United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-453/B-93-023
October 1993
Air
EPA A Guidebook for Explaining
Environmental Regulations
to Small Businesses
control
technology center
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EPA-453/B-93-023
A Guidebook for Explaining Environmental
Regulations to Small Businesses
CONTROL TECHNOLOGY CENTER
Sponsored by
Emission Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Air and Energy Engineering Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
October 1993
This publication was prepared for EPA by ViGYAN Incorporated
of Falls Church, Virginia, under EPA Contract # 68-D1-0073.
U.S Environ;-^: ^-ction A.ency
, 12th Floor
Chicago, IL 60604-3590
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DISCLAIMER
This report has been reviewed by the Control Technology Center (CTC) established
by the Office of Research and Development (ORD) and Office of Air Quality Planning and
Standards (OAQPS) of the U.S. Environmental Protection Agency (EPA), and has been
approved for publication. Approval does not signify that the comments necessarily reflect
the views and policies of the EPA, nor does mention of trade names, organization names,
or commercial products constitute endorsement or recommendation for use.
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ACKNOWLEDGEMENTS
We would like to take this opportunity to thank the many people who contributed
to the development of this document:
Nancy Davis Georgia Tech Research Institute
Environmental Science & Tech. Lab.
John Conefes Iowa Waste Reduction Center
Mark Trapani
Kevin Dick Nevada Small Business Development Center
Mike Magera
Dan Kraybill Hazardous Waste Research & Information Center
Gary Miller Illinois Dept. of Energy & Natural Resources
Jerry Thielen Department of Ecology
Leighton Pratt Washington State
Richard Cook Institute for Cooperation in Environmental Management
LaRonda Bowen South Coast Air Quality Management District
Office of Small Business
Karen Brown U.S. EPA Office of the Small Business Ombudsman
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PREFACE
This project was funded by EPA's Control Technology Center (CTC) and prepared by
ViGYAN Incorporated.
The CTC was established by EPA's Office of Research and Development (ORD) and
Office of Air Quality Planning and Standards (OAQPS) to provide technical assistance to State
and local air pollution control agencies. Several levels of assistance are provided by the CTC.
First, a CTC Hotline is available to provide telephone assistance on matters relating to air
pollution control technologies. Second, more in-depth engineering assistance is provided when
appropriate. Third, the CTC can provide technical guidance by designing technical guidance
documents, developing personal computer software, and presenting workshops on control
technology matters. The CTC is also the focal point of the Federal Small Business Assistance
Program, and maintains the Reasonably Available Control Technology/Best Available Control
Technology/Lowest Achievable Emission Rate (RACT/BACT/LAER) Clearinghouse and Global
Greenhouse Gases Technology Transfer Center. Information concerning all CTC products and
services can be accessed through the CTC Bulletin Board System (BBS), which is part of the
OAQPS Technology Transfer Network (TTN) bulletin board system.
This publication was prepared in support of the Federal Small Business Assistance
Program. One main pro-active function of the Small Business program will be to provide
materials to explain new standards and rules to small businesses. This document presents
guidelines on how to prepare materials that explain technical information in layman's terms.
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TABLE OF CONTENTS
Page
OVERVIEW i
SECTION 1. SMALL BUSINESS ISSUES 1-1
1. Small Business Concerns 1-1
2. Small Business Perceptions of Government & Regulations 1-2
3. Writing for Different Reading Levels 1-3
SECTION 2. GUIDELINES FOR PREPARING AN ENABLING DOCUMENT . . . IM
1. Content & Format II-l
a. Prepare an Overview II-l
b. Use a Question & Answer Format II-2
c. Provide a Disclaimer . II-2
d. Use a Table of Contents For Longer Documents II-6
e. Include Contact Phone Numbers and Addresses II-6
f. Refer the Reader to State and Local Agencies II-6
2. Style II-8
a. Avoid Jargon II-8
b. Avoid Quoting Verbatim II-8
c. Keep the Language Conversational - II-9
d. Avoid Large Blocks of Text II-9
e. Get Straight to the Point H-9
3. Use of Communication "Tools" 11-10
a. Illustrate Your Document 11-10
" b. Use Charts and Tables to Present Data 11-12
c. Provide Checklists & Flow Charts 11-12
d. Provide Samples 11-17
e. Simplify Calculations 11-17
4. Presentation Options 11-20
a. Highlight Important Information 11-20
b. Enhance the Appearance of Your Document 11-21
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TABLE OF CONTENTS (Continued)
Page
APPENDIX A: A CHECKLIST FOR YOUR ENABLING DOCUMENT A-l
APPENDIX B: EXAMPLE CALCULATION B-l
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LIST OF EXHIBITS
Page
EXHIBIT A II-3
EXHIBIT B II-4
EXHIBIT C H-7
EXHIBIT D 11-11
EXHIBIT E 11-13
EXHIBIT F : IM4
EXHIBIT G 11-15
EXHIBIT H 11-16
EXHIBIT I 11-18
EXHIBIT J 11-19
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OVERVIEW
WHAT'S IN THIS DOCUMENT
A discussion of issues such as:
small business concerns
The purpose of this guidebook is to give you, the writer of materials that explain
environmental regulations to small businesses, ideas on how to effectively prepare such
documents. These materials will help "enable" the small business to comply with applicable
requirements. Therefore, throughout the remainder of this guidebook, we will refer to such
materials as small business enabling documents.
As you are aware, many small business owners are non-technical people, with little
engineering expertise and a general aversion to regulations. Some of this aversion stems from
an inability to sort through the technical and legal phraseology that is inherent in regulations,
permits, technical guidance documents, etc.
The objective of your enabling documents,
therefore, is to present technical and legal
information in an easy-to-understand manner.
In other words, your goal is to "translate"
from a techno-legal collection of "thou shalts"
and "thou shalt nots," to a down-to-earth
document that the small business person will
not only comprehend, but will actually want
to read. As you read through the pages of
this guide book, you will come across ideas
that we hope will make your job easier.
The first section of this guidance
document presents issues relevant to small
businesses. It begins with a discussion of
small business concerns (in which we outline
the most commonly asked questions, and
discuss small business' frequent lack of
understanding of what is required of them).
Other issues covered in this section are small
business' perceptions of government and
regulations, and the problems of writing for
different educational levels and non-English
speaking audiences.
US'
small business perceptions of government
& regulations
lŪ" writing for different educational levels and
non-English speaking audiences
Ideas for preparing an enabling document:
"=§" content & format
<Ū" style
Ū" using communication "tools"
"^ presentation options
A checklist to help you prepare enabling documents
An example of how a calculation may be simplified
1
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The second section of this guidance document highlights specific areas that you will need
to address when you prepare an enabling document, and introduces some ideas that you may find
useful while dealing with these issues. The four areas you will be faced with are content and
format, style, the use of communication "tools," and presentation options.
Throughout this guidance document we have included actual examples of materials being
produced by various agencies across the country in their efforts to assist small business people.
