United States
                          Environmental Protection
                      Solid Waste
                      and Emergency Response
June 1996
                           1996 Buy-Recycled  Series
                           Paper Products
EeoPurchasing means
considering attributes
      such as
  recycled content
   before you buy
     a product.
      Eight years ago, hardly any recycled-
      content printing and writing paper
    .... existed. Now, it's readily available, along
with recycled-content computer printout paper,
stationery, note pads, paper towels, and
corrugated packaging—and at higher quality and
more competitive prices than ever before. That's
in part due to the leadership shown by
government agencies since 1988, when the U.S. Environmental Protection
Agency (EPA) issued the Procurement Guideline for Paper and Paper
Products Containing Recovered Materials. The 1988 paper guideline's
buy-recycled requirements are now part of EPA's Comprehensive
Procurement Guideline (CPG).

  The CPG identifies seven categories of items, including paper
products, that federal, state, or local agencies, or government contractors,
using appropriated federal funds should purchase with recycled content.
To help guide your purchasing decisions, EPA also issues Recovered
Materials Advisory Notices (RMANs), which recommend ranges of  ..
recycled content for each product designated in the CPG. EPA has now
updated the recommendations for paper products in the recently issued
Paper Products RMAN.
  Although federal agencies have made great strides in buying recycled-
content paper, more can be done. After all, paper is still the most
predominant material in our trash. So the next time you stock up on
paper for your printer,  copy machine, cafeteria, or restrooms, buy
recycled.  By doing this, you're helping create a demand for the used
office paper, old newspapers, and boxes we recycle every day.
                              Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

                      What Is The CPG?
    The CPG
'„	1	lliJ!!;i!l|
  agencies to

give preference
             "'' "!'' '"'"fs!,'!
 to items made
               :: 'ii-fiii;	in	ii|
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from recovered
             ••. 'c j.'jf'Si
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      Paper recycling is increasing all
      across America, making it more
      important than ever to find buyers
for this recovered fiber and promote
purchasing of recycled-content paper by
government agencies.
  That's in part why Congress included
government buy-recycled requirements
for paper in the Resource Conservation
and Recovery Act (RCRA). In response to
RCRA, EPA issued its recycled-content
recommendations for paper products in
1988. President Clinton reinforced those
requirements when he signed Executive
Order 12873 in October 1993 calling for
an increase in the federal government's
use of recycled-content products,
especially paper products.
  In response to the Executive Order,
EPA issued the CPG in May 1995. The
CPG designates 19 new products and
incorporates 5 previously designated
items (including paper) in 7 product
categories that procuring agencies are
required to purchase with recycled
content. (A procuring agency is any
federal, state, or local agency or
government contractor that uses
appropriated federal funds to purchase
products.) If your agency spends more
than $10,000 per year on a product
listed in the CPG, you are required to
purchase it with the highest recycled-
content level practicable. The CPG also
applies to lease contracts covering
designated items.
   The items covered in the paper
products category include various types
of printing and writing papers,
newsprint, sanitary tissue products, and
paperboard and packaging. Your agency
should review its existing affirmative
procurement program to see if any
changes are necessary to meet the
requirements for these products. This
might involve reviewing specifications
or solicitation documents for paper
products and eliminating provisions that
might pose a barrier to their
procurement (such as aesthetic
requirements, including brightness and
dirt content, unrelated to product
performance). As soon as the updated
program is in place, your agency should
begin following the guidelines for
purchasing these products whenever
   The CPG acknowledges, however, that
specific circumstances might arise that
could preclude the purchase of paper
products with recovered materials.
Under the CPG, you may choose to
purchase designated items that do not
contain recovered materials if you
determine that (1) the price of a given
item made with recovered materials is
unreasonable, (2) there is inadequate
competition (not enough sources of
supply) for the item, (3) unusual and
unreasonable delays would result from
obtaining the item, or (4) the item does
not meet your agency's reasonable
performance specifications.

How Do I Purchase Recycled-Content Paper Products?
Key Terms
      Before buying recycled-content
      paper products meeting EPA's
      recommendations, you'll need to
understand some important terms. (See
the RMAN for a complete discussion of
these terms.)

Postconsumer fiber:
• Is the paper recovered in our homes
  and offices.
• Does not include newsstand returns
  and printers' overruns.

