United States
Environmental Protection
                   Office of the
EPA 100-R-00-023A
November 2000
Project XL: Dmectoi^y cr
"Regulato^y, Policy, and

Volume 'I

Executive Summary	ix
Introduction	1
Learning from Experiments	3
Innovations in Core Functions	9
Ongoing Innovations	13
Emerging Innovations	83
Building a National Laboratory for Innovation	95
Information Sources and Methodology	99
Glossary	101

Project XL 2000 Comprehensive Report compiles available
information on Proj ect XL. It follows up the work started in the
Project XL 1999 Comprehensive Report (October 1999).

This report has two volumes. Volume 1: Directory of Regulatory,
Policy, and Technology Innovations describes more than 70
innovations being explored by Proj ect XL. These innovations are
catalogued by the core functions that are the fundamental processes
and operations the U. S. Environmental Protection Agency must use in
order to perform its mission to protect human health and the
environment. Volume  1 presents technical and policy information
relevant to each innovation.

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

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


                                               of  ,X]—   T-Vojecfs
Projects in Implementation December 1999 or
1.   Andersen Corporation, Bayport, MN
2.   Atlantic Steel Redevelopment, Atlanta, GA
3.   Crompton Corporation Sistersville Facility (formerly
4.   DOD: Elmendorf Air Force Base, Anchorage, AK
5.   DOD: Vandenberg Air Force Base, Santa Barbara
    County, CA
6.   ExxonMobil Corporation, Fairmont, WV
7.   HADCO Corporation, Derry, and Hudson, NH; Owego,
8.   Intel Corporation, Chandler, AZ
9.   Jack M. Berry Corporation, LaBelle, FL
10.  Lucent Technologies, Allentown, and Reading, PA;
    Orlando, FL
11.  Massachusetts Dept. of Environmental Protection-ERR
    Commonwealth of Massachusetts
12.  Merck & Co. Inc., Elkton, VA
13.  Molex Incorporated, Lincoln, NE
14.  New England Universities Laboratories, Boston College,
    University of Massachusetts-Boston, University  of
15.  NY State Dept. of Environmental Conservation, State of
    New York
16.  Weyerhaeuser Company, Ogelthorpe, GA

Projects Underway or Under Development Since
December 1999
17.  Anne Arundel County Bioreactor, Severn, MD
18.  Autoliv Automotive Safety Devices, Promontory, UT
19.  Buncombe County Landfill, Buncombe County, NC
20.  Chicago Regional Air Quality and Economic
    Development Strategy, Chicago, IL
21.  City of Albuquerque, Albuquerque, NM
22.  City of Columbus (XLC), Columbus, OH
23.  City of Denton, Denton, TX
24.  City of Fort Worth, Forth Worth, TX
25.  Clermont County Watershed Management Program,
    (XLC) Clermont, OH
26.  Crompton Corporation TBT Project, Greenwich, CT
27.  DOD: Naval Station Mayport, Jacksonville, FL
28.  DOD: Puget Sound Naval Shipyard, Bremerton, WA
29.  Eastman Kodak Corporation, Rochester, NY; Windsor,
    CO; Peabody, MA; White City, OR
30.  Georgia-Pacific, Big Island, VA
31.  IBM East Fishkill Facility, Hopewell Junction, NY
32.  IBM Semiconductor Manufacturing Facility, Essex
    Junction, VT
33.  Imation Corporation, Camarillo, CA
34.  International Paper- Effluent Improvements, Jay, ME
35.  International Paper- Emissions Monitoring, Jay, ME
36.  Labs21, Nationwide
37.  Lead Safe Boston, Boston, MA
38.  Louisville and Jefferson Counties Metropolitan Sewer
    Districts, Louisville and Jefferson Counties, KY
39.  Metropolitan Water Reclamation District of Greater
    Chicago, Chicago, IL
40.  Naragansett Bay Commission POTW, Providence, RI
41.  National Aeronautic Space Administration White  Sands
    Test Facility, Las Cruces, NM
42.  New Jersey Department of Environmental Protection
    Gold Track Program, State of New Jersey
43.  Ortho-McNeil Pharmaceutical, Spring House, PA
44.  Pennsylvania Department of Environmental Protection,
    State of  Pennsylvania
45.  Port of Houston Authority, Houston, TX
46.  PPG Industries, Inc., Pittsburgh, PA
47.  Progressive Auto Insurance Company, Nationwide
48.  Steele County, Minnesota (XLC),  Steele County, MN
49.  United Egg Producers, Nationwide
50.  USFilter Recovery Systems, Inc., Roseville, MN
51.  U.S. Postal Service Denver, Denver, CO
52.  Waste Management, Inc. Virginia Landfill Bioreactors
    Project, King George and Amelia Counties, VA
53.  Yolo County Bioreactor, Yolo County, CA

                                        Project  XL  2000
                                                   Vol ume  "1 :

               Directory  oj-  "Regulatory,  Policy/  and "TecKnology  innovation
                                        Affected Media    Featured on

            Weyerhaeuser Company

            3M Proposal
            Crompton Corporation
            (formerly Witco)

            Atlantic Steel
            New York State DEC

            New England Universities

            HADCO Corporation
            Molex Incorporated

            IBM Vermont
Integrated Pulp & Paper NESHAP
& Effluent Guidelines

NESHAP for Magnetic Tape Manufacturing

NESHAP for Miscellaneous Organic

Clean Air Act Flexibility During
Conformity Lapse

RCRA Waste Handling Waiver

Performance-based Environmental
Management Standard

RCRA Conditional Delistings and
Solid Waste Variances

Process Exemption for Copper Plating
            City of Albuquerque

            City of Denton
            County MSD

            Steele County
            Steele County
Integrating Pollution Prevention into

Remote Monitoring and Watershed

Watershed-based Pretreatment

Mass-Based Compliance Standard for
Pretreatment Industrial Users

Reduced Monitoring for Regulated
Pollutants not Present
                                        Air,                    17

                                        Air                    18
                                       Air                    19

                                       Hazardous Waste        21

                                       Hazardous Waste        22

                                       Hazardous Waste        23

                                       Hazardous Waste        25

            ExxonMobil Corporation
CERCLA Streamlining to Recycle
Superfund Site
                                        Hazardous Site


Intel Corporation
Weyerhaeuser Company
Merck & Company
Imation Corporation
Andersen Corporation
Elmendorf AFB
International Paper-El

Facility-wide Permit Air Emission Caps
Performance-Based Permitting
Pollution Prevention Incentives Through
Title V Streamlining
NPDES Effluent Improvements
Affected Media Featured on
Air 34
Air 36
Air 38
Water 39
 Weyerhaeuser Company

 Berry Corporation
Water Effluent Limits                      Water

The Consolidated Multimedia Operating      Multimedia
Permit (COP)
 Information  Management and Access
 Steele County


 Intel  Corporation


 Merck & Company
 Intel Corporation
 Merck & Company
 Weyerhaeuser Company
Alternative Reporting on Web site
for POTWs
Enhancing Public Access: Internet Reporting   Multimedia
and Stakeholder Input

Tiered Reporting: Building Incentives into     Multimedia
Data Collection Requirements

Consolidated Reporting: Streamlining the     Multimedia
Reporting Burden


 Enforcement  and  Compliance Assurance

 Massachusetts DEP,        Business Self-certification
 Weyerhaeuser Company
 International Paper-PEM   Predictive Emissions Monitoring
 Massachusetts DEP
 Merck & Company
Environmental Business Practice
Indicators (EBPIs)

Alternative Compliance Mechanism
 Weyerhaeuser Company   Tiered Compliance Testing
 Georgia Pacific
Gasification of Pulping Liquor under








Affected Media   Featured on
             Environmental Stewardship
             Weyerhaeuser Company
             Berry Corporation

             Lucent Technologies
             (formerly Witco)
Link EMSs to Facility Standard Operating

An EMS Model That Can Be Used at

Facility-based Reviews That Inventory
and Suggest Process-level Pollution
Prevention Approaches
             Weyerhaeuser Company   Timberland Resource Strategies
             New England Universities

             Intel Corporation
             Vandenberg AFB

             U.S. Postal Service Denver

             Progressive Insurance

             Intel Corporation

             Naval Station Mayport
Institutional Recycling by Managing
All Laboratory Chemicals

Process Modifications and
Waste Minimization

Reduce Permit Burdens Through
Pollution Prevention
Transition to Lower-emitting Flexible        Air
Fuel Vehicles

Base Automobile Insurance Rates upon      Air
Specific Driving Factors

Water Reclamation and Reuse               Water

Reuse Dredged Material                   Water

Multimedia             59
Multimedia             60
Multimedia             61

Hazardous Waste        63
Solid and               64
Hazardous Waste

Air                    65


             Stakeholder Involvement
             ExxonMobil Corporation   Public Participation
             Weyerhaeuser Company   Public Participation
             Intel Corporation
             Merck & Company
             HADCO Corporation
             New England Universities
             Vandenburg AFB
             Atlantic Steel

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

             Program wide
Project XL Stakeholder Involvement Guide

Build Stakeholder Capacity
                                        Hazardous Site





Affected Media    Featured on
 Agency Culture Change
 Program wide


 Program wide


 Program wide


 Program wide
Senior Management Support and
Involvement through the Reinvention
Action Council
Managing Experiments in Partnership with   Multimedia
State and Tribal Governments
Effective Cross-Agency Teams for
Multimedia Experimentation

Compliance Screening for XL's
Voluntary Project Sponsors


 Emerging Innovations
 Anne Arundel
 Buncombe County
Testing Bioreactor Method: Recirculating
Leachate over Alternative Liners
Solid Waste
 Safety Devices

 City of Chicago


 Lead Safe Boston

 Chicago POTW

 Narragansett Bay
 Commission POTW

 USFilter Recovery
Enabling Metals Recovery from
Pyrotechnic Material

Regional Air Quality and Economic
Development Project

Using F006 Wastes as an Ingredient in
Cement Production

Lead-based Paint Debris Disposal Flexibility

Alternative Effluent Discharge Monitoring

Enhancing the Metal Finishing 2000 Program
Hazardous Waste

Hazardous Waste

Hazardous Waste


Encouraging Metals Recycling and Recovery  Hazardous Waste
 Virginia Landfills (Amelia   Bioreactor Method: Comparing a Leachate
 and King George County)   Recirculation System to the Introduction of
                          Additional Liquid Amendments in Sanitary
 Yolo County

 Pennsylvania DEP

 United Egg Producers
Bioreactor Method: Aerobic versus
Anaerobic Technology

Investigating an Alternative Approach to
Promoting Coal Remining

Environmental Management Systems/
Third-Party Certification
                                         Solid Waste
Solid Waste





Affected Media   Featured on
              Emerging  Innovations (Continued)
              Puget Sound Naval

              New Jersey Gold Track
                      Enforcement and Compliance Assurance
                       Integrated Marine Environmental           Water
                       Compliance Program
                       Performance-based Approaches to
                       Environmental Management
Port of Houston Authority Port/Tenant Environmental Management
                             Environmental Stewardship
                       Community-based Watershed Protection     Water
              Clermont County

              City of Columbus

              Crompton TBT
              City of Fort Worth

                       Enhancing a Local Lead Hazard Program

                       Flexibility in the Tributyltin Monitoring
Hazardous Waste


                       Pollution Prevention Assessment           Chemical Management/  92
                       Framework (Developing Environmentally    Hazardous Waste
                       Preferable Products in the Chemical
                       Industry Through Technology Transfer)
                       Proactive Demolition of Structures
                       Containing Asbestos

                       Increased Efficiency in Lab Operations

                       Catalytic Oxidation of "Mixed Waste"

Hazardous Waste
                        Information Management and Access
                       Real Time Web-Based Information           Multimedia


Iv 111

In 1995, the U.S. Environmental Protection Agency (EPA) launched
an unprecedented new initiative known as Project XL to test innova-
tive ideas that demonstrate environmental excellence and Leadership
by those who must comply with Agency regulations and  policies.
Project XL is one of several high-priority initiatives that challenged
EPA to think about new ways to fulfill America's environmental and
human health protection goals, while simultaneously allowing businesses
and other regulated  entities to achieve those goals in a smarter, cleaner,
and cheaper way.
                                         Innovation - An
                                         action that starts  or
                                         introduces something
                                         new or creative.
      Project XL solicits ideas from private
      and public  sector facilities,
      states, trade associations, and com-
munities that propose solutions to difficult
regulatory or technical problems and ex-
plore new approaches to protecting human
health and the environment, usually at a lower cost or lessened regula-
tory burden for the  sponsor. In opening the door to experimentation,
EPA has sent the message that it values innovation and, above all,
wants superior environmental results.

The experiments being conducted under Project XL are in various
stages: some are just getting started, others have been underway for
several years. In the 7999 Comprehensive Report, we identified  14
projects with signed Final Project Agreements; as of November 2000,
there are 48. What we are learning from these experiments has grown
dramatically in the
past year. Last year,  ••••••••••••••••••••••••••
we  identified 35 in-        5
novations within
projects, this  year
                                 Permit Reform
                      Environmental Information Management
                      Enforcement and Compliance Assurance
                            Environmental Stewardship
                             Stakeholder Involvement
                                 Culture Change
more than 70 inno-
vations have been
identified. The 2000
Comprehensive Re-
port, Volumes 1 and
2 are intended to be
a reference guide
for those interested

in the details of Project XL. Volume 1: Directory
of Regulatory,  Policy, and Technology Innova-
tions presents the innovations and lessons learned
organized by how they relate  to the seven core
functions that the Agency  typically performs to
carry out its mission to protect human health and
the environment. Specifically, it discusses the:

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

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

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

Volume 2: Directory of Project Experiments and
Results provides a status report of the more than
50 projects and proposals Project XL has supported
to date. Volume 2 highlights overall program ac-
complishments, such as cumulative environmental
benefits as exhibited below.