These materials are meant primarily to illustrate the points we are making in this guidance
document; as such their inclusion is not meant to imply that you necessarily use exactly the same
ideas. Feel free to alter these ideas if by doing so you will enhance the quality of your enabling
document. Be creative: this book presents ideas and concepts in a general fashion; it's up to you
to work with these ideas and expand them, to produce an enabling document that is easy (and
perhaps even enjoyable) to read.
Appendix A of this guidance document contains a checklist that you can use to help you
prepare your enabling documents. It captures the main points that are discussed in this guidance
document, and offers them to you in a concise format. Note that it is simply an outline of some
the things you need to be thinking about when you prepare your enabling document. It is not
an exhaustive description of everything you need to do.
In Appendix B we provide an example that demonstrates how formulae and calculations
may be simplified or explained for the small business person.
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SMALL'BUSIESS
Your enabling document must tell the reader what he or she is expected to do in
response to an agency initiative (such as a regulation, a permit program, or a technical
guidance effort). At the same time it must anticipate the concerns, questions, and perhaps
misconceptions that the reader may have. All of this must be done in a way that makes
your document readable and understandable. It is, therefore, important for you to be aware
of the nature of such issues. This section will provide insights into these issues, thereby
allowing you to address them more effectively.
Concerns
Put yourself in the shoes of a small business person running, say, a degreasing
operation. You hear about this new set of Federal regulations. You are not among the 20
percent or so of small businesses belonging to a trade association, and are therefore typically
not aware of new regulations and other environmental initiatives in advance. Neither are
you a member of a local Chamber of
Commerce, which often receives
information from the State Chamber of
Commerce for distribution to members.
Thus, once more, you miss this information.
How do you react? Probably with a
flurry of questions: "Does this regulation
apply to me? What will I be required to do
to comply? How much time do I have to
comply?" Then you get your hands on a
copy of the regulations. Again you have
questions: "Do I really understand what is
being said in this Federal Register notice?
Which part of this regulation am I covered
under? Who do I call to get clarification?"
FREQUENTLY ASKED QUESTIONS
S3"
tar
What :part of this agency initiative
applies to me?
What
comply?
I be required to do to
By when do I need to comply?
From whom can 1 seek clarification?
How will I benefit by complying?
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Pretty soon you are probably in over your head trying to comprehend terminology
you are not familiar with. You wonder how you will benefit if you comply or what will
happen to you if you don't comply. You try to figure out how much it is going to cost you
and how it will affect your competitiveness. You ask yourself where you will get the
technical assistance to enable you to comply. You scan the notice to determine how this
new regulatory initiative is different from other State or local regulations to which you are
already subject. On top of everything, the information is couched in language that you're
afraid you'll need a lawyer to decipher.
The preceding scenario is fairly common in small business circles. What the small
business person needs is a document that answers those questions in a manner that is easy
to read and understand. Therefore, your enabling document must address such concerns;
whenever possible it must do so in a way that is comprehensive, yet direct and to the point.
Small Business Perceptions of Government and ^Regulations
Small business people typically do not fully understand the roles of the different
levels of government regulations (e.g., local, State, Federal). Sometimes, they may not even
be aware that they fall within the jurisdiction of particular agencies, or that they need to
comply with certain regulatory requirements. At other times, they perceive that they are
being subjected to duplicative requirements at different levels of government. And yet
again, they may believe that some of the requirements are contradictory to each other.
They may wonder, "I don't understand why, when my business is so small, government has
to pick on me. Government should go after the big polluters." All of these concerns
emerge from a platform of constantly changing regulations covering various environmental
media.
One way to address these issues is simply to state in the enabling'document that
there may be requirements from other agencies that the reader may need to comply with:
The reader is urged to independently determine what those requirements may be, possibly
through their State's Small Business Assistance Program or local environmental agency.
Enabling documents may include a message alerting businesses to the possibility that
seeming duplications in requirements may exist, and that the business must seek clarification
if duplications are perceived. In addition, the enabling document ought to contain a
clarification that although several regulations may apply to the business, the agency
responsible for producing the enabling document may only be able to answer questions
about its own initiative. Your document may give a brief background addressing why the
small business is being covered in the regulations, by stating, for example, that EPA has
completed environmental studies which reveal that combined emissions from small industries
exceed those from large industry.
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With the establishment of small business assistance programs, such concerns by small
business people will, to some extent be alleviated. Presumably more and more small
business concerns will be addressed in the regulatory development process. Through public
meetings and representative organizations, small businesses can voice their concerns, thereby
indirectly contributing to the development of an enabling document.
3, Writing for DifferentReading'Levels
Writers of technical or legal documents sometimes take the educational levels of the
target audience for granted. The experience of some agencies providing assistance to the
country's small businesses suggests that the educational levels of small business people vary
from industry to industry. You need to be aware of the range in educational levels of the
people you are writing for; the lower the level, the simpler must be the language you use.
Regardless of the level, however, you must strive to be direct and concise. (More on this
in the next section.)
Another related issue is that there are numerous owners of small businesses who,
perhaps because of their ethnic origins, may not be very familiar with the English language.
For example, there appears to be a sizeable number of small dry cleaners in the Los
Angeles area who are of Korean origin and who speak little English. The same is probably
true of businesses run by people of other ethnic backgrounds (e.g., Hispanic, Chinese). To
some extent, effective communication with such groups (short of providing enabling
documents translated in their respective languages) requires a similar treatment as
communicating with people with lower educational levels. Avoiding complex terminology,
and keeping the writing style simple and concise is particularly important.
Illustrations are powerful communication tools regardless of the reader's educational
level or ethnic background. However, the lower the educational level of the, reader, and the
more ethnically diverse the target audience, the more illustrations become crucial to
effective communication. Thus, when preparing an enabling document for groups with low
educational levels (e.g., grade school) or multi-ethnic backgrounds, you should consider
extensive use of illustrations.
1-3
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SECTION H.
GUIDELINES FOR PREPARING AN ENABLING DOCUMENT
In this section you'll read about the various elements that go into an effort to prepare
a small business enabling document. We'll give you some ideas on how you can incorporate
these elements into your own enabling document, and we'll illustrate these ideas with
examples from actual enabling documents prepared by different agencies. Remember that
what you read in this section are only guidelines; these guidelines are not meant to be a set
of rigid rules, and they are certainly not meant to stifle your creativity in any way.
There are four areas that you should address while developing an enabling document:
content;
style;
the use of communication "tools"; and
presentation options.
A discussion of these areas, along with specific ideas for addressing them, are presented
below.
When you prepare an enabling document your first concern, naturally, is with the
"translation" of technical and legal information. However, there are other aspects of
document content and format that you also need to address. In this segment, we will discuss
those other aspects, and provide suggestions for addressing them.
a. Prepare an Overview
As a writer of small business enabling documents, you are often required to meet
dual, and sometimes conflicting, objectives. On the one hand, you need to keep your
document brief and easy to read; on the other hand, your document needs to be
comprehensive and provide all the necessary information. These objectives may be fulfilled
by producing a document containing two different sections.
