement actions as a substi-tute for the federally required Clean-Fuel VehicleProgram for the Denver nonattainment area. Inorder to qualify as a substitute program, all require-ments that USPS has agreed to will be made en-forceable through a SIP revision.

Results/Anticipated Outcomes: Delivery of thefirst group of vehicles is expected in October 2000.Due to the unique specifications needed for USPSdelivery vehicles, the only bid received for this pur-

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chase involved TLEVs, which would not meet LEVrequirements. TLEVs are capable of using unleadedgasoline with up to 85 percent ethanol (E-85) andmeet or exceed California TLEV certification stan-dards. Flexibility under the Colorado CFFP will al-low aging postal delivery vehicles to be replacedwith TLEVs. For each E-85 vehicle that the USPSdeploys in Denver, it has agreed to remove either apre-1984 route vehicle or a long-life-vehicle(LLV—1987-1991 vintage) from service in theDenver area. The USPS project commits to de-stroying 512 pre-1984 delivery vehicles and relo-cating 282 LLVs to other western cities where theywill replace aging fleet vehicles. The destructionand relocation of vehicles is planned for comple-tion by July 31, 2001. As each of the vehicles to bescrapped emits approximately 250 pounds moreCO

2 per year than an E-85 vehicle, this replace-

ment program is anticipated to significantly de-crease USPS’s contribution to mobile sourceemissions in the Denver metropolitan area.

USPS has developed technical specifications formodifying an existing underground storage tank toproperly house E-85 fuel. This modified under-ground storage tank will serve as a demonstrationproject for public evaluation of alternative fuel stor-age.

Transferability: The USPS project will replaceolder, higher-emission vehicles with new, lower-emissions flexible fuel vehicles (FFVs) and couldserve as a model for vehicle fleets across the coun-try. In addition, as the project proceeds, there willbe an opportunity to examine and evaluate the op-portunities and barriers in developing and maintain-ing an E-85 fueling infrastructure. The intent of theUSPS Western Area Flex Fuel Vehicle Plan is toconcentrate new FFVs in a small number of met-ropolitan areas across the western United States,concentrating FFVs at facilities within those ar-eas. An objective in this strategy by the USPS is topromote the development of a retail E-85 fuelinginfrastructure. Lessons learned from USPS devel-opment of an E-85 substructure could have appli-cation in the development of any alternative fuelinfrastructure.

Testing Incentives for Pollution Preventionin Mobile Sources

Experiment: The Progressive Auto Insurance(Progressive) project supports a unique voluntaryinsurance program that will base automobile insur-ance rates on specific driving factors such as mile-age driven, time of day, and geographic location, inaddition to more customary factors such as age,sex, and marital status. This new program is madepossible through the use of a global positioning sys-tem (GPS) device installed in customers’ vehicles.There are plans underway for a number of auto-mobile manufacturers to incorporate progressive’stechnology in their GPS units for new vehicles. Theinformation recorded by the device ensures thatthe cost of insurance is based on the usage of thevehicle. The focus of this project is an analyticalstudy that will determine the extent to which theProgressive program has an effect on environmentalquality. EPA is interested in determining the de-gree to which people who sign up for Progressive’susage-based insurance program reduce their totaldriving or their driving during congested periods,which could result in lower mobile source emis-sions. According to EPA’s Indicators of the Envi-ronmental Impacts of Transportation reportreleased in October of 1999, U.S. travel is respon-sible for a substantial portion of U.S. ozone pre-cursor emissions (31 percent of VOCs and 36percent of NO

x), 61 percent of nationwide CO

emissions, and 31 percent of CO2 emissions. Al-

though Progressive is not currently requesting regu-latory relief, if future analysis shows that the projectis environmentally beneficial, some alternativesmight be explored that will offer regulatory flexibility.

Anticipated Results: Progressive’s system, whichhas already been piloted in Texas, is designed notonly to lower costs for its customers, but also toencourage positive driving behaviors that may leadto a reduction in accidents and harmful air emis-sions. By measuring and integrating factors thatrelate to vehicular use into insurance rates, Pro-gressive is providing its customers with a financialincentive to drive less and choose alternate formsof transportation, which could reduce negative en-vironmental impacts from automobile usage. Thusfar, Progressive has not directly measured the en-

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vironmental impacts of this program. However, ifconsumers respond to the increased per mile costsof a usage-based insurance program in the sameway as they do to the variable costs associatedwith rising fuel prices, a significant reduction invehicle usage could result.

The possibility of offering SIP credits in those statesthat enable this program to move forward is onealternative for offering regulatory flexibility in thefuture. In 1997, EPA adopted a policy to allow creditin SIPs for Voluntary Mobile Emissions Programsdesigned to reduce emissions. The policy allows 3percent of the total reductions needed for attain-ment in a local or regional geographic area to befrom voluntary mobile source reduction programs.

Transferability Potential: As the Progressiveproject proceeds, it will analyze the extent to whichusage-based auto insurance can positively impactvehicle miles traveled and associated air qualityimpacts. This unique approach has already beenmade available in the state of Texas and could ben-efit other states concerned with transportation andair quality problems. Progressive has taken stepsto begin pilot programs in the states of Ohio, Illi-nois, and California. A potential difficulty involvedin expanding the program is the limited availabilityand high expense of GPS technology. Facilitatingthe retrofitting of GPS systems in older vehicles toenable participation in Progressive’s program isnecessary to ensure that the benefits extend toconsumers in all income brackets and that driversof older, more pollution prone vehicles can be re-warded for driving less. Expansion of the programwill also be dependent in part on the insurance regu-lations in specific states.

Partnership for Water Reclamation andReuse

The Experiment(s): The Intel project, an innova-tive partnership between the company and the Cityof Chandler, has created opportunities to (1) reusetreated city wastewater at the Intel facility for usein cooling towers and on landscaping (Figure 2)and (2) reclaim rinsewater used during manufac-turing processes for reverse osmosis (RO) treat-ment and reinjection into the local aquifer (Figure3). Intel needs high-quality water for semiconduc-

tor operations, thus the two water use streams arenot connected and are used in different processes.

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City of Chandler-Ocotillo WastewaterReclamationFacility treats water fromsewage treatment plant

Treated citywastewateris sent to Intelfacility

Intel Fab-12cooling toweroperationsand landscaping

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Intel facilitysemiconductoroperations

Select streams ofrinse water frommanufacturingprocesses are treatedon site

Water sent toChandler ROfacility foradditional treatmentand aquifer reinjection

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Use of Treated City Wastewater: Intel has com-mitted to voluntarily minimize its consumption offreshwater by using treated city effluent for con-sumptive uses of semiconductor manufacturingcooling tower makeup and landscaping. Intel willpurchase water from the Ocotillo ManagementGroup that has been treated by the City of Chan-dler. Intel’s initial goal was to achieve 100 percentuse of treated water by January 1997.

Reclamation of City Water: Intel’s core manu-facturing processes need high-quality water, butIntel has arranged for the treatment of some of therinsewater from its manufacturing processes forreuse or reinjection into the groundwater to helpreplenish the local aquifer. The rinse water is firsttreated within the facility and is then treated at anoff site facility using RO filtration. The City ofChandler can either recharge the treated water intothe groundwater to replenish the aquifer or reusethe water. The city recharges the local aquifer un-der an Aquifer Protection Permit issued by the Stateof Arizona.

Results/Anticipated Outcomes: Although there isno regulatory requirement or standard to serve asa baseline, Intel will significantly reduce its fresh-water demands through its water reclamation andreuse goals.

Reuse of Treated City Wastewater: The per-centage of wastewater reuse is calculated by thequantity of city effluent used for landscaping andcooling tower makeup, divided by the total quantityof water used for landscaping and cooling towermakeup. A mid-course review in January of 1999

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changed the established goal of 100 percent to 95percent* use of treated city effluent for coolingtower and landscaping use. This change was en-acted based on a review of cooling tower designand the need to ensure that there is a constant sup-ply of water for cooling tower uses during mainte-nance downtime at the city treatment plant. Intel’seffluent reuse results are shown in Table 19.

Reclamation of City Water: The RO filtrationprocess treats the process rinse water to applicabledrinking water standards before it is returned tothe local aquifer. Intel’s reclamation results areshown in Table 20.

As a result of the Intel project commitment to usetreated wastewater from the City of Chandler’sPOTW, the city received a grant to study reuseoptions for industrial process water. The study ex-amined the selective use of manufacturing process

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Reuse of Treated City Water

Year Treated Effluent Reuse Performance Goal Treated Effluent Reuse Achieved

1997 100 percent use of treated city water for Ocotillo facility achieved 80 percent use oflandscaping and cooling tower uses treated effluent. (132 million gallons of water)

1998 100 percent use of treated city water for Ocotillo facility achieved 97 percent use oflandscaping and cooling tower uses treated effluent (183 million gallons of water)

1999 * Revised goal to achieve 95 percent use of Ocotillo facility achieved 98 percent use oftreated city water for landscaping and cooling treated effluent (205 million gallons of water)tower uses

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Process Water Reclamation

Year Reuse Performance Goal Reuse Achieved

1997 45 percent of the total volume of freshwater 66 percent of water purchased from the citypurchased from the city will be sent to the city’s was returned for RO treatment and re-injectioneffluent treatment plant for recycling into the aquifer (355 million gallons)

1998 No goal established for 1998 61 percent of the water purchased from the citywas returned to the city for treatment(399 million gallons)

1999 55 percent of the total volume of freshwater 61 percent of the water purchased from thepurchased from the city will be sent to the city’s city has been returned to the city for treatmenteffluent treatment plant for recycling (422 million gallons)

effluent in cooling tower applications and the useof cooling tower effluent for specific irrigationneeds. The study has led to the development of amodel that portrays the representative quality ofcooling tower effluent to help determine if it can bereused in other applications.

Transferability: The water conservation partner-ship between Intel and the City of Chandler pro-vides an innovative model for arid regions that areincreasingly faced with low groundwater replen-ishment rates and for areas of where municipalwater suppliers need to conserve water in bothdomestic and non-domestic activities. In Arizona,the 1980 Groundwater Management Act providedsuch a requirement for the City of Chandler. Aswater cost and scarcity increases, treated effluentis one “source of water” that is expected to con-tinue to increase and could provide future watersupplies through reclamation and reuse.

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tailoring environmental performance to an issuerelevant to a local community (water conservation)and serves as the foundation for a model to iden-tify potential cooperative water conservationprojects between industries and their neighbors. Inaddition to identifying technical and economic op-portunities to conserve and reuse treated water,there will be a need to examine any technical andeconomic barriers to reclamation and reuse. Issuesto further explore include (1) the costs of RO tech-nology and the opportunities as well as costs todesign systems from the ground up to allow themto use treated effluent; (2) the potential cost barri-ers of retrofitting facilities to enable them to reusetreated effluent; and (3) the potential technical limi-tations and high cost of treating and reusing pro-cess effluent. (Cooling towers can experienceproblems with microbial growth and solid precipi-tates from treated POTW effluent.)

Dredged Material Pollution PreventionOpportunities

The Experiment(s): In an effort to eventuallyeliminate ocean dumping of its dredged material,Naval Station Mayport (NS Mayport) in Jackson-ville, Florida, is seeking to use the Project XL/ENVVEST process to examine and demonstrateinnovative and beneficial reuse of the dredgedmaterial. The proposed reuse options will be (1)production of construction building blocks and (2)production of artificial reef material for new or re-paired reef habitat. To maintain sufficient depthsfor naval ships, NS Mayport must dredge approxi-mately 600,000 cubic yards of sediment from theentrance channel on the St. John’s river and theinstallation’s turning basin every 18 to 24 months.Historically, this material was stored in two uplandholding sites at the installation. Once this space wasexhausted in 1993, ocean disposal of the dredgedmaterial was approved temporarily by U. S. ArmyCorps of Engineers (USACE) for the navalstation.

EPA and USACE share responsibility for manag-ing ocean disposal of dredged materials. Permitsfor disposing dredged material into ocean watersare issued by USACE, subject to EPA concurrence.NS Mayport is currently required to obtain three

permits with three different durations to dredge anddispose of its maintenance sediment—two permitsfrom USACE and one from the State of Florida.The naval station has sought flexibility to adjust thelengths of these permits to synchronize their dura-tion and combine their testing and evaluation re-quirements. Through Project XL, NS Mayport,EPA, USACE, Florida Department of Environmen-tal Protection, and the City of Jacksonville are cre-ating a partnership to provide flexibility bystreamlining the dredging and ocean disposal pro-cess by means of extending the length of one per-mit to synchronize permit cycles. Anticipated savingsfrom the streamlining process and the reduction inpaperwork from synchronized or extended permitswill be reinvested into development of the benefi-cial reuse applications for the dredged material.

Results/Anticipated Outcomes: The NS Mayportproject is pursuing pollution prevention opportuni-ties through the minimization and eventual elimina-tion of ocean disposal of dredged maintenancematerial. Current dredging cycles at NS Mayportare generating more than 600,000 cubic yards ofsand and silt every two years. Lacking the abilityto develop products through the reuse of dredgedmaterial, NS Mayport has estimated that by 2020,it will have disposed of nearly 10 million cubic yardsof dredged material in the ocean.

Initially, the dredged material for construction ofthe building blocks and artificial reef material willbe derived from the existing upland storage cells.During this time, ocean disposal of freshly dredgedmaterial will continue. After these storage cells areemptied, dredged material will be stored tempo-rarily in one of the upland storage cells, therebyeliminating the need for ocean disposal. The sec-ond storage cell will be used for constructing build-ing blocks and artificial reef material. By establishinga procedure and cycle for using the two storagecells for reuse projects and temporary dredgedmaterial storage, NS Mayport anticipates it wouldbe able to continue to use the cells in perpetuitywithout reaching capacity. In addition, NS Mayporthas proposed using excess fly ash from the localelectric authority as a solidification material for theconstruction blocks (not for reef material). If flyash is not suitable, another solidification agent willbe used in the construction blocks.

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This project will proceed in phases that will allowNS Mayport to demonstrate and evaluate that thedredged material finished products are safe to hu-man health and the marine environment. Implemen-tation will include (1) collecting samples of dredgedmaterial from the upland disposal sites to ensurethey meet all Federal, state, and local building re-quirements; (2) researching the cost and benefitsanalysis to support long-term commercial and/orpublic use of the new materials; and (3) evaluatingthe need and cost effectiveness of mobilizing por-table equipment to manufacture products at or nearthe upland storage cells. If it is determined that thefinished products present any risk to human healthor the marine environment, implementation will stop.

Transferability: The disposal of dredged mate-rial is a Navy-wide as well as nationwide issue,and this project can serve as the test bed to inves-tigate the degree of transferability and savings be-yond NS Mayport. While complete elimination ofocean disposal may not be feasible at all similarlocations, the NS Mayport ENVVEST/XL projectcould serve as a model for other locations seekingto decrease the frequency and amount of oceandisposal for dredged material.

Additionally, designated in 1994 as the Navy Envi-ronmental Leadership Program East Coast facility,NS Mayport has been charged with leading thedevelopment of innovative technologies and state-of-the-art management practices to reduce theecological footprint and effect of naval facilities.In setting an environmental management standardfor all Navy installations, NS Mayport will look toexport its lessons learned from this project through-out the Navy and the Department of Defense.