Recovered fiber:
• Includes scrap generated at mills after
  the end of the papermaking process;
  converting and printing scrap;
  newsstand returns and printers'
  overruns; obsolete inventory of mills,
  printers, and others; damaged stock;
  and postconsumer fiber.
• Is not waste. EPA has replaced the
  term waste paper used in the 1988
  guidelines with recovered fiber, to
  acknowledge that this material  is a
  valuable resource.
• Must be repulped. Paper cannot
  simply be re-cut or repackaged  to
  count as recovered-content paper.
• Does not include forest residues
  such as sawdust and wood chips
  from forestry operations.

Mill broke:
• Is  scrap generated  in a mill prior to
  the completion of the papermaking
• EPA recommends that you allow mills
  to count the recycled-content portion of
  mill broke. You should not count the
  nonrecycled-content portion, however.
      The Paper Products RMAN
      recommends recycled-content
      levels that you can look for
when purchasing paper products, as
shown in the chart on pages 4 and 5.
Use EPA's RMAN recommendations as
a starting point. The recommendations
are based on market research to
identify recycled-content products that
are commercially available.
   Rather than just one level of recycled
content, the RMAN recommends ranges
for many paper products that reflect
what is currently available in the
United States. Because the recycled
content of paper products varies, you
should contact local paper mills or
merchants to determine product
availability. Try to purchase paper
containing the highest content that is
available to you.
   When buying paper other than
printing and writing paper, specify that
you want paper "containing X percent
recovered fiber, including Y percent
postconsumer fiber." (For most printing
and writing papers, you can simply say
you're looking for 20 percent
postconsumer content.)
   In addition, make sure that you
measure recovered and postconsumer
fiber content as a percentage of the
weight of all fiber in the paper, not as a
percentage of the total weight of the
sheet. (The total weight also includes the
weight of dyes, fillers, and water used in
the manufacturing process.)
yels to look for
   n purchasing

RMAN Levels for Paper Products
Recovered      Post-
 Content     consumer
   (%)      Content (%)
Cotton fiber
High-quality papers used for stationery, invitations,
currency, ledgers, maps, and other specialty items
r Text and cover
; Offset
, Forms bond
Machine finished
Check safety
File folders
Dyed filing products
Index and card stock
Tags and tickets
Premium papers used for cover stock, books, and
stationery and matching envelopes
Used for invitations and greeting cards
Used for book publishing, commercial printing,
direct mail, technical documents, and manuals
Business papers such as bond, electrostatic, copy,
mimeo, duplicator, and reproduction
Bond type papers used for business forms such as
continuous, cash register, sales book, unit sets, and
computer printout, excluding carbonless
Office paper such as note pads and notebooks
Kraft, white and colored (including manila)
Kraft, unbleached
Excludes custom envelopes
Groundwood paper used for advertising and mail
order inserts, catalogs, and some magazines
Groundwood paper used in magazines and catalogs
Used in the manufacture of commercial and
government checks
Used for annual reports, posters, brochures, and
magazines. Have gloss, dull, or matte finishes
Used in the production of multiple impact copy
Manila or kraft
Used for multicolored hanging folders
Used for index cards, postcards
High-strength paperboard used in binders and
report covers
Used for toll and lottery tickets, licenses, and
identification and tabulating cards
• 20
•;.-. ;.••--- 20. .;.;;;
J ::' ' ''. ". 20 '.•• -.1
';'.' ...-".: v-, 2° ':•-.•••'"••
.. -. _ ' . _•
'..'.. '._•,'.-'. : '20 '-. ;:
10-20 ••';'•
.,:'•," 16 -:.?J
10 :
-• •/ - - -.,
20 :
.".••' ."•. 20 ••-";

                           Groundwood paper used in newspapers
              Content (%)
 Bathroom tissue

      • towels

 Paper napkins

IFacial tissue

 industrial wipers
                           Used in rolls or sheets
                           Used in rolls or sheets

                           Used in food service applications
                           Used for personal care

                           Used in cleaning and wiping applications








 Corrugated containers

    (<300 psi)
    (300 psi)

£ Solid fiber boxes
 Folding cartons
grlndustriai paperboard

 rtadded mailers

?:Brown papers
                           Used for packaging and shipping a variety of
Used for specialized packaging needs such as
dynamite packaging and army ration boxes
Used to package a wide variety of foods,
household products, cosmetics,
Pharmaceuticals, detergent, and hardware

Used to; create :tubes, cores, -cans, and drums
                           Includes "chipboard" pad backings, book
                           covers, covered binders, mailing tubes, game
                           boards, and puzzles