The first section is a fact sheet that is broad in coverage, yet no more than one or
two pages long. This section provides an overview of the agency's initiative; here, at the
II-l
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beginning of the document, the objectives of the initiative should be clearly stated. In this
overview, you should state who is affected, what the affected entity must do to comply with
the requirements, how compliance may be
achieved and demonstrated (if applicable),
and any timetables for compliance. The
overview will contain enough information to
allow a small business to figure out if the
agency initiative applies to them. Beyond
that, the business is encouraged to review
the second section of the enabling
document, which describes the initiative at
length.
tar
83*
CONTENT & FORMAT
Provide an overview
tSf
tar
tar
Present the most asked questions, and
answers to them I
State that there may be requirements by
other agencies :
Provide (able of content for longer
documents ;
Include a disclaimer
Include contact phone numbers and
addresses -.-']
Exhibit A shows a stand-alone
summary that presents a good overview of
EPCRA (SARA Title m, Section 313).
b. Use a Question & Answer Format
In an effort to be direct and to the
point, you need to identify the questions
most frequently asked by affected small
businesses, and answer them. (Some of the
typical types of questions were discussed in Section I of this guidance document.) These
questions and answers may be put into a separate section in your document; alternatively,
they may be incorporated into both, the overview, as well as the detailed section. In either
case they may be highlighted to draw attention to them (refer to "Using Communication
Tools," later in this section).
Exhibits A and B demonstrate the question and answer approach..
c. Provide a Disclaimer
The enabling document is not a legally binding document, and is not meant to
replace any other legal document (such as regulations, permits, etc.). Moreover, the
enabling document may emphasize specific aspects of a regulation (based on the industry's
need for detailed information on those aspects), and may not cover all parts of the
regulation. To avoid any misunderstanding on the part of the reader, you must make it
clear that the enabling document is simply a clarification of the appropriate legal document,
and that the final authority rests solely in the legal document. You may do this with a
disclaimer at the beginning of your enabling document.
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EXHIBIT A
Toxic
Title I^Sectionj
je and Community Right-to-Kno^
**,.-, .:".:',*U**Ŧa^r , * '-'.-^fefSii''-i. .. i"
Tech Guide No. 3 Published by the Environmental Science and Technology Laboratory of Georgia Tech Research Institute 1988
Do I have to report? Yes! If...
Q Your facility has ten or more full-time employees (or full-time
equivalents); and
Q Your facility has operations in Standard Industrial Classification
(SIC) Codes 20-39; and
Q Your facility used more than 10,000 pounds of any Toxic Chemical
during the previous calendar year; and/or
Q Your facility imported, manufactured, or processed more than 50,000
pounds of any Toxic Chemical during 1988 (or 25,000 pounds in
1989).
How do I begin?
Q Obtain a copy of the Toxic Chemical Release Inventory Reporting
Form R, Instructions, and Title HI Section 313 Toxic Chemical List by
calling the EPA Hotline at 1-800-535-0202.
Q Compare your facility's chemical inventory with the Title El Section
313 Toxic Chemical List and reporting thresholds.
The Emergency Planning and
Community Right-to Know Act is
intended to encourage and support
emergency planning efforts at the
state and local level and provide
citizens and local agencies with
information concerning potential
chemical hazards in their commu-
nities. In order to meet these goals,
Title III provides for an annual
inventory of hazardous chemical
releases to the environment.
What do I report?
You must submit a separate EPA Form R for each listed Toxic Chemical
at your facility. The reports include:
Facility name, location, and principal business activity
Certification of accuracy and completeness
Whether the chemical is manufactured, processed, or otherwise used
An estimate of the maximum amounts present at any time
The treatment or disposal method for each waste stream
Annual quantity of each toxic chemical entering each environmental
medium
For further assistance:
The professionals in ESTL's Hazardous Waste Technical Assistance Program can provide additional assis-
tance and information about upcoming workshops on Completing Forms and Estimating Releases for Title III.
When do I report and to whom?
Owners and operators must submit the report for
any calendar year on or before July 1 of the
following year, to
U.S. Environmental Protection Agency
P.O. Box 70266
Washington D.C 20024-0266
Attn: Toxic Chemical Release Inventory
Georgia Right-to-Kno w Program
Georgia Environmental Protection Division
205 Butler Street S.E.
Suite 1166, Floyd Towers East
Atlanta G A 30334
For more information, please contact GTRI/ESTL, O'Keefe Building,
Atlanta GA 30332, (404) 894-3806
INSTITUTE
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EXHIBIT B
PAGES
Ground-Water Monitoring
NOTE: Ground-water monitoring cannot be used
at sites where ground water is more than 20 feet
below the surface.
Will I be in compliance?
When installed and operated according to manu-
facturer's instructions, a ground-water monitor-
ing system meets the Federal leak detection re-
quirements for new and existing USTs.
Operation of a ground-water monitoring system
at least once each month fulfills the requirements
for the life of the tank Ground-water monitoring
can also be used to detect leaks in piping (see the
later sections on leak detection for piping). You
should find out if there are State or local limita-
tions on the use of ground-water monitoring or re-
quirements that are different from those present-
ed below.
How does it work?
Operation
Ground-water monitoring involves the
use of one or more permanent monitor-
ing wells placed close to the UST. The
wells are checked at least monthly for
the presence of product that has leaked
from the UST and is floating on the
ground-water surface.
. The two main components of a ground-
water monitoring system are the moni-
toring well (typically a well of 2-4 inches
in diameter) and the monitoring device.
Installation
The number of wells and their place-
ment is very important. Many State
and local agencies have developed regu-
lations for this, usually requiring some-
where between one and four monitoring
wells per UST (additional ones may be
required! for piping).
Before installation, a site assessment is
necessary to determine the soil type,
ground-water depth and flow direction,
and the general geology of the site.
Variations
Detection devices may be permanently
installed in the well for automatic, con-
tinuous measurements of leaked prod-
uct.
Detection devices are also available in
manual form. Manual devices range
from a bailer (used to collect a liquid
sample for visual inspection) to a device
that can be inserted into the well to
electronically indicate the presence of
leaked product. Manual devices must
be operated at least once a month.
What are the regulatory requirements?
ŧ
* Ground-water monitoring can only be
used if the stored substance does not
easily mix with water and floats on top
of water.
* If ground-water monitoring is to be the
sole method of leak detection, the
ground water must not be more than 20
feet belcw the surface, and the soil be-
tween the well and the UST must be
sand, gravel or other coarse materials.
Monitoring wells must be properly de-
signed and sealed to keep them from be-
coming contaminated from outside
sources. The wells must also be clearly
marked and locked.
Source: Straight Talk on Tanks, EPA/530/UST-90/012, August 1990
II-4
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EXHIBIT B
PAGE?
Wells should be placed in, or very near
to, the UST backfill so that they can de-
tect a leak as quickly as possible.
Product detection devices must be able
to detect one-eighth inch or less of
leaked product on top of the ground
water.
Will it work at my site?