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The American public has demanded active involve-ment in community decisions that affect their healthand the quality of their environment. In response,EPA is increasing public participation in its pro-grams and providing more environmental informa-tion to help the public understand critical, and oftencomplex, issues. EPA also hosts forums like theNational Community Involvement Conference tosupport public participation in environmental issues.In addition, EPA is revising the regulations thatguide public participation efforts and providingmodels to help staff learn how to get the publicinvolved in their work. Project XL is an opportu-nity to test new stakeholder involvement ap-proaches that give communities a clearer, morecoordinated voice in crafting environmental solu-tions.

Stakeholder involvement is one of the eight ProjectXL selection criteria. Because the projects involveinnovative strategies that differ from what wouldbe allowed under regulation, this ensures that thepublic has ample opportunity to review and influ-ence actions first. However, stakeholder involve-ment in these experiments has also been verychallenging. Project XL, as a program, has soughtout approaches (through principles, tools, and pro-cesses) that support collaborative working relation-ships with project sponsors, governmentrepresentatives, and stakeholders. Table 21 identi-fies these approaches.

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ExxonMobil Hazardous Enhanced Stakeholder Involvement: Unique approach by workingWaste Site closely with stakeholders to plan the cleanup and determine the

Remediation future uses for the contaminated site; to ensure that the site will be and Reuse redeveloped for business or commercial use after cleanup.

Weyerhaeuser Multimedia Stakeholder Involvement in Experimental Projects: Identifying models forIntel stakeholder involvement; evaluation of models linking publicMerck participation to environmental decision-making.HADCO

Program-wide Multimedia Multistakeholder Involvement in “Reengineering”: Manual for EPAProject XL Teams, Project XL Stakeholder InvolvementGuide and Project XL—Best Practices for Proposal Development:Using a corporate sector tool called “work process reengineering” toengage stakeholders in major redesign and restructuring of coreprogram practices.

Program-wide Multimedia Project XL Stakeholder Involvement Guide: Developing a clear, plainlanguage guide that provides helpful ideas and tools to projectsponsors and stakeholders for successful interactions.

Program-wide Multimedia Capacity and Trustbuilding: Providing technical assistance andprofessional facilitation to improve trust among stakeholder groupsand to build local stakeholder participation.

12 To avoid duplication, this section does not cover innova-tions in other core functions that address stakeholder involve-ment issues such as “Internet Reporting and StakeholderInput” (environmental information management and access).

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Enhanced Stakeholder Involvement:Facilitating Site Redevelopment

The Challenge(s): To facilitate the likelihood thatthe Fairmont Coke Works Site will be redevelopedfor business or commercial use after cleanup,ExxonMobil has committed to (1) involve stake-holders and community groups in planning thecleanup and determining future uses for the site,(2) demolish and dispose of all on-site structures,and (3) seek interested developers for property re-development. Public involvement in the traditionalSuperfund process can vary from site to site.ExxonMobil, EPA, and West Virginia DEP haveagreed to go beyond the minimum Superfund com-munity relations requirements in the National Oiland Hazardous Substances Pollution ContingencyPlan (NCP) and involve the community through itsrepresentative, the Fairmont Community LiaisonPanel (FCLP), in the planning and implementationof the site cleanup. ExxonMobil, the state and theFCLP have resolved to work together to build aprocess geared toward achieving a consensus onmajor aspects of the cleanup and incorporatingpotential reuse opportunities into the cleanupprocess.

Although commercial redevelopment is typically notaddressed in the Superfund process, the Fairmontcommunity has expressed a strong interest in re-developing the site. The site is suitable for redevel-opment due to its location and size. ExxonMobil,beyond its statutory responsibility to clean up thesite, has committed to actively seek interested de-velopers and to facilitate a productive reuse for thesite. To stimulate interest, ExxonMobil has conductedan extensive on-site building demolition programthat will enhance the market and redevelopmentpotential of the property. On-site building demoli-tion is typically required only at Superfund siteswhere it has been demonstrated that hazardoussubstances are or have the potential to migrate fromsuch buildings or if the buildings impede a responseaction. ExxonMobil is implementing a site-widedemolition plan to increase the redevelopment po-tential of the site and provide aesthetic benefits tothe site and the community even if there is no pres-ence of hazardous substances.

Results/Anticipated Outcomes: Substantial in-volvement and support of project stakeholders areimportant catalysts in the planning and implemen-tation of the ExxonMobil project. The project en-hances community and other stakeholderparticipation in the Superfund cleanup process byproviding citizen participation in the process throughsolicitation of stakeholder input into cleanup alter-natives and future use determinations for the site.Establishment of a community panel along withroutine communications with the project team re-sulted in consistently supportive local media cover-age and support from the community in projectdecisions. This project will also demonstrate howthe consideration of future uses of a contaminatedsite in the early cleanup planning stages can be apractical and valuable component of the Superfundprocess.

ExxonMobil’s completion of an on-site buildingdemolition and facilitation of redevelopment willprovide additional environmental benefits to thecommunity not found in a typical Superfund pro-cess. ExxonMobil also purchased the site to helpfacilitate development. As property owner and theparty responsible for cleanup, ExxonMobil has con-trol over redevelopment preparation and final dis-position of the site. ExxonMobil will provide EPA aplan that outlines the strategy for facilitating siteredevelopment that goes beyond planning and as-sessment stages.

Transferability: By considering and integrating fu-ture use opportunities into the cleanup plan for aSuperfund site, the ExxonMobil project will serveas a model for returning Superfund sites back toproductive economic use. The project provides anopportunity to analyze an atypical approach topartnering with local community members and otherstakeholders to solicit their input throughout theprocess of selecting and implementing a cleanupremedy and determining future use plans for thesite. For communities situated near similarly dis-tressed properties, the ExxonMobil project will ex-plore the potential to improve the health andproductivity of a local community by remediatingenvironmental hazards and allowing those commu-nities to reclaim distressed properties as valuableand productive assets.

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Stakeholder Involvement in ExperimentalProjects: Identifying Basic Models

The Challenge(s): Since the inception of ProjectXL, EPA has stated that meaningful and organizedparticipation on the part of community and national,nongovernmental organization representatives is animportant criterion for selecting projects. However,when Project XL was first announced in 1995, EPAdid not give specific guidelines for the design of thestakeholder processes. Since the project sponsor,not EPA, is responsible for initiating and maintain-ing the stakeholder involvement process for projects,EPA left the responsibility for creating models thatwould meet the stakeholder criterion to those projectsponsors. Though sometimes difficult, the experi-ences of these early projects proved critical to theAgency’s understanding of the approaches andresources needed to make the stakeholder processeffective.

The Result(s): Project XL has undertaken a com-mitment to document and evaluate models of stake-holder involvement on an ongoing basis. As a firststep, in the report titled Evaluation of Project XLStakeholder Processes (September 1998), EPAexamined four early projects with FPAs: Intel,Merck, HADCO and Weyerhaeuser. As a secondstep, EPA recently completed a second evaluationof stakeholder processes entitled Project XL Stake-holder Evaluation (August 2000). This report buildsupon the earlier report and examines the stake-holder processes used in eight projects: Andersen,Atlantic Steel, Crompton, ExxonMobil, HADCO,Intel, New England Universities Laboratories, andVandenberg AFB.

The first report found that different models ofstakeholder involvement resulted from the originalcall from EPA for project sponsors to design pro-cesses for stakeholder participation. Specifically,the report identified two early models used by theproject sponsors: consensus decision making withstakeholders (used by Intel and Merck) and publicconsultation and information sharing (used byHADCO and Weyerhaeuser). Weyerhaeuser’sproject was rated as most effective by survey re-spondents; this project used a public consultationprocess that relied heavily on longstanding com-munity-company relationships to establish supportfor the regulatory experiment. The HADCO project

was rated least satisfactory on most measures; thisproject also used the consultation and informationsharing process. The two projects using consensusdecision-making processes were ranked in be-tween.

In the September 1998 evaluation, neither the con-sensus decision-making model nor the public con-sultation and information sharing model was clearlydetermined to be a superior method of involvingstakeholders in the project development process.However, the results did show that clarity of struc-ture and objectives for the process are more im-portant to success and credibility than the type ofstakeholder involvement process. The processesthat were rated as highly effective, that is, clearlystructured with adequate resources, had a combi-nation of broad distribution of benefits (financial,environmental, and public access) among all of theparticipants and high individual/organizational sat-isfaction with the outcome of the negotiation. Theprocesses with barriers to participation (such aslack of technical information, unclear objectives,inadequate resources to participate) were rated lesssatisfactory regarding the distribution of benefitsand the outcome. Thus, process satisfaction andsubstantive results are closely linked—both arecritical elements of the success of future projects.

The August 2000 evaluation built upon the originalstakeholder evaluation and considered (1) the earlydynamics of stakeholder processes in projects de-veloping their FPA, (2) stakeholder satisfaction andeffectiveness of stakeholder involvement forprojects that had recently signed their FPA, and(3) stakeholder involvement in project implemen-tation for projects that had signed their FPA at leastone year before the evaluation. The analysis is basedon case studies developed for eight projects. In theprojects analyzed, project sponsors developed stake-holder models that centered mainly around publicconsultation and information. In four projects, spon-sors engaged stakeholders in some form of joint-problem solving or consensus, often done in additionto public consultation and information sharing.These included Atlantic Steel, ExxonMobil, Intel,and the national stakeholder process used in NewEngland Universities Laboratories. However, ofthese, only the Intel project based its stakeholderprocess on consensus.

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• Of those interviewed, most stakeholders weresatisfied with the project outcomes and theirlevel of involvement in the stakeholder processregardless of the type of process used. Inprojects where interviewees were less satis-fied with the stakeholder process, the stake-holders’ expectations about opportunities toparticipate went beyond the avenues of par-ticipation made available.

• Those projects that typically support a processwith satisfied stakeholders tend to exhibit thefollowing characteristics. First, the process in-volves stakeholders at a level that is consistentwith stakeholders’ concerns and expectations.Second, the process ensures that stakehold-ers’ perceptions regarding their actual influ-ence over the project outcome match theirexpectations regarding the level of influencethey thought they would have at the start ofthe project. Finally, the process allows stake-holders to participate efficiently and is not un-necessarily drawn out.

• In addition to factors that determine satisfac-tion with stakeholder processes, the secondstakeholder report also identifies barriers thatlimit effective stakeholder participation. Forstakeholder processes focused on consultation,the amount of time required for stakeholdersto participate and their capacity to understandtechnical issues can influence effective stake-holders involvement. For stakeholder processescentered on information exchange, the great-est barrier to effective participation is the lackof a systematic approach for outreach an ob-taining feedback from the community.

Project XL continues to emphasize the principlesand process by which stakeholder involvement inprojects should be governed, rather than advocat-ing that projects use a single model. By focusingon principles, the sponsors, as the “managers” ofthe process, can tailor the stakeholder involvementprocess to reflect the scope and complexity of theproject. EPA expects that the design of each stake-holder process adequately reflect a proper balancebetween the complexity and uncertainty of theproject, the stakeholders’ desire to participate andhave influence over the project, and the projectsponsors’ ability to direct resources towards stake-

holder process development. This also allows thestakeholders themselves to have a say in how theprocess is structured and conducted.

In addition to emphasizing principles, EPA is be-ginning to focus on additional resources needed tobetter ensure the design of effective stakeholderprocesses. The August 2000 evaluation makes clearthat neither project sponsors nor Project XL staffalways have the proper experience to effectivelydesign or oversee a stakeholder process. In suchinstances, project sponsors may design participa-tion processes that lack clear structure and objec-tives, are reactive rather than proactive, and do notallow stakeholders to participate to the extent theythink they should be able. By directing resourcesto enable the development of more effective stake-holder processes, EPA hopes to ensure that in thefuture, these pitfalls will be avoided.

Transferability: Project XL’s goal is to promotecontinuous learning and develop a more compre-hensive understanding of the factors that contrib-ute to the success of, and that pose challenges to,involving stakeholders in experimental projects. Thelessons learned in managing the stakeholder as-pects of Project XL are increasingly being sharedwith other EPA programs and Federal agenciesstruggling with similar issues. Most recently, ProjectXL’s stakeholder involvement guide was highlightedin EPA’s Public Participation Policy ReviewWorkgroup’s Report to the Administrator. The pre-vious year, Project XL stakeholder involvementtools and experiences were discussed at thePresident’s Council on Environmental Quality’sworkshop, “Linking Public Participation to Envi-ronmental Decision Making: An Exploratory Work-shop.” In addition, the program continues to shareinformation throughout the network of EPA staffthat have responsibility for various stakeholder in-volvement efforts.

Multistakeholder Involvement in“Reengineering”

The Challenge(s): Based on strong feedback fromProject XL participants, EPA recognized that itneeded a more user-friendly process that would bequicker and more cost effective, produce a consis-tently superior result, and provide more focusedstakeholder involvement and information ex-

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changes. So, in 1998, EPA sought to improveProject XL using a process developed by corpo-rate America called “business processreengineering.”13 for restructuring of core businessprocesses. Many corporations have found that, overtime, core processes within their organization be-come inefficient, bureaucratic, cumbersome andlose their intended focus. Routine practices oftenadd tasks and steps that do not add value to thecore business goal. These inefficiencies slow downthe organization, detracting from the intended goals.Therefore, reengineering is most effective in iden-tifying when a particular process is impeding thegrowth or competitiveness of an organization, orwhen a particular process is only minimally meet-ing a business need. A reengineering initiative tar-gets a process and is applied across multiplefunctions within an organization; must have thesupport of upper management; and leverages in-formation technologies to overhaul, support, anddramatically improve work processes.Reengineering refers to the major redesign andrestructuring of core business processes. The pro-cess reengineering model used by EPA was de-signed to bring about meaningful, lasting change tothe Project XL process. EPA convened aworkgroup consisting of industry members, non-governmental organizations (NGOs), state and lo-cal regulators, and a community group.14 Sixsubgroups were formed, each focusing on a criti-cal Project XL problem. Each subgroup conducteda step-by-step assessment of existing processesand identified inefficiencies and bottlenecks.

Result(s): The reengineering workgroup createda new process that is faster, clearer, and more ef-fective for project sponsors, other stakeholders, andEPA. With the help of a representative group ofstakeholders, EPA produced three documents thataddress the primary concerns of many Project XLstakeholders. Combined, these documents serve to

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parent to all Project XL participants, thus promot-ing understanding, trust, and realistic commitmentsand expectations. These documents include:

• Project XL Stakeholder Involvement: AGuide for Project Sponsors and Stakehold-ers. This provides helpful ideas and tools toproject sponsors and stakeholders for success-ful interactions. (This guide is further describedin the next section below titled “Guidance forSponsors and Stakeholders.”)

• Manual for EPA Project XL Teams. This in-structs EPA on how to build effective internalteams to develop proposals. (This manual isfurther described as an Project XL innovationin the section on the core function of “AgencyCulture Change.”)

• Project XL: Best Practices for Proposal De-velopment. This helps project sponsors createeffective Project XL proposals. (While veryimportant for Project XL, this type of guidanceis not considered an innovation.)