                           Made from kraft paper that is usually brown
                           but can be bleached white
                           A type of folding carton designed for multi-
                           pack beverage cartons
                           Used for bags and wrapping paper












 Tray liners
                           Used to line food service trays. Often contain
                           printed information

                      How Do I Purchase Recycled-Content Paper Products? (continued)
          ,    ,;v	'.	tig
 Remember t
           •'    1
    recycled-  	^	j
content papers  j
in printing and
            " 'h' ,'!'"!!!"'',!
Buying Tips
      To make it even easier to buy
      recycled-content paper products,
      EPA offers the following
purchasing tips for the  various paper
product categories outlined in the RMAN.
Printing and writing papers comprise
one of the largest categories of paper and
paper products. Examples include
stationery, computer printout paper, note
pads, copier paper, and offset paper.
Printing and writing papers can be either
uncoated or coated.
   When buying printing and writing
paper, remember to:
• Work with your printer. Different
  papers exhibit differences in
  performance and printability. Some
  printers may first want to test certain
  papers with a particular ink. Printers
  can also help you select papers based
  on how they will be  used (i.e., "whether
  they will be folded, die-cut, or made
  into self-mailers).
• Work with your graphic designer.
  Some papers are better than others for
  certain design needs. Make sure both
  the designer and printer agree that the
  paper you choose will meet your
• Consider the environmental
  ramifications of your purchasing
  decisions. Papers with certain
  characteristics such as deep colors,
  coatings, or groundwood content might
  not be recyclable in your existing
  office paper recycling program or
  might require changes to the program.
  Consider the effects of your paper
  purchases before deciding to purchase
  a specific paper.
                                                              Newsprint is a type of groundwood paper
                                                              generally used to print newspapers.
                                                              Recycled-content newsprint is usually
                                                              manufactured from fiber recovered from
                                                              old newspapers and magazines. The
                                                              federal government uses newsprint for
                                                              printing the Federal Register, Congressional
                                                              Record, and other publications.
                                                                 When purchasing newsprint, consider
                                                              these helpful hints:
                                                              • Pay attention to newsprint's basis
                                                                weight. Basis weight is the weight in
                                                                pounds of a ream of paper cut to a
                                                                specified size. Different weights hold
                                                                up better in different presses.
                                                                Recycled-content newsprint ranging
                                                                from 25 to 32 pounds generally
                                                                performs well. The U.S. Government
                                                                Printing Office specifies 25 pound
                                                                recycled-content newsprint.
                                                              • Consider your requirements  for the
                                                                newsprint you're buying. Recycled-
                                                                content newsprint manufacturers are
                                                                making products that meet their
                                                                clients' performance requirements (e.g.,
                                                                printability, brightness, cleanliness,
                                                                and opacity).

  Determine whether newsprint is
  recyclable in your existing recycling
  program. Some office paper recycling
  programs do not accept groundwood
  papers such as newsprint. Find out
  •whether yours does before you buy
Sanitary tissue products include
bathroom and facial tissue, paper towels,
napkins, and general-purpose industrial
wipers. When purchasing these
• Avoid misconceptions about softness,
  absorbency, and strength. Some
  recycled-content sanitary tissue
  products are softer, stronger, and more
  absorbent than others. Consider your
  aesthetic and functional requirements
  for tissue products before purchasing a
  specific product.
• Remember to review your janitorial
  supply contracts because commercial
  tissue products are often purchased
  through contractors. Make sure your
  supply contracts specify recycled-
  content, not virgin, products.
• When changing brands, consider other
  factors that could influence your
  purchasing decision. For example,
  when switching from sheet to roll
  paper towels, you may incur costs to
  replace dispensers or fixtures if such
  costs are not borne by the supplier.
Paperboard and packaging is a broad
category of paper products that includes
corrugated containers, folding cartons,
book and report covers, mailing tubes,
video cassette boxes, paper bags, and
kraft wrapping paper. They can be
manufactured with a wide variety of
recovered fibers including old
newspapers, old corrugated containers,
mixed papers, and sorted white office
paper. In fact, paperboard mills use more
recovered fiber than any other segment
of the paper industry.
   When purchasing recycled-content
paperboard and packaging:
• Remember that you can print on
  recycled boxes,  not just on virgin,
  bleached boxes.
• Be aware that you can use recycled
  boxes in food applications and still
  meet Food and Drug Administration
     ther your
  jram includes
lewsprint and