In general, ground-water monitoring
works best at UST sites where:
- The ground-water surface extends
beneath the tank;
- Monitoring wells are installed in the
tank backfill;
- Ground water is between 2 and 10
feet from the surface; and
- There are no previous releases of
product that would falsely indicate a
current release.
A site assessment is critical for
determining these site-specific condi-
tions.
What other information do I need?
The proper design and construction of a
monitoring well system is crucial to ef-
fective detection of leaked product and
should be performed by an experienced
contractor. Before construction begins,
any specific State or local construction
requirements should be identified.
Purchasing a ground-water monitoring
system is similar to any other major
purchase. You should "shop around,"
ask questions, get recommendations,
and select a company that meets the
needs of your UST site.
How much does it cost?
The capital costs for ground-water moni-
toring are generally much greater than
the annual operating costs.
The following cases illustrate the effect
that different factors have on the cost of
ground-water monitoring:
Case#l
One tŧ"Tc well in backfill
short piping runs manual
monitoring two wells installed:
Equipment Cost = $200-250
Installation Cost = $15-25/ft well depth
Annual Operating Cost = Under $100
Case #2
One tank well not in backfill
long piping runs automated
monitoring five wells installed:
Equipment Cost = $2,200-5,000
Installation Cost = $50-70/ft well depth;
conduit to the central console =
$500-2,000
Annual Operating Cost = Under $200
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d. Use a Table of Contents For Longer Documents
Finding specific items of information in long documents can be a time-consuming and
frustrating process. This is especially true when the information is highly technical, even
when the document is only 30 or 40 pages long. A table of contents is invaluable in guiding
the reader through the enabling document. In addition, it can often help you, the writer,
to decide if your document is well organized.
e. Include Contact Phone Numbers and Addresses
Consider the scenario of John Doe, the small business person who is reading about
a new set of regulations for the first time. He has read the enabling document, so much of
the information has been simplified and, to the extent possible, explained to him in layman's
terms. And yet there are lingering doubts in John's mind: Have 1 interpreted this requirement
correctly? Do the special circumstances under which I operate mean I am exempt? I never
took math in high school; how exactly do I estimate some of this stuff? His first instinct is to
grab a phone and get some answers. He thumbs through the enabling document, and Voila!
he has the telephone number of the person he needs to speak with.
No matter how well you write your enabling document, there will always be someone
who doesn't quite understand all that you are saying. This is particularly true when the
agency initiative you are explaining is broad in scope, and requires that special cases be
dealt with on a case-by-case basis. To anticipate such problems, always include the
telephone numbers and addresses of offices to be contacted for additional information and
clarification. Also, include a blank area, such as a box, for the State or local agency to
insert its contact information.
Exhibit C illustrates a humorous way of providing contact information.
f. Refer the Reader to State and Local Agencies ,
The small business person may not know that complying with a Federal regulation
does not exempt him or her from complying with State and local regulations. Your enabling
document must specify that there may be requirements from other agencies that the reader
may need to comply with. When appropriate, you may mention the types of agencies that
the reader should contact for further information (e.g., State or local air pollution control
agencies, State emergency response commissions, State small business assistance center,
etc.).
Sometimes, small business persons want to know where they can get assistance in
terms of equipment, contractors, vendors, etc. This information is best provided by State
and local agencies. Additionally, most States have technical assistance organizations outside
of the environmental agency, usually in universities, non-profit organizations, etc. It is useful
for small businesses to know the names of these organizations. Once again, however, it is
appropriate to let the State and local agencies provide this information.
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EXHIBIT C
r
''': :*^HS$||L
"Who ya gonnWcffl
, : .Ŧŧ"ŧ'j-i,- ' O -.,..''.! :r'**?J&
Source: 77ze Nevada Waste Reporter, Nevada Small Business Development Center, College of Business
Administration, University of Nevada, Fall 1991.
II-7
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Although style is a highly individual manner of expression, there are several aspects
of style that, for the purposes of an enabling document, may be generalized. It is important
to address each of these aspects when you wish to produce a document that is concise and
easily understandable, and even more so when the document is meant for an audience with
low educational levels. In this section, we discuss those aspects of style that may be
generalized, and which contribute to making an enabling document easily readable.
a. Avoid Jargon
One of the keys to effective communication through an enabling document is to avoid
the use of highly legal or technical language, including specialized jargon. Don't assume
that the reader is familiar with terminology or methodologies. Avoid "technicalese," which
may be loosely defined as "the specialized language of the technical profession." Writers of
regulations or permits or other such documents
have no choice but to present them in terms that
preclude legal or technical ambiguity. To achieve
this they must use precise legal or technical
language and convey complex ideas in very
specialized terms. However, because enabling
documents are not considered legal documents,
and because they are meant to clarify legal or
technical documents, you can be direct in your
answers to questions, and you can use everyday
language. Again, it is important to remind your
reader that these documents are not legal or
binding and refer them again to the actual
regulation, etc. However, when technical
terminology is necessary, provide a definition on
the same page, possibly also providing a
pronunciation guide.
b. Avoid Quoting Verbatim
Avoid lengthy verbatim quotations of whatever it is you are transcribing, whether it
is a regulation, a permit document, or technical guidance materials. One reason small
business persons are reading your enabling document is to gain a general understanding of
what is required of them without having to wade through the language of the original
document. Including lengthy texts of such language in your enabling document may only
pose the same obstacles to comprehension as does the original document. Transcribe the
text in simple language, steering away from making it legal-sounding.
3" Avoid jargon ;
*^f Avoid quoting verbatim;;.
cr Keep language conversational
** Avoid large blocks of text
car
Get straight to :|he point
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c. Keep the Language Conversational
Be informal in your language and tone, within the allowable legal framework. Use
the first person, addressing the facility owner/operator as "you." This degree of informality
not only simplifies what you are trying to say, it also puts readers at ease. Thus, they
actually want to read your enabling document, rather than approaching it as a distasteful
task that they feel obliged to perform.
Use analogies or examples, when appropriate. For instance, if you were to tell
readers that the quantity of municipal trash generated in the U.S. was 160 million tons in
1989, they might not readily visualize the magnitude of 160 million tons. However, if you
were to add that the garbage would fill a convoy of 10-ton trash trucks 145,000 miles long,
and that the convoy could circle the equator nearly six times, your readers might (quite
literally) get the picture.
While being conversational, however, try to avoid using too many synonyms (for
example, "worker" ought to remain "worker" throughout your document). Although it may
lead to repetitive-sounding text, avoiding synonyms provides consistency and is less confusing
for lower reading levels.
d. Avoid Large Blocks of Text
Avoid large blocks of text (e.g., 10 to 15 lines per paragraph or more). Large blocks
of text tend to daunt readers at the outset, and may turn them off even before they have
given your material a chance. Furthermore, long passages of text generally indicate the
inclusion of several ideas, some of which may not be clearly distinguishable from others.
This requires the reader to re-read what you have written, in order to sort through the
various ideas and put them in perspective. Break up long paragraphs into smaller, more
succinct ones that address distinct ideas.