Transferability: The lessons learned from theoverall reengineering process, as well as the spe-cific documents produced, are being sharedAgency-wide as part of the Stakeholder ActionPlan. For example, the Manual for EPA ProjectXL Teams has been distributed to the ReinventionAction Council and shared with the state’s envi-ronmental commissioners as a model of accom-plishing cross-Agency multimedia decision making.In order to share the information with Agency pro-fessionals and stakeholders, the stakeholder guideis on EPA’s Stakeholder Involvement Web site athttp://www.epa.gov/stakeholders/involvework.htm.

Guidance for Sponsors and Stakeholders

The Challenge(s): One key challenge early inProject XL was that some industry project spon-sors lacked experience with convening and man-aging a site-specific, intensive stakeholder process,and they feared the inherent costs in time and moneyto conduct such a process. However, there is rea-son to believe that the time and money that projectsponsors invest in the stakeholder process is lesscostly than originally perceived and can accrue un-

13Business process reengineering as developed by the corpo-rate sector refers to the major redesign and restructuring ofcore business processes.

14The participating organizations were: Citizens for a CleanEnvironment; City of Portland, Oregon; Dow Chemical;Florida Department of Environmental Protection; Environ-mental Defense Fund; Environmental Law Institute; Massa-chusetts Department of Environmental Protection; and UnionCarbide. In particular, Union Carbide and Dow Chemicalplayed a leadership role in describing and helping EPA applythe reengineering approach.

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15The Cost of Developing Site-Specific Environmental Regu-lations: Evidence from EPA’s Project XL, Blackman andMazurek, Resources for the Future, Discussion Paper 99-35,April 1999.

16“Direct participants” are involved in the day-to-day as-pects of project negotiations; they influence the design ofprojects; and their views strongly influence the details anddevelopment of the project as well as EPA’s ultimate decisionto approve or disapprove it. “Commentors” are stakeholderswho have an interest in the project but do not participate inday-to-day negotiations; EPA requires sponsors to provideinformation to potential commentors and create periodic fo-rums in which they can express their comments. The “generalpublic” is involved by having clear access to information onthe development and environmental results of the project;EPA expects the project sponsor to arrange public meetingswhen the information is available, allowing the public oppor-tunities to influence decision making.

expected benefits. At least two private surveys ofproject sponsors (including project sponsors thatwere not successful in gaining FPAs) show thattheir Project XL stakeholder involvement with en-vironmental organizations and community groupshas been beneficial to the companies in the longrun. The results from one study found that the ex-pense of the stakeholder involvement process is anaverage of 20 percent of the total transaction costfor the project sponsor—a far smaller proportionthan originally assumed.15 Still, project sponsorslooked to EPA for improved guidelines to reducethe early confusion about, and time-consuming na-ture of, stakeholder involvement procedures.

Another early challenge was that the participationof national NGOs received mixed reviews fromthe other stakeholders. In some projects, the par-ticipation of the national NGOs was consistent,timely, and helped to move the project developmentprocess forward. Local stakeholders often gavethe national environmental NGOs high praise forbeing very helpful to local citizens and bringing sub-stantive expertise to the table that local citizensthemselves may lack. In other projects, however,the participation of the national NGOs was consid-ered by local citizens to be inconsistent, late, anddifficult to predict. In these cases, the NGOs’ ap-proach was considered “intervention” and discon-nected from local citizen involvement.

In the April 23, 1997, Federal Register Notice,Clarifying the XL Process, EPA took steps to ad-dress these issues for the project sponsors, NGOs,and local citizens. In particular, EPA defined threelevels of public participation in Project XL16 to bring

clarity to the roles of public stakeholders, to moveaway from “local citizens versus national environ-mentalists” clashes, and to enable industry projectsponsors to be more responsive. The Federal Reg-ister Notice also covered the importance of well-defined and transparent ground rules.17 However,while the Federal Register Notice helped definethe policy issues, project sponsors and stakehold-ers still sought clear, plain guidelines that could helplead them to successful interactions.

Result(s): A product of the reengineering process,Project XL Stakeholder Involvement: A Guidefor Sponsors and Stakeholders, clarifies rolesand responsibilities of sponsors and stakeholders,suggests guiding principles, and provides ideas andtools to help develop, negotiate, and implement suc-cessful projects. It explains the potential benefitsof stakeholder involvement to the sponsor as wellas to the potential stakeholders. It also explains theEPA and state government roles in assessing thestakeholder involvement process.18 Ultimately, thestakeholder involvement guide provides general in-formation about the project development processand advice to both stakeholders and potential spon-sors regarding how to determine what type of pro-cess is appropriate, stakeholder needs regardingtime commitment and technical assistance, and theappropriate scope and complexity of the involve-ment process.

17Key ground rule topics for consideration include the levelof the participant’s role (advisory, consultative, or decisional)and how that input should be expressed (i.e., by consensus ormajority vote). These topics, as well as other ground rules,must be discussed and consented to by the direct partici-pants.

18While the sponsor has the primary responsibility for thestakeholder group, experience shows that in the most suc-cessful processes, the sponsor and the stakeholders share inthe process creation. EPA will participate as a member of theoverall stakeholder group. This participation is important tohelp ensure that these processes are transparent; it shouldnot be confused with EPA’s ultimate role of guaranteeing anadequate stakeholder process to meet Project XL’s criterionfor public participation. EPA also retains the authority toapprove or disapprove a project—based on how well thecriteria are met. States also share the ability to veto projectsthat do not meet the criteria. While this authority is not del-egated to stakeholder groups, the views and recommenda-tions of direct participant groups strongly influence thedecisions of the regulators.

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Involvement: A Guide for Project Sponsors andStakeholders is specifically designed to help lessexperienced project sponsors grasp the essentialprinciples of designing and managing a stakeholderinvolvement process. Thus, the Guide is featured,along with other documents such as the Construc-tive Engagement Resource Guide (March 1999),in the Agency’s Stakeholder Involvement ActionPlan (December 1998). Similarly, the Guide isprominent on the EPA Stakeholder Web site. TheWeb site, a product of the EPA Stakeholder In-volvement Action Plan, is designed to share les-sons, information, and tools on stakeholderinvolvement, throughout EPA and with externalstakeholders. The Guide is now being widely usedby Project XL teams. However, EPA is continuingto encourage the other programs to use the Guideas a model for initiating stakeholder involvement,and will seek to evaluate its usefulness to projectstakeholders and sponsors, other industry repre-sentatives, and EPA staff.

Capacity and Trustbuilding Resources toImprove Stakeholder Involvement

The Challenge(s): A key lesson from Project XLis that resources may need to be made available toensure that all stakeholders, particularly local citi-zens, have the ability to assess the technical andenvironmental issues. Repeatedly, EPA found thatsome form of technical assistance and meeting fa-cilitation were necessary to ensure that all partici-pants had the capacity to understand and thewillingness to engage in these experimental dem-onstration pilots. But early on, EPA did not haveclear mechanisms or guidelines in place to eitherassess the needs or supply these resources. EPAneeded practical solutions to address the re-source gap.

Result(s): EPA strongly suggests that newlyformed stakeholder groups perform a “needs as-sessment” to determine whether training or tech-nical assistance is needed to ensure interest andunderstanding of all stakeholders in Clarifying theXL Process and Project XL StakeholderInvolvement: A Guide for Project Sponsors andStakeholders. There can be a number of meansfor local stakeholders to receive technical assis-

tance. For example, the project sponsor, the stategovernment, a national environmental organizationor an academic institution might provide technicalinformation or assistance to local stakeholders.However, when these means are not available orappropriate, EPA has set up a mechanism to pro-vide task-specific technical assistance to ProjectXL stakeholders: the Institute for ConservationLeadership, manages this service under a coop-erative agreement with EPA. This assistance isavailable up to $25,000 per project when requestedby the direct participant stakeholder group. Thispast year, two stakeholder groups involved in theInternational Paper projects (IP-EI and IP-PEM)accessed the technical assistance grants. In addi-tion, the stakeholder group involved the Andersenproject plans to use the technical assistance grantonce the project is further along in implementation.

EPA has undertaken other activities aimed at build-ing and maintaining stakeholder trust. In particular,EPA provides contract support for meeting facili-tation assistance to project sponsors for initiating aproject and determining the best overall stakeholderprocess. Also, because facilitation by a third party,face-to-face meetings, and site visits stand out asdemonstrated mechanisms for building trust, EPAstaff actively seek opportunities for scheduling face-to-face meetings and facility site visits.

Transferability: A key action in the InnovationsTask Force Report is to “build leadership capacityin communities to participate in local environmen-tal problem solving.” EPA will work with the TaskForce to incorporate the lessons learned fromProject XL regarding how and when to providekey resources into the analysis and recommenda-tions for building local capacity.

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��A new emphasis on innovation has changed theway EPA thinks and operates, leading to real envi-ronmental improvements and real reductions incosts. Regulatory and enforcement programs arestill at the core of our environmental system, butinnovation has provided new tools to meet futuredemands. The challenge ahead is to make theseinnovative ideas a permanent part of EPA’s cul-ture. Project XL is one venue through which EPAis learning to change its organizational behavior,particularly to encourage cross-Agency support forinnovation. Project XL has led to discreet changesin EPA’s planning and operational procedures.These changes support EPA’s commitment to testand incorporate innovative solutions to environmen-tal problems. Table 22 describes the planning andmanagement innovations that are leading to changein the Agency’s culture.

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Program wide Multi-media Reinvention Action Council: Build and maintain support,empowerment, and accountability for projects and innovationsAgency-wide.

Program wide Multi-media ECOS-EPA Innovations Agreement: Expand the potential for state andtribal partnerships for innovative projects.

Program wide Multi-media Cross-Agency Project Teams—the Manual for EPA Project XL Teams:Offers a model to guide cross-Agency teams in project planning,management, and monitoring.

Program wide Multi-media Compliance Screening Guidance: Creation of guidelines for Agencyscreening process for regulatory flexibility projects.

Senior Management Support and Involvementthrough the Reinvention Action Council

The Challenge(s): Each of the projects has hadvarying levels of management involvement at dif-ferent junctures in the projects’ development andimplementation. In fact, EPA found that there weremany instances where a lack of senior manage-ment participation in a project hindered or stoppedprogress. For projects to develop and systemchange to occur, there is a need for active supportfrom senior Agency management. This support in-cludes personally championing individual projects,empowering Agency staff that participate in nego-tiations, giving clear direction to Project XL teams,and providing resources.

Results/Anticipated Outcomes: In early 1996, EPAestablished the Reinvention Ombudsmen, latercalled the Reinvention Action Council (RAC), toassist in reaching the Agency’s goal of 50 projects.Chaired by the Associate Administrator for theOffice of Policy, Economics and Innovation, the

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RAC consists of the senior Agency managers(Deputy Assistant Administrators and Deputy Re-gional Administrators) from each of the Headquar-ters and regional offices. Originally, the RAC servedas a resource to Project XL teams when they facedeither disagreements or difficult technical, legal, orpolicy issues. Since then, RAC members have com-mitted to working directly with Project XL Coordi-nators within their offices to support quick decisionmaking and ensure that Project XL teams havesuitable resources. Involving senior managers hasproven to be effective in identifying and resolvingproblems for Project XL. Building on the ProjectXL experience, in 1997, the Administrator ex-panded the RAC responsibilities to support theAgency’s overall commitment to reinventing envi-ronmental protection.

Transferability: To date, the RAC has taken ahard look at reinvention efforts throughout theAgency and has addressed a broad array of rein-vention issues including incentives, permitting, andenvironmental management systems and continuesto set new reinvention priorities. For example, theRAC is the key implementing body of the recom-mendations from the 1999 EPA Task Force on In-novative Approaches. The RAC’s expandedagenda also calls attention to RAC endorsementof innovations throughout the Agency and ultimatelyserves as encouragement for staff to experiment.The RAC will play a vital role in designing a sys-tematic approach for evaluating and adopting newideas and building innovation into the work of theAgency.

Managing Experiments in Partnership withState and Tribal Governments

The Challenge(s): Federal sharing of environmen-tal responsibilities requires that each project havethe full support of the appropriate state and tribalgovernment. In fact, the state or tribal governmentis a signatory to most projects. Within the frame-work of Project XL, EPA, states, and tribal gov-ernments are innovatively working together throughuncharted territory. In particular, the challenge ofdeveloping, refining, and implementing Project XLtogether has magnified EPA-state, as well as state-state, similarities, differences, agreements, and dis-agreements. States and tribal governments are, and

will continue to be, primary partners with EPA inboth regulating public health and the environmentand designing and applying innovative approaches.Therefore, it is incumbent that EPA, and state andtribal governments rectify differences and produceagreements that satisfy each entity. Project XLserves as a testing ground for managing experi-ments to the satisfaction of Federal, state, tribal,and local authorities.

Results/Anticipated Outcomes: The promise ofmore efficient and effective government has en-couraged several states to develop their own ProjectXL-like legislation providing the authority to testand implement innovative approaches to state en-vironmental programs. To provide an additionalvehicle to test innovative environmental manage-ment strategies for the future, EPA and the Envi-ronmental Council of the States (ECOS) negotiatedan agreement to guide environmental regulatoryinnovations in the future. The ECOS-EPA Innova-tions Agreement was developed as a result of theProject XL experience. The agreement definesseven principles to guide regulatory innovations anda process that clarifies how EPA and states willput these good ideas to the test. As of August 2000,the ECOS-EPA Innovations Agreement was mov-ing forward with three projects in implementationand five additional projects having preliminary ap-proval.

Transferability: As Project XL closes in on its 50project milestone, two things are clear: (1) EPAwill continue to test innovative ways of achievingdesirable environmental outcomes that are moresupportive of the marketplace and business needsthan the current system and (2) state and tribalgovernments will continue to be partners in achievingthese outcomes. The prominent role of states inthe Project XL process, as well as the ECOS In-novations Agreement, has advanced Federal-statepartnerships in developing and managing innova-tion strategies for environmental protection. Theexperiences of Project XL continue to influencestates as they consider, develop, or expand theirown programs that offer regulatory flexibility tofacilities or industry sectors. For example, ProjectXL is being used as a tool by New Jersey as itthinks about expanding its regulatory reinventionprogram. As the idea of testing tomorrow’s solu-

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tions today spreads throughout state and tribal gov-ernments, Project XL will continue to serve as aviable model. Additionally, in fulfilling the principlesof the Joint State/EPA Agreement to Pursue Regu-latory Innovation, a number of states have enteredinto Memorandums of Agreement to pilot andevaluate innovative environmental regulatorymethods.

Effective Cross-Agency Teams forMultimedia Experimentation

The Challenge(s): To institute change within anagency requires creating guidance and proceduresfor staff action. Projects often test innovations thatcut across traditional EPA media programs (e.g.,air, water, waste and toxics), which have their ownregulations, budgets, policies and procedures.Projects are region-led, but typically involve na-tional policy issues that require regions and Head-quarters’ offices to coordinate. Initially, a lack ofsuch coordination was a major challenge withProject XL, and a major factor in the high transac-tion costs of participation for EPA and its ProjectXL partners.19

Projects require prompt and effective cooperationamong various EPA offices in order to properlyaddress project sponsor proposals. Normally, projectproposals impact multiple Agency functions, so EPAstaff experts are convened who (1) do not nor-mally work together, (2) answer to separate andindependently managed “chains-of-command,” and(3) have different priorities (e.g., responsibilities forseparate statutes and programs that face very dif-ferent time, policy, legislative, and budget con-straints).