                             How Do I  Get More Information?
            Information Available from EPA

            The following publications on buying recycled and
            the CPG are available through the RCRA Hotline. To
            order, call 800 424-9346 (or 800 553-7672 for the
            hearing impaired). In Washington, DC, the number is
   703 412-9810 or TDD 703 412-3323. The RCRA Hotline is open
   from Monday through Friday, 9 a.m. to 6 p.m. EST.
•> Federal Register notices establishing the CPG (60 FR
   21370/EPA530-2-95-007), May 1,1995, and the Paper Products
   RMAN (61 FR 26985/EPA530-Z-96-005),  May 29,1996.
& EPA Issues Comprehensive Procurement Guideline
   (EPA530-F-95-010).This four-page fact sheet provides general
   information about the CPG and the development of affirmative
   procurement programs.
•> Summary of Comments on the Proposed Paper Products
   RMAN (EPA530-R-96-003) and Final Paper Products
   RMAN—Response to Public Commehts (EPA530-R-96-
   004). These  background documents to the Paper Products
   RMAN summarize comments EPA received on the draft RMAN
   and ERA'S response to those comments.
* Draft Paper Products RMAN-Supporting Analyses
   (EPA530-D-95-001).This document provides useful
   information about the various paper products listed in the
   Paper Products RMAN.
The following lists of recycled-content paper manufacturers are
also available from EPA:
•> Mills Which Manufacture Printing and Writing Paper,
   Computer Paper, Office Paper, Envelopes, Bristols, and
   Coated Printing and Writing Papers Using Recovered
   Paper (EPA530-B-95-010).
<• Mills Which Manufacture Newsprint Containing at Least 40
   Percent Postconsumer Recovered Paper (EPA530-B-95-009).
<• Tissue Mills Which Use Postconsumer Recovered Paper

  The above documents are also available on EPA's Public
 Access Server on the Internet (gopher.epa.gov). For the text of
 Federal Register notices, choose: Rules, Regulations, and
 Legislation; Waste Programs; EPA Waste Information-GPO;
 and Year/Month/Date. This fact sheet, the technical support
 documents, and the product availability lists are available  under
L EPA Offices and Regions; Office of Solid Waste and
 Emergency Response; Office of Solid Waste;
 Nonhazardous Waste; and Procurement.
              Other Sources of Information

              * Executive Orders 12873 (October 30,1993)
              and 12995 (March 28,1996). Copies of these
              Presidential Executive Orders are available from
              the Executive Office of the President Publications
   Distribution Service at 202 395-7332.
* U.S. General Services Administration (GSA). GSA
   publishes various supply catalogs, guides, and schedules for
   products available through the Federal Supply Service. The
   Environmental Products Guide is designed to help
   procurement officials identify environmentally preferable
   products and services. It contains more than 1,500 paper and
   paper products containing recovered materials. For a copy of
   the guide, contact GSA, Centralized Mailing List Service
   (7CAFL), 4900 Hemphill St., P.O. Box 6477, Fort Worth, TX
   76115. Phone: 817 334-5215. Fax: 817 334-5227.
* U.S. Government Printing Office (GPO). GPO provides  a
   variety of recycled-content paper products to federal agencies
   to meet their printing needs. For more information about the
   paper products available from GPO, contact Doris Reynolds,
   Printing Specialist, U.S. GPO, Paper and Materials Control
   Section, Stop POL,  North Capitol and H Streets, NW,
   Washington, DC 20401. Phone: 202 512-0241.
* The Official Recycled Products Guide. This directory lists
   more than 5,000 manufacturers and distributors of recycled-
   content products. For more information, contact the Recycling
   Data Management Corp.,  P.O. Box 577, Ogdensburg, NY
   13669. Phone: 800 267-0707.
* National Office Paper Recycling Project. The National Office
   Paper Recycling Project maintains a list of recycled-content paper
   producers and has published several guidebooks on setting up
   and promoting office buy-recycled and recycling programs. For
   more information, contact the National Office Paper Recycling
   Project, 1620 Eye St., NW, Sixth Floor, Washington, DC 20006.
   Phone: 202 293-7330. Fax: 202 429-0422.
* Jaakko Poyry Recycled Gradefinder. This quarterly
   publication provides a comprehensive, up-to-date directory
   of almost 1,000 brands  of recycled-content paper. Entries
   include brand name, manufacturer, grade, postconsumer
   content, brightness, and basis weights. The entries are
   organized alphabetically by brand name, manufacturer or
   distributor, and grade. A one-year subscription costs $90. To
   order, contact Ronni Schram, Jaakko Poyry Consulting, Inc.,
   580 White Plains Road, Tarrytown, NY 10591-5183.
   Phone: 800 872-5792. Fax: 914 332-4411.
               In addition, contact your state solid waste agency for information about local and regional businesses
                                 that produce or distribute recycled-content paper products.
United States
Environmental Protection Agency
401 M Street, SW. (5306W)
Washington, DC 20460