Similarly, you should avoid long, multi-part sentences (such as 'those found in
regulations). As with large blocks of text, long sentences generally indicate that several
ideas have been expressed together. Split them up into smaller sentences, ensuring that
there is a logical flow to your ideas. This will make your material easier to read, especially
for audiences with low reading levels. Use indented bullets when listing information, rather
than putting the information in running text.
e. Get Straight to the Point
Tell the readers right up-front what they are most interested in learning from your
document; long-winded introductions often serve to distract from the idea you are trying to
convey. This principle applies to all components of your document (the complete document,
sections within the document, and paragraphs within sections). Being direct provides the
reader with important information in the briefest possible time.
II-9
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Avoid repeating similar requirements that the small business person must fulfill under
different circumstances. Regulations and permits, perhaps for legal reasons, often repeat
the same provisions as they apply under different circumstances. This tends to get confusing
and some of the language appears redundant. Your enabling document can simplify such
provisions by doing it hi reverse: state the requirement and list the circumstances under
which it is applicable.
By this time you're probably thinking: So I've read about content and I've read about
style; the important stuff. There's more? Sure, there's more. So far we've only talked about
matters pertaining to structure and concepts. It's time to look at different ways by which
you can transform bland information into a dynamic and appealing format. Your document
does not have to be one long series of text, the way a speech might look. Using your
imagination and the right tools, you can produce an enabling document that is not only easy
to read and understand, but also looks attractive and makes the reader want to continue
reading. In this section we'll outline some of these so-called communication "tools."
a.
Illustrate Your Document
Use illustrations whenever appropriate. To coin a phrase: A picture is worth a
thousand words. This is eminently true in the case of lower education or reading levels.
If you write your document using strictly
text and keep it simple, your readers
will probably get your message
eventually. The key word here is
"eventually." If, however, your objective
is to deliver your message quickly and
effectively, illustrations combined with
brief explanations are for you.
USING COMMUNICATION "TOOLS"
Illustrate your documents
Use charts and tables to present data
Bar
B3T
You can consider using
illustrations outside your text too. For
example, if a particular section you are
writing about deals with data processing,
you could use a drawing of a computer
terminal to indicate the nature of the
section (refer to Exhibit D). Note that
it may not always be appropriate, or
even possible, to use illustrations.
Don't force an illustration into the text simply for the sake of using one; illustrations ought
to be used to enhance the delivery of your message, not to replace the message altogether.
Provide checklists and! flow charts
Provide samples
Simplify calculations
11-10
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EXHIBIT D
LEPCs and Computers
You may have decided that the right computer could
help you with your LEPC tasks. Available software can
provide you with a way to store information submitted
by facilities, conduct hazards analyses, map hazards in
your community as part of your planning process, and
store information on the properties and health risks
posed by chemicals in your area. Appendix K of the
Technical Guidance for Hazards Analysis includes
information on computer applications for emergency
response planning.
Source: Implementing the Emergency Planning & Community Right-to-Know Act (SARA Title III), GPO 1988-516-
002/80230, September 1988
11-11
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Keep illustrations as simple as possible. Use line drawings to simplify illustrations
and make them easy to follow. Avoid complex schematic diagrams, which, while they look
technically impressive, may not mean much to a small business person who is not technically
inclined. (Refer to Exhibit E for a fairly simple, yet polished technical illustration.)
Consider using cartoon characters where appropriate. A series of cartoon panels (like those
in comic books) can be both informative and entertaining.
b. Use Charts and Tables to Present Data
When presenting data, whenever possible use charts and diagrams rather than tables.
Charts present numbers and numeric relationships more effectively than tables. The four
basic types of data-driven charts are line, bar, area, and pie. When you have data that
changes in value over time, and there are a large number of data points, you should
consider using a line graph. Vertical bar charts display values at discrete points hi time, and
may be used when data points are relatively few. Horizontal bar charts allow you to
compare data for items at a single point in time. Use an area chart when you want to
indicate not only a trend (a tune-variant trend, for example), but also the volume of data
at any point in time. Use pie charts to make static, percentage comparisons; when you have
time-variant percentage data, however, a 100% stacked bar chart is more readable than a
series of pie charts. Exhibit F has examples of bar and line graphs. Exhibit G demonstrates
the graphic and effective use of a pie chart.
If your information is not the kind that is easily represented in a chart, but is numeric
in nature (such as emission standards in a regulation or emission limits in a permit), use
summary tables. Such tables yield data far more quickly than if those data were enumerated
in text form. Keep your tables simple, and present only those data that will be informative
without being confi'sing.
c. Provide Checklists and Flow Charts
j
Checklists and flow charts are useful implements for small business persons,
especially when they are required to understand and comply with multiple provisions. A
checklist logically and systematically organizes the tasks and activities they must conduct
The degree of detail in your checklist may vary. At the simplest level, you will outline the
major tasks that the reader is required to perform; in successive levels you will describe
those tasks in greater detail. Several State and local agencies have found checklists to be
quite effective in facilitating compliance. Exhibit H is a technical guidance document in
checklist form.
Flow charts or decision trees are used when there is an element of time, and when
one event succeeds another. Some checklists may be converted into flow charts and vice
versa, but flow charts generally involve a sequential process while the same is not necessarily
11-12
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EXHIBIT E
Figure 2. Details of a Monitoring Well
Source: Leak Lookout, EPA/530/UST-88/006, August 1988
11-13
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EXHIBIT F
Facts and Figures
Broadly defined, a pesticide is any agent used to kill
or control undesired insects, weeds, rodents, fungi,
bacteria, or other organisms. Thus, the term
"pesticides" includes insecticides, herbicides,
rodenticides, fungicides, nematicides, and acaracides, as
well as disinfectants, fumigants, and plant growth
regulators.
At present, approximately 25,000 formulated pesticide
products are registered for marketing and use in the
United States. EPA regulates these products primarily
on the basis of their pesticidal active ingredients, the
component of a pesticide product that acts on the
pest. There are fewer than 750 active ingredients
currently in production, with 200 leading active
ingredients.
Total U.S. annual pesticide consumption is estimated
at 2.7 billion pounds of active ingredients. Of this
amount, 1.6 billion pounds represents wood
preservatives, disinfectants, and sulfur (a fungicide).
The remaining 1.1 billion pounds of "conventional
pesticides" (herbicides, insecticides, and fungicides)
were sold to users at a cost of $7.4 billion in 1988.
In the conventional pesticide market (see Figure 1),
agriculture accounts for over two-thirds of pesticide
user expenditures and about three-quarters of the
volume used annually; the remainder of the market
comprises industry, government, and home and garden
goo
700
600
500
400
300
200
100
0
millions Ibs. a.i.