Results/Anticipated Outcomes: To carry out theProject XL experiments, EPA had to evaluate itshistory and effectiveness of working across mediadoing a major Project XL reengineering20 effort.

In order to allow EPA to quickly make decisionsacross Program Offices, speak with one voice toproject sponsors, and share a common understand-ing of the project at hand, EPA created a new para-digm for Project XL cross-Agency teams. This newparadigm is defined in the Manual for EPA ProjectXL Teams. The Manual has a detailed outline ofthe proposal development process, and clarifica-tion of roles and responsibilities among EPA mediaoffices, enforcement staff, and senior managers.These clarifications are helping new Project XLteams make decisions faster and communicate withproject sponsors more clearly and decisively. TheManual also explains that the EPA teams are re-quired to have a project schedule for all new projectsto help keep the team focused on key milestonesand on track. In addition, another tool EPA hasdesigned to assist each new Project XL team isthe option of having a neutral facilitator kick offthe proposal development process and guide theEPA staff in setting the foundation for an open,productive decision-making process.

These Project XL teams are continuing to makekey decisions in the Project XL process faster. Thisis more satisfying to participants both outside andinside the Agency. For example, involving keyAgency decision makers early in the process andimproving the functioning of the cross-Agency teamhas paid off in the complex Atlantic Steel project.Several of the streamlined techniques were appliedresulting in an agreement on the project’s PhaseOne signed by the sponsor and EPA nine monthsafter initial discussions began—a marked improve-ment over earlier proposals, some of which lingeredmore than 24 months without closure. EPA’s trackrecord for shortening the timeframe involved indeveloping agreements after sponsors initially sub-mit their proposals continues to improve. Examplesof projects that have accomplished this in 12 monthsor less include Progressive, Louisville POTW,Denton POTW, and USPS Denver.

Transferability: EPA will continue to monitor theeffects of these process improvements and the re-lated transaction costs. Currently, EPA is finalizingan economic analysis framework for Project XL(to be completed 2001). The framework will de-velop an analysis plan that will permit effectiveevaluation of the financial costs and benefits ac-

20See page 75 for description of the Project XL reengineeringeffort.

19See Evaluation of Project XL Stakeholder Processes pre-pared by Resolve, Inc., for EPA (September 1998, EPA-100-R-98-009) and The Cost of Developing Site-SpecificEnvironmental Regulations: Evidence from EPA’s Project XL,Blackman and Mazurek, Resources for the Future, Discus-sion Paper 99-35, April 1999.

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cruing to projects. Ultimately, as part of a samplingplan, the information on transaction costs andproject benefits for facilities, EPA, and other stake-holders will be collected. The sampling plan willfirst focus on the Weyerhaeuser and the NYSDECprojects. EPA will use this information to continueto improve Project XL and to help design the nextphase of experimentation in the Agency.

As EPA continues to test new approaches to solv-ing environmental problems, the solutions increas-ingly cross traditional media program lines. Thelessons learned and new tools developed for ProjectXL teams are now widely available for other rein-vention initiatives that cross the traditional Agencystructure and require cross-Agency team building.Current and future reinvention efforts can now startwith a blueprint for avoiding many of the problemsinherent to cross-Agency team building and usetools that focus these new teams on their sharedgoal of cleaner, cheaper, and smarter environmen-tal protection.

Compliance Screening for Project XL’sVoluntary Project Sponsors

The Challenge(s): Agency guidance on criticalprogram components is needed by project spon-sors to optimize the effectiveness of the ProjectXL experimental process. EPA actively encour-ages a wide variety of public and private entities toparticipate, but all project sponsors must have agood history of compliance with EPA regulations.A potential sponsor’s overall compliance history isrelevant to ensure the experimental Project XLapproach will not pose undue risks to human healthand the environment, and to enable EPA to makean informed judgement regarding the likelihood ofthe participants ability to achieve superior environ-mental performance. As the Project XL processmatured, compliance screening became more fre-quent and time-intensive and the screening processcontinued to lack definition. Clear compliancescreening practices and expectations needed to beestablished.

The Result: OECA developed the Guidance forCompliance Screening for Project XL in 1998 tostandardize and streamline compliance screening.This compliance screen provides the Agency with

useful information on a participant’s current com-pliance status and history. It also provides factorsthat could bear on a potential participants eligibilityfor Project XL, such as the possibility of a conflictbetween a proposed project and an ongoing en-forcement effort. The guidance specifies the scope,criteria, and process for conducting enforcementscreens and indicates that compliance screens willbe updated prior to high-visibility public events.

Transferability: Project XL is one example of ashift in our national strategy for protecting the en-vironment. Increasingly, EPA is trying to achieveits mission through building partnerships with smalland large businesses, citizen groups, state and lo-cal governments, and institutions. The Project XLscreening guidance is a program-specific applica-tion of the broader framework, and an example ofa rigorous screening process for a regulatory flex-ibility program. Project XL has helped lay thegroundwork for testing and establishing guidancefor an increasing number of EPA voluntary pro-grams requiring compliance screening. In additionto the Project XL screening guidelines, on April 5,1999, OECA and the Office of Reinvention issuedthe Guidance for Compliance Screening for Vol-untary Programs, the Agency’s comprehensivescreening framework, applicable to all voluntarypartnership programs. �

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This section catalogues 23 emerging innovations—promisingideas and concepts, that as of November 2000, were in earlierstages of exploration. These expected innovations are being

provided here in order that future project sponsors and stakeholdershave a more complete picture as to the experiments underway. Asthese innovations move forward, the Agency will be tracking and as-sessing the results in future reports.

The table immediately below identifies the types of emerging innova-tions represented by each project. This table is designed to give thereader a “roadmap” for this section. It is not intended to be used as achecklist for future projects.

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Regulations Permitting Information Enforcement Environmental Stakeholder CultureManagement Compliance Stewardship Involvement Change

Anne Arundel XCounty

Autoliv X

Buncombe County X

City of Chicago XDevelopmentZones

Clermont County X

Columbus X

Crompton TBT X

Puget Sound X

Kodak X

Fort Worth X

IBM Fishkill X

Labs21 X

Lead Safe Boston X

Chicago POTW X

NBC POTW X

NASA X

New Jersey Gold XTrack

Ortho-McNeil XPharmaceutical

Pennsylvania DEP X

Port of Houston XAuthority

PPG X

United Egg XProducers

USFilter X

Virginia Landfills X

Yolo County X

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Innovations Media

Anne Arundel and Buncombe County —Testing Bioreactor Methods: Solid WasteRecirculating Leachate over Alternative Liners

Autoliv—Enabling Metals Recovery from Pyrotechnic Material Hazardous Waste

Chicago Regional Air Quality and Economic Development Project Air

IBM Fishkill—Using F006 Wastes as an Ingredient in Cement Production Hazardous Waste

Lead Safe Boston—Lead-based Paint Debris Disposal Flexibility Hazardous Waste

Chicago POTW—Alternative Effluent Discharge Monitoring Water

NBC POTW—Enhancing the Metal Finishing 2000 Program Water

US Filter—Encouraging Metals Recycling and Recovery Hazardous Waste

Virginia Landfills—Testing the Bioreactor Methods: Comparing a Leachate Solid WasteRecirculation System to the Introduction of Additional Liquid Amendmentsin Sanitary Landfills

Yolo County—Testing a Bioreactor Method: Aerobic versus Anaerobic Technology Solid Waste

Anne Arundel and Buncombe County—Test-ing Bioreactor Methods: RecirculatingLeachate over Alternative Liners. Both AnneArundel County in Maryland and BuncombeCounty in North Carolina are seeking flexibility torecirculate leachate and/or gas condensate overan alternate composite liner and collection systemnot constructed as prescribed in the Resource Con-servation and Recovery Act (RCRA). AnneArundel County is interested in effectively increas-ing its landfill waste capacity while decreasing theconcentration of leachate and reducing the amountof leachate requiring pretreatment and being dis-charged to the local wastewater treatment plant.After design and construction of a small bioreactortest area, liquid will be injected over a four- toseven-year period through injection devices. Toimprove the evaluation of different infiltration sys-tems, the test area will contain both vertical injec-tion wells and horizontal injection trenches.Settlement resulting from accelerated waste de-composition will be monitored using settlementplates.

For its project, Buncombe County is looking to im-prove leachate quality and accelerate waste de-composition and landfill gas generation. Re-

circulating leachate over a specific section of itslandfill will accelerate decomposition of its wasteand shift that waste to a more benign state. Morerapid decomposition will also compress the timelandfill gas is generated, reducing emissions andmaking gas recovery more efficient. To measurehow this alternative approach can provide superiorenvironmental performance, the county would pro-vide a baseline estimate of current conventionalsanitary landfill maintenance. It is anticipated thatthe county will quantify the benefits of the projectagainst this established baseline.

Autoliv—Enabling Metals Recovery fromPyrotechnic Material. Autoliv ASP (Autoliv)manufacturers automobile safety products, includ-ing the pyrotechnic (explosive) materials used todeploy air bag inflators. During the manufacturingof these materials, reactive hazardous wastes aregenerated. These wastes are presently treated offsite at a RCRA permitted treatment storage anddisposal facility (TSDF) that accepts hazardouswaste from outside sources and treats it via openburning. Autoliv currently operates a highly ad-vanced metals recovery facility (MRF) designedto process and recover aluminum and steel fromunfired air bag inflator units as well as previously

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fired inflator units. The MRF has an extensive airpollution control train that is capable of capturingemissions produced by the waste pyrotechnic ma-terial. Autoliv proposes that the technology andpollution control devices used in the MRF beadapted to process their waste pyrotechnic mate-rials on-site rather than sending the materials off-site to a TSDF for open burning. Autoliv is seekingpermitting flexibility under RCRA to be able tomodify their MRF operations and effectively treatand dispose of this pyrotechnic material.

Chicago Regional Air Quality and EconomicDevelopment Project. The City of Chicago’sDepartment of Environment is seeking to exercisea seldom used section [Section 173(a)(1)(B)] ofthe Clean Air Act (CAA) that will create innova-tive criteria to promote clean air and economic de-velopment in urban areas. Section 173(a)(1)(B)allows the EPA Administrator, in consultation withthe Secretary of Housing and Urban Development,to identify zones in which economic developmentshould be targeted. Chicago has dubbed such ar-eas “development zones.” A development zonewould generally be defined as an area that needseconomic development and that advances environ-mental improvements, particularly concerning cleanair. Chicago, U.S. EPA, and Illinois EPA will de-velop criteria that an area must meet to be desig-nated as a development zone. Under thislivability-focused project, a new or modified majorstationary source (facility) that locates in a devel-opment zone (within the Chicago CAAnonattainment area) would draw emission reduc-tions from a growth allowance generated from thestate’s emission inventory—a structure to be ap-proved by the U.S. EPA and Illinois EPA. Thisgrowth allowance would be used in lieu of obtain-ing emission offsets required under CAA—NewSource Review. The growth allowance would becreated using emissions reductions generated byChicago and other municipalities and would bemade available to companies who locate in the de-velopment zones.

IBM Fishkill—Using F006 Wastes as an In-gredient in Cement Production. The IBMFishkill project proposal will help examine the needfor RCRA regulation of a subset of recycling sce-narios involving the production of products used on

the land. Through Project XL, IBM Fishkill is seek-ing an exclusion for the use of the electroplatingwastewater treatment sludge (i.e., F006) as an in-gredient in the production of cement. Under cur-rent regulations there is an exclusion for hazardoussecondary materials that are properly recycledthrough use as an ingredient to produce a product.However, this exclusion is not available if the prod-uct being produced is to be used on the land (orburned for energy recovery). Therefore, eventhough the sludge can be recycled as an ingredientin cement (F006 typically has high concentrationsof calcium, needed in producing cement), it remainssubject to full RCRA regulation, including storagepermits and hazardous waste manifests.

Lead Safe Boston—Lead-based Paint DebrisDisposal Flexibility. Lead Safe Boston is seek-ing to allow less expensive handling and disposal oflead-based paint (LBP) architectural debris fromresidential units. The Lead Safe Boston programcurrently requires toxicity characteristic leachingprocedure (TCLP) lead testing on architecturaldebris before disposal for all projects in accordancewith Massachusetts and EPA regulations. The re-sults of this analysis determines if waste is to beclassified and disposed of as hazardous or non-haz-ardous. When lead waste exceeds EPA limits oftoxicity for disposal as construction debris, it is dis-posed of as hazardous waste. Disposal for classi-fied hazardous waste is costly. TCLP testing canbe costly and time consuming as well. Lead SafeBoston is seeking the flexibility to use provisions ofthe RCRA Household Hazardous Waste Exclusion(HWE) rule for LBP debris. This exclusion wouldallow household LBP debris to be disposed of in amunicipal solid waste landfill that meet certain mini-mum criteria for liners, leachate collection, andgroundwater monitoring. Anticipated cost savingsfrom the flexibility (270 percent reduction in aver-age disposal costs per project) would enable LeadSafe Boston to remove lead from an additional 12residential units.

Chicago POTW—Alternative Effluent Dis-charge Monitoring. The Metropolitan WaterReclamation District of Greater Chicago (ChicagoPOTW), one of the largest publicly owned treat-ment works (POTW) in the country, requested regu-latory flexibility from the Clean Water Act (CWA)

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oversight requirements (i.e., inspection and sam-pling) of the General Pretreatment Regulationspertaining to discharges from small (de minimus)categorical industrial users (CIUs) into the ChicagoPOTW’s water reclamation plants. The ChicagoPOTW project will test several ideas. First, Chi-cago POTW has proposed a new definition of “deminimus” significant industrial user (SIU), usingcriteria specific to their location. Second, ChicagoPOTW, with EPA and Illinois EPA, will developToxic Reduction Action Plans to identify prioritypollutants that are present in quantities that maypose an environmental risk but are not currentlysubject to regulation. Third, Chicago POTW wouldlike to build on its experiences with the CommonSense Initiative’s21 Strategic Goals Program (SGP)to create strategic performance partnerships(partnerships) with metal-finishing facilities that fullyachieve the individual facility goals outlined in theSGP. Under these partnerships, Chicago POTWwill work cooperatively with demonstrated sectorleaders to develop, test, and implement an alterna-tive measurement system for demonstrating envi-ronmental performance. Under currentpretreatment regulations, SIUs must conduct self-monitoring according to EPA sampling protocols,typically involving “end-of-pipe” sampling of efflu-ent. Possible alternative monitoring in the Chicagoproject would use statistical process control datacollected by the SIU that would provide more pre-cise performance and product quality data than tra-ditional monitoring data.

NBC POTW—Enhancing the Metal Finish-ing 2000 Program. The Narragansett Bay Com-mission POTW (NBC POTW), located in themetropolitan areas of Providence and BlackstoneValley, Rhode Island, is working to improve the en-vironmental performance of a select number ofmetal finishing facilities. NBC POTW wants toestablish incentives that promote and reward su-perior performers and focus compliance and tech-nical assistance on problem performers. In 1994,NBC POTW developed a pollution prevention in-tegration program, NBC Metal Finishing 2000, to

test new approaches to improve environmentalcompliance by the local industrial community. Spe-cifically, NBC POTW proposal asks for the flex-ibility to reduce self-monitoring requirements andinspections for top performing industrial users (IUs)so staff can focus on problem IUs. Problem IUswould be identified and given increased oversightin addition to pollution prevention technical assis-tance. This project would define quantitative per-formance criteria for NBC POTW’s metal finishingfacilities and measure the effect of this new ap-proach using performance indicators. To implementthe project, NBC POTW is seeking regulatory flex-ibility that will allow them to (1) replace categori-cal and mass-based standards with more stringentlocal limits specifically designed to protect the fa-cilities’ operations and (2) eliminate certain cat-egorical monitoring requirements for pollutants notpresent based on a facility’s non-use of certain rawmaterials.