Then each project is described including  a discus-
sion of the achieved and expected environmental
performance, achieved or expected financial and
other benefits to the businesses and communities
sponsoring projects, achieved or expected benefits
to the other stakeholders involved, legal flexibility
that allows the  project to work, and barriers con-
fronted and lessons learned.
(Old   and
<£rvv i ^o v\ me. rvta I
Today, EPA has experiments with a variety of part-
ners: Fortune 500 companies and small businesses,
state and local government agencies, and commu-
nities. Each project has been designed to produce
important benefits for the sponsor and the environ-
ment. Companies are cutting costs, communities
are addressing priority concerns, and regulatory
agencies are targeting their resources more effec-
tively. Each of these benefits must meet the stan-
dards of superior environmental performance and
enhanced environmental protection.

But the intent of the program is not to serve only a
select few. The goal of Project XL continues to be
much broader — to find solutions that can be inte-
grated into our environmental protection system for
everyone's benefit. This goal is being achieved  in
two ways: first, by creating more options for envi-
ronmental management and second,  by taking a
more comprehensive approach to environmental

Creating More Options for Environmental Man-
agement. Through Project XL, EPA provides com-
panies  and other project sponsors with a forum  to
demonstrate their abilities to find innovative ap-
preaches to environmental protection. For example.
Project XL provides a way to move state-of-the-
art environmental technology from the fringes into
the mainstream. It does so by providing companies
with the incentives they need to make the requisite
testing and evaluation worth their time and invest-
ment. We can see in the following examples how.
over time, if a technology proves successful and
others become  more receptive to its use, better
results will be achieved for a growing number of

•   Georgia-Pacific Corporation. At its Big Is-
    land, Virginia, pulp and paper mill, George-Pa-
    cific is testing anew "gasification" technology
    to control emissions of hazardous pollutants.
    One of the byproducts of their manufacturing
    is a "black  liquor," which contains a mix of
    chemicals used in pulp production.  With con-
    ventional technology, these chemicals are re-
    covered through combustion evaporation.
    Preliminary testing shows the new gasification
    technology uses less energy and significantly
    lowers emissions of hazardous pollutants. How-
    ever, the Georgia-Pacific test is the first com-
    mercial-scale demonstration and there is some
    potential that the technology may not work as
    well as expected. In order for testing of this
    promising new technology can proceed, EPA
    will temporarily exempt the company from new
    hazardous waste emission requirements that
    are expected to become effective during  the

•   Molex Incorporated. At its electroplating fa-
    cility in Lincoln, Nebraska, Molex is using new
    technology to reduce the metal loadings in its
    wastewater. The new technology separates the
    wastewater streams from individual metal plat-
    ing processes, enabling the company to recover
    different metal contaminants, such as lead and
    copper, from its wastewater. Molex  had  ex-
    pected this  new technology to reduce metal
    loadings to the community's wastewater treat-
    ment plant by 50 percent. Molex estimates that
    the new technology has resulted in an average
    65 percent reduction in the concentration of
    copper, tin and  lead, and nickel in the effluent
    discharged by the wastewater treatment plant
    in 1999 and 2000.
For the past decade, EPA has been building greater
flexibility into regulatory programs through trading
of emission "allowances" and other approaches.
As the following examples show, in Project XL we
continue to find that a little flexibility can go a long
way toward getting better results.

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

•  New England Universities Laboratories. In
   the Northeast, a consortium of university labo-
   ratories proposed a new approach for manag-
   ing hazardous wastes in laboratory settings. The
   project enables laboratories to integrate some
   EPA hazardous waste requirements with Oc-
   cupational Safety and Health Administration
   (OSHA) standards for managing chemicals.
   This approach will potentially lead to better
   management of the chemicals, which should
   help prevent pollution and improve worker and
   student safety.

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

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

expensive method for handling and disposing
of lead-based paint debris. Massachusetts and
EPA regulations currently require extensive lead
testing on architectural debris and disposal in
costly hazardous waste landfills. Through
Project XL, Lead Safe Boston identified a po-
tentially more cost-effective option of using a
household hazardous waste exception to allow
such debris to be disposed of in a municipal
solid waste landfill that meets certain perfor-
mance criteria. With this project, Lead Safe
Boston expects to substantially reduce disposal
costs, remove lead from more homes, and pro-
tect up to 30 more children from lead expo-

Atlantic Steel Redevelopment. In Atlanta,
Georgia, a unique public/private partnership has
the potential to serve as a national model  for
creative problem-solving. This redevelopment
project expects to demonstrate that the appli-
cation of "smart growth" concepts can make
a difference in addressing transportation and
environmental issues. Real estate developers,
neighborhood groups, the City of Atlanta, Geor-
gia Department  of Transportation,  Georgia
Environmental Protection Division, and other
government agencies are working toward re-
development of a 138-acre site formerly owned
by Atlantic  Steel. This project, proposed by
Jacoby Development Corporation, includes a
multimodal (automobile, pedestrian, bicycle, rail)
bridge that would  cross and provide access
ramps to the adjacent highway as well as con-
nect the site to a nearby MARTA (mass tran-
sit) station.

Intel Corporation. With the advent of e-com-
merce and an increasingly global economy,
businesses need to be more flexible to change
product lines and processes than ever before.
First to market is no longer measured in months
but days. EPA and the Arizona Department of
Environmental Quality approved a facility-wide
emissions cap for Intel's semiconductor manu-
facturing plant in Chandler, Arizona. The new
limits allow Intel to make equipment and pro-
cess changes and to expand production capac-
ity, without regulatory reviews, as long as the
total emissions stay below the specified cap.
    Since the project began, the company has re-
    mained well under its emission limits for all
    applicable pollutants. Intel also has  avoided
    millions of dollars in production delays by elimi-
    nating 30 to 50 new source permit reviews a
    year. The company has  found the emission
    caps so successful that it will invest $2 billion
    to build a new wafer fabrication facility (Fab
    22) at the site. So long as it remains under the
    existing cap, Intel can proceed with expansion
    without first going through regulatory review.
                    a  ^Xlatiorval
As a vehicle for testing new ideas in environmen-
tal protection, Project XL is unprecedented. Pre-
dictably for an experimental program, it has
experienced some conflict and controversy. But it
also has brought important discoveries and insights
about ways to improve environmental results. Of
the many lessons EPA has learned from this unique
program, the following are some of the most im-

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

   Some businesses and communities are not only
   willing, but eager, to take greater responsibility
   for environmental results if they are given flex-
   ibility in meeting the goals.

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

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

With experiments now underway, we have begun
cataloging and evaluating the results. This is an
important step if we are to progress toward our
ultimate goal: bringing successful concepts and ap-
proaches to broader application. To realize the true
potential of these experiments, we must use what
we learn to make improvements in our national pro-
grams. In some cases, existing policies and regula-
tions  may have  to  be  adapted to  reflect more
up-to-date knowledge and technology. Already
some  Project XL innovations have been applied
beyond their original experiment. For example, us-
ing information from projects that have included
plant-wide applicability limits (PALs)—Intel,
Merck, Weyerhaeuser, Imation, and Andersen—
EPA expects to publish a rule in six months that
establishes PALs as a way for facilities to estab-
lish emission caps on their total air emissions. This
action will allow facilities to make process or manu-
facturing changes without the need for reoccur-
ring permit  modifications  and will give greater
certainty to community members of the emissions
being discharged into the local air. In another ex-
ample, the Lead Safe Boston project has resulted
in a new policy issued by EPA this summer allow-
ing residential lead-based paint debris to be dis-
posed of in municipal landfills, thus enabling
contractors across the  country to  perform lead
abatement more quickly and cost-effectively.

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


In the last decade environmental protection has become more com-
plex. We face challenges, like global warming and urban sprawl, that
are not addressed through traditional regulatory approaches. To en-
sure progress on these and other issues, we need strategies that  take
into account all the factors affecting the quality of our air, land, and
water, that respect natural  ecosystems, and that reflect the priorities
of local stakeholders. We also need to improve regulatory procedures
so businesses and communities can focus on problems, not paper-
    In 1995, the EPA launched a portfolio of high-priority initiatives
    which challenged us to think of new ways to fulfill America's
    environmental and human health protection goals. Since then, busi-
nesses, communities and other federal agencies have responded to
this challenge by participating in these initiatives, including Project XL
(which stands for excellence and Leadership).

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

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

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

a lot, made adjustments to the program, and found
ways to be more responsive to stakeholder needs.
As a result, projects are underway throughout the

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

This volume, Directory of Regulatory, Policy, and
Technology Innovations, describes early results
and how lessons learned from these efforts might
be incorporated in EPA's everyday work, such as
regulation development, permitting,  information
management and access, enforcement and com-
pliance assurance, environmental stewardship,
stakeholder involvement, and Agency  culture
change. In order to better understand the detailed
information contained in this volume, please refer
to the Innovations in Core Functions by Project
Table on page 14. For summaries of the progress
and results of individual projects, please see the
second volume, Directory of Project Experiments
and Results.

Project XL is one of many initiatives that EPA na-
tional and regional programs are conducting to ad-
dress environmental problems that have yet to be
solved through the current system. For more infor-
mation on these initiatives, please see A Decade
of Progress: Innovation at the Environmental
Protection Agency (April 2000) available at
http://www.epa.gov/opeihome/decade/ and the
1999 EPA Innovations Task Force report Aiming
for Excellence: Actions to Encourage Steward-
ship and Accelerate Environmental Progress
(July 1999) available at http://www.epa.gov/rein-
vent/taskforce/report99/.  '£

EPA's innovation initiatives aim to improve an already strong system
of environmental protection while building commonsense, cost-effec-
tive ways to "identify important problems and fix them".1 The United
States has one of the strongest systems of environmental protection in
the world, but it is neither perfect nor complete . Everyday, conditions
are changing: new technology is entering the market, better informa-
tion is becoming available, and environmental professionals are gain-
ing more understanding and  experience in managing their
responsibilities. These and other developments mean the system must
change too. By giving sponsors a chance to identify problems and
potential solutions, Project XL is learning how to adapt environmental
protection to the emerging challenges  of the new economy.
   In a development that could revolutionize computing, in Essex
   Junction, Vermont, IBM is testing a way to make computer chips
   with copper rather than aluminum — an approach that promises
   cheaper computers and faster calculations.  The new process,
   which is approximately 30 to 40 percent more efficient than the
   previous one, enables IBM to deposit a layer of metal on its
   wafers much more efficiently, maximizing metal use in manu-
   facturing and minimizing releases into the plant's wastewater
      Project XL emphasizes more comprehensive, integrated ap-
      proaches to environmental protection, helping to optimize envi-
      ronmental, community, and business outcomes by stepping back
and considering all the issues affecting environmental quality. By looking
at facilities, sectors, and communities as a whole, we are finding that
a broader view often leads to better results. States are actively ex-
perimenting with new tools to improve the performance of industry
sectors and promoting pollution prevention. Businesses increasingly
view environmental management as a fundamental part of a smart
business strategy. They recognize that they can realize a competitive
advantage while addressing environmental problems. Project XL pro-
vides a forum for communities and businesses to step forward with
innovations that have improved results, cut costs, and opened the door
to fundamentally new ways of doing business—the new tools of en-
vironmental protection.
'Sparrow, Malcom, The Regulatory Craft, Washington, DC: Brookings, 2000

  Both self certification and self audit ap-
  proaches for small businesses (Massachusetts
  Environmental Results Program)  offer en-
  hanced business accountability with enhanced
  compliance. Per unit of production emission
  limits (Andersen and Intel projects) provide
  an incentive to increase efficiency while main-
  taining flexibility; and the predictive emissions
  monitoring system (International Paper
  project) offers improved environmental per-
  formance with reduced capital expenditures.

EPA has embraced innovation as a way to facili-
tate environmental gains. But clearly, EPA is not
alone in pursuing innovative environmental ap-
proaches—it has to  happen through partnerships
with others. Other government agencies, particu-
larly the states, are active players, and local com-
munities play an increasingly important role in
environmental and human health protection. They
are developing strategies that address their own
priorities and concerns and that help sustain the
baseline of environmental protection all our citizens
have  come to expect. These cleaner,  cheaper,
smarter ways of protecting the environment have
challenged EPA to diversify the role it plays in
environmental protection—from that of Federal
command and control regulator to a co-regulator
with states, a convener of public discourse, and
partner with business and community in pollution

   A)ew Roles  for  tKe  j\ge.ncy
  Project XL supports new roles for EPA as a
  co-regulator— supporting new local govern-
  ment water pretreatment operations in the
  Steele County project, and helping communi-
  ties link their economic and environmental
  goals through the Atlantic Steel project.

The following section highlights some of the prom-
ising innovations achieved through Project XL to
date. It shows preliminary results and takes on the
broader task of Project XL—describing better ap-
proaches that are being adopted  into  our national
system of environmental protection.
                              America's industrial sectors face new problems in
                              today's economy. International competition gener-
                              ates continuously changing market demands, which
                              means that companies who can design and develop
                              new products quickly can be more strategic in the
                              marketplace. Under the Clean Air Act, companies
                              must obtain permit approvals from EPA or delegated
                              state agencies when they install new equipment or
                              change a manufacturing process. Each process or
                              type of equipment may have its own permit re-
                              quirements. Yet some industries, such as pharma-
                              ceutical or  semiconductor manufacturers, must
                              change their processes frequently to meet customer
                              demands  for new products. The paperwork and
                              time required to obtain permit approvals are costly,
                              both for the companies and the government agen-
                              cies charged with permit review. At the same time,
                              local communities also have an increased aware-
                              ness and concerns with industry impacts on human
                              health and the environment and are demanding a
                              greater degree of access to facility information and
                              government decision making about permit actions.