510
Herbicides
H Insecticides
Q Fungicides
S Other
Agriculture Ind/Com/Covt Home & Garden Total
Fig.l-Vo/umeofConventionalPesticideAetivelngredientsUsed/nU.S., 1988
Source: EPA's Pesticide Program,
21T-1005, May 1991
uses. Herbicides are the leading type of conver
pesticide, with over 50 percent of both domestic
and volume used. EPA estimates that total U.S
expenditures on pesticides, $5.1 billion in 1988,
represents less; than 4 percent of total farm proc
expenditures ($132 billion in 1989).
Trifluralin
Cysinazine
Carbaryl
Malathion
Metribuzin
Fig. 2 - Annual Usage of the Largest Agricultural Pesticides in the U.S.
The 10 largest-use agricultural pesticides are shov
Figure 2, along with estimates of their annual usa
for all agricultural and non-agricultural uses. Ala<
and atrazine are the two most widely used pestici<
by volume. Eight of the 10 pesticides shown are
herbicides (carbaryl and malathion are insecticides
1200-
1000-
800-
600-
400-
200
million Ibs. a.i.
Total
64 66 68 70 72 74 76 78 80 82 84 86 88
Fig. 3 - Trends in U.S. Pesticide Usage. 1964-1988
After increasing steadily throughout the 1960's and
1970's, pesticide usage reached its all-time high in i
early 1980's; since then, it appears to be holding
steady at just slightly lower levels (see Figure 3) an
may decline in coming years. More efficient use ol
pesticides, the availability of even more effective
pesticides, and an increased interest in sustainable
agriculture contribute to this trend.
II-14
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EXHIBIT G
Landfills
Waste Piles,
Land Application
Surface
Impoundments
Underground
Injection Wells
Of the hazardous waste disposed of on
land, nearly 60 percent is disposed of in
underground injection wells, approxi-
mately 35 percent is disposed of in surface
impoundments, 5 percent is disposed of
in landfills, and less than 1 percent is
disposed of in waste piles or by land
application.
Source: Solving the Hazardous Waste Problem: EPA's RCRA Program, EPA/530-SW-86-037, November 1986
11-15
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EXHIBIT H
Guide #4
Spring 1991
Waste Reduction
Options
Electroplating
The best waste reduction options fall into two categories: those that
eliminate wastes, emissions, or discharges at the source through changes
in operating practices, technologies, input materials, or products; and
those that recover and recycle spent materials.
Use good operating procedures.
O Check process tanks every month for spills,
leaks, and overflows.
O Maintain racks.
O Check barrels to make sure they are draining
efficiently.
O Store materials and supplies properly to
maintain their shelf life.
O Use drain boards to catch drips.
Use other available technologies.
O If space permits, use multiple rinse tanks,
which require less waf er.
O Use spray rinses and air knives to keep solu-
tions inside process tanks.
O Use air agitation in rinsing solutions to improve
rinsing efficiency and to lower the amount of
rinsewater used.
O Use flow restrictors to avoid wasting water.
Flow controls that use conductivity cells will .
ensure that water flows only when needed for a
process.
O.Use noncyanide plating solutions to reduce ;
pretreatment of solutions and to reduce health
and safety hazards.
The state of Georgia has a new Hazardous Waste
Reduction Planning requirement. Please request
Guide #1 for more information.
O Use trivalent instead of hexavalent chromium
plating and chromating solutions to reduce
health risks. Because trivalent chromium
processes are more dilute than hexavalent
processes, losses to the rinsing system are
reduced.
G Use nonchelated process chemical baths to
reduce hazardous waste generation.
Control dragout, the amount of excess solution that
gets carried out of the bath along with the work-
piece.
O Use automated speeds for withdrawing parts
from processing solutions to control dragout.
O Extend drain times to reduce dragout.
O Place parts in the solution with points or corners
downwards. '
Recycle dragout solutions.
O Use a nonflowing rinse or an empty tank to
retain process solutions. These solutions can be
returned to the process tank, with or without
further separation or concentration.
Switch to deionized water for replacing water that
evaporates from plating process solutions. Tap or
softened water is a potential contaminant to pro-
cessing solutions.
For more information, contact the Pollution Prevention Coordinator at 404/894-3806
Environmental Science and Technology Laboratory Atlanta, Georgia 30332
Gcorm Tech
Printed on recycled paper
n-i6
-------
true of checklists. Decision trees also describe a train of events sequentially through time;
however, they explicitly involve points at which the user, depending on the outcome of given
events, may need to divert from one course of action to another. This is similar to the
switching of a train from one track to another, depending on the schedule of other trains,
etc. Not all flow charts involve decision points. Exhibit I presents a flow chart.
d. Provide Samples
Sometimes small businesses are required to submit information (for example,
notifications, reports, data, etc.) to the agency, as part of their reporting requirements. In
such instances you should consider providing a sample of the type of information you expect
to receive. Whenever feasible, prepare sample forms or sheets that the small business
person may use to complete required information for reporting purposes (e.g., monitoring
data, emission test results, etc.). Exhibit J shows a sample hazardous waste label.
e. Simplify Calculations
Small business people typically have a problem dealing with formulae and
calculations. And yet, there is no easy way to simplify calculations; by their very nature,
formulae are the simplest form of expressing a numerical relationship. How then, does one
go about simplifying it? Perhaps what is needed is a combination of simplification and
clarification. For example, consider a complex formula involving several variables, each of
which may be independently determined:
You could break the formula up into its various components, providing
smaller (and presumably easier to use) formulae for each.
Then you would explain where the reader must obtain the data to use
as inputs for these smaller formulae. This should be done in a logical
fashion, so that the most basic information is collected first, and is then
used to derive the other values.
Finally, you would instruct the reader to insert the values for the
various components into the original formula to calculate the result.
When instructing the reader on how to perform the calculation, you should simplify
some of the terminology for different numerical components. When the regulations permit
it, recommend using data derivations rather than actual measurements (which may be
difficult and expensive to do). Itemize information that the reader needs to obtain. Provide
blank forms to collect data for input into the calculations, and pinpoint sources for obtaining
the data. When appropriate, tell the reader how to obtain the data. Be flexible about
measurement units required. When appropriate, provide information on derivations, metric
conversions, standard values, etc.
11-17
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EXHIBIT I
Product Development:
Product discovery
Laboratory & greenhouse testing
Experimental use permit obtained from EPA
Large-scale field testing
Application:
Registrant submits test data, application
to register product, draft labeling, & tolerance
petition (for food-use pesticide)
Registration Review:
Review of Data:
- toxicology - ecological effects
- residue analysis - exposure assessment
Are data valid?
When used according to label directions, does the pesticide
pose unreasonable risks of adverse effects to human health
and the environment?
Approval:
EPA establishes tolerance
for food use pesticide,
approves registration, publishes
notice in Federal Register
Returned:
EPA returns application, noting:
need for more or better data
need for Labeling modifications
need for use restrictions
Producer markets product for
use according to label
J
Figure 4 - Pesticide Registration Process for New Chemical
Source: EPA's Pesticide Program, 21T-1005, May 1991
11-18
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EXHIBIT J
!