Official Business
Penalty for Private Use

                         United States
                         Environmental Protection
Solid Waste
and Emergency Response
June 1996
                         The  Hazardous Waste
                         Facility  Permitting  Process
                           What Are Hazardous Wastes?
                               • azardous wastes can be liquids, solids, or sludges. They can be by-prod-
                               ucts of manufacturing processes or discarded commercial products. If
                               . hazardous wastes are not handled properly, they pose a potential hazard
                           to people and the environment. To ensure that companies handle waste safely
                           and responsibly, EPA has written regulations that track hazardous wastes from
                           the moment they are produced until their ultimate disposal. The regulations set
                           standards for the hazardous waste management facilities that treat, store, and
                           dispose of hazardous wastes.

                           What Is a Hazardous Waste Management Facility?
                             Hazardous waste management facilities receive hazardous wastes for treat-
                           ment, storage, or disposal. These facilities are often referred to as treatment,
                           storage, and disposal facilities, or TSDFs.

                                ^- Treatment facilities use various processes (such as incineration or oxi-
                                   dation) to alter the character or composition of hazardous wastes.
                                   Some treatment processes enable waste to be recovered and reused in
                                   manufacturing settings, while other treatment processes dramatically
                                   reduce the amount of hazardous waste.

                                ^- Storage facilities temporarily hold hazardous wastes until.they are
                                   treated or disposed of.
                                ^- Disposal facilities permanently contain hazardous wastes. The most
                                   common type of disposal facility is a landfill, where hazardous wastes •
                           .  .      are disposed of in carefully constructed units designed to protect
                                   ground-water and surface-water resources.

                           What Laws and  Regulations Govern TSDFs?
                             EPA has written detailed regulations to make sure that TSDFs operate safely
                           and protect people and the environment. EPA wrote these regulations to imple-
                           ment the Resource Conservation and Recovery Act (RCRA) of 1976 and the
                           Hazardous and Solid Waste Amendments of 1984. The U.S. Congress passed
                           these laws to address public concerns about the management of hazardous
                           waste.   :                                                  •
                             EPA can authorize states to carry out the RCRA program. To receive autho-
                           rization, state requirements must be as strict, or stricter, than the federal
                           requirements. Federal or state agencies that implement RCRA are known as
                           "permitting agencies."
                                   ••§• Printed on paper that contains at least 20 percent postconsumer fiber.

                  What Is  a
                RCRA Permit?

                A RCRA permit is a legally binding
            document that establishes the waste man-
          agement activities that a facility can conduct
       and the conditions under which it can conduct
       them. The permit outlines facility design and
       operation, lays out safety standards, and describes
       activities that the facility must perform, such as
       monitoring and reporting. Permits typically
       require facilities to develop emergency plans, find
       insurance and financial backing, and train employ-
       ees to handle hazards. Permits also can include
       facility-specific requirements such as ground-
       water monitoring. The permitting agency has the
       authority to issue or deny permits and is responsi-
       ble for monitoring the facility to ensure that it is
       complying with the conditions in the permit.
      According to RCRA and its regulations, a TSDF
      cannot operate without a permit, with a few

      Who Needs  a RCRA Permit?

         All facilities that currently or plan to treat,
      store, or dispose of hazardous wastes must obtain
      a RCRA permit.
      ^•New TSDFs must receive a permit before they
         even begin construction. They must prove that
         they can manage hazardous waste safely and
         responsibly. The permitting agency reviews the
         permit application and decides whether the
         facility is qualified to receive a RCRA permit.
         Once issued, a permit may last up to 10 years.
      '^- Operating TSDFs with expiring permits must
         submit new permit applications six months
         before their existing permits run out.
      ^- TSDFs operating under Interim Stattts must also
         apply for a permit. Congress granted "interim
         status" to facilities that already existed when
         RCRA was enacted. Interim status allows exist-
         ing facilities to continue operating while their
         permit applications are being reviewed.