                              Some  companies have developed projects under
                              Project XL to make the permitting process more
                              efficient and predictable for their quick-to-market
                              manufacturing needs. These projects are based on
                              facility -wide air emission caps, which prevent the
                              facility from increasing its emissions, but allow pro-
                              cess or equipment changes without regulatory ap-
                              proval. Under this approach, facilities must offset
                              any emission increases with a reduction somewhere
                              else within the facility. EPA generally sets the cap
                              below the facility's  regulatory threshold for com-
                              pliance, thus ensuring that the project achieves bet-
                              ter environmental results than would otherwise be
                              achieved  under current regulatory requirements.
                              This allows the company flexibility (e.g., using
                              pollution prevention instead of treatment when that
                              is a better option) in meeting pollution goals. At the
                              same time, it provides  certainty to the public by
                              creating an enforceable regulatory cap on total air
                              emissions and to the regulated facility by telling them
                              what they can emit, what they  can change quickly,
                              and what limited number of major changes will re-

quire new public review. These permit caps will
provide accountability to the public by improving
their ability to gain a overall picture of a facility's
performance and ensuring that emissions will not
exceed permitted levels without giving them a new
chance to become involved.

EPA and the Arizona Department of Environmen-
tal Quality approved a facility-wide emissions cap
for Intel Corporation's semiconductor manufactur-
ing plant in Chandler, Arizona. The new limits al-
low Intel to make equipment and process changes
and to expand production capacity, without regula-
tory  reviews, as long as the total  emissions stay
below the specified cap. Since the project began,
the company has remained well under its emission
limits for all applicable  pollutants. Intel also has
avoided millions of dollars in production delays by
eliminating 30 to 50 new source permit reviews a
year. The company has found the emission caps so
successful that it will invest $2 billion to build a
new wafer fabrication facility (Fab 22) at the site.
Under the existing cap, Intel can proceed with ex-
pansion without first going through regulatory re-
view. In announcing this decision, Intel noted that
"the new facility will help us maintain our leader-
ship in the extremely competitive world of semi-
conductors. Fab 22 will give us more manufacturing
capacity in order to help us better address our cus-
tomers' growing need for high-performance  mi-

A significant part of Project XL's influence on sys-
tem change  comes from the combined impact of
several projects tackling a problem area. New regu-
lations and policy guidance for air permitting that
have been heavily influenced by Project XL inno-
vations are described in the following box.
  7\)ational  (Z-\e~an j\\t* ;Act "Permitting T^pproacKes  Influenced  by
                             Project  ,X.L Innovations

  Implementing Site Specific Caps for Determining Major New Source Review (PAL Rule): This
  forthcoming rule will establish plant-wide applicability limits (PALs) as a way for plants to establish
  capped limits on their total emissions, providing communities with certainty that emissions will not
  increase above permitted levels, in exchange for increased flexibility to add and subtract production
  units without having to go through new source review (NSR) and the associated permitting. Project
  XL has served as a test bed for several ideas of an alternative major NSR applicability system that
  allows PALs instead of traditional NSR netting for determining whether modifications are subject to
  major NSR. Projects that have included PALs as key innovations include Merck, Intel, Weyerhaeuser,
  Imation, and Andersen.

  Part 70 Revisions (Permit Revision Process Rulemaking):  This rule will provide industry with
  the flexibility to make quick operational changes while providing the public and EPA with more
  efficient and meaningful review of significant actions that could effect air quality. Instead of the
  current "one size fits all" process, which is paperwork intensive and time consuming for everyone
  involved, EPA will establish a new five-tiered system, which will provide increased flexibility for
  simple changes and increased accountability for important ones. The Part 70 changes will allow for
  an expedited review process for all facilities and will incorporate the flexibility used by the Intel

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

           Project XL is providing new ways for manufactur-
           ers to address existing compliance problems. At
           the facility level, manufacturers can find potential
           opportunities for improving environmental perfor-
           mance, yet these options may require that greater
           flexibility be added to federal regulations' technol-
           ogy requirements. In a move similar to that of the  2
           Intel project, EPA and the Virginia Department of
           Environmental Quality created a facility-wide emis-
           sions cap for Merck's Stonewall pharmaceutical
           manufacturing plant in Elkton, Virginia. Developed
           under a Clean Air Act permit that prevents signifi-
           cant deterioration of air quality,  Merck's cap also
           eliminates regulatory review for equipment or pro-
           cess changes as long as the facility's emissions stay
           below the specified cap. With this approach, Merck
           is reducing the plant's total emissions of criteria air
           pollutants by 20 percent, sulfur dioxide emissions
           by 25 percent, and nitrogen oxides emissions by 10
           percent, thus ensuring better environmental results.
           In addition, Merck will have flexibility under future
           regulations to lower its cap instead of implement-
           ing specific control technologies that might be re-
           quired  for other facilities. When a new criteria  3
           pollutant regulation  is promulgated and becomes
           applicable to the site, or when an existing regula-
           tion becomes newly applicable to the equipment at
           the site, Merck has two options.  (1) It can comply
           with the  regulation(s) as written and install new
           control equipment. (2) Alternatively, it can adjust
           the facility's site-wide emissions cap(s) by the
           amount of emission reductions that would have re-
           sulted from direct compliance with the rule (e.g.,
           reducing  the cap by the amount of emissions re-
           ductions  the new control equipment would have
           achieved, if it was installed at the site).

           Project XL has also allowed manufacturers to use
           innovative approaches and a wider variety of tech-
           nologies to control hazardous air pollutants (HAPs).
           The affect this has had on creating new regulatory
           options under HAP-related regulations is described
The 3M Hutchinson XL proposal did not reach
final agreement, however, one of the flexibilities
3M requested in their proposal was incorpo-
rated in the mid-1999 direct final rule for HAP
emissions from magnetic tape manufacturing
operations. Based on the 3M proposal  and
other  industry input, EPA determined that it
would be useful to offer regulated entities an
alternative compliance option for balancing
HAP emissions from solvent storage tanks with
emissions from other pieces of magnetic tape
manufacturing equipment.

In 2001, EPA plans to promulgate National
Emission Standards for HAPs (NESHAPs) for
"miscellaneous  organic processes." These
standards are referred to as the miscellaneous
organic NESHAPs or "the MON." Produc-
tion activities at Crompton Sistersville, West
Virginia, facility are classified as one type of
these  miscellaneous organic processes. It  is
expected that the MON will require a  level of
process vent controls  similar to the level re-
quired for the vent incinerator installed by
Crompton as part of its project. Thus, this project
is providing some preliminary data  for the
MON on the effectiveness of this type of air
pollution control technology in satisfying HAP
compliance requirements.

Innovations being  tested as part  of the
Weyerhaeuser project helped shape  several
compliance options in the Integrated Pulp and
Paper NESHAP and Effluent Limitations
Guidelines Rule  promulgated in 1998. Three
specific regulatory flexibilities undergoing test-
ing include using: alternative  compliance re-
gimes for HAP emission reductions, advanced
technologies to reduce effluent discharges, and
pollution prevention technologies to reduce air
emissions in kraft-pulping operations.


Disposal  arvd

Recycling   of Waste

Local communities and businesses are concerned
with the impact that the handling and disposal of
wastes can have on both quality of life for their
citizens and the community's economy. Designing
methods  that increase safety and reduce costly
hazardous waste generation are critical to these
concerns. As described below, changes to Re-
source Conservation and Recovery Act (RCRA)
policies are underway or under consideration as a
result of information learned from Project XL.

    EPA is releasing a national RCRA policy de-
    termination that will allow the use of an alter-
    native disposal technique for lead-based paint
    architectural debris from residential sources.
    Under Project XL, Lead Safe Boston (a Bos-
    ton, Massachusetts, city government entity) is
    testing the use of a RCRA Household Haz-
    ardous Waste Provision exclusion that would
    allow the disposal of residential-generated,
    lead-based  paint debris  in  RCRA-certified
    municipal waste landfills. Lead Safe Boston
    believes that lead-based paint debris can be
    safely managed in municipal solid waste land-
    fills that meet RCRA requirements for landfill
    liners, leachate collection systems, groundwa-
    ter monitoring, and corrective action provisions.
    It is expected that this  decision will enhance
    the cleanup of more lead-contaminated sites
    within urban areas because of the lower costs
    associated with handling and disposal of non-
    hazardous designated wastes. In addition, it is
    expected to facilitate  additional residential
    abatement, renovation and remodeling, and re-
    habilitation  activities, thus protecting children
    from continued exposure to lead paint in homes
    and making residential dwellings lead safe for
    children and adults. Specifically, Lead Safe
    Boston expects to substantially reduce disposal
costs, remove lead from more homes, and pro-
tect up to 30 more children from lead expo-
sure. EPA has used data generated during the
development of the Lead Safe Boston project
and other sources to support its recent policy

Every day many products containing economi-
cally valuable metals are being disposed of as
hazardous waste because few alternatives for
resource recovery exist. The USFilter project
proposes to eliminate or substantially reduce
the need for electroplators (i.e., metal finish-
ers, printed wiring board manufacturers) to treat
and/or dispose of their F006 hazardous waste
streams. USFilter proposes to offer "portable
exchange deionization systems" (ion exchange
canister)  to  electroplators  in lieu of on-site
physical-chemical treatment and off-site dis-
posal requirements. Once their resins become
spent, these canisters can be recharged by
USFilter  who regenerates the resins. The re-
claimed metals then can be sold rather  than
land disposed.  EPA is considering altering its
RCRA manifest and waste treatment require-
ments for electroplators who elect to use ion
exchange canisters for some or all of their F006
waste handling requirements.

RCRA hazardous waste manifest and waste
accumulation requirements often entail  high
transportation and collection costs associated
with low volume waste disposal. The New York
State Department of Environmental Conser-
vation (NYSDEC) project is testing a solution
to this problem by allowing utilities (primarily
electric and gas companies) located in the  state
to consolidate their hazardous waste generated
at remote locations at central collection facili-
ties (utility owned) before the waste is sent to
a commercial RCRA permitted treatment,  stor-
age,  and disposal facility (TSDF). Currently,
utility hazardous waste generators must have
their wastes  collected  individually at remote
sites and transported directly to a TSDF. In
many instances, this results in a large number
of vehicle trips to transport small waste loads.
As a result of the data generated from this
project, EPA is considering the modification of
its RCRA waste accumulation and  manifest

               provisions for utilities to allow national adapta-
               tion of the New York-based system.2

               Municipal solid waste landfill capacity is dwin-
               dling in United States and there is a great deal
               of interest in how to design and manage land-
               fills to extend their useful life. There are four
               project proposals currently being reviewed that
               explore various options for using leachate re-
               circulation systems (bioreactors) to extend the
               life of existing sanitary landfills by speeding up
               the decomposition process of organic materi-
               als, thereby creating more space in the landfill
               and extending its life. Each proj ect—Buncombe
               County, Virginia Landfills, Yolo County, and
               Anne Arundel County—will be exploring dif-
               ferent aspects of a bioreactor system. Collec-
               tively, the various engineering and technical
               parameters being investigated among these
               projects will provide EPA with background data
               to determine if it is appropriate to modify exist-
               ing RCRA municipal landfill design require-
           In February 1999, the Administration unveiled a
           comprehensive Clean Water Action Plan, highlight-
           ing the public's concern for protecting the nations'
           waters. In a July 1999 proposed rule affecting the
           National Pretreatment Regulations, EPA sought to
           streamline the procedures for measuring pollutant
           loadings for  industrial waste water  dischargers.
           Under the proposed rules, publicly owned treat-
           ment works (POTWs) have the option of using
           mass-based limits in lieu of concentration limits for
           industrial users if these users meet certain criteria.
The rule proposes that potential users (dischargers
to the POTW) must install the best available tech-
nology (BAT) or have equivalent BAT installed, and
they must use some form of water conservation
methods that substantially reduce their water us-

The Steele County project is referenced in the pro-
posed Pretreatment rule as one example of a mass-
based compliance experiment. Under Project XL,
the POTW of Steele County, Minnesota, will allow
participating industrial users to use mass-based limits
in lieu of concentration limits for discharges to the
wastewater treatment facility. These industrial us-
ers are primarily metal finishing facilities in
Owatonna, Minnesota. Using a mass-based limit
will allow industrial dischargers to minimize their
water usage while maintaining compliance with
their POTW requirements.  Using  a concentration
limit would not allow this to occur. Steele County
also  is testing other alternative compliance  ap-
proaches such as reduced monitoring for regulated
pollutants not present and alternative significant non-
compliance reporting. Collectively these approaches
toward complying with pretreatment regulations can
help establish a benchmark against which EPA and
other regulators will determine whether these as-
pects of the regulations should be permanently
modified. $
            2On October 7, 1999, the Atlantic States Legal Foundation
            and other parties filed a Petition for Review of EPA's final
            Project XL Rule for New York State Public Utilities in the
            U.S. Court of Appeals for the District of Columbia Circuit.
            EPA is currently exploring the option  of settlement with
            these petitioners.