HAZARDOUS WASTE
FEDERAL LAW PROHIBITS IMPROPER DISPOSAL
If found, contact the nearest police or public
safety authority or the U.S. Environmental
Protection Agency.
Proper D.O.T. UN or
Shipping Mama NA hin
Hpnoratnr
Arlrlri>Ŧ:<:
firy Sfato
Manifest Accumulation
p^riimpnt Nn Start Datp
t.P.A. E.P A.
1 n (Mn H W Nn
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-------
Often, calculations are best done by example, supplemented by a description of the
steps needed to perform the calculation. However, it may not be feasible to use examples
to explain all calculations; the more complex calculations get, the less likely that the
methodology will be effectively transmitted exclusively via a publication. This is especially
true when one calculation requires data derived from another, and so on in a confusing and
tangled progression. There is a certain point beyond which it is not feasible to clarify or
simplify formulae, because they have become so complex. In such cases, despite all your
efforts to simplify and clarify it, the business may need to obtain support beyond the
enabling document. Recommend several options to seek assistance (i.e. State small business
assistance center, or local environmental agency).
Appendix B provides an example of how a calculation of emission rates may be
simplified and clarified.
4. .- Presentation Options
In this section you will read about some of the options for presenting your
information. Presentation options grab the reader's attention and make your information
jump out at him or her. In addition, some options make your document more polished and
attractive. We have divided these options into two main areas - highlighting and enhancing
appearance.
a. Highlight Important Information
When motels or diners want to attract business they have a flashing neon sign
outside. When airlines want you to take a closer look at their low, low fares, they put in a
full-page ad in magazines. When there
is a major item of news, the newspapers
have large bold letters splashed across
their front pages. So what do you do
when there is something in your
document that you absolutely want
readers to look at? You use similar (if
less dramatic or gaudy) methods.
One of the most basic ways of
highlighting information is to use titles
for the various topics and sections in
your document. A tide stands out,
because it appears in the page by itself;
by virtue of this fact it automatically
draws attention to itself. Once you
PRESENTATION OPTIONS
isr;
Highlight important information
Enhance the appearance of your document;
Type of paper j
Ŧ Artwork
Color ;
11-20
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have drawn the reader's attention, use the title to tell the reader what he or she is about to
read. Don't be ambiguous with the title - essentially summarize the material it covers,
using a word or short phrase. Reading a document that has sections without titles is like
trying to shop in a grocery store with aisles that have no signs above them: it can be done,
but it takes longer.
Another thing to keep in mind when preparing titles is to present them in some kind
of hierarchy, much in the manner that theatrical or other performances are billed. The
main act (or player) gets top billing with its name in large letters; less well known acts get
second or third billing, with their names getting successively smaller. Likewise, the main
title in your section should be large, bold, perhaps within a shaded box, and perhaps
centered on the line. Other titles should be smaller, and perhaps left justified.
Titles are not the only parts of your document that may be put in bold letters or in
a shaded box. Any other information in the text that you wish to emphasize may be made
bold or inserted in a shaded box. Alternatively, you may wish to underline the passage, or
italicize it, or combine these two options with bold face and shading options. Keep in mind,
however, that you should reserve such highlighting options for instances where highlighting
is useful and necessary. Too much highlighting makes it difficult for readers to distinguish
between what is essential and what is merely nice for them to know.
Another useful tool for emphasizing information is to put it into box insets. A box
immediately catches the readers eye. Once again, remember not to overuse this tool. Also,
do not use boxes for lengthy passages of text; keep the boxes uncluttered and easy to read.
If the material in a box looks the same as the material outside it, people are less likely to
read what's in the box.
b. Enhance the Appearance of Your Document
We have outlined three methods to enhance the appearance of your document. All
of them are typically more expensive than simply producing your document on a word
processor and using desk-top publishing software. Your flexibility in using these methods
may depend on the budget at your disposal for the production of the enabling document.
Type of Paper The paper you use may be glossy, bond with high rag
content, plain, etc. Generally, glossy paper and heavy paper with high
rag content are considered to be more "classy" than plain computer
print paper. People tend to read documents printed on these types of
paper with more enthusiasm than documents printed on plain paper.
Artwork You may choose to include photographic illustrations or
other enhancing artwork in your enabling document. Artwork,
(particularly photographs) breaks up the monotony of continuous text,
and makes the document look "professional." Unfortunately, to
11-21
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incorporate such artwork into your documents you would generally
need the services of a professional printing or publishing outfit.
Using Color Color enhances the visual aspect of documents. Consider
television: would you rather watch your favorite show on black-and-white TV
or color TV? It's the same way with reading material. On the down side,
however, color documents are usually more expensive to produce than non-
color ones (which is also true for TV sets). Although it is possible to produce
color documents at your own desk, you would first need access to a color
printer (preferably a laser printer if you want to do fancy stuff). Such printers
are not common, and are quite expensive to purchase.
11-22
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APPENDIX A
A CHECKLIST FOR YOUR ENABLING DOCUMENT
SMALL BUSINESS ISSUES
D Have you addressed the questions frequently asked by small businesses?
D Have you stated that there may be requirements from other agencies that the reader may need to
comply with?
D Have you mentioned that your agency can answer questions only about its own initiative?
D Have you considered if some of your readers may be in lower educational or reading levels?
D If some of your readers are in lower educational or reading levels, have you prepared your document
accordingly?
CONTENT & FORMAT
D Have you prepared a summary sheet as an overview of the agency's initiative?
D Have you included a section that presents the information about the initiative in a question-answer
format?
D Do you have a disclaimer?
D If your document is long and has many sections, have you included a table of contents?
D Have you included contact phone numbers and addresses?
D Have you included a space for the state or local agency to insert their contact phone numbers and
addresses?
>
D Have you referred the reader to the state or local agency for additional assistance?
STYLE
D Have you steered away from "technicalese?"
D Have you provided definitions beside the term being defined?
D Have you avoided lengthy verbatim quotations?
D Have you kept the language conversational and informal?
D Have you kept your paragraphs and sentences to a reasonable length?
D Have you been direct in telling the readers what they need to know?
A-l
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COMMUNICATION TOOLS
D Have you used illustrations?
D If you haven't used illustrations, is it because they were not appropriate?
D If you have used illustrations, have you kept them simple?
D If you have data, did you use charts or tables to present them?
D Have you provided checklists and/or flow charts for the reader to use?
D Have you provided samples of forms or sheets that the reader may use?
D Have you simplified complex calculations by breaking them into smaller formulae?
D Do you have a logical, step-by-step description of how the calculation needs to be done?
D Have you directed the reader to the source of input data for the calculation?
D Do you have an example calculation?
PRESENTATION OPTIONS
D Have you highlighted important information?
D Have you taken care not to overuse highlights?
D Do you have titles that are descriptive and follow a hierarchy?
D Have you used box insets to draw attention to important information?
D If your budget permits, have you unproved the appearance of your document by using:
D good quality paper?
D artwork, such as photographs, etc?
D color?