USFilter—Encouraging Metals Recycling andRecovery. US Filter Recovery Services (US Fil-ter), a fully permitted hazardous waste treatmentand storage facility in Roseville, Minnesota, is pro-posing to install its resin regeneration system incustomer businesses—such as metal finishers orprinted circuit board manufacturers—that totallydeionizes rinse waters containing F006 wastes,making it available for reuse. Rather than sendingrinse waters to local POTWs, USFilter’s custom-ers would increase recycling, promote recovery,conserve water, and reduce the use of hazardouschemicals. The resin regeneration system consistsof ion exchange canisters that USFilter would in-stall on customer’s process lines that contain waste-waters. Once diverted into the canisters, the metalsin the wastewater will adhere to the resin materialin the canister, rendering the water free of metalcontaminants. The water can then be reused in thecustomer’s process lines. Once the resins are spent,these canisters can be replaced by US Filter, whothen regenerates the resins. This potentially allowsthe metals to be reclaimed rather than land dis-posed. Excluding ion exchange canisters from someor all RCRA hazardous waste requirements couldpromote improved electroplating sludge manage-ment. In place of existing RCRA regulatory re-quirements, the USFilter proposal asks participantsto manage the F006 (electroplating sludge)

21EPA launched the Common Sense Initiative in 1994 withthe broad purpose of seeking “cleaner, cheaper, and smarter”sector-based approaches to protecting human health and theenvironment, and has been a primary component of EPA’sregulatory reinvention efforts.

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wastestreams in accordance with alternative man-agement requirements.

Virginia Landfills—Testing BioreactorMethods: Comparing a Leachate Recircula-tion System to the Introduction of AdditionalLiquid Amendments in Sanitary Landfills. Thisproposal encompasses two separate Waste Man-agement landfill sites in Virginia that are being con-sidered together as part of one larger project. WasteManagement will implement two slightly differentwaste treatment systems at the sites. One site(Maplewood Landfill in Amelia County) will recir-culate leachate to provide moisture. The other (KingGeorge County) will introduce additional liquidamendments (graywater, stormwater) to its land-fill. In addition to implementing two different wastetreatment systems, the project will compare theperformance and results achieved at the two sites(biodegradation potential, methane generation,settlement, landfill capacity extension) and exam-ine the costs and benefits associated with eachtreatment method. To be able to apply liquids otherthan leachate or gas condensate to the King Georgesystem, Waste Management is requesting flexibil-ity from current RCRA requirements.

Yolo County—Testing a Bioreactor Method:Aerobic versus Anaerobic Technology. TheYolo County Bioreactor Landfill (Yolo County), lo-cated in California, will operate its next landfillmodule as a controlled bioreactor landfill. To dothis, Yolo County is seeking flexibility from RCRArestrictions that preclude the addition of bulk or non-containerized liquid amendments (graywater, sep-tic water) to landfills. The bioreactor methodaccelerates waste decomposition and leachatetreatment via the addition of liquid amendmentsthrough a network serving the waste mass. Thisprocess is designed to accomplish a more rapidcompletion of composting, waste stabilization, andmethane generation than in a conventional landfill.The Yolo County proposal plans to physically sub-divide the landfill module and operate it as both ananaerobic and aerobic bioreactor. The aerobicbioreactor differs from an anaerobic one in being aprocess of “landfill-based composting.” For theaerobic half of the module, atmospheric air will bedelivered to the waste in addition to liquid. This airwill in effect dry out the waste mass. The amount

of liquid added to the aerobic part of the modulewill then be increased to accommodate any dryingeffects. The aerobic bioreactor will not createmethane but will degrade significant waste frac-tions such as lignin and leachate chemical oxygendemand (COD) components.

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Pennsylvania DEP—Investigating an Alterna-tive Approach to Promoting Coal Remining.The Pennsylvania Department of EnvironmentalProtection (Pennsylvania DEP) is exploring an al-ternative approach to improve overall in-streamwater quality by reducing mine drainage and re-claiming scarred lands resulting from abandonedcoal mines in Pennsylvania. Pennsylvania DEP willdevelop a new approach to promoting coal reminingbased on compliance with best management prac-tices (BMPs) instead of National Pollutant Dis-charge Elimination System (NPDES) numericeffluent limitations. The CWA NPDES permits forremining currently establish site-specific numericeffluent limitations representing best available tech-nology. To implement its alternative permit ap-proach, Pennsylvania DEP is exercisingenforcement discretion to provide that reminors maycomply with non-numeric limitations in the form ofspecific BMPs as well as in-stream monitoring re-quirements to measure the performance ofremediation activities on in-stream water quality.

United Egg Producers—Environmental Man-agement Systems/Third-Party Certification.The United Egg Producers (UEP), a farmer coop-erative representing egg producers nationwide, isseeking the capability to operate under a statewidepermit rather than a facility specific NPDES per-mit as required under the CWA. A significant por-tion of the farms that the UEP represents areclassified as Concentrated Animal Feeding Opera-tions (CAFO), which must obtain individual NPDESpermits for their activities. If these farms were al-lowed to operate under a statewide general permit,it would significantly reduce compliance costs forthese UEP farms. In exchange for the reducingthe permitting burden, these UEP farms wouldachieve “zero discharge” status through the devel-opment of a comprehensive environmental man-

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Innovations Media

Pennsylvania DEP—Investigating an Alternative Approach to Promoting WaterCoal Remining

United Egg Producers—Environmental Management Systems/Third-Party WaterCertification

agement system (EMS). Furthermore, UEP pro-poses to establish an EPA-approved third-partycertification program that would be required toverify individual EMS’s and the zero discharge sta-tus among CAFO operations. This new stream-lined permitting would alleviate the pressure onstates to perform inspections on the egg industry,expedite the permitting process for egg producingfacilities, help ensure continuing compliance, andachieve superior environmental performance.

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Puget Sound—Integrated Marine Environ-mental Compliance Program. Using the ProjectXL/ENVVEST process, the Puget Sound NavalShipyard (Puget Sound) in Bremerton, Washing-ton, is proposing to develop and demonstrate analternative, long-term, cost-effective strategy forprotecting and improving the health of Sinclair In-let. The Puget Sound project is intended to achieveits objectives through the use of sound ecologicalscience and risk based management, employingapproaches consistent with the draft EPA Ecologi-cal Risk Assessment Guidelines. It will demonstrateconcepts currently under development for navalshipyards by marine scientists at the Naval Com-mand, Control, and Ocean Surveillance Center.While retaining Puget Sound’s existing pollutioncontrol baselines as the floor, existing permits wouldbe revised to replace traditional narrowly focusedmonitoring, compliance, and reporting requirementswith innovative monitoring programs and pollutionprevention measures that are anticipated to achievebetter environmental results.

New Jersey Gold Track—Performance-basedApproaches to Environmental Management.The New Jersey Department of EnvironmentalProtection (New Jersey DEP) envisions the GoldTrack as a multimedia program that will move awayfrom a front-end review and approval process to-ward back-end monitoring while tracking and main-taining a cost-effective high level of public healthand environmental protection. Gold Track is as anenhancement of the state’s Silver Track Program,New Jersey DEP’s first step toward implementinga regulatory structure that is accountable, measuresenvironmental performance and provides opera-tional flexibility. The premise of Gold Track is thatdifferent levels of environmental performance war-rant varying degrees of regulatory oversight andflexibility. The Program is being designed to re-

quire increased levels of commitment in return forincreased regulatory flexibility for qualifying enti-ties based upon their demonstrated capability andenvironmental performance. The New Jersey GoldTrack proposal plans to use media-specific addendato define specific state and Federal flexibilities tobe granted to program participants. Each adden-dum would be negotiated separately—the first ad-dendum for the project would be air specific—andwould define flexibility granted, superior environ-mental performance gained, and the evaluation pro-cess used to judge the effectiveness and benefitsof the flexibility.

Port of Houston Authority—Port/Tenant En-vironmental Management Programs. The Portof Houston is a 25-mile-long complex of diversi-fied public and private facilities. The Port of Hous-ton Authority (PHA) is authorized by Texas law asan autonomous governmental entity that acts as alandlord for port tenants. Additionally, the PHA maybe subjected to enforcement actions for tenant vio-lations of environmental regulations. The PHAproject proposal seeks to test the benefits of pro-viding regulatory flexibility in exchange for a ten-ant environmental management program designedto improve compliance. To improve tenant compli-ance, the PHA would develop a compliance manualthat contains guidelines describing the roles andresponsibilities of key members of the port staff.Specifically, the guidelines will include environmentalcompliance procedures and an environmental regu-latory matrix that summarizes federal, state, andlocal regulations that affect operations at the PHA.PHA’s proposal also establishes a compliancebaseline and has set a goal for 20 percent improve-ment in compliance. In exchange, the PHA is seek-ing regulatory flexibility to minimize the liability/compliance obligations of a landlord port for actsand omissions of their tenants.

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Innovations Media

Puget Sound—Integrated Marine Environmental Compliance Program Water

New Jersey Gold Track—Performance-based Approaches to Environmental Multi-mediaManagement

Port of Houston Authority—Port/Tenant Environmental Management Programs Water

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Clermont County XLC—Community-basedWatershed Protection. Clermont County, Ohio,(Clermont County) is developing a community-de-signed watershed management plan consistent withits goals of improving water quality in the LittleMiami River Watershed while maintaining oppor-tunities for economic growth. To improve waterquality and encourage all polluters to share in thenecessary expense, Clermont County seeks to de-velop and apply locally developed water quality stan-dards that are based on local environmentalconditions while employing a collaborative goal set-ting approach for managing its resources. Thisproject will develop an environmental protectionplan to integrate Clermont County’s watershedmanagement plan into a broader state plan admin-istered by the Ohio Environmental ProtectionAgency (OEPA). Clermont County will develop asampling and monitoring program and a computer-based watershed model as part of its watershedmanagement plan. Sampling and monitoring willallow the compilation of data on existing environ-mental conditions in the watershed and help assessthe effects of point and non-point source pollution.Computer modeling will enable predictions of theimpact land management policies will have on thewatershed. As an incentive to encourage non-pointsource reductions, Clermont County’s watershedmanagement plan could use an effluent trading sys-tem in which pollution credits may be exchangedamong point and non-point source polluters.Clermont County is seeking flexiblity under the

NPDES permit system to provide time to study andanalyze watershed conditions in order to preparethe watershed management plan. Flexibility mayalso be needed in considering the development of apoint/non-point effluent trading system.

Columbus—Enhancing a Local Lead HazardProgram. The City of Columbus’ Division of Wa-ter (Columbus) is pursuing a means to increase thefunds needed to implement a comprehensive Lead-Safe Columbus Program (LSCP) to identify andreduce lead hazards. The LSCP would be an leadabatement alternative to the Lead and Copper Rule(LCR) requirements for testing and replacementof lead service lines (LSLs). Specifically, Colum-bus seeks a three-year window of regulatory flex-ibility from LSL testing requirements in the Leadand Copper Rule, which was promulgated underthe Safe Drinking Water Act. As long as the con-ditions of this flexibility are met, Columbus will give$300,000 a year for 15 years to the Columbus healthdepartment to fund the LSCP. These funds will al-low the LSCP to provide greater public health pro-tection from lead exposure in Columbus’community than would be obtained by strict adher-ence to the LCR requirements. The scope andbreadth of the LSCP would enable it to proactivelyidentify and prevent potential lead hazards. LSCPinterventions will be developed for children most atrisk for lead poisoning and targeted at those expo-sure pathways that would have the greatest im-pact on a child’s body-lead burden.

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Innovations Media

Clermont County—Community-based Watershed Protection Water

Columbus—Enhancing a Local Lead Hazard Program Hazardous Waste

Crompton TBT—Flexibility in the Tributyltin Monitoring Program Water

Kodak and PPG—Pollution Prevention Assessment Framework (Developing Hazardous WasteEnvironmentally Preferable Products In the Chemical Industry Through TechnologyTransfer)

Fort Worth—Proactive Demolition of Structures Containing Asbestos Air

Labs21—Increased Efficiency in Lab Operations Water

Ortho-McNeil Pharmaceutical—Catalytic Oxidation of “Mixed Waste” Hazardous Waste

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Crompton TBT—Flexibility in the TributyltinMonitoring Program. The Crompton TBT pro-posal focuses on eliminating water monitoring re-quirements for the Crompton Corporation.Crompton is a major manufacturer of tributyltin(TBT), a compound used in producing paint coat-ings for marine vessels. TBT-based paints assist inkeeping ship hulls free of marine organisms by act-ing as a biocide and as an agent that introduces a“self-polishing” quality to marine paints. TBT-basedpaints contain toxic substances and have the po-tential to affect non-target marine organisms in thevicinity of shipyards and marinas. In 1989, pursu-ant to the Federal Insecticide, Fungicide and Ro-denticide Act (FIFRA), EPA issued a data call-in(DCI) to Crompton, which required the companyto measure, for 10 years, the effectiveness of regu-lations in reducing tributyltin concentrations in wa-ter columns, sediments, and marine organism tissueat certain specified areas of the Great Lakes andthe intercoastal waterways of the United States.The 1989 DCI mandated the collection and gen-eration of a significant amount of data and docu-mentation. For example, the company’s annualreport, which only summarizes the end results ofthe monitoring program, is typically more than 3,000pages long. To date, Crompton has gathered overseven years of data. These data from Cromptonand other TBT-manufactures have shown a down-ward trend in TBT concentrations. Given that trend,Crompton is seeking to eliminate the monitoringrequirements mandated by the 1989 DCI and touse the resulting cost savings to decrease emis-sions of hazardous air pollutants (HAPs) and vola-tile organic compounds (VOCs) at Crompton’s Taft,Louisiana, plant by 15 percent.

Kodak and PPG —The Pollution PreventionAssessment Framework (Developing Envi-ronmentally Preferable Products in the Chemi-cal Industry Through Technology Transfer).Eastman Kodak (Kodak) and PPG Industries(PPG) are applying the EPA Pollution PreventionFramework (Framework) to design and developnew chemicals. Use of the Framework can yieldsafer new chemicals, stimulate reformulation ofexisting products, and reduce generation of haz-ardous wastes. The Framework is a set of com-puter models, developed by EPA’s Office ofPrevention, Pesticides, and Toxic Substances, that

predicts risk related properties of chemicals wheredata are limited. The models derive risk informa-tion based on chemical structure to promote pollu-tion prevention and improve product design andstewardship. The Framework can be used to esti-mate physical-chemical properties, environmentalfate, and hazard to humans and aquatic life. Use ofthe Framework will enable the companies to sub-mit chemicals that are on average less toxic thanthose from a development cycle with no assess-ment feature. Both Kodak and PPG XL projectsinvolve the use of this chemical risk screening earlyin the product development cycle. Kodak and PPGare seeking regulatory flexibility under thepremanufacture notice (PMN) provisions of theToxic Substances Control Act (TSCA). UnderProject XL, Kodak and PPG will be allowed tomanufacture PMN chemicals in 45 days, ratherthan after 90 days as is currently required underthe TSCA. This flexibility will apply only to lowerrisk chemicals that will generally have been as-sessed by EPA within 25 to 28 days. Both PPGand Kodak will disseminate information about theFramework to other chemical companies and in-dustries. PPG will publish a validation study to verifythe accuracy of selected Framework models.Kodak will complete an environmental cost ac-counting study that will describe the economic andbusiness benefits that result from use of the Frame-work. Kodak will also complete a study identifyingmanagement practices that facilitate pollution pre-vention outcomes.