      Who Does Not Need a RCRA

        There are certain situations where a company
      is not required to obtain a RCRA a permit.
 ^•Businesses that generate hazardous waste and
   transport it off site without storing it for long
   periods of time do not need a RCRA permit.
 ^ Businesses that transport hazardous waste do not
   need a RCRA permit.
 ^•Businesses that store hazardous waste for short
   periods of time without treating it do not need
   a permit.

 What Are the Steps in the
 Permitting Process?
    1 '1 Starting the Process
   Before a business even submits a permit
 application, it must hold an informal meeting with
 the public. The business must announce the
 "preapplication" meeting by putting up a sign on
 or near the proposed facil-
 ity property, running an
 advertisement on radio or .
 television, and placing a  '*
 display advertisement in
 a newspaper. At the meeting, the
 business explains the plans for the facility, includ-
 ing information about the proposed processes it
 will use and wastes it will handle.  The public has
 the opportunity to ask questions and make sug-
 gestions. The business may choose to incorporate
 the public's suggestions into its application. The
 permitting agency uses the attendance list from
 the meeting to help set up a mailing list for the

      J Applying for a Permit
   After considering input from the preapplica-
 tion meeting, the business may decide to submit a
permit application. Permit applications are often
lengthy. They must include a description of the
facility and address the following:
      r the facility will be designed, constructed,
  maintained, and operated to be protective of
  public health  and the environment.
       • any emergencies and spills will be han-
  dled, should they occur.
       the facility will clean up and finance any
  environmental contamination that occurs.
       the facility will close and clean up once it
  is no longer operating.

     3 Receipt and Review of the Application
   When the permitting agency receives a permit
application, it sends a notice to everyone on the
mailing list. The notice indicates that the agency
has received the application and will make it avail-
able for public review. The permitting agency
must then place a copy of the application in a
public area for review.
   Simultaneously, the permitting agency begins
to review the application to make sure it contains
all the information required by the regulations.
The proposed design and operation of the facility
are also evaluated by the permitting agency to
determine if the facility can be built and
operated safely.
     4 Revisions, Revisions, Revisions
   After reviewing the application, the permitting
agency may issue a Notice of Deficiency (NOD)
to the applicant. NODs identify and request that
the applicant provide any missing information.
During the application review and revision
process, the permitting agency may issue several
NODs. Each time the permitting agency receives
a response from the applicant, it reviews the
information and, if necessary, issues another
NOD until the application is complete. Given the
complex and technical nature of the information,
the review and revision process may take several
   !»JT Drafting the Permit for Public Review
   When the revisions are complete, the agency
makes a preliminary decision about whether to
issue or deny the permit. If the agency decides
that the application is complete and meets appro-
priate standards, the agency issues a draft permit
containing the conditions under which the. facility
can operate if the permit receives final approval. If
the permitting agency determines that an appli-
cant cannot provide  an application that meets the
standards, the agency tentatively denies the permit
and prepares a "notice of intent to deny."
   The permitting agency announces its decision
by sending a letter to everyone on the mailing list,
placing a notice in a local paper, and broadcasting
it over the radio. It also issues a fact sheet to
explain the decision. Once the notice is issued, the
 public has 45 days to comment on the decision.
 Citizens also may request a public hearing by con-
 tacting the permitting agency. The permitting
 agency may also hold a hearing at its own discre-
 tion. The agency must give 30-day public notice
 before the hearing.

'i&Sep 'tj§The End Result: A Final Permit Decision
   After carefully considering public comments,
 the permitting agency reconsiders the draft permit
 or the notice of intent to deny the permit. The
 agency must issue a "response to public com-
 ments," specifying any changes made to the draft
 permit. The agency then issues the final permit or
 denies the permit.
   Even  after issuing a permit, the permitting
 agency continues to monitor the  construction and
 operation of the facility to make sure they are
 consistent with state and federal rules and with
 the application.
   Several additional steps can also take place
 after the original permit is issued:
 ^-Permit Appeals. Facility owners and the public
   both have a right to appeal the final permit
   decision. The appeal is usually decided upon by
   administrative law judges.
 ^•Permit Modifications. If a facility changes its
   management procedures, mechanical opera-
   tions,  or the wastes it handles, then it must
   secure a permit modification. For modifications
   that significantly change facility operations,  the
   public must receive early notice and have a
   chance to participate and comment. For minor
   modifications, the facility must notify the pub-
   lic within a week of making the change.
 ^•Permit Renewals. The permitting agency can
   renew permits that are due to expire.  Permit
   holders that are seeking a permit renewal must
   follow the same procedures as  a facility seeking
   a  new permit.
 ^•Permit Terminations. If a facility violates the
   terms  of its permit, the permitting agency can
   terminate the permit.