A-2
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APPENDIX B
EXAMPLE CALCULATION
Consider a glass melting furnace operation that uses arsenic as a fining agent in the
manufacture of glass, and has uncontrolled arsenic emissions. Uncontrolled emissions are
the inorganic arsenic in the glass melting furnace exhaust gas precluding any add-on
emissions control device. CFR 40, Part 61, Subpart N (National Emission Standards for
Inorganic Arsenic Emissions from Glass Manufacturing) requires owners or operators to
determine the uncontrolled arsenic emission rate every 12 months. (This 12-month period
coincides with the period for submitting various reports, as required by other parts of the
regulation.) Now let us suppose you want to explain to the owner or operator of the furnace
how they can determine the emission rate. The following example demonstrates how
formulae and methodologies described in the regulations may be simplified and explained
for the small business person.
DETERMINING UNCONTROLLED ARSENIC EMISSIONS
As an owner or operator of a glass melting furnace with uncontrolled arsenic
emissions, you are required to determine the uncontrolled arsenic emission rate for your 12-
month reporting period. The steps outlined below should enable you to accurately
determine this rate. If you need assistance with these calculations, contact us at the phone
number or address shown on the last page.
Step 1:
You will need to do the following mathematical calculation for each type of arsenic-
containing glass you produce.
Step A: Gather the following information for each type of arsenic containing glass
produced:
Ab - The fraction by weight of elemental arsenic in the fresh batch.
Wb - Weight in grams of fresh batch melted per kilogram of glass produced.
Ac - The fraction by weight of elemental arsenic in the cullet.
B-l
-------
Wc - The weight in grams of cullet melted per kilogram of glass produced.
Ag - The weight in grams of elemental arsenic per kilogram of glass
produced.
Step B: Multiply Ab by Wb.
Step C: Multiply Ac by Wc.
Step D: Add the results of Step B and Step C. Then, from this sum, subtract Ag.
The result of the calculation in Step D = T, the theoretical uncontrolled arsenic
emission factor.
You will need to use T to conduct the calculations described in Steps 2, 5, and 6.
Step 2:
You will need to do the following mathematical calculation for each type of arsenic-
containing glass you produce.
Step A: Gather the following information for each type of arsenic containing glass
produced:
T - The theoretical uncontrolled emission factor, as calculated in Step 1.
G - The quantity (kg) of glass produced during the 12-month period.
Step B: Multiply T by G.
Step C: Divide the result of Step B by 1 million, or 106.
The result of the calculation in Step C = Y, the theoretical uncontrolled arsenic
emissions for the 12-month period.
Repeat this calculation for each arsenic-containing glass type you produce. Once this
has been done, identify the arsenic-containing glass type with the highest value for Y - the
highest theoretical uncontrolled arsenic emissions. The remaining steps will be completed
using information for that glass type.
B-2
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Step 3:
You will conduct this step for the arsenic-containing glass type with the highest
theoretical uncontrolled arsenic emissions. This is the glass type with the highest value as
calculated in Step 2 above. In this step you will need to conduct emission testing using the
following test methods and procedures:
(a) Use Method 108 in Appendix B of 40 CFR Part 61 to determine the
arsenic emission rate in grams per hour. The emission rate is to be
determined using the arithmetic mean of the results of three 60-minute
test runs.
(b) Use the following methods in Appendix A of 40 CFR Part 60:
(i) Method 1 for sample and velocity traverse.
(ii) Method 2 for velocity and volumetric flowrate.
(iii) Method 3 for gas analysis.
(iv) For sources equipped with positive pressure fabric filters, use
Section 4 of Method 5D to determine a suitable sampling
location and procedure.
In this step you have determined the actual uncontrolled arsenic emission rate during
production of the arsenic-containing glass type with the highest theoretical uncontrolled
arsenic emissions.
Step A: Gather the following information:
Ea - The actual uncontrolled arsenic emission rate (in grams per hour,
g/h). This is the result of your calculations in Step 3, above.
P - The rate of glass production (in kilograms per hour, kg/h). To obtain
the value of P, divide the weight (kg) of glass pulled from the furnace
during the emission test by the number of hours (h) it took to perform
the test in Step 3, above.
B-3
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Step B: Divide Ea by P. Your result should be expressed in grams of elemental
arsenic per kilogram of glass produced.
In this calculation you have determined the actual uncontrolled arsenic emission
factor R.
Steps-
A: For this calculation you will need the following information:
Ra - The actual uncontrolled arsenic emission factor (g/kg) calculated in
Step 4, above.
T - The theoretical uncontrolled arsenic emission factor (g/kg) calculated
in Step 1, above, for the same glass type for which R, was determined
(the glass type with the highest theoretical uncontrolled arsenic
emissions).
Step B: Divide R, by T.
The resulting value, F, is what is called a correction factor. The correction factor is
a factor which makes an adjustment for the difference between the theoretical uncontrolled
emission factor, T, and the actual uncontrolled emission factor, R,.
Step 6:
Step A: Gather the following information for the calculation:
T - The theoretical uncontrolled arsenic emission factor as calculated in
Step 1, above.
F - The correction factor calculated in Step 5, above.
G - The quantity (kg) of glass produced during the 12-month period.
B-4
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Step B: Multiply T by F by G (T x F x G) for each arsenic containing
glass type that you produce. The product of this calculation is
called the "Individual Rate" for each glass type.
Step C: Add the products of Step B for each glass type. In other words, in Step B you
calculated the Individual Rates for each glass type. If you produce four
arsenic containing glass types, you did the calculation in Step B four times.
Add the results of each Step B calculation. This gives you what is called the
"Total Rate."
Step D: Divide the Total Rate, which you calculated in Step C, by one million (10*).
The result is the uncontrolled arsenic emission rate in Mg/Year.
B-5
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-453/B-93-023
3, RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
A Guidebook for Explaining Environmental
Regulations to Small Businesses
5. REPORT DATE
April 1993
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Rahul Chettri and Stefani Olsen
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
ViGYAN Inc.
5203 Leesburg Pike
Suite 900
Falls Church. VA 22041-3406
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
EPA 68-D1-0073
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Emission Standards Division (MD-13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park. NC 27711
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
BSD Work Assignment Manager: Ms. Deborah M. Elmore
MD-13; Telephone: (919) 541-5437
16. ABSTRACT
This report was prepared by the EPA's Control Technology Center (CTC) in support
of the Federal Small Business Assistance Program. This report presents guidelines
on how to prepare materials that explain technical information in layman's terms,
specifically focusing on producing enabling documents. Enabling documents explain
new standards and rules to small business operators, conveying the information
that they will need to know in order to comply with these standards and regulations.
The document discusses small business' concerns and perceptions of government
and regulations; writing for your audience; document content, format, and style;
use of graphics and other communication "tools"; and presentation options.
U.S. Env:; .
Region 3,
''.vj.i:,n Agency
_2j)
3>'3rd, 12th
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Small business assistance
Compliance - enabling documents
Non-technical writing
8. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
21. NO. OF PAGES
20. SECURITY CLASS (This page!
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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