Fort Worth, Texas—Proactive Demolition ofStructures Containing Asbestos. The City ofFort Worth’s proposal features an alternativemethod for the demolition of structures that haveasbestos-containing building materials (ACBM) butthat are not in danger of imminent collapse. Essen-tially, Fort Worth is seeking the regulatory flexibil-ity to demolish substandard structures not in dangerof imminent collapse similar to the shortened pro-cedure that exists for structures that are in immi-nent danger of collapse. In place of the currentCAA National Emission Standards for HazardousAir Pollutant (NESHAP) requirements for the regu-lated asbestos-containing materials (RACM) instructures, Fort Worth would test its own processfor managing HAPs. This “Fort Worth” methodintegrates “wet” demolition methods, air monitor-

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ing, and proper handling/disposal techniques to testif their method with RACM left in place is at leastas protective as demolition with the RACM re-moved. The Fort Worth method will create signifi-cant cost savings for performing environmentallysound proactive nuisance demolitions allowing lo-cal governments to tackle the problem of urbanblight more successfully by performing more demo-litions.

Labs21—Increased Efficiency in Lab Opera-tions: The Labs21 proposal endeavors to encour-age laboratory owners, operators, and designers toimprove their energy efficiency and water conser-vation with a new laboratory management ap-proach. This agreement would function as anumbrella final project agreement (FPA), and doesnot describe any specific federal regulatory flex-ibility. These flexibilities would be agreed upon at alater date and would attain measurable superior en-vironmental performance beyond what is achievedby labs under current federal and state regulatorysystems. Using the Labs21 approach, EPA andDOE estimate that laboratories can decrease en-ergy consumption by 60 to 75 percent. EPA hasapplied the Labs21 approach to an existing EPAlaboratory and expects to reduce its annual elec-tric demand by 68 percent and its utility costs byalmost 75 percent. Assuming that only 25 percentof U.S. laboratories achieve a 60 percent reduc-tion in energy consumption, the United States wouldreduce its annual energy consumption by an amountequivalent to the yearly energy consumption of840,000 U.S. households and save $1.25 billiondollars. In the future, as laboratory energy efficiencyimproves, Labs21 will focus on even more aggres-sive pollution prevention goals and strategies uniqueto each type of laboratory.

Ortho-McNeil Pharmaceutical—CatalyticOxidation of “Mixed Waste.” Ortho-McNeilPharmaceutical (OMP), in conjunction with theR.W. Johnson Pharmaceutical Research Institute(PRI), uses radio-labeled compounds for pharma-ceutical research and development. This manufac-turing process yields a waste solution containingboth radioactive material and an organic compound,which constitutes a low-level “mixed waste” un-der RCRA. Ortho-McNeil is proposing to use anon-site bench-top catalytic oxidation process to

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treat the mixed waste, which would use a moreefficient, environmentally safe process as comparedwith current off-site waste management and dis-posal practices. The oxidation treatment processdestroys the hazardous organic component of themixed waste, transforming it into a relatively in-nocuous low-level radioactive waste that is easilystabilized. This oxidation process meets the RCRAdefinition of “treatment,” requiring a TSDF permitunder RCRA. To use catalytic oxidation as an on-site treatment alternative, EPA will grant OMP andPRI a conditional exclusion from the RCRA haz-ardous waste definition for the organic componentof its process waste solution.

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Innovations Media

NASA—Realtime Web-based Information Management Multi-media

NASA—Real-time Web-based InformationManagement. The National Aeronautics andSpace Administration (NASA) White Sands TestFacility proposes to implement an extensive Web-based information management and regulatory re-porting system that will provide EPA and multiplestate agencies from New Mexico real-time accessto reports and information. This system will saveresources, including document preparation time,white paper usage, and triplicate reproduction re-quirements. A Web-based system will have sev-eral benefits over the existing reporting systemwhich is largely paper-based. Web-based informa-tion management will provide more real-time, userfriendly data. This will enhance communicationswith other agencies by providing immediate accessto detailed environmental compliance informationincluding graphical illustrations of current conditions,access to the groundwater monitoring databasesystem, and an electronic archival of historical docu-mentation. In turn, NASA seeks regulatory flex-ibility from certain reporting requirements specifiedin site-specific regulatory documentation and per-mits. The information contained in the NASA Web-based system would be sufficient to satisfy currentregulatory requirements; only the format, deliverymethod, and data archival procedures would bemodified. �

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With experiments now underway, we are carefully watching the re-sults. This is an important step if we are to progress toward our ulti-mate goal—scaling up successful concepts and approaches for broaderapplication. We know that in order for these experiments to realizetheir true potential, we must use what we learn to make improvementsin our national programs. In some cases, existing policies and regula-tions may have to be adapted to reflect more up-to-date knowledgeand technology.

As highlighted in “Learning From Experiments,” some innova-tions are already being adopted into our system of environ-mental protection for everyone’s benefit. Some innovations

are still emerging, yet throughout the process for developing theseexperiments, even projects that are very early in the implementationstages have highlighted opportunities for EPA to adopt fresh, transfor-mational strategies for achieving cleaner, cheaper and smarter solu-tions to environmental problems.

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�� Throughout the experimentation process, EPA remains committed tothe basic principles of Project XL. Some projects last for several years,so EPA will remain engaged with project sponsors to track the evolu-tion of innovations and gauge the actual environmental performanceagainst expected outcomes. Experiments must show superior envi-ronmental performance and meaningful involvement of interested par-ties and they must be transferable to other facilities, processes ortechnologies. Early Project XL results indicate that we can createbetter environmental outcomes when all affected parties work togethertoward a common goal.

Today, as an organization EPA faces new phases of the Project XLchallenge: As the information on project results expands exponentially,what are the best methods for transforming results into knowledge?As we evaluate and learn how these new tools work, how do wematch the right tools to the right problems? How do we increase ourrate and scale of adopting new ideas into appropriate system-widepractice? How do we translate our innovation experience into improvedprocesses that will enhance our ability to test new concepts?

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22 Everett M. Rogers. Diffusion of Innovations, 4th Edition,New York: The Free Press, 1995.

In theory, the innovation process in an organizationcan be divided into two broad activities— incuba-tion and implementation22 . Incubation is defined ascollecting information, conceptualizing, and plan-ning for the innovation’s testing, all leading up tothe decision to adopt. During the incubation phase,the organization must recognize the need for inno-vations and have a matching willingness to experi-ment. For Project XL, incubation includes the stepsleading up to the signing of the final project agree-ment (FPA). The decision to test a Project XL in-novation separates the incubation phase from theimplementation phase. Implementation consists ofall the events, actions, and decisions leading to theadoption of an innovation. In the implementationphase, the organization must produce results toverify the innovation’s potential, clarify results asthe innovation is put into more widespread use, androutinize the innovation into its regular activities.The innovation process is complete when the inno-vation becomes a routine part of the organization’sbusiness process and environmental protection system.

EPA plans to explore the application of this theoryof the innovation process, as well as related theo-ries and processes in an effort to continue buildingour system of innovation for Project XL. This im-portant phase of Project XL coincides with aAgency-wide effort to learn from this and otherinnovation efforts how to best infuse the regula-tory climate with processes that will address con-stantly changing conditions—environmental,technical, socioeconomic, and political—throughnew, creative solutions.

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�� As a vehicle for testing new ideas in environmen-tal protection, Project XL is unprecedented. Pre-dictably for an experimental program, it has notbeen without some conflict and controversy. But italso has yielded important discoveries and insightsabout ways to improve environmental results. Of

the many lessons EPA has learned from this uniqueprogram, some of the most important are:

• It is possible to experiment with new ap-proaches outside the traditional regulatory sys-tem as long as strong, reliable safeguards arein place.

• Some businesses and communities are not onlywilling, but eager, to take greater responsibilityfor environmental results if they are given flex-ibility in meeting the goals.

• If given an opportunity, citizens and other stake-holders can play an active, creative role in find-ing solutions to problems.

• The opportunities to improve become more vis-ible, and the results potentially more significant,when you step back and look at communitiesor facilities as a whole, rather than as a set ofseparate, unrelated components.

Although we have substantial number of experi-ments underway, EPA’s need to test new tools andnew solutions will not end. Our stakeholders willcontinue to have innovative ideas for achievingcleaner, cheaper, and smarter environmental pro-tection and EPA is committed to providing a ve-hicle for testing and implementing those concepts.This next phase will reflect the Agency-wide com-mitment to adopt and implement innovative ideason a larger scale. EPA’s goal is to provide evenstronger incentives for good performance and go-ing beyond compliance by developing new programsand approaches, such as the National EnvironmentalPerformance Track program launched on June 26,2000. Lessons learned in Project XL will continueto be integral to developing these high performancealternatives.

We believe that the type of experimentation allowedunder Project XL is fundamental to continued ad-vances in environmental protection. Indeed, webelieve that sustaining our strong national legacyof environmental progress depends on innovation—at EPA, in state environmental programs, in localgovernments, in businesses, in communities—in allparts of our society. That is why EPA launchedProject XL, and it is why we will continue support-

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ing and encouraging the search to diversify ourenvironmental protection tools, identify new ap-proaches, learn about the keys to their effectiveuse, and match the right tools to the right problems.

The future will undoubtedly raise new challengingissues, but we are better prepared than ever to re-spond. With the results of the full array of projectsat hand, along with the results from the Agency’sother innovative efforts, the greatest challenge willbe selecting among all the available options to de-sign the most effective response to existing andemerging environmental problems. In some cases,existing laws and regulations will continue to bethe best way to reduce risk. But better results atlower costs may be realized by applying tailoredstrategies that involve pollution prevention, maxi-mizing the use of new technology, site specific re-investment, new reporting alternatives, livability andsmart growth strategies, and other incentives.Through Project XL and EPA’s other innovativeefforts we will meet the challenges of tomorrowby finding, testing and adopting cleaner, cheaperand smarter environmental management strategiestoday. �

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2��This report relies on the cumulative information from a number ofsources. The sections below describes these sources with brief de-scriptions of the methodologies involved in developing them.

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Project sponsors prepare quarterly, midyear, or annual reportsas required by the individual project final project agreements(FPAs). For more information on these reports, please visit

EPA’s Project XL Web site at http://www.epa.gov/ProjectXL.

%�(��!��Progress reports completed in March and December 1999 provide anoverview of the status of projects implementing final project agree-ments for one year or more. These reports are developed by EPAwith the assistance of the project sponsors and co-regulators; and thestakeholders who are direct participants in the projects have the op-portunity to review them. The progress reports include (1) a back-ground section briefly describing the facility’s project and anticipatedenvironmental benefits, (2) a description of the regulatory flexibilityoffered by EPA and other regulatory agencies, (3) a summary of inno-vations and potential system change, (4) the status of commitmentsmade by the facility, (5) a review of the progress in environmentalperformance, (6) a summary of the stakeholder involvement for theproject, (7) names and organizations of the project contacts, and (8) asix-month outlook section. These progress reports are available on theInternet via EPA’s Project XL Web site at http://www.epa.gov/ProjectXL.

��)��=��!�EPA conducted focus groups in December 1998, January 1999, andJanuary 2000 for various projects. Focus group participants includedcompany employees, co-regulator representatives (typically state andlocal governments), citizen and non-government organization stake-holders, and EPA Headquarters and regional staff. Project-specificprotocols were distributed to participants prior to each focus groupconference call. During the focus groups, participants gave opinionson (1) the ease and effectiveness of the project implementation pro-

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cess, (2) the value of the project to their organiza-tion, and (3) the opportunities to apply informationgained from the projects more broadly. These arepart of an annual program evaluation cycle forProject XL and serve as an opportunity for projectparticipants to provide feedback to EPA on anyaspect of their experience in developing and imple-menting a project. A list of the focus groups andtheir participants are in Volume 2: Directory ofProject Experiments and Results.

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��!��In September 1998, a report entitled Evaluationof Project XL Stakeholder Processes (EPA-100-R-98-009) was prepared by Resolve, Inc. This re-port provided a review of the design and conductof the stakeholder processes at four of the initialprojects (Intel, Weyerhaeuser, HADCO, Merck).The report described the involvement of stakehold-ers in FPA negotiation and implementation, withinformation on national and local stakeholder per-spectives about their role. It also outlined the vari-ous models developed by company sponsors andreported stakeholder perspectives on the processesas gathered in a stakeholder survey.

In 1999, EPA initiated a second extensive evalua-tion, which was conducted by the Southeast Nego-tiation Network. Project XL StakeholderInvolvement Evaluation (August 2000) coverseight projects in various stages of negotiation orimplementation (Andersen, Atlantic Steel,Crompton, ExxonMobil, HADCO, Intel, New En-gland Universities Laboratories, and VandenbergAFB). It considers the early dynamics of stake-holder processes in projects developing their FPA,stakeholder satisfaction and effectiveness of in-volvement for projects that had recently signed theiragreements, and the status of ongoing involvementin projects that have been underway for at leastone year.

,��%�(��!��The Project XL Preliminary Status Report (Sep-tember 1998) examined three projects in implemen-tation for at least a year as of January 1998: Berry,Intel, and Weyerhaeuser. The report covers theprojects’ initial results on innovation and systemchange, as well as progress in meeting FPA com-mitments, stakeholder participation outcomes, en-vironmental performance, and lessons learned.

The Project XL 1999 Comprehensive Report (Oc-tober 1999) provides an overview of the status of14 projects, as well as program-wide results andlessons learned. It also presents technical and policyinformation on 25 innovations sorted by core func-tions. Information complied in progress reports,focus groups, stakeholder reports, and other docu-mentation and information gained through the ex-perience of Agency staff is synthesized anddescribed. The report follows up the work startedin the Preliminary Status Report.

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Biodegradable: Capable of decomposing under natu-ral conditions.

Black liquor: Spent cooking liquor that has been sepa-rated from the pulp produced by the kraft, soda, or semi-chemical pulping process.

Brownfield: Abandoned, idled, or underused indus-trial and commercial facilities/sites where expansion orredevelopment is complicated by real or perceived en-vironmental contamination. They can be in urban, sub-urban, or rural areas.

Carbon Monoxide (CO): A colorless, odorless, poison-ous gas produced by incomplete fossil fuel combus-tion.

Catalytic Oxidation: Catalytic oxidation is an alterna-tive technology used in selective applications to greatlyreduce emissions due to VOCs, hydrocarbons, odors,and opacity in process exhaust. VOCs are thermally de-stroyed at high temperatures by using a solid catalyst.Catalyst systems used to oxidize VOCs typically usemetal oxides.

Categorical Industrial User: An industrial user whichis subject to a categorical standard promulgated by EPA.

Categorical Pretreatment Standard: A technology-based effluent limitation for an industrial facility dis-charging into a municipal sewer system.

Chemical Oxygen Demand (COD): A measure of theoxygen required to oxidize all compounds, both organicand inorganic, in water.

Chloroform: A colorless liquid with a sweet odor. It isused primarily in the production of chlorofluorocarbonand in the production of plastics. Its other uses are asan industrial solvent in the extraction and purificationof some antibiotics, alkaloids, vitamins, and flavors; asa solvent for lacquers, floor polishes, resins, fats, adhe-sives, oils, and rubber.

Clean Air Act (CAA): The Clean Air Act is the com-prehensive Federal law that regulates air emissions fromarea, stationary, and mobile sources. This law autho-rizes EPA to establish National Ambient Air Quality Stan-dards (NAAQS) to protect public health and theenvironment.

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Adsorbable Organic Halogens (AOX): AOX is a mea-surement of the amount of organic halogens present inwater. In paper manufacture organic halogens are com-monly byproducts of chlorine bleaching processes. TheAOX value is expressed in equivalent chlorine.

Aerobic: Life or processes that require, or are not de-stroyed by, the presence of oxygen. (See: anaerobic.)

Aluminum Chemical Vapor Deposition Process: A dryprocess used for the current generation semiconductordevice technologies. Vapor deposition technologies in-clude processes that put materials into a vapor state viacondensation, chemical reaction, or conversion.

Anaerobic: A life or process that occurs in, or is notdestroyed by, the absence of oxygen.

Area of Contamination (AOC): A non-discrete landarea on which there is generally dispersed contamina-tion. Generally, for contaminated soil, considered aresampling locations that indicate observed contamina-tion and the area lying between such locations to be anarea of observed contamination. Asphalt or other im-penetrable materials contaminated by site-related haz-ardous substances may be considered areas of observedcontamination.

Asbestos-Containing Waste Materials (ACWM): Milltailings or any waste that contains commercial asbes-tos and is generated by a source covered by the CleanAir Act Asbestos NESHAPS.

Attainment Area: A designated geographic area con-sidered to have air quality as good as or better than thenational ambient air quality standards as defined in theClean Air Act. An area may be an attainment area forone pollutant and a nonattainment area for others.

Baseline Standard: The measure by which future en-vironmental performance can be compared.

Best Management Practice (BMP): Methods that havebeen determined to be the most effective, practical meansof preventing or reducing pollution from non-pointsources.

Biochemical Oxygen Demand (BOD): A measure ofthe amount of oxygen consumed in the biological pro-cesses that break down organic matter in water. Thegreater the BOD, the greater the degree of pollution.

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Clean Water Act (CWA): The Clean Water Act setsthe basic structure for regulating discharges of pollut-ants to waters of the United States. The law gives EPAthe authority to set technology-based effluent stan-dards on an industry basis and continues the require-ments to set water quality standards for all contaminantsin surface waters. The CWA makes it unlawful for anyperson to discharge any pollutant from a point sourceinto navigable waters unless a National Pollutant Dis-charge Elimination System (NPDES) permit is obtainedunder the Act.

Comprehensive Environmental Response, Compensa-tion, and Liability Act (CERCLA): CERCLA is the leg-islative authority for the Superfund program funds andcarries out EPA solid waste emergency and long-termremoval and remedial activities. These activities includeestablishing the National Priorities List (NPL), investi-gating sites for inclusion on the list, determining theirpriority, and conducting and/or supervising cleanup andother remedial actions.

Conditional Delisting: Use of the petition process tohave a facility’s toxic designation rescinded.

Conformity: Conformity is a Clean Air Act requirementintended to ensure that new transportation investmentsdo not jeopardize air quality in nonattainment and main-tenance areas. According to the Clean Air Act, no trans-portation activity can be funded or supported by theFederal government unless it conforms to the purposeof a state’s air quality plan. An EPA rule describing thecriteria and procedures for determining conformity isfound in 40 CFR parts 51 and 93.

Consent Decree: A legal document, approved by ajudge, that formalizes an agreement reached betweenEPA and potentially responsible parties (PRPs) throughwhich PRPs will conduct all or part of a cleanup actionat a Superfund site; cease or correct actions or pro-cesses that are polluting the environment; or otherwisecomply with EPA initiated regulatory enforcement ac-tions to resolve the contamination at the Superfund siteinvolved. The consent decree describes the actionsPRPs will take and may be subject to a public commentperiod.

Consumptive Water Use: Water removed from avail-able supplies without return to a water resources sys-tem, e.g., water used in manufacturing, agriculture, andfood preparation.

Continuous Emission Monitoring (CEM): Continuousmeasurement of pollutants emitted into the atmospherein exhaust gases from combustion or industrial pro-cesses.

Criteria Air Pollutants: The CAA requires EPA to setNational Ambient Air Quality Standards (NAAQS) forcertain pollutants known to be hazardous to humanhealth. EPA has identified and set standards to protecthuman health and welfare for six criteria air pollutants—ozone, carbon monoxide, total suspended particulates,sulfur dioxide, lead, and nitrogen oxides. EPA must de-scribe the characteristics and potential health and wel-fare effects of these pollutants.

Data Call-In: A part of the Office of Pesticide Programs(OPP) process of developing key required test data, es-pecially on the long-term, chronic effects of existingpesticides.

Dioxin: Any one of a family of compounds knownchemically as dibenzo-p-dioxins. Concern about dioxinarises from their potential toxicity as a contaminant incommercial products. Tests on laboratory animals indi-cate that dioxin is one of the most toxic of syntheticcompounds.

Discharge Monitoring Reporting (DMR): Facilities thatdischarge wastewater directly from point sources tosurface waters must submit DMRs under National Pol-lution Discharge Elimination System (NPDES) waste-water permitting.

Dredge: Dredging: Removal of mud from the bottomof water bodies. This can disturb the ecosystem andcauses silting that kills aquatic life. Dredging of con-taminated muds can expose biota to heavy metals andother toxics. Dredging activities may be subject to regu-lation under Section 404 of the Clean Water Act.

Ecological Risk Assessment: The application of a for-mal framework, analytical process, or model to estimatethe effects of human action(s) on a natural resource andto interpret the significance of those effects in light ofthe uncertainties identified in each component of theassessment process. Such analysis includes initial haz-ard identification, exposure and dose response assess-ments, and risk characterization.

Effluent: Wastewater or other liquid, raw (untreated),partially or completely treated, flowing from an indus-trial user, treatment process or treatment plant.

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Electroplating Operations: Involves plating variousmetals onto printed wiring boards and computer com-ponents that provide electronic interconnection.

Emergency Planning and Community Right to Know(EPCRA): Also known as Title III of SARA, EPCRAwas enacted by Congress as the national legislation oncommunity safety. This law was designated to help lo-cal communities protect public health, safety, and theenvironment from chemical hazards.

Emissions Cap: A limit designed to prevent projectedgrowth in emissions from both existing and future sta-tionary sources from exceeding any mandated levels.Generally, such provisions require that any emissionincrease from equipment at a facility be offset by emis-sion reductions from other equipment under the samecap.

End-of-Pipe Controls: Technologies, such as scrubberson smokestacks and catalytic convertors on automo-bile tailpipes, that reduce the emission or discharge ofpollutants to the environment after they have formed.

Engineering Evaluation/Cost Analysis (EE/CA): TheEE/CA is a flexible document tailored to identify andanalyze the scope, goals, objectives, and effectivenessof a non-time-critical removal action. It contains onlythose data necessary to identify the selection of a re-sponse alternative and relies on existing documenta-tion whenever possible.

Environmental Council of States (ECOS): The missionof ECOS is to improve the environment of the UnitedStates by providing for the exchange of ideas, viewsand experiences among states and territories, fosteringcooperation and coordination in environmental man-agement, and articulating state positions on environ-mental issues.

F006 Listing: A hazardous waste that is wastewatertreatment sludge produced from nonspecific electroplat-ing processes and operations.

Feasibility Study (FS): Analysis of the practicabilityof a proposal; e.g., a description and analysis of poten-tial cleanup alternatives for a site such as one on theNational Priorities List. The feasibility study usuallyrecommends selection of a cost-effective alternative. Itusually starts as soon as the remedial investigation isunderway; together, they are commonly referred to asthe “RI/FS.”

Federal Insecticide, Fungicide, and Rodenticide Act(FIFRA): The primary focus of FIFRA was to providefederal control of pesticide distribution, sale, and use.EPA was given authority under FIFRA not only to studythe consequences of pesticide usage but also to re-quire users (farmers, utility companies, and others) toregister when purchasing pesticides. Through lateramendments to the law, users also must take exams forcertification as applicators of pesticides. All pesticidesused in the United States must be registered (licensed)by EPA.

Fenceline Standard: A baseline standard measured atthe property line of a facility.

Flexible Fuel Vehicle (FFV): A vehicle specially de-signed to use methanol or regular unleaded gasoline inany combination from a single tank. The vehicles havea special sensor on the fuel line that detect the ratio ofmethanol to gasoline that is in the tank. The vehicle’sfuel injection and ignition timing are adjusted by anonboard computer to compensate for the different fuelmixtures.

Fly Ash: Non-combustible residual particles expelledby flue gas.

Fugitive Emissions: Emissions not caught by a cap-ture system.

Gasification: Conversion of solid material such as coalinto a gas for use as a fuel.

Global Positioning System (GPS): A precise survey-ing system based on a set of satellites that orbit about12,000 miles above the earth. On earth, a hand-held spe-cialized computer, a portable GPS receiver, can receivesignal from a GPS satellite above the horizon. The re-ceiver then calculates absolute position, an accuracythat is usually within a few feet, or better.

Greenfield: Greenfields are generally parkland, previ-ously undeveloped open space and agricultural lands,located near the outskirts of towns, cities and largermetropolitan areas. (See: Brownfield)

Hazardous Air Pollutants (HAPs): Air pollutants thatare not covered by the National Ambient Air QualityStandards but that may have an adverse effect on hu-man health or the environment. Such pollutants includeasbestos, beryllium, mercury, benzene, coke-oven emis-sions, radionuclides, and vinyl chloride.

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Hazardous Waste: Byproducts of society that can posea substantial or potential hazard to human health or theenvironment when improperly managed. Hazardouswaste possesses at least one of four characteristics(ignitability, corrosivity, reactivity, or toxicity), or ap-pears on special EPA lists.

Hydrogen Chloride: Hydrogen chloride is a non-com-bustible compound that is highly soluble in water. Inaqueous solution, it forms hydrochloric acid. Hydro-chloric acid is used to make and clean metals, to makechloride dioxide for the bleaching of pulp and otherchemicals, to make phosphate fertilizers and hydrogen,for the neutralization of basic systems, in the treatmentof oil and gas wells, in analytical chemistry, and in theremoval of scale from boilers and heat-exchange equip-ment.

Hydrogen Flouride: Hydrogen fluoride, or hydrofluoricacid, is a colorless gas or fuming liquid. It is a chemicalintermediary for fluorocarbons, aluminum fluoride, cryo-lite, uranium hexafluoride, and fluoride salts. It is usedin fluorination processes, as a catalyst, and as a fluori-nating agent in organic and inorganic reactions. It isused to clean cast iron, copper, and brass; remove efflo-rescence from brick and stone; or sand particles frommetallic castings.

Indirect Discharge: Introduction of pollutants from anon-domestic source into a publicly owned waste-treat-ment system. Indirect dischargers can be commercial orindustrial facilities whose wastes enter local sewers.

Influent: Wastewater or other liquid, raw (untreated),partially or completely treated, flowing into a treatmentprocess or treatment plant.

Industrial User: Any non-domestic source which in-troduces pollutants into a municipal wastewater collec-tion system [40CFR 403.3(h)]

Interference: A discharge which, alone or in conjunc-tion with a discharge from other sources, both (1) inhib-its or disrupts the POTW and (2) therefore is a cause forviolation of any requirement of the POTW’s NPDESpermit (including an increase in the magnitude or dura-tion of a violation).

International Organization for Standardization (ISO)14000: ISO 14000 is primarily concerned with environ-mental management. The ISO 14000 series sets out themethods that can be implemented in an organization tominimize harmful effects on the environment caused bypollution or natural resource depletion.

Kraft Mill: Any industrial operation that uses for acooking liquor an alkaline sulfide solution containingsodium hydroxide and sodium sulfide in its pulping pro-cess.

Land Disposal Restrictions (LDR): Rules that requirehazardous wastes to be treated before disposal on landto destroy or immobilize hazardous constituents thatmight migrate into soil and ground water.

Lignin: Organic substance that acts as a binder for thecellulose fibers in wood and certain plants and addsstrength and stiffness to the cell walls. It imparts con-siderable strength to the wall and also protects it againstdegradation by microorganisms.

Low-emitting Vehicle (LEV): A vehicle that emits 0.075g of hydrocarbons per mile.

Maximum Available Control Technology (MACT): Theemission standard for air pollution sources requiringthe maximum reduction of hazardous emissions, takingcost and feasibility into account. Under the CAA Amend-ments of 1990, the MACT must not be less than theaverage emission level achieved by controls on the bestperforming 12 percent of existing sources, by category,of industrial and utility sources.

Maximum Containment Level (MCL): The maximumpermissible level of a contaminant in water delivered toany user of a public system. MCLs are enforceable stan-dards.

Methanol: An alcohol that can be used as an alterna-tive fuel or as a gasoline additive. Poisonous if ingested.

Methyl Chloride: A colorless flammable gas. Used inthe production of chemicals, as a solvent and refriger-ant, and as a food additive. Mildly toxic if inhaled.

Metallization: The fabrication step in which properinterconnection of circuit elements is made. The act orprocess of imparting metallic properties to something.

Mobile Source: Any non-stationary source of air pol-lution such as cars, trucks, motorcycles, buses, air-planes, and locomotives.

“The MON”: The National Emission Standard for Haz-ardous Air Pollutants (NESHAP) for the source category“Miscellaneous Organic Chemical Production and Pro-cesses.” Some examples of these processes are: explo-sives production; photographic chemicals production;polyester resins production; and the production ofpaints, coatings and adhesives.

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Multimedia: Several environmental media, such as air,water, and land.

National Ambient Air Quality Standards(NAAQS): Standards established by EPA under theClean Air Act applicable to outdoor air throughout thecountry.

National Contingency Plan (NCP): The Federal regu-lation that guides determination of the sites to be cor-rected under both the Superfund program and theprogram to prevent or control spills into surface watersor elsewhere.

National Emissions Standards for Hazardous Air Pol-lutants (NESHAPs): Emissions standards set by EPAfor air pollutants not covered by National Ambient AirQuality Standards (NAAQS), that may cause an increasein fatalities or in serious, irreversible, or incapacitatingillness. Primary standards are designed to protect hu-man health, and secondary standards are designed toprotect public welfare (e.g., building facades, visibility,crops, and domestic animals).

National Pollutant Discharge Elimination System(NPDES): A provision of the CWA that prohibits thedischarge of pollutants into waters of the United Statesunless a special permit is issued by EPA, a state, orwhere delegated, a tribal government on an Indian res-ervation.

National Priorities List (NPL): EPA’s list of the mostserious uncontrolled or abandoned hazardous wastesites identified for possible long-term remedial actionunder Superfund. The list is based primarily on the scorea site receives from the Hazard Ranking System. EPA isrequired to update the NPL at least once a year. A sitemust be on the NPL to receive money from the TrustFund for remedial action.

New Source Performance Standards (NSPS): Uniformnational EPA air emission and water effluent standardswhich limit the amount of pollution allowed from newsources or from modified existing sources.

New Source Review (NSR): The NSR provisions of theClean Air Act strive to ensure that potential new sourcesof air pollution (new plants or facilities, or additions toexisting ones) take proper steps to minimize pollutionlevels. The goals of the NSR program are (1) to ensurethat an increase in emissions due to a new source ormodification to an existing source does not significantlydeteriorate air quality; ( 2) to ensure that source emis-sions are consistent with applicable State attainmentplans; (3) to ensure that air quality related values are

not negatively impacted in areas that have greater pol-lution problems; and (4) to establish control technol-ogy requirements that maximize productive capacitywhile minimizing impacts on air quality.

Nitrogen Oxides (NOx): Air pollutants that are the re-

sult of photochemical reactions of nitric oxide in ambi-ent air. Typically, it is a product of combustion fromtransportation and stationary sources. It is a major con-tributor to the formation of tropospheric ozone, photo-chemical smog, and acid deposition.

Nonattainment Area: A designated geographic areathat does not meet one or more of the National AmbientAir Quality Standards for the criteria pollutants desig-nated in the Clean Air Act. (See: Attainment)

Non-time-critical Removal (NTC): Those removalswhere, based on the site evaluation, the lead agencydetermines that a removal action is appropriate and thatthere is a planning period of more than six months avail-able before on-site activities begin.

Organic Compounds: Naturally occurring (animal orplant-produced) or synthetic substances containingmainly carbon, hydrogen, nitrogen, and oxygen.

Oxygen Delignification: Use of oxygen to remove lig-nin from pulp after high-density stock storage and priorto the bleaching system. Oxygen delignification systemequipment includes the blow tank, washers, filtratetanks, any interstage pulp storage tanks, and any otherequipment serving the same function as those previ-ously listed.

Particulate Matter (PM): Fine liquid or solid particles,such as dust, smoke, mist, fumes, or smog, found in airor emissions.

Phosphine: Phosphine occurs as a colorless, flammablegas that is slightly soluble in water. It is used as anintermediate in the synthesis of flame retardants forcotton fabrics, as a doping agent for n-type semicon-ductors, a polymerization initiator, and a condensationcatalyst.

Plant Site Emission Limits (PSELs): Plant site emis-sion limits are facility based emission caps that allowproduction changes and facility expansion without re-curring air quality permit reviews.

Point Source: A stationary location or fixed facility fromwhich pollutants are discharged; any single identifiablesource of pollution; e.g., a pipe, ditch, ship, ore pit,factory smokestack.

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Pollution Prevention: 1. Identifying areas, processes,and activities which create excessive waste products orpollutants in order to reduce or prevent them throughalteration, or eliminating a process. Such activities, con-sistent with the Pollution Prevention Act of 1990, areconducted across all EPA programs and can involvecooperative efforts with such agencies as the Depart-ments of Agriculture and Energy. 2. EPA has initiated anumber of voluntary programs in which industrial, orcommercial or “partners” join with EPA in promotingactivities that conserve energy, conserve and protectwater supply, reduce emissions or find ways of utilizingthem as energy resources, and reduce the waste stream.

Pass-through: A discharge which exits the POTW intowaters of the United States in quantities or concentra-tions which, alone or in conjunction with other dischargesources, is a cause of a violation of any requirement ofthe POTW’s NPDES permit (including an increase in themagnitude or duration of a violation).

Perfluorinated Compounds (PFCs): Compounds inwhich all the hydrogen atoms are replaced by fluorine.PFCs are greenhouse gases and are expected to havelong atmospheric lifetimes.

Point Source: A stationary location or fixed facilityfrom which pollutants are discharged; any single iden-tifiable source of pollution; e.g., a pipe, ditch, ship, orepit, factory smokestack.

Potentially Responsible Party (PRP): A PRP is theowner or operator of a contaminated site, or the personor persons whose actions or negligence may havecaused the release of pollutants and contaminants intothe environment, requiring a remedial action responseunder CERCLA and SARA. The PRP is potentially li-able for the cleanup costs in order to compensate thegovernment for its remediation expenditures.

Pretreatment: Processes used to reduce, eliminate, oralter the nature of wastewater pollutants from non-do-mestic sources before they are discharged into publiclyowned treatment works (POTW).

Premanufacture Notification (PMN): Section 5 ofTSCA regulates anyone who plans to manufacture orimport a “new” chemical substance for commercial pur-poses. Under section 5, EPA requires notice beforemanufacture or importation of non-exempt substancesso that EPA can evaluate whether the chemical sub-stance poses a threat to human health or the environ-ment. This notice is called a premanufacture notice(PMN).

Prevention of Significant Deterioration (PSD): Stan-dards aimed at keeping areas that are in compliance withNational Ambient Air Quality Standards from backslid-ing.

Printed Wiring Board (PWB): A device that provideselectronic interconnections and a surface for mountingelectronic components.

Production Unit Factor (PUF): A production-basedperformance measure.

Pyrolyzed: (Pyrolysis): Decomposition of a chemicalby extreme heat.

Radiolabel: To tag (a hormone, an enzyme, or othersubstance) with a radioactive tracer.

Relative Accuracy Test Audits (RATA): The primarymethod of determining the correlation of continuousemissions monitoring system data to simultaneouslycollected reference method test data, using no fewerthan nine reference method test runs conducted as out-lined in 40 CFR 60, Appendix A.

Regulated Asbestos-Containing Material(RACM): Under the asbestos NESHAP, RACM is de-fined as: (1) friable asbestos material, (2) Category Inon-friable Asbestos Containing Material (ACM) thathas become friable, (3) Category I non-friable ACM thatwill be or has been subjected to sanding, grinding, cut-ting or abrading, or (4) Category II non-friable ACMthat has a high probability of becoming or has becomecrumbled, pulverized, or reduced to powder by the forcesexpected to act on the material in the course of demoli-tion or renovation operations.

Remedial Investigation (RI): An in-depth study de-signed to gather data needed to determine the natureand extent of contamination at a Superfund site; estab-lish site cleanup criteria; identify preliminary alterna-tives for remedial action; and support technical and costanalyses of alternatives. The remedial investigation isusually done with the feasibility study. Together theyare usually referred to as the “RI/FS.”

Remining: The surface mining of previously-mined andabandoned surface and underground mines to obtainremaining coal reserves.

Remote Monitoring Station: Self-containedmultidetector electronic instruments installed at remotelocations in creeks and other water bodies to assessambient water quality and detect real-time changes ofdissolved oxygen, pH, conductance and temperature.

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Removal Action: A removal action is a short-term Fed-eral response to prevent, minimize, or mitigate damageto the public or the environment at sites where hazard-ous substances have been released. Examples of re-moval actions are excavating contaminated soil, erectinga security fence, or stabilizing a berm, dike, or impound-ment. Removal actions may also be necessary in theevent of the threat of release of hazardous substancesinto the environment such as taking abandoned drumsto a proper disposal facility. Removal actions may takeplace at NPL or non-NPL sites.

Remedial Action: Remedial actions are actions docu-mented in the ROD that are taken at NPL sites to elimi-nate or reduce the pollution to levels which prevent orminimize the release of hazardous substances so thatthey do not migrate or cause substantial danger to pub-lic health or welfare, or the environment. An example isto remove hazardous constituents from groundwaterusing pump and treat technologies.

Resource Conservation and Recovery Act(RCRA): Passed in 1976, RCRA gives EPA the author-ity to control hazardous waste from “cradle-to-grave.”This includes the generation, transportation, treatment,storage, and disposal of hazardous waste. RCRA alsosets forth a framework for the management of nonhaz-ardous wastes. RCRA enables EPA to address environ-mental problems that could result from undergroundtanks storing petroleum and other hazardous sub-stances. RCRA focuses only on active and future facili-ties and does not address abandoned sites.

Response Action: Generic term for actions taken in re-sponse to actual or potential health-threatening envi-ronmental events such as spills, sudden releases, andasbestos abatement/management problems. ACERCLA-authorized action involving either a short-termremoval action or a long-term remedial response.

Record of Decision (ROD): A ROD documents the rem-edy decision for a site or operable unit. The ROD certi-fies that the remedy selection process has followed therequirements of CERCLA and the NCP, and discussesthe technical components of the remedy. The ROD alsoprovides the public with a consolidated source of infor-mation about the site.

Reverse Osmosis (RO): Reverse Osmosis is a high-pressure filtration process which separates dissolvedsalt and minerals from water, using a membrane. Cleanwater passes through the membrane, and the salt andminerals are rejected.

Riparian Zone: Areas adjacent to rivers and streamswith a differing density, diversity, and productivity ofplant and animal species relative to nearby uplands.

Safe Drinking Water Act (SDWA): SDWA was es-tablished to protect the quality of drinking water. Thislaw focuses on all waters actually or potentially desig-nated for drinking use, whether from above-ground orunderground sources. The Act authorizes EPA to es-tablish safe standards of purity and requires all ownersor operators of public water systems to comply withprimary (health-related) standards. State governments,which assume this power from EPA, also encourage at-tainment of secondary standards (for example, waterclarity).

Semi-chemical Mill: A mill that produces pulp using acombination of both chemical and mechanical pulpingprocesses, with or without bleaching.

Sludge: A semi-solid residue from any of a number ofair or water treatment processes; this can be a hazard-ous or non-hazardous waste.

Sludge Dryers: A piece of equipment that reduces thevolume and weight of the semi-solid sludge wastes bydrying and reducing the water content of the sludge.

Smelter: A facility that melts or fuses ore, often withan accompanying chemical change, to separate its metalcontent. Emissions cause pollution. “Smelting” is theprocess involved.

State Implementation Plan (SIP): EPA approved stateplans for the establishment, regulation, and enforce-ment of air pollution standards.

Stationary Source: A fixed-site producer of pollution,mainly power plants and other facilities using industrialcombustion processes. (See: Point Source.)

Sulfur Dioxide (SO2): SO

2 gases are formed when fuel

containing sulfur (mainly coal and oil) is burned andcan be formed during metal smelting and other indus-trial processes. Sulfur dioxide is associated with acidifi-cation of lakes and streams, accelerated corrosion ofbuildings and monuments, reduced visibility, and suchadverse health effects as inhibition of breathing, respi-ratory illness, and aggravation of existing cardiovascu-lar disease.

Sulfuric Acid: Sulfuric acid is a clear, colorless, oily,and odorless liquid. It is also known as sulphine acid

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and hydrogen sulfate. Its main use is in phosphate fer-tilizer production. It is also used to manufacture otheracids, explosives, dyestuffs, parchment paper, glue,wood preservatives, and lead-acid batteries in vehicles.It is used in the purification of petroleum, the pickling ofmetal, electroplating baths, nonferrous metallurgy, andproduction of rayon and film; and as a laboratory re-agent.

Superfund: The program operated under the legisla-tive authority of CERCLA and SARA that funds andcarries out EPA hazardous waste emergency and long-term removal and remedial activities. These activitiesinclude establishing the National Priorities List, investi-gating sites for inclusion on the list, determining theirpriority, and conducting and/or supervising cleanup andother remedial actions.

Sustainable Forestry Initiative (SFI): The SustainableForestry Initiative™ is a comprehensive program of for-estry and conservation practices designed to ensurethe continuing sustainable management of forestlands.The SFI was developed nationally through the Ameri-can Forest and Paper Association (AF&PA), whosemembers produce 90 percent of the paper and 60 per-cent of the lumber produced in America today. Compli-ance with the SFI guidelines is mandatory for AF&PAcompanies to retain AF&PA membership.

300-millimeter Wafer: Early this year, Intel announcedit will build its first 300-millimeter, high-volume produc-tion manufacturing facility at its Chandler site. The 300-millimeter wafers represent a technological advance insemiconductor chips over the standard 200-millimeter(8-inch) wafers that are used in many semiconductormanufacturing plants today. 300-millimeter chips offerover twice as much surface area over the conventionalchips and will reduce manufacturing costs per wafer bymore than 30 percent.

Title V of the Clean Air Act: Establishes a Federaloperating permit program that applies to any major sta-tionary facility or source of air pollution. The purposeof the operating permits program is to ensure compli-ance with all applicable requirements of the CAA. Un-der the program, permits are issued by states or, when astate fails to carry out the CAA satisfactorily, by EPA.The permit includes information on which pollutantsare being released, how much may be released, and whatkinds of steps the source’s owner or operator is takingto reduce pollution, including plans to monitor thepollution.

Toxic Release Inventory (TRI): Database of toxic re-leases in the United States compiled from SARA TitleIII Section 313 reports.

Toxic Substances Control Act (TSCA): TSCA wasenacted by Congress in 1976 to give EPA the ability totrack the 75,000 industrial chemicals currently producedor imported into the United States. EPA repeatedlyscreens these chemicals and can require reporting ortesting of those that may pose an environmental or hu-man-health hazard. EPA can ban the manufacture andimport of those chemicals that pose an unreasonablerisk.

Total Kjeldahl Nitrogen (TKN): TKN is defined func-tionally as organically bound nitrogen. TKN is the sumof free ammonia and organic nitrogen compounds whichare converted to ammonium sulfate. Organic nitrogenincludes such materials as proteins, peptides, nucleicacids, urea and numerous synthetic organic compounds.

Total Suspended Solids (TSS): A measure of the sus-pended solids in wastewater, effluent, or water bodies,determined by tests for “total suspended nonfilterablesolids.”

Transitional Low-Emitting Vehicles: A vehicle thatemits 0.125 g of hydrocarbons per mile.

Transportation Control Measure(TCM): TCMs includea variety of measures used to reduce motor vehicle emis-sions, primarily reducing the amount of vehicle milestraveled (VMTs). These can include carpool and vanpoolprograms, parking management, traffic flow improve-ments, high occupancy vehicle lanes, and park-and-ridelots.

Tributyltin (TBT): TBT based paints assist in keepingship hulls free of marine organisms by acting as both abiocide and as an agent that imparts a “self-polishing”quality to marine paints. For ocean going vessels, TBTself-polishing copolymer paints are currently the mosteffective means of preventing ship hull fouling by ma-rine organisms.

Variance: Government permission for a delay or ex-ception in the application of a given law, ordinance, orregulation.

Vehicle Miles Traveled (VMT): A measure of the totalamount of miles traveled by vehicle within a region.

Volatile Organic Compounds (VOCs): Any organiccompound that easily evaporates and participates in

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atmospheric photochemical reactions, except those des-ignated by EPA as having negligible photochemical re-activity.

Wastewater: Spent or used water from a home, com-munity, farm, or industry that contains dissolved or sus-pended matter.

Wastewater Treatment Sludge: The sludge that is pro-duced from the treatment and removal of pollutants ofwastewater.

Watershed: The land area that drains into a stream;the watershed for a major river may encompass a num-ber of smaller watersheds that ultimately combine at acommon point.

“Wet” Demolition Method: A demolition techniquespecified in the Asbestos National Emissions Standardsfor Hazardous Air Pollutants (NESHAP) requirementsto limit the release the asbestos particulates.

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