^}nnovations   \n
                     The more than 70 innovations tested under Project XL are sorted by
                     EPA's core functions—the processes and operations that EPA typi-
                     cally performs to carry out its mission to protect human health and
                     safeguard the natural environment—(1) regulations, (2) permitting, (3)
                     information management and access, (4) enforcement and compli-
                     ance assurance, (5)  environmental stewardship,  (6) stakeholder in-
                     volvement, and (7) Agency culture change. These core functions are
                     defined briefly below.
A                             significant portion of EPA's work concerns developing regu-
                             lations that define for businesses, municipalities, other regu-
                             lated entities, and  the public the actions, technologies, and
                     standards required to meet federal environmental laws passed by Con-
                     gress. Under Project XL, EPA seeks to explore new and flexible ap-
                     proaches to implementing existing and future environmental regulations.
                     Projects have provided Agency regulation writers with experiential
                     data and results that influence the options available in new regulations.
                     Project XL has been particularly successful at exploring specific regu-
                     latory and policy options under the Clean Air Act (CAA), the Re-
                     source Conservation and Recovery Act (RCRA), and the Clean Water
                     Act (CWA).
                     A permit is an authorization, license, or equivalent control document
                     issued by EPA or a state or tribal agency to implement the require-
                     ments of environmental standards for a specific facility or group of
                     similar facilities. Federal permitting requirements are very important
                     environmental protection tools, but they can pose a burden for regu-
                     lated entities and regulators alike. The alternative permitting approaches
                     tested in Project XL fit into a national reform effort to shift permitting
                     toward measuring performance while providing more flexibility in how
                     standards are met, strengthen the role of the public in important deci-
                     sions, focus on results instead of procedures, reduce unnecessary bur-
                     dens, and improve environmental performance.

                      rmati o n
            EPA has national information policy and manage-
            ment responsibilities which stem from the nation's
            environmental laws and include collecting, main-
            taining, and ensuring the quality of data used for
            both internal decision-making and public purposes.
            EPA's regulations and permits have data collection
            and reporting requirements that can be burdensome
            for facilities to prepare and for regulators to col-
            lect, when publicly presenting environmental infor-
            mation and results. In many cases, state and tribal
            governments are the primary collectors and man-
            agers for this information. The required data are
            often in a specified format that is  difficult for the
            general public to access and understand.  Project
            XL explores different approaches  that seek to im-
            prove government systems for managing environ-
            mental information. These approaches include
            gaining more stakeholder input on data presenta-
            tion, building performance -based incentives into
            reporting requirements, and eliminating duplicative
            or unnecessary information requirements.
            EPA, tribal governments, and authorized states are
            responsible for ensuring that the regulated com-
            munity complies with the laws and regulations that
            protect human health and safeguard the natural en-
            vironment. To do so, an array of approaches are
            employed, including EPA's traditional regulatory en-
            forcement program and compliance assistance sup-
            port and incentives. In recent years, national efforts
            have centered around identifying and addressing
            environmental problems using innovative, integrated
            initiatives that combine compliance assistance, in-
            centives, monitoring, and enforcement. These com-
            pliance  incentives include self-certification,
            compliance measurement and management pro-
                  grams, tiered compliance testing requirements, and
                  options to use new technologies that will ensure
                  compliance by preventing pollution. Compliance
                  incentives encourage improved environmental per-
                  formance and have been explored by states, tribes,
                  local governments, and EPA. Project XL provides
                  another platform for testing these new activities as
                  well as innovative approaches for measuring com-
                  pliance on a facility and sector level.
                   £rvv i ro n me rvta I
                ds Kip
                       e war
Environmental stewardship is a way of identifying
and pursing good business strategies that are con-
sistent with environmental protection. Environmen-
tal  management  systems  (EMS), pollution
prevention, and recycling are pathways to environ-
mental stewardship that help organizations improve
their environmental performance and potentially go
beyond regulatory compliance. An EMS allows an
organization to systematically integrate environmen-
tal concerns into business and operations decisions,
address environmental decisions and focus on im-
provements in compliance rates, while  boosting
efficiency, compliance rates, and improving worker
safety. Pollution prevention, or "source reduction"
as defined by the 1990 Pollution Prevention Act
and EPA guidance,  involves protecting natural re-
sources  through conservation or increased effi-
ciency in the use of energy, water, and materials.
Recycling shares many of the advantages of pollu-
tion prevention :  they both reduce the need for treat-
ment or disposal by conserving energy and natural
resources. Project XL is a platform for testing dif-
ferent EMS approaches, and many projects have
incorporated pollution prevention and recycling ac-
tivities into their agreements.
                  The American people have demanded active in-
                  volvement in decisions that affect their health and
                  the quality of their environment. In response, EPA
                  has worked to increase stakeholder involvement

by providing them opportunities to participate in the
development and implementation of projects that
may affect them. A stakeholder may be a  civic
organization, particular interest group, governmen-
tal entity, or individual. Past, present, and potential
participants in Project XL have identified the stake-
holder involvement process as an area in which all
groups (e.g., project sponsors, government  staff,
and public participants) will benefit from additional
experience and better guidance. These projects are
producing important insights into the site-specific,
multi-stakeholder involvement process and its role
in Agency experimentation and innovation.
The emphasis on innovation has changed the way
EPA thinks and operates, leading to real environ-
mental improvements and cost reductions. The
challenge ahead is to make these innovative ideas
a permanent part of EPA's culture and reinforce
those Agency  processes and behaviors that will
address constantly changing conditions—environ-
mental, technical, socioeconomic, and political—
through new, creative solutions. Project XL has
served as a laboratory for creating a work envi-
ronment  that supports cross-Agency multimedia
innovation. While designing and testing potential
innovations, the Agency has also undertaken man-
agement, team-building, and experimentation
challenges. $


       This section catalogues 50 ongoing innovative ideas being tested
       under Project XL. These innovations are generally from the
       more mature projects underway. The catalogue uses the fol-
lowing structure to describe these innovations:

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

•   Results/Anticipated Outcome(s):  What is the potential  advan-
    tage of the innovation over the current system of environmental
    protection? Included are data that document results and data for
    those projects that are "more mature." For those projects still early
    in implementation, this section provides the operating context for
    the innovation and anticipated results of the experimental approach.

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

The table  below is a summary of the types  of ongoing innovations
sorted by EPA's core functions. This table is designed to give the reader
a "roadmap" for this section. It is not intended to be used as a check-
list for future projects.

                     "1 :   innovations  in (Z-o^e. functions  by  Project
                 Regulations Permitting  Information  Enforcement Environmental Stakeholder  Culture
                                        Management  Compliance  Stewardship  Involvement  Change

Atlantic Steel


Denton POTW

(formerly Witco)

Elmendorf AFB

NS Mayport

Vandenberg AFB


Georgia Pacific


IBM Vermont





Louisville POTW





New England

New York State


Steele County

USPS Denver



3M (Proposal)

Project XL has helped to identify and test new.
flexible options under federal regulations. To date.
project proposals have focused on hazardous air
pollution and conformity issues under CAA regu-
lations, process streamlining for RCRA hazardous
waste  compliance, promoting metals recovery
within RCRA hazardous waste requirements, im-
proving the effectiveness of CWA pretreatment
operations, and  streamlining cleanups under
CERCLA (known as Superfund). Project XL will
continue collecting data about new regulatory pro-
posals and will influence how well-established rules
are interpreted and implemented. New projects are
proposing to explore regulatory changes that can
enhance our solutions for increasing the capacity
of sanitary landfills, reducing urban air toxic emis-
sions, and decreasing persistent, bioaccumulative,
and toxic pollutants.

Because of the large number of regulatory innova-
tions underway, these innovations have been orga-
nized according to media—air, hazardous waste,
water,  and site  cleanup. Under each sub-section,
Tables 2 through 5 identify the regulatory innova-
tions being tested in current projects and illustrate
the adaptability that is possible in complying with
existing regulatory requirements.
                              A large proportion of EPA's rulemaking activities
                              have involved the ongoing development of National
                              Emission Standards for Hazardous Air Pollutants
                              (NESHAPs). These standards are required by Sec-
                              tion 112(d) of the CAA, which dictates that EPA
                              regulate the emissions of 189 hazardous air pollut-
                              ants (HAPs). The intent of Section 112 is to pro-
                              tect public health by requiring new and existing
                              "major sources" of these  HAPs to reduce their
                              generation through pollution prevention or to con-
                              trol their emissions to the level possible through the
                              use of Maximum Achievable Control Technology
                              (MACT). This technology-based requirement must
                              take into account cost, non-air quality impacts, and
                              energy requirements. NESHAPs are generally
                              structured in terms of numerical emissions limits,
                              although under certain conditions they can specify
                              a design, equipment, work practice, or operational

                              According to the CAA, no transportation activity
                              can be funded or supported by the Federal govern-
                              ment unless it conforms to the purpose of a state's
                              air quality plan. Though conformity was included
                              in the 1977 CAA, it was not clearly defined until
                              the 1990 CAA amendments. Conformity links trans-
                              portation planning with air quality planning, and func-
                                        Regulatory  innovations
 Weyerhaeuser       Water
 3M Proposal
  Crompton           N/A
 (formerly Witco)
 Atlantic Steel     Site Cleanup
Pulp and Paper Cluster Rule: Voluntary effluent discharge limitations—
allows additional time for MACT standards compliance; testing
alternative compliance approaches for HAPs; using pollution prevention
technologies to reduce HAP emissions across the facility provides
additional time to comply with MACT standards.

NESHAP for Magnetic Tape Manufacturing Operations MACT: Modification
to NESHAP based on data submitted in proposal regarding balancing
HAP emissions between controlled and uncontrolled sources.

RCRA Organic Emission Standards/Miscellaneous Organic Processes
MACT: Early compliance with NESHAP and air emission control
flexibility; use of alternative control technology, reducing organic air
emissions and potential compliance with a new MACT standard.

CAA Transportation Control Measure (TCM): Flexibility and smart growth
applications of a TCM for a brownfield redevelopment project moving
forward in area previously out of conformity with CAA.

            tions by means of reinforcing a state's air quality
            plan and keeping areas on track in meeting their air
            quality goals. It requires areas that have poor air
            quality now or had it in the  past to examine the
            long-term air quality impacts of their transportation
            system and ensure that it is compatible with clean
            air goals. These areas must assess the impacts of
            growth up front and decide how to manage it.

            Pulp and  Paper Cluster Rule

            The Experiment(s):  The Weyerhaeuser project
            has been in implementation since early 1997. While
            the project will be using a site-specific rulemaking
            to authorize MACT compliance, it has helped to
            verify compliance options in  the MACT standard
            provisions of the Pulp and Paper Cluster Rule. Flex-
            ibility for  Weyerhaeuser under Project XL paral-
            leled two major aspects of the Cluster Rule: bleach
            plant and kraft pulping operations.

            The Pulp and Paper Cluster Rule was promulgated
            in April 1998. The Water Effluent Limitations Guide-
            lines and Standards portion of the rule requires more
            stringent reductions for toxic pollutants in the waste-
            water discharges during the bleaching process and
            in the final discharge from the mill. The Effluent
            Guidelines Voluntary Advanced Technology Incen-
            tives Program, a compliance  option incorporated
            into the Cluster Rule,  encourages bleach plant op-
            erators to  install advanced technologies or make
            process changes that will reduce effluent dis-
            charges beyond the rule's  limits. If a pulp and pa-
            per mill enrolls in this program and can meet the
            strict discharge limits through advanced technolo-
            gies, the facility receives reduced monitoring and
            inspection  opportunities and additional time to com-
            ply with the air (e.g., NESHAP) portion of the rule.
            Although not required  by the Cluster Rule,
            Weyerhaeuser has conducted  a feasibility study of
            plant-wide effluent reductions through innovative
            technologies. While Weyerhaeuser's  Flint River
            facility is not participating in this program, it ex-
            pects to exceed the effluent requirements for this
            Cluster Rule option.  In addition, the facility has
            helped to confirm the usefulness of this incentive
            program and its potential to achieve stronger envi-
            ronmental performance.
Voluntarily reducing hazardous air emissions from
process water streams is another compliance op-
tion for kraft-pulping operations that was incorpo-
rated under the Pulp and Paper Cluster Rule. The
Clean Condensate Alternative Program focuses on
reducing the HAP emissions throughout the pulp
mill by reducing the HAP mass in process water
streams. By lowering the HAP mass loading in
wastewater streams, fewer HAPs will be volatil-
ized to the atmosphere. Many of the  pollutants
emitted from production vents originate in mill con-
densates that circulate throughout the mill. If amill
can reduce these condensates instead of control-
ling individual specified vents, they will achieve
greater air emission  reductions and reduce their
compliance costs. Although not participating in this
alternative program, Weyerhaeuser's willingness
to redesign its mill  to reduce vent condensate
streams throughout the facility was instrumental in
formalizing this opportunity within the Cluster Rule

The Pulp and Paper Cluster Rule also provides  in-
centives for using pollution prevention technologies
in kraft pulping operations. The MACT standards
provide for an extension of up to eight years from
promulgation for compliance if pollution prevention
approaches that otherwise would not have been
used are used. Pulp and paper facilities will have
the flexibility to demonstrate HAP emission reduc-
tions using innovative pollution prevention ap-
proaches in lieu of, or in addition to, end-of-pipe
HAP controls. This extension is designed to en-
courage mills to install pollution prevention tech-
nology that will reduce HAP emissions from the
pulping process as well as both air and water pol-
lutant discharges from the bleaching process. Aside
from the incentives offered to all pulp and paper
manufactures  in   the   Cluster  Rule, the
Weyerhaeuser project is demonstrating pollution
prevention approaches to reducing HAP emissions.
These  approaches include reducing process con-
densate wash water HAP content, reducing bleach
plant  HAP  emissions,  reducing  oxygen
delignification HAP emissions, and reducing cylin-
der mould decker and filtrate tank HAP emissions.

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

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

Weyerhaeuser has prepared a site-specific MACT
compliance plan. This plan documents HAP emis-
sion reductions that have been realized at the Flint
River Facility. A  review of the data has shown that
the facility is collecting and destroying  more HAPs
than is required  under the Cluster Rule. A draft
site-specific MACT rule has been prepared, and it
is anticipated that this rule will be proposed soon.
Transferability: The Pulp and Paper Cluster Rule
has been promulgated and now regulates toxic air
pollutants in 155 of the 565 pulp, paper, and paper-
board mills in the United States. Ninety-six of those
155 mills also have their toxic water discharges
regulated by the rule. Individual mills may choose
the control technologies and process change com-
binations that are the most advantageous for them
to meet these regulations. As noted earlier, data
and information  from the  development of the
Weyerhaeuser project helped to inform many of
the compliance options associated with the rule.

NESHAP for Magnetic Tape Manufacturing
Operations MACT

The Proposal: The  3M Hutchinson XL proposal
did not reach final  agreement. However, one of
the flexibilities 3M had requested is being used in
the revised Magnetic Tape Manufacturing opera-
tions MACT standard. This standard, a recent
amendment to a 1994 industry-specific HAP rule,
illustrates EPA's willingness to amend regulatory
requirements when the regulated community  can
provide persuasive data suggesting new alterna-
tives. Since the 1994 rule was issued, 3M provided
EPA with data showing that the volume of HAP
emissions from uncontrolled solvent storage tanks
is very close to that of HAP emissions  from  un-
controlled vessels of mix-preparation process equip-
ment.  By balancing emissions from these
uncontrolled sources against those sources in the
process line that are controlled, 3M was  able to
suggest alternative control options. EPA accepted
3M and other industrial data  and  proceeded to
amend the 1994 rule providing facility owners  and
operators with 25 options for "undercontrolling"
tanks and/or mix-equipment vessels based on the
level of control they achieve on their coating lines.
3M developed these data in conjunction with a regu-
latory flexibility proposal the company submitted to
Project XL.

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

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

            Transferability: The MACT rule amendment is
            a permanent change to an earlier promulgated rule.
            It is expected that this amendment will increase
            compliance with this regulation, enhance flexibility
            for affected entities, and reduce companies' com-
            pliance costs.

            RCRA Organic  Emission Standards/
            Miscellaneous Organic Processes MACT

            The Experiment(s):  The Crompton (formerly
            Witco) project aims to reduce air emissions through
            a combination of flexible air pollution control and
            waste minimization/pollution prevention (WM/PP)
            activities.  The polyether  methyl capper unit at
            Crompton's Sisterville, West Virginia, plant is the
            focus of air emission control efforts. The capper
            unit is the site of a two-step reaction that results in
            one of Crompton's products,  methyl-capped
            polyether.  Methyl chloride, dimethyl ether,  and
            methanol emissions generated in the capper unit
            during production of the methyl-capped polyether
            will be collected and routed to a new process vent
            incinerator installed on the capper unit.

            EPA and West Virginia Department  of Environ-
            mental Protection (WVDEP) deferred the RCRA
            Subpart CC organic air emission standards appli-
            cable to Crompton's two surface impoundments.
            These surface impoundments are  1-million-gallon
            reservoirs that hold wastewater from the facility's
            pollution control equipment and other sources.
            Without the  deferral, the  Subpart CC standards
            would have required Crompton to install air emis-
            sion controls on these impoundments. However,
            Crompton could have replaced the existing reser-
            voirs with open-top reservoirs that are  not regu-
            lated under RCRA Subpart CC, and air emissions
            would not have been reduced. With the deferral,
            Crompton will now install a vent incinerator on the
            capper unit.
Based on an XL-generated  site-specific rule,
Crompton installed the vent incinerator in lieu of
complying with RCRA organic air emission stan-
dards. In 2001, EPA plans to promulgate NESHAPs
for "miscellaneous organic processes," called "the
MON." Production activities at Crompton's
Sistersville facility are classified as one type of these
miscellaneous organic processes.  Based on cur-
rent understanding, it is expected  that the MON
will require a level of process vent controls similar
to the level required for the vent incinerator installed
by Crompton  under the project. While the
Sistersville project will provide superior environ-
mental performance only until the  MON is in ef-
fect, the Crompton project has provided a test bed
for experimenting with air emissions control tech-
nology under RCRA. The project's FPA requires
a reevaluation of the project following proposal of
the MON. Crompton will prepare a project reevalu-
ation report within 90 days following the close of
the comment period for the  MON. If EPA,
WVDEP, and other stakeholders agree to continue
the project, the FPA will be amended to identify
new approaches to achieve superior environmen-
tal performance beyond the MON  requirements.

Results/Anticipated Outcomes:  Installing a pro-
cess vent incinerator on Crompton's capper unit in
return for a deferral of air emission standards for
its surface impoundments will lead to air emission
reductions several years earlier  than would have
been obtained without undertaking the project. As
required by a site-specific rule, the vent incinerator
has destroyed at least 98 percent  of the organic
compounds (about 271,000 pounds) in the  vent
stream. In 1998, the capper unit  emitted a total of
59,898 pounds of organic compounds. Since the
vent incinerator was installed and put into opera-
tion, air emissions of total organics have been re-
duced by over 217,000 pounds per year as compared
with 1995 baseline levels. Performance tests indi-
cated that the oxidizer is reducing total organics in
the vent stream by 99.99 percent, versus the 98
percent minimum required by the facility's site-spe-
cific rule. In addition, undertaking this project will
allow Crompton to defer the  expenditure of ap-
proximately $2 million in environmental control costs
for several years.

Transferability:  The Crompton project demon-
strates the potential benefits for allowing air emis-
sion control technology flexibility under RCRA
regulations in order to provide superior and more
cost-effective environmental protection. Flexibility
in the control of air pollutants by Crompton's
Sistersville plant demonstrates the adaptability that
is possible in complying with air regulatory require-
ments. Similar adaptations may be applicable to
other plants that are facing similar compliance prob-
lems and should be investigated relative to existing
and future air emissions issues.

CAA Transportation Control Measure (TCM)

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

Although the State of Georgia is seeking to redes-
ignate for attainment, at the time the Atlantic Steel
final project agreement was being developed, the
City of Atlanta was out of compliance  with Fed-
eral CAA  standards for ground-level ozone emis-
sions. Between January 1998 and July 2000, the
Atlanta Regional Commission had failed to dem-
onstrate that new transportation activities will not
further degrade or delay timely attainment of air
quality standards for the region. The CAA gener-
ally  prohibits new transportation construction
projects that use Federal funds or require Federal
approval in areas where conformity with CAA re-
quirements has lapsed. Under the CAA, a project
must demonstrate an air quality benefit to be con-
sidered a TCM. In a traditional sense, the Atlantic
Steel project would not qualify as a TCM, but EPA
views the combination of transit linkages (17th
Street Bridge), site location, site design, and other
elements collectively as a TCM.

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

Results/Anticipated Outcomes: EPA completed
an environmental assessment for the Atlantic Steel
project in compliance with the National Environ-
mental Quality Policy Act. While the project is still
undergoing State Implementation Plan (SIP) ap-
proval, it is proceeding based on the premise that
the unique "livability" attributes and interconnected
design of this specific project will result in long-
term air quality benefits for the region. EPA evalu-
ated the air quality benefits of this project based on
the fact that (1) the Atlanta metropolitan region is
projected to continue to grow over the next 20 years
and (2) if the Atlantic Steel site were not redevel-
oped, more of this growth would occur in outlying
areas.  By comparing this development of a
brownfield to similar development of greenfield sites,
the Atlantic Steel project and its associated trans-
portation measures were linked to analyze the over-
all air quality effects of the development. An analysis
of regional transportation and air emissions impacts
of the Atlantic Steel development showed that by
absorbing a larger portion of Atlanta's growth, the
Atlantic Steel project would create as many as 34
percent fewer vehicle miles traveled (VMTs) and
reduce associated NOx emissions by 45 percent
when compared to growth occurring at alternative
greenfield sites.

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

            Transferability: Urban growth has resulted in in-
            creased traffic congestion, continued encroach-
            ment on green  spaces, and resultant air quality
            conformity problems. The Atlantic Steel project—
            an integrated, mixed-use, multimodal project, lo-
            cated near the central business district—can serve
            as a model for future smart growth planning and
            redevelopment. As more cities struggle with urban
            development, transportation, and air quality prob-
            lems comparable to those in Atlanta, many aspects
            of this project will have the potential to be trans-
            ferred to these locations. EPA is in the process of
            drafting policy guidance identifying methodologies
            to help account for the  air quality benefits  of
            brownfield developments in the air quality and trans-
            portation planning process. As the Atlantic Steel
            project proceeds, there will be a need to analyze if
            the regulatory flexibility that will enable the project's
            site design to positively impact transportation and
            air quality can provide opportunities to maximize
            environmental performance at comparable rede-
            velopment sites.
                   RCRA regulations classify hazardous waste as ei-
                   ther characteristic or listed. Characteristic wastes
                   have  measurable properties that indicate that  a
                   waste poses enough of a threat to require regula-
                   tion. EPA established four hazardous waste char-
                   acteristics: ignitability, reactivity, corrosivity, and
                   toxicity. Listed wastes come from generic indus-
                   trial processes, certain sectors of industry, and un-
                   used  pure  chemical products and formulations.3
                   F006 wastes — wastewater treatment sludges from
                   electroplating operations — have been the subject
                   of several projects.
                                3-  Hazardous  Waste Regulatory  innovations
             New York State DEC
             New England
             Universities Laboratories
             Molex, HADCO
             IBM Vermont
 RCRA Streamlining—Waste Handling Waiver: Revisions to streamline
 remote waste handling and transportation. Satellite waste consolidation.
 RCRA Performance-based Environmental Management Standard: Laboratory
 environmental management standard to streamline RCRA and
 OSHA regulatory programs.
 RCRA Streamlining—Delistings and Variances: Conditional delistings and
 solid waste variances to encourage metals recovery and recycling;
 optimizing the recovery of metals by operating a segregated treatment
 system; testing F006 waste stream and copper dust recycling.
 Process Exemption—Innovative Copper Metallization:  IBM-VT has introduced
 a new, innovative copper plating process to deposit a layer of metal on the
 wafer and is seeking a site specific process exemption from the F006 listing
 for its copper plating process rinsewater.
                                                             3These wastes are listed according to waste categories, such a
                                                             F, K, P, and U. Wastes from non-specific sources are F codes.
                                                             wastes from specific sources are K codes, and wastes from
                                                             commercial products are U and P codes. Wastes from non-
                                                             specific sources include material-specific wastes generated
                                                             by a variety of processes. This category of wastes include
                                                             solvent wastes,  electroplating wastes, metal heat treating
                                                             wastes, and dioxin-containing wastes.

RCRA Streamlining—Waste Handling Waiver

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

Utilities are currently allowed to accumulate haz-
ardous waste at remote locations for up to 90 days
without a RCRA permit prior to transporting the
waste to  a permitted TSDF. Since remote loca-
tions are  often unstaffed, it can be difficult to ac-
cumulate hazardous  waste and secure it against
releases resulting from accidents or vandalism.
Additionally, in urban "remote" locations, waste left
at street access locations can disrupt normal traf-
fic patterns. For these reasons, utilities would pre-
fer to transport hazardous waste immediately from
remote locations. However, the waste must be
transported directly to  a TSDF, and arranging to
bring  the waste directly to the TSDF can take sev-
eral days, especially if the event is unplanned. Un-
der the New York State DEC project, these utilities
will be able to transport remote location hazardous
waste as soon as it is collected and to consolidate
wastes for up to 90 days at their designated UCCFs
before it is transported to a permitted TSDF. In
addition, utilities will be allowed to combine similar
wastes at their UCCFs. Consolidation will result in
fewer vehicle trips, with each trip carrying a larger
waste load. The regulatory flexibility in this project
is expected to streamline the reporting process,
resulting in a reduction of duplicative paperwork,
streamlined information for the public, and a cre-
ation of direct cost savings for participating utili-
ties, EPA, and New York State DEC.

Results/Anticipated Outcomes:  EPA issued a fi-
nal rule in July of 1999 providing regulatory flex-
ibility under RCRA that will allow participating New
York State utilities  to consolidate the hazardous
waste generated at remote locations at designated
UCCFs. New York State has received authority to
administer most of the RCRA program and the rule
will not  become effective until the state adopts
equivalent requirements as state law. New York
State will be promulgating a specific state rule with
equivalent provisions to the federal rule. The state
will review and approve UCCF participation. This
rule change will provide superior environmental
performance and protect public health by facilitat-
ing the removal and consolidation of hazardous
wastes at remote locations. Under the rule, haz-
ardous waste will be transported to a UCCF within
a utility  right-of-way network immediately after
collection or  when the staff collecting the waste
leave the location, whichever occurs first.

Under the New York State DEC project, each par-
ticipating utility is required to reinvest one-third of
its direct cost savings into environmental remediation
or pollution prevention activities that go beyond
what is legally required and that were not planned
prior to participation in the project. In their annual
progress reports, participating utilities will be re-
quired to identify the monetary value of the direct
cost savings they have experienced as a result of
the project as well as the environmental activities
in which they are investing.

Transferability:  The New York project seeks to
enable innovative waste handling practices to safely
and effectively deal with the problems associated
with the generation of hazardous wastes at remote
locations. These new practices can benefit utilities
across the country facing similar problems with the
remote generation, transportation, and secure ac-
cumulation of hazardous wastes. This project pro-
vides the opportunity to examine (1) if immediate
transport of hazardous waste to central collection
facilities reduces accidental releases and risks to
human health and the environment, (2) whether the

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

RCRA Performance-based Environmental
Management  Standard

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

The three New England universities' laboratories
want to  experiment with a Laboratory EMS  ap-
proach because it provides a means for compre-
hensively managing all laboratory hazardous wastes.
It is through the Laboratory EMP that the universi-
ties will have the opportunity, and the obligation, to
create a performance-based EMS. This compre-
hensive environmental management approach will
complement their OSHA requirements, encourage
waste minimization, and stimulate the redistribu-
tion and reuse of laboratory waste within each uni-

Results/Anticipated Outcomes:  The New En-
gland Universities Laboratories project provides the
participating universities atemporary conditional de-
ferral from two specific RCRA regulations (Haz-
ardous Waste Determination  and  the Satellite
Accumulation Provisions). These RCRA regula-
tions have  been identified by the universities as
impediments to a more efficient and effective labo-
ratory waste management system. This deferral is
based on the universities' compliance with the
Laboratory EMP and minimum performance cri-
teria set forth in the site-specific RCRA rule.

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

Environmental benefits also will  result from in-
creased environmental awareness. Training, de-
fined policies and procedures, enhanced audit
programs, and pollution prevention  strategies are
key management elements. One  element of the
Laboratory EMP requires  each university to de-
fine a list of "hazardous chemicals of concern" and
annually conduct a risk assessment survey of these

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

Transferability: The Laboratory EMS is designed
to offer a potential RCRA waste management ap-
proach for research and teaching institutions. The
long-term vision of the participating universities in
proposing the laboratory standard is that, by stream-
lining and coordinating the RCRA and OSHA regu-
latory programs,  an integrated and transferable
Laboratory EMS will allow scientists and research-
ers who move from one institution to another (or
temporarily perform research on a sabbatical at a
different institution) to be subject to and familiar
with a consistent approach. The search for an al-
ternative regulatory system for managing hazard-
ous wastes in laboratories is currently  being
discussed in California, North Carolina, and other
states and regions of the country.  Minnesota has
expressed interest in testing this Laboratory EMS
and other research organizations have expressed
interest in becoming "second-tier adopters."

Since Massachusetts and Vermont have been au-
thorized to administer most of the RCRA program
in lieu of the Federal program, this rule will not
take effect until both states adopt the requirements
as state law. Each state has begun the process of
incorporating this new regulation into their autho-
rized programs while the universities are in the pro-
cess of developing their EMPs.

All three New England universities participating in
this project and implementing  Laboratory EMPs
are members of the Campus Consortium for Envi-
ronmental Excellence (C2E2), which originated in
the New England geographic region. The lessons
learned from these pilots could be transferable to
other C2E2 members. If results indicate success,
the sharing of information and resources from these
pilots will not be limited to the New England geo-
graphic area, however, and are expected to be
transferable to other academic institutions, hospi-
tals,  and corporations with extensive laboratory
efforts. The types of information and resource shar-
ing that is envisioned include (1) developing educa-
tional and training materials for laboratory work-
ers, (2) sharing information about managing and
environmental performance monitoring for labora-
tories, and (3) integrating environmental manage-
ment with laboratory health and safety practices.

RCRA Streamlining—Delistings and

The  Experiment(s):  Under RCRA regulations,
regulated entities may petition the Agency to ex-
empt or exclude materials from being classified as
a solid or hazardous waste. Two of the RCRA pro-
cedures being tested in the HADCO and Molex
projects are, respectively, conditional delistings and
solid waste variances. Delisting is a form of relief
for generators and handlers of listed wastes with
low  concentrations  of hazardous constituents.
Through a site-specific process, a waste handler
can submit to an  EPA region or state a petition
demonstrating that even though a particular waste
stream (generated at its facility) is a listed hazard-
ous waste, it does not pose a sufficient hazard to
merit RCRA regulation.

Generators, owners,  and operators of hazardous
waste management facilities also may petition EPA
for a variance from their wastes being classified
as a solid and hazardous waste. The Agency may
determine on a case-by-case basis that certain
materials should not be classified as a solid or haz-
ardous waste.

HADCO is examining ways to overcome barriers
to the recovery of metals that are associated with
sludge waste. There  are three HADCO facilities
in two different  states—New York and New
Hampshire—currently involved in the project. The
HADCO project tests various aspects of hazard-
ous materials recycling. Transporting hazardous
waste sludges off-site is costly and there are risks
inherent in their long-distance transport. On-site
recycling of some of these materials may be eco-
nomically  feasible. The HADCO project addresses
three different waste recycling and reduction ques-
tions: (1)  Can F006  RCRA wastes be safely re-
cycled by primary  metals smelters or other
appropriate metal  reclamation facilities? (2) Is it
possible to recycle copper dusts, a current by-prod-
uct of HADCO operations that is being sent to a

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

Molex has upgraded the wastewater treatment
system at its Lincoln, Nebraska, facility to optimize
the recovery of metals  used in its electroplating
processes. This is being  accomplished through use
of a segregated treatment system for nickel, cop-
per, and tin/lead wastestreams. EPA and Nebraska
issued Molex a temporary variance from hazard-
ous waste regulations  based  on the company's
agreement to (1) routinely collect  environmental
data on the waste sludges and wastewater efflu-
ent and (2) collect appropriate cost information
associated with the operation of the segregated
treatment system and sludge handling activities.
Obtaining the temporary variance classifies its seg-
regated process sludge as a "commodity-like" ma-
terial rather than as a hazardous waste, allowing
Molex to change not only the method of shipping
(to common carriers from hazardous waste haul-
ers subj ect to RCRA regulations), but also the ship-
ping frequency (on an as-needed basis rather than
every 90 days as required for hazardous waste).

Results/Anticipated Outcomes:  HADCO  will
measure the benefits of its  copper recycling ex-
periments by estimating the reduction of air emis-
sions associated with their truck shipments of sludge
wastes. The company hopes to reduce annual fuel
usage by 75 percent once regulatory relief is pro-
vided. In its 2000 annual report, HADCO submit-
ted data developed from F006 sludge shipments
from 1995 through 1999, in addition to data analy-
ses and estimates of additional parameters for the
same period.  Once regulatory relief is provided,
HADCO will begin documenting progress in meet-
ing its fuel reduction goal in its annual reports. The
company's annual goal  is to reduce by 75 percent
its air emissions based  on F006 sludge shipment
records from  1995 through 1999.  HADCO's fu-
ture annual reports will describe its progress on
meeting this goal once regulatory relief is secured.
Similarly, HADCO expects to include in future an-
nual reports the project-related savings from the
reclamation of its copper drilling, sawing, and edg-
ing dusts, as well as from the reduction in copper
use throughout the facility. HADCO installed one
sludge dryer in its Deny, New Hampshire, facility,
and the company's goal is to reduce the sludge from
this facility by 40 percent. HADCO will describe
the utility of the sludge dryer installation in future
annual reports and discuss the feasibility of install-
ing dryers in other New Hampshire facilities.

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

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

•   a 65 percent reduction in the concentration of
    total metals in the effluent discharged by the

    decreased  copper  concentrations in the
    POTW's effluent by 81  percent;

    decreased nickel concentrations in the POTW's
    effluent by 80 percent; and

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

Transfer ability: By offering regulatory flexibility
to HADCO and Molex, EPA and the states of New
York, New Hampshire, and Nebraska are able to
evaluate the effectiveness of offering a conditional
delisting or solid waste variance for RCRA-listed
wastes so as to encourage metals recycling and
reduce solid waste generation. Many printing wir-
ing board manufacturers face environmental prob-

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

The Molex project expects to reduce metals' load-
ings in its effluent discharges to the Lincoln, Ne-
braska, POTW by at least 50 percent.  This goal
should provide a benchmark against which other
potential requests for temporary variances may be
measured. Fundamental to both of these projects
will be the environmental and economic feasibility
of these alternative compliance  strategies. It must
be demonstrated that these regulatory flexibilities
not only cause no adverse  environmental impact
but also, in fact, offer significant environmental

Process  Exemption—Innovative Copper

The Experiment(s):  The technologically dynamic
life cycle of semiconductor chip manufacturing has
led to a rapid evolution of manufacturing process
technologies. IBM's semiconductor manufacturing
facility in Burlington, Vermont, has developed and
introduced a new, innovative copper metallization
step into the chip manufacturing process that uses
a copper plating process to deposit a layer of metal
on the wafer. This process replaces the Aluminum
Chemical Vapor Deposition process, a dry process
used for the current  generation  of semiconductor
device technologies.  IBM's new metallization step
adds 400 gallons per day of copper plating
rinsewater (present generation rate, rising to ap-
proximately 3,000 gallons per day in 2002) to all
other process wastewaters (approximately 4.1 mil-
lion gallons) generated at the Burlington facility.
Prior to implementation of this new metallization
step, these other process wastewaters were not
regulated as a hazardous waste under RCRA.

Commingling of the copper plating rinsewater with
all other wastewaters  has required that the
Burlington facility classify all sludge generated by
the wastewater treatment process  (3 tons per day)
as an F006 hazardous waste, even though the cop-
per plating rinsewater negligibly changes pollutant
concentrations in the sludge. Additionally, copper
is not one of the materials listed  as the basis for
F006 classification. Current RCRA regulations state
that wastewater treatment sludges from electro-
plating operations are F006 wastes, and this new
plating process meets the narrative description of
electroplating. Rather than pursue delisting of the
wastewater treatment sludge, IBM Vermont sought
a site-specific process exemption from a F006 list-
ing for its copper plating rinsewater and resultant
treatment sludge. This exemption removes an "up-
stream" manufacturing process (copper metalliza-
tion) from EPA's  definition of an electroplating
operation as the newer process is considerably dif-
ferent from the electroplating that was performed
when the regulation was conceived. Specifically,
this process does not involve plating baths of thou-
sands of gallons of water that can result in large
amounts  of toxic metals in wastewater treatment
sludges, but instead uses only 40 gallons of plating
bath for several wafers.

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

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

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

            Transferability: IBM's copper  metallization pro-
            cess could have application in other chip manufac-
            turing facilities that are seeking  to attain more
            efficient production methods while reducing waste
            generation per unit output. By focusing on the pro-
            duction (copper metallization process) side, this
            project  also offers EPA an opportunity to test a
            different approach in determining whether "down-
            stream" treatment waste resulting from a new "up-
            stream"  process should be  subject to hazardous
            waste listings.
                                          1^ emulations
                            Publicly owned treatment works (POTWs) that
                            have mastered the programmatic aspects of the
                            industrial pretreatment program (identifying users,
                            permitting, monitoring) are seeking to move toward
                            more performance-based environmental processes.
                            Some POTWs want to make decisions on allocat-
                            ing resources based on the risk associated with the
                            industrial contributions they receive along with other
                            factors.  Others want to be able to focus more re-
                            sources  on ambient monitoring in their receiving
                            waters and/or to integrate their pretreatment pro-
                            grams with other environmental monitoring pro-
                            grams. In general, POTWs want the opportunity
                            to redirect limited resources toward activities that
                            they believe can produce greater environmental
                            benefits. A performance-based pretreatment pro-
                            gram pilot can allow experimentation with certain
                            programmatic  requirements of POTWs' approved
                            Pretreatment Program. This flexibility will enable
                            POTWs to shift resources toward innovative ac-
                            tivities likely to yield superior environmental results.

                            Project XL is  sponsoring a series of projects in-
                            volving POTWs. While each project investigates
                            unique innovations, they all offer EPA the prospect
                            for improving the pretreatment program as a whole .
                                        4-:  Water "Regulatory  innovations
             Albuquerque POTW
             Denton POTW
             County POTW
             Steele County

             Steele County
Integrating Pollution Prevention into Pretreatment: Resource reapportionment
toward pollution prevention outreach and implementation at 25 new
industrial users a year; reduce or stabilize 13 water pollutants of concern as
well as mass and concentration loadings of influent, effluent, and biosolids.

Remote Monitoring and Watershed Protection: Reduced monitoring and
annual inspections while having greater focus on pollutants in urban
stormwater drainage. Resource savings from regulatory flexibility
reapportioned to watershed protection activities.

Watershed-based Pretreatment Management: Three-phase project that will
reallocate pretreatment resources to develop a more holistic watershed
protection approach. The FPA describes project Phases I and II and will
allow implementation of a third phase.

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

Reduced Monitoring for Regulated Pollutants Not Present: Reduced or eliminated
monitoring for regulated categorical pollutants not present in a facility's discharge.

They all test alternative methods for protecting the
environment and better ways to maintain healthy

Integrating Pollution Prevention into

The Experiment(s): The City of Albuquerque (New
Mexico) POTW project aims to reduce the amount
of water pollutant loadings from business and in-
dustry in the city by integrating pollution prevention
activities with Albuquerque POTW's existing In-
dustrial Pretreatment Program (IPP). This will be
achieved by shifting resources from currently re-
quired IPP activities and requirements. Albuquer-
que POTW's current pollution prevention outreach
efforts will be expanded through various methods
and will be guided by new sampling and monitoring
of sewer system sub-basin manhole locations. Sub-
basin monitoring will investigate the feasibility of
detecting  where in the city certain pollutants of
concern are most prevalent. The Albuquerque
POTW project will create a baseline from which a
pollution prevention program can be customized to
meet the requirements of an area. Sub-basin moni-
toring is a change from the current system of sam-
pling influent at the POTW and deducing the
upstream source(s). The monitoring information will
be used to target the development and promotion
of pollution prevention outreach material at appro-
priate locations  and businesses within the sub-
basin(s) of the city.

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

Pollutant reductions will be guided by sewer sub-
basin monitoring to  determine where certain pol-
lutants of concern predominate. Actual pollutant
levels will be monitored in the sub-basins before
pollution prevention outreach and implementation
occurs. Once the monitoring baseline is established.
certain sub-basins could receive more focused and
intense pollution prevention outreach efforts de-
pending on the type and amount of pollutants iden-
tified. This is expected to  result in an eventual
stabilization and/or decline of targeted pollutants of
concern, reducing targeted pollutants by 10 to 20
percent over time.

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

Remote Monitoring  and Watershed

The Experiment(s): The  Denton POTW project
is using regulatory flexibility to begin development
of a watershed protection program  for the Pecan
Creek. The City of Denton, Texas, (Denton POTW)
will receive flexibility from the Pretreatment Pro-
gram to modify its annual industrial user inspection
and monitoring schedule for individually approved
facilities and focus on pollutants in urban stormwater
drainage. Saved resources due to this flexibility will
be reapportioned to site-specific watershed pro-
tection activities, including developing buffer zones
along underdeveloped areas in the watershed and
establishing a remote  creek monitoring network
integrated with a local flash flood warning system.
This remote monitoring network, being developed
in partnership with the University of North Texas,
will transmit real-time water quality data from au-
tomated, remote monitoring stations located up- and
downstream from the  POTW.

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

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

Results/Anticipated Outcomes:  The Denton
POTW project tests the application and develop-
ment of technological methods to  achieve
stormwater and watershed monitoring requirements
with minimal personnel demand. The project will
focus on establishing baseline ambient conditions
of Pecan Creek with monitoring designed to as-
sess the impact of pollution control measures.

The Denton POTW will assess the impact of its
efforts to control stormwater runoff and pollution
using elements of the State of Texas' Receiving
Water Assessment  and  Clean Rivers Program.
Water quality and aesthetic indicators will be used
to measure the effectiveness of all proposed wa-
tershed protection activities.

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

Watershed-based Pretreatment Management

The Experiment(s):  The Louisville  and Jefferson
County Metropolitan Sewer District (MSD) wants
to more effectively manage  its local pretreatment
program and establish links between other District
wastewater programs (e.g., stormwater). This will
move MSD toward a more holistic watershed pro-
tection strategy for the Chenoweth Run watershed.
The  MSD  project will  move forward in three
phases: (1) data collection and development of pre-
treatment performance measures, (2) pretreatment
program redesign to reduce key pollutants and iden-
tify areas  of resource inefficiency, and (3) new
program implementation to reduce mass loadings.
Phase I  of the project was cemented in a Phase I
agreement. Phase II is described in greater detail
in the FPA.  Phase III is intended to result in re-
source savings that MSD can shift to pollution pre-
vention outreach activities, first within  the
pretreatment program and then in other watershed
based programs.
Results/Anticipated Outcomes:  The MSD project
has proposed to better manage the Jeffersontown
POTW's pretreatment program through a holistic
watershed approach. In Phase I, MSD collected
supplemental and improved data from "strategic"
points in the sewer collection system. These data,
combined with existing pollutant data, enabled MSD
to establish a baseline for pollutant loadings. With
this baseline established, MSD will develop loading
projections and reductions, performance measures,
and new pretreatment program elements.

MSD has already realized benefits from meaning-
ful data and better coordination of information. MSD
expects to realize further benefits through enhanced
response to wastewater treatment plant upsets,
reapportioning monies that would have been spent
on permitting and monitoring to pollution preven-
tion projects within the watershed. These projects
are intended to maintain or decrease loadings of
certain pollutants within the watershed.

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

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

Mass-based Compliance Standard

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

finishing facilities, that will commit to a cumulative
reduction of some regulated wastewater effluents
while reducing overall water usage.

One project goal is to facilitate water conservation
measures at sponsor facilities. To effectively insti-
tute such measures,  sponsors in Owatonna sought
regulatory flexibility to express concentration-based
pretreatment categorical limits with mass-based lim-
its. The CWA's National Pretreatment  Standards
establish limits on pollutants in specific industrial
categories.  The standards establish pollutant limi-
tations in different ways for different categories.
The Owatonna sponsor facilities are currently op-
erating under concentration-based standards. Cur-
rent regulations do not allow alternative mass-based
limits to be substituted for a concentration-based
limit when  the applicable standard is expressed in
terms of concentration. This lack of flexibility can
cause obstacles for industrial users that are attempt-
ing to reduce or minimize water use. By reducing
volume, water conservation can increase the con-
centration of pollutants, even if the total mass of
pollutants has decreased. A facility that has cut its
water use might exceed its concentration-based
limit despite having reduced pollutants in its dis-
charge. By  complying with a mass-based limit that
is equivalent to or less than the total pollutant load
from a concentration limit, pollutant loading would
be unchanged or reduced, even though effluent
concentration might have increased. Through the
Steele County project, the local POTW is able to
allow sponsor facilities in Owatonna to use mass-
based limits in lieu of concentration limits for dis-
charges to the wastewater treatment facility.

Sponsor facilities will also pursue wastewater ef-
fluent reductions that are greater than what is
achieved under current regulations. The sponsors
in Owatonna, a group of small-to-medium sized
facilities, have made a voluntary commitment to a
20 percent  reduction in  the discharge of each of
four priority metals (chromium, copper, nickel, zinc).
The sponsor facility in Blooming Prairie has made
a voluntary commitment to a 20 percent reduction
in biological oxygen demand (BOD),  total sus-
pended solids (TSS), and total Kjeldahl Nitrogen
(TKN) that flow to the local POTW. If these dis-
charge reductions goals are met, sponsor facilities
could receive flexibility in the form of reduced
monitoring frequency.
Results/Anticipated Outcomes: In return for the
equivalent mass-based limit flexibility, Owatonna
sponsor facilities have committed to a goal of re-
ducing the total amount of water flowing from spon-
sor facilities to the wastewater treatment facility
by 10 percent over the course of the project. Regu-
latory limits for industrial discharges from the spon-
sor facilities will remain in effect, but these limits
will be changed from  concentration-based to
equivalent mass-based limits. Any exceedance of
a mass-based limit could result in the use of a tra-
ditional enforcement tool. To ensure the appropri-
ateness of the mass-based limits, sponsor facilities
will be required to notify the POTW in the event
that production rates vary, impacting mass loading.

For the  Owatonna sponsor facilities, if the metal
discharge goals are  met, the POTW would have
the option to reduce the frequency of monitoring
from quarterly to biannual monitoring for facilities
with satisfactory compliance records. For the
Blooming Prairie sponsor facility, if the effluent dis-
charge goals are met, the frequency of monitoring
for BOD, TSS,  and TKN could change from a
weekly requirement to a bimonthly schedule.

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

EPA is currently considering allowing POTWs to
set equivalent mass-based limits  as an alternative
to concentration limits to meet concentration-based
categorical pretreatment standards on a national
scale through the proposed rule Streamlining the
General Pretreatment Regulations for Existing and
New  Sources of  Pollution (July  22, 1999
64FR39564). The Steele County project is helping
to provide information. It is also helping to deter-
mine whether providing mass-based limit flexibility
prior to  implementation of water conservation ef-
forts will encourage more widespread adoption of
such practices.

            Reduced  or Eliminated Monitoring for
            Regulated Pollutants Not Present

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

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

            Results/Anticipated Outcomes:  The Steele
            County project gives the participating POTWs the
            flexibility to allow facility sponsors to eliminate or
            reduce monitoring. This determination will be based
            on both sampling data and other technical data (raw
            material usage, industrial processes and potential
            process byproducts). Existing data on pollutant con-
            centrations in the local public water supply will help
            characterize background concentrations. If a spon-
            sor facility uses an alternative water supply, repre-
            sentative sampling will be needed to characterize
            background pollutant concentrations from the al-
            ternative influent. At least three years of facility

            4 This flexibility will not apply to industrial users subject to
            the Categorical Standards for the Organic Chemicals Plastics
            and Synthetic Fibers point source category, 40 CFR Part
sponsor effluent data will then be compared to the
background data in making the determination that
a given pollutant is not expected to be present. This
determination will also be based on raw materials
used, industrial processes and potential process
byproducts. It will not consider the capability or
efficiency of the sponsor facility's pretreatment
system. Once the POTW determines that  one or
more regulated pollutants are not expected to be
present at a sponsor facility, it can modify that
sponsor's permit to reduce or eliminate monitoring
requirements for those pollutants.

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

Transferability: By testing the flexibility to waive
or reduce monitoring for categorical standard pol-
lutants not expected to be present in the waste
stream, the Steele County project approach could
be applied broadly by POTWs. This reduced moni-
toring approach was proposed as part of the July
22,1999, proposed rule affecting the National Pre-
treatment Regulations.
In response to growing concern over health and
environmental risks posed by hazardous waste sites,
Congress established CERCLA, commonly known
as Superfund, on December 11,1980. This law cre-
ated a tax on the  chemical and petroleum indus-
tries and provided Federal authority to respond
directly to releases or threatened releases of haz-
ardous substances that may endanger public health
or the environment. By April 2000, more than 100
Superfund sites (many thought to be unusable) had
already been recycled without an organized effort

                       5'  Site  Cleanup  Regulatory  innovations
 Project(s)                                        Innovation
 ExxonMobil        CERCLA Streamlining to Recycle Superfund Site: Streamlined strategy for Superfund site
                   remediation; early consideration and planning in remediation process for site
                   redevelopment and reuse.
on the part of EPA. The Agency is now embarking
on a coordinated effort called the Superfund Site
Redevelopment Initiative, begun in July, 1999, to
facilitate the return of these sites to productive use.
Through partnerships with states, tribes, other Fed-
eral agencies, local governments, communities, land-
owners, developers, and  parties  potentially
responsible for contamination, EPA has achieved
substantial results protecting public health and the
environment, while piloting and experimenting with
improvements to the cleanup process.

CERCLA Streamlining to Recycle Superfund

The Experiment(s): Proposed in September 1998,
the ExxonMobil project implements a streamlined
strategy to the traditional  Superfund remediation
approach to  expedite the cleanup of the Fairmont
(West Virginia) Coke Works Superfund Site (Site).
To clean up the Site, ExxonMobil will be adminis-
tering a series of changes to the traditional Superfund
process that will affect site characterization, risk
assessment,  management of on-site landfills, and
mitigation requirements for on-site wetlands. Al-
though many of the administrative procedures be-
ing used  in this project  are available through
CERCLA, concurrent use of them  represents a
departure from conventional cleanup actions. These
changes are intended to minimize the impact of the
Superfund site  on human health and  the environ-
ment, enabling the Site to be cleaned up in approxi-
mately half the time a normal Superfund response
might take.

Site Mitigation: While maintaining protection of
human health and the environment, ExxonMobil is
seeking to reduce the total time involved in clean-
ing up the Site. Due to the specific nature of con-
tamination at the Site, it was recommended that a
non-time critical (NTC) removal action framework
be used to address the remediation of process ar-
eas and waste management units at the Site. Re-
moval actions are short-term responses to mitigate
imminent threats to the public or the environment
while remedial  actions are longer-term cleanup
actions to permanently remedy problems at a site.
The NTC action will be consistent with any long-
term remedial action at the Site. Other potential
cleanup issues at the Site (e.g., groundwater con-
tamination) will be addressed by the remedial ac-
tion process. EPA site managers have estimated
that this use of a NTC removal action will result in
a faster, more efficient cleanup. ExxonMobil plans
to  use removal and remedial  actions in a coordi-
nated manner to reduce the total time involved in
cleaning up the Site.

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

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

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

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

            Site Management:  A specific area in the north-
            ern part of the Site will be designated as an area of
            contamination (AOC)6  to avoid triggering a RCRA
            land disposal restriction (LDR) during remediation
            activities. Under RCRA, land disposal or place-
            ment of RCRA classified hazardous wastes with-
            out previous treatment is generally restricted. Under
            the AOC concept, EPA has designated activities
            not considered land disposal or placement. All waste
            management units in the northeast area of the Site
            will be designated as a single AOC so that on-site
            waste management can proceed in a regulatory
            compliant and efficient manner without being con-
            strued as placement or  invoking an LDR. This des-
            ignation is justified due to the close proximity of the
            waste management units.

            Wetlands Mitigation: Some wetland areas (e.g.,
            drainage channels) were formed during interim re-
            moval actions on the Site between 1993 and 1996.
            ExxonMobil has prepared a map identifying poten-
            tial wetland areas created by the removal actions
            and EPA will evaluate the mapped areas and de-
            termine flexible mitigation requirements for the Site
            based on the following: (1) If any of the mapped
            6 EPA defines an AOC as a non-discrete land area on which
            there is generally dispersed contamination. The AOC con-
            cept arose out of the EPA's definition of "land disposal" and
            was introduced as a tool for the management of remediation
            wastes. Land disposal is broadly defined to include virtually
            any placement of hazardous waste on the land, including
            temporary placement.
wetland areas are part of existing treatment of
drainage systems, no mitigation will be required.
(2) In addition, if, in the process of anticipated Site
cleanup, these wetland areas will be improved due
to grading or reconstruction, such actions could be
considered mitigation. Wetlands created during the
1993-1996 EPA removal actions not fitting the above
criteria will be evaluated on a case-by-case basis.

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

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

Transfer ability:  At this stage in  the project, it is
too early to measure changes in environmental per-
formance, but by examining options for streamlin-
ing the Superfund cleanup response timeline, this
project can serve as a model for expeditiously and
effectively cleaning up a Superfund site and facili-
tating its return to productive use. As the project
proceeds, there will be an opportunity to analyze
how streamlined risk assessment and focused site
characterization can provide benefits to the com-
munity and environment and how expedited cleanup
schedules can help mitigate migration of contami-
nation and reduce  or eliminate potential risks to
human health and the environment.

EPA, state, and tribal programs require industrial
and municipal facilities to obtain permits that limit
their emissions and discharges to the air, land, and
water. Permits, which contain detailed descriptions
of proposed activity and operating procedures, are
the chief vehicles through which statutes and regu-
lations are translated into facility-level ordinances.
They have been one of our most effective environ-
mental protection tools and are the nexus at which
most people first encounter the regulatory process.
Permit provisions may include any combination of
requirements addressing (1) limits on emissions or
effluents;  (2)  monitoring, reporting,  and
recordkeeping; (3) pollution treatment or control
technologies;  (4) management practices;  and (5)
pollution prevention requirements. Permits are typi-
cally issued by states, tribes, or EPA (when a co-
regulator permitting program has not yet been
approved  by  EPA). Interested stakeholders are
encouraged to provide input into the permitting pro-
cess  during  the mandated  public comment
                               The present system has developed into a sophisti-
                               cated one that controls significant sources of pollu-
                               tion from industrial  and municipal facilities.
                               However, government permitting regulations reflect
                               the single media, "command-and-control" focus of
                               our environmental statutes. Industry, government,
                               and community partners recognize the need to de-
                               sign flexible permitting approaches that are funda-
                               mentally performance-based. The essence of the
                               performance-based approach is to shift the focus
                               of environmental permitting toward measurement
                               and assurance of performance, while providing flex-
                               ibility in how a regulated entity meets performance
                               standards. In theory, a system  that  focuses more
                               on a facility's overall environmental impacts, and
                               less on narrow decisions about particular technolo-
                               gies or process changes, should be more beneficial
                               to the public as well as  less prescriptive for the
                               facility. Project XL experiments with approaches
                               that apply this theory, as briefly described in Table 6.
                        "Cable.  6:  "Permitting
 Project(s)      Media

 Elmendorf AFB    Air
 International     Water
 Weyerhaeuser   Water
 Jack M. Berry Multi-media
Facility-wide Permit Air Emission Caps: Flexible use of plant site emission
limits (PSEL), prevention of significant deterioration (PSD) permit, or
plant-wide applicability limits (PALs); facility-wide emissions caps allow
preapproval of production changes without recurring permit revisions.

Performance-based Permitting: Incentive-based approach to reduce VOC
emissions based on per unit of production emissions limit.
             Pollution Prevention Incentives through Title V Streamlining:  New approach
             to streamline Title V permit process leading to cost savings that can be
             applied to currently non-funded pollution prevention projects.

             Tailoring NPDES Effluent Improvements: Through use of a collaborative
             process, IP will replace a set of qualitative regulatory requirements—best
             management practices (BMPs) from the water portion of EPA's Pulp and
             Paper Cluster Rules—with targeted, enforceable, and quantitative NPDES
             permit limits

             Water Effluent Limits:  A revised NPDES permit reflecting more stringent
             limits on BOD, TSS, and adsorbable organic halogens (AOX). Voluntary
             reductions below permit limits resulted in no fish tissue sampling or water
             body assimilative capacity studies.

             Comprehensive Operating Permit: Consolidate individual media permits into
             a multimedia all-permit reporting requirements for a facility.

Facility-wide Permit Air Emission Caps

The Experiment(s):  The complexities of air regu-
lations require a considerable effort by both regu-
lators and facilities in their preparation and review
of permit applications for many process modifica-
tions. Project XL is testing how innovations in the
air permitting systems can reduce a facility's envi-
ronmental impact, while streamlining the  permit-
ting process and reducing paperwork.  Using
facility-wide emission caps is a way to bring about
                                   such changes. Facility-wide emission caps are de-
                                   signed to prevent growth in discharges from both
                                   existing and future stationary sources. In general.
                                   such provisions require that any emission increase
                                   from equipment at a facility be offset by emission
                                   reductions from other equipment under the same
                                   cap. Table 7 includes the Project XL experiments
                                   with facility-wide air emission caps under the fol-
                                   lowing permits: Prevention of Significant Air Qual-
                                   ity  Deterioration (PSD), New  Source  Review
                                   (NSR), and Title V of the Clean Air Act (CAA).
                    "Cable.  7-  Paci I itywide  Permitting  in
 Permit Type

 New Source

 New Source
EPA and the State of Arizona have provided Intel with
the flexibility to make equipment and process changes
and construct new facilities at the site without air
quality permit reviews, as long as the PSELs are not
exceeded and all other EPA and permit limits are met.
To provide an additional safety factor, Arizona Ambi-
ent Air Quality Guideline limits for HAPs will not be
exceeded at the Intel facility property line or elsewhere
on the site.
EPA and the State of Georgia have modified the
facility's existing air quality permit to include dual
emission caps for air pollutants. The dual emission caps
are (1) a cap that allows the recovery furnace, smelt
dissolving tank, calciner, and combination boiler (the
facility's major sources emissions) to be operated to
their design capacity without triggering permit review;
and (2) a cap covering all facility sources except those
four major sources. The modified air quality permit
streamlines the permit renewal process, includes
alternate excess emission reporting protocols, and
includes a protocol for conducting manufacturing
process experiments without triggering a permit
     Emission Caps
Emissions for the entire facility are
capped as follows: VOCs at 40
tons per year; NOx and CO2 at 49
tons per year; SO2 and particulate
matter at 5 tons per year; phos-
phine at 4 tons per year; sulfuric
acid at 9 tons per year; organic
HAPs and inorganic HAPs at 10
tons per year.
The caps reduce allowable air
emissions by 60 percent. The dual
emission caps apply to particulate
matter, SO2, NOx, CO , VOCs, and
total reduced sulfur (odor-causing
 Merck         EPA and the State of Virginia issued a new PSD air
               quality permit for a facility wide air emissions cap at
 Prevention of  the Merck Stonewall Plant. Under the new permit,
 Significant     changes or additions to facility operations that result in
 Air Quality    emission increases will no longer require prior ap-
 Deterioration  proval under either Federal or state regulations. The
               new permit provides the flexibility to implement a
               change in operations that increases emissions within
               the constraints of the emission caps. In addition, Merck
               will have the option of reducing the facility-wide caps
               instead of implementing specific control technologies
               prescribed by certain future regulations.
                                                    The facility-wide cap limits total
                                                    emissions of criteria air pollutants
                                                    to levels 20 percent below baseline
                                                    (i.e., prior actual emissions): SO2
                                                    emissions to levels 25 percent
                                                    below baseline levels, NOx
                                                    emissions to levels 10 percent
                                                    below baseline levels, and
                                                    particulate matter to levels
                                                    approximately equal to baseline

     "7 :  Paci I ity wide  "Permitting  in
 Permit Type

 New Source
Imation will use the concept of a pollutant-specific, PAL
for new source review (NSR) purposes. The PAL
concept is intended to allow major sources to avoid
case-by-case NSR applicability determinations. Instead,
under the PAL concept, sources are allowed to make
facility modifications without triggering major or
minor NSR so long as their actual emissions do not
exceed the PAL, which is set at a level representative of
actual emissions. The existing preconstruction air
permitting regulations that govern modifications at  the
facility, specifically the CAA minor NSR and major
nonattainment NSR regulations, require that changes
to Imation's manufacturing processes must be re-
viewed and approved in advance by the Ventura
County (California) Air Pollution Control District
     Emission Caps
Imation Camarillo will be subject
to a PAL (a voluntary emission
cap) for VOC emissions of 150
tons per year. While providing no
NSR flexibility, facility emission
caps for other pollutants include:
CO, 30 tons per year, NOx, 8 tons
per year; particulate matter and
SO2, less than 15 tons per year
each; any individual HAP less than
10 tons per year.
Results/Anticipated Outcomes:  Under Project
XL's flexible approach to permitting, businesses
have avoided costly production delays. They also
have improved their worker health and safety stan-
dards, increased the public's access to useful envi-
ronmental information, and reduced their facility's
emissions to the environment:

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

•   Merck anticipates being able to avoid millions
    of dollars worth of potential production delays
    by eliminating redundant permit reviews.

•   Since 1997, the Weyerhaeuser Flint River fa-
    cility has remained under its caps. In 1999
    Weyerhaeuser was 33  percent under its cap
    for particulate matter (PM), 44 percent for to-
    tal reduced sulfur, 66 percent for sulfur dioxide
    (SO ), 37 percent for nitrogen oxides (NO  ),
                                     36 percent for carbon monoxide (CO), and 61
                                     percent for volatile organic compounds

                                     The site-specific air permit will allow Imation
                                     to avoid potentially costly delays in making
                                     changes in their existing magnetic tape manu-
                                     facturing  equipment and processes provided
                                     that all of their air permit conditions are satis-
                                     fied and their air emissions remain below the
                                     caps. In addition to the 150 tons per year cap
                                     on VOC emissions, Imation must meet a mini-
                                     mum of 95 percent and 100 percent capture
                                     efficiency for organic compounds (VOCs and
                                     HAPs) emitted from coating manufacturing
                                     operations at the  facility. While providing no
                                     NSR flexibility, Imation has committed to emis-
                                     sion caps for other criteria pollutants, including
                                     NOx, 8.34 tons per year; and CO and SO2, less
                                     than 5 tons per year, respectively.

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

            limited preapproval of certain types of production
            changes without requiring permit revision for each
            modification. The Agency is formally considering
            further expanding this use of preapproval and "cap

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

            Performance-based Permitting

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

            One of the means Andersen will use to achieve its
            reduced VOC and participate matter emissions lev-
            els will be through  the expanded use of Fibrex
            material. The Fibrex composite material is a com-
bination of reclaimed sawdust and vinyl. The manu-
facture of Fibrex composite allows for the use of
wood byproduct materials rather than virgin wood.
The use of Fibrex materials is beneficial since it
reduces the need for raw material and requires no
wood preservation treatment, which accounts for
a substantial amount of VOC air emissions from
the Bayport facility. Expanded use of Fibrex com-
posite will result in substantial reductions in the
emissions of VOCs per unit of production.

In addition, Andersen wants to increase the use of
its in-line waterborne treatment systems and re-
duce the use of solvent-based wood preservatives.
The current regulatory system discourages the use
of the  waterborne treatment systems such that
Andersen has to use a greater amount of solvent-
based wood treatment. Because solvent-based
treatment emits substantially more VOCs than
waterborne treatment, current regulations actually
cause Andersen to have greater VOC emissions
at it facility. This project removes the limits  on
Andersen's use of its in-line waterborne treatment
systems so that Andersen can make greater use of
this environmentally beneficial process.

Andersen may also experiment with recycling win-
dows as feedstock for the Fibrex process. This
entails collecting old window components from
buildings where replacement windows are being
installed, removing the paint (some of which may
contain lead), processing the lead for reuse, and
using the wood as feedstock for  the Fibrex pro-
cesses. Andersen's goal is to manage its window
take-back program without invoking RCRA treat-
ment, storage, and disposal facility requirements.

Results/Anticipated Outcomes:  The Andersen
project emphasizes an incentive-based system for
the reduction of Andersen's VOC emissions  per
unit of product produced. The cap on per unit VOC
emissions will ensure that Andersen's per unit VOC
emission rate does not significantly exceed their
range of current actual VOC emissions per unit.
The penalty limit will be set at two standard devia-
tions above Andersen's five-year average per unit
emission rate. The reason for setting the rate at
two standard deviations is that the emission rate
fluctuates on a daily basis depending on production
need: Fibrex demand, use of waterborne treatment.

use of solvent- based treatment, and the number of
painted windows ordered. This approach, which is
not available under existing regulatory schemes, is
intended to "lock-in" existing efficient manufac-
turing methods and processes while encouraging
environmental efficiency and rewarding continued
improvement. Andersen will use as a baseline the
penalty limit (an enforceable pound per unit limit
for its VOC emissions); the other performance limits
and thus the performance ratio will be based on
the penalty limit. Table 8 describes the various per-
formance limits used.

Transferability:  The  Andersen  project tests
whether a tiered air emission ratio system with both
rewards and penalties can provide a better incen-
                                                tive than traditional approaches for reducing air
                                                emissions. Specifically, EPA will gain reference data
                                                as to whether emission rates per unit of production
                                                can be used to effectively limit VOC emissions and
                                                encourage environmental efficiency.

                                                In addition, the project will provide information on
                                                whether RCRA treatment, storage, and disposal
                                                requirements can be eliminated for companies that
                                                plan to reuse materials. This could be useful to other
                                                window manufacturing and production facilities as
                                                well as other manufacturers who are interested in
                                                reuse or product "take back."
                "Cable. 8:  \?O(2- (Smissicm "Performance  .Limits
 Advisory Council
 (CAC) Limit
                      The CAC limit serves as the main limit for evaluating Andersen's ongoing
                      performance. The CAC limit is the average of the prior five years' performance
                      ratios and will be recalculated once every three years. It will decline if appropriate,
                      and will increase only if the changes are approved, with concurrence of EPA and
                      Minnesota Pollution Control Agency.  If its annual performance ratio exceeds the
                      CAC limit, Andersen will be required to provide a specific explanation of the
                      exceedance to the CAC as well as establish an approved corrective action plan to
                      bring the performance ratio below the limit. The CAC—a group of individuals
                      representing local residents,  employees, environmental groups, and government
                      officials—was formed to assist Andersen in development and implementation of
                      this project.

Enforcement Limit      A static enforcement limit for the ten-year duration of the project will be
                      established using the initial CAC limit plus two standard deviations.
 Project Limit
 Reward Limit
                      The project limit will be set at two standard deviations above the CAC limit. It
                      will be the same as the enforcement limit for the first three years, but will be
                      adjusted with the CAC limit. The project limit will never exceed the
                      enforcement limit.
                      This limit will be two standard deviations below the CAC limit. The reward limit
                      will not increase and will only decline if Andersen remains below it for three
                      consecutive years. In addition to the per unit VOC limits described above,
                      Andersen plans to make enforceable commitments to keep its overall VOC
                      emissions for both its Bayport facilities below 2,397 tons per year. Andersen also
                      will maintain a VOC emission sub-limit of 96 tons per year at its as yet
                      undeveloped West facility.

            Pollution Prevention Incentives through
            Title V Streamlining

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

            Under Title V, military installations are treated as a
            single major emissions source, with accountability
            for all emission sources at the installation. The CAA
            requires that each installation permit not only large
            pollutant sources, but also  a significant number of
            smaller sources.  For Elmendorf AFB, this would
            involve the permitting of 106 separate sources un-
            der a Title V permit,  which would create costly
            administrative burdens for Elmendorf and regula-
            tory agencies. Elmendorf AFB has proposed to use
            the Project XL/ENVVEST process to help reduce
            CO emissions and to reallocate money, currently
            earmarked for Title V permitting requirements, into
            other currently non-funded pollution prevention
            projects. Elmendorf AFB  intends to demonstrate
            superior environmental performance in part through
            the introduction of a compressed natural gas (CNG)
            fleet and fueling program.

            Results/Anticipated Outcomes:  