How Can the  Public

   Members of the public have valid concerns
about hazardous waste management. They and
other interested parties can contribute valuable
information and ideas that improve the quality
of both agency decisions and permit applica-
tions. EPA believes that public participation is a
vital component of the permitting process.
Accordingly, EPA has written regulations that
create opportunities for the public  to learn
about RCRA activities and give input during
the permitting process. The preapplication
meeting, public comment arid response periods,
and public hearings are all instances where citi-
zens can engage companies and regulators in a
dialogue. Furthermore, EPA encourages permit-
ting agencies, permit holders or applicants, and
other interested parties to provide additional
public participation activities where they will be
   EPA also realizes that some of the most
important public participation activities happen
outside the formal permitting process. Citizens
can contact environmental, public interest, and
civic and community  groups that have an inter-
est in the facility and  become involved in their
activities. The permit holder or applicant may
also create informal opportunities for public
input and dialogue.
   The permitting process gives citizens a num-
ber of opportunities to express their ideas and
concerns. Here are several steps you can take to
ensure that your voice is heard:
^- Know whom to call at the permitting agency.
   Early in  the process, call the agency to deter-
   mine the contact for the project. This per-
   son's name also should be on fact sheets and
   other printed materials.
^-Ask to have your name put on the facility
   mailing list for notices, fact sheets, and other
   documents distributed by the agency.
^ Do your own research by talking to local
   officials,, contacting research or industry
   organizations, reading permitting agency
   materials, and interacting with interested
   groups in the community.
^- Submit written comments that are clear, con-
   cise, and well documented. Remember that,
   by law, permitting  agencies must consider all
   significant written  comments submitted dur-
   ing a formal comment period.
^•Participate in public hearings and other
   meetings. Provide  testimony, that supports
   your position. Remember that a  public hear-
   ing is not required unless.a citizen specifical-
   ly requests one in writing.
 ^- If any material needs further explanation, or
   if you need to clear up some details about
   the facility or the permitting process, request
   an informational meeting with the appropri-
   ate official. You also may want to call the
   facility to meet with the staff or to request a
   tour or other information.
 ^- Follow the process closely. Watch for per-
   mitting agency decisions and review the
   agency's responses to public comments.
   Remember that citizens may have an oppor-
   tunity to appeal agency decisions.
 ^- Remember that your interest and input are
   important to the permitting agency.     »

 In  Conclusion
   The permitting process for a hazardous
 waste management facility requires a significant
 amount of time and effort. Each participant
 plays a distinct and essential role.  Permit
 applicants must carefully consider the RCRA  .
 regulations when  developing and submitting
 their applications and planning public involve-
 ment activities. The permitting agency must
 review the permit application to ensure that it is
 complete, adequate, and protective of public
 health and the environment. The  agency must
 also coordinate this review to ensure communi-
 ty involvement. The public should become
 familiar with the permitting process and partici-
 pate in it so that community concerns are heard
 and  acted upon. This coordination of efforts
 will  help to ensure that the environment and
 citizens of the United States are protected by
 proper management of hazardous wastes.

 For More Information
   For more information, call the RCRA
 Hotline at 800 424-9346 or TDD 800 553-
 7672 (hearing impaired). In the Washington,
 DC, area, call:703 412-9810 or TDD 703 412-
 3323. You can request the documents RCRA
 Public Participation 'Manual or RCRA Expanded
 Public Participation Rule (brochure). You can 'also
 obtain contact people and phone numbers for
 your state or regional hazardous waste agency.
 Additional information can be found in Title 40
 Code of Federal Regulations, Parts 124, 270, and
 271.    .                     .       .
   The RCRA Expanded Public Participation Rule
 brochure and this fact sheet are accessible on
.the Internet. Go to either gopher.epa.gov or
 http://www.epa.gov, and then Offices and
 Regions, Office of Solid Waste and Emergency
 Response, Office of Solid Waste.