United States
Environmental Protection
Agency
Solid Waste
and Emergency Response
(5306W)
EPA530-F-96-014
June 1996
1996 Buy-Recycled Series
Paper Products
EeoPurchasing means
considering attributes
such as
*
recycled content
toxicity
reusability
durability
repairability
*
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)
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What Is The CPG?
The CPG
requires
federal
'„ 1 lliJ!!;i!l|
"'ii'iiniifi
agencies to
give preference
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to items made
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from recovered
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materials.
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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
practicable.
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.
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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
process.
• EPA recommends that you allow mills
to count the recycled-content portion of
mill broke. You should not count the
nonrecycled-content portion, however.
Recycled-Content
Recommendations
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.)
The RMAN
S^cled-content
yels to look for
n purchasing
pefproducts.
-------
RMAN Levels for Paper Products
Item
Notes
Recovered Post-
Content consumer
(%) Content (%)
Cotton fiber
High-quality papers used for stationery, invitations,
currency, ledgers, maps, and other specialty items
20
20
r Text and cover
Papeteries
; Offset
Reprographic
, Forms bond
Tablet
Envelope
s
Supercalendered
Machine finished
groundwood
Check safety
Coated
Carbonless
File folders
Dyed filing products
Index and card stock
Pressboard
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
Wove
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
forms
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
• 20
20
20
20
20
10-20
10
10
10
10
10
20
20
20-50
50
50
20-50
•;.-. ;.••--- 20. .;.;;;
20
J ::' ' ''. ". 20 '.•• -.1
20
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.. -. _ ' . _•
20
'..'.. '._•,'.-'. : '20 '-. ;:
10-20 ••';'•
.,:'•," 16 -:.?J
10
10 :
10
10
-• •/ - - -.,
20
20 :
20
.".••' ."•. 20 ••-";
20
20
-------
Item
Newsprint
Notes
Groundwood paper used in newspapers
Recovered
Content
20-100
Post-
consumer
Content (%)
20-85
Bathroom tissue
• towels
Paper napkins
IFacial tissue
General-purpose
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
20-100
40-100
30-100
10-100
40-100
20-60
40-60
30-60
10-15
40
Corrugated containers
(<300 psi)
(300 psi)
£ Solid fiber boxes
Folding cartons
grlndustriai paperboard
Miscellaneous
rtadded mailers
Carrierboard
?:Brown papers
Used for packaging and shipping a variety of
goods
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
25-50
25-30
40
100
100
90-100
5-15
10-100
5-40
25-50
25-30
40
40-80
45-100
75-100
5-15
10-15
5-20
Tray liners
Used to line food service trays. Often contain
printed information
100
50-75
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How Do I Purchase Recycled-Content Paper Products? (continued)
, ,;v '. tig
Remember t
•' 1
specify
recycled- ^ j
content papers j
in printing and
" 'h' ,'!'"!!!"'',!
janitorial
contracts.
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
expectations.
• 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
newsprint.
Sanitary tissue products include
bathroom and facial tissue, paper towels,
napkins, and general-purpose industrial
wipers. When purchasing these
products:
• 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
requirements.
ther your
Recycling
jram includes
lewsprint and
)ackaging.
-------
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
(EPA530-B-95-008).
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.
&EPA
United States
Environmental Protection Agency
401 M Street, SW. (5306W)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
-------
United States
Environmental Protection
Agency
Solid Waste
and Emergency Response
(5305W)
EPA530-F-96-007
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."
PUBLIC 'NOTICE'
••§• 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
exceptions.
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
Permit?
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
facility.
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.
FIiMI
-------
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
years.
!»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.
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How Can the Public
Participate?
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
helpful.
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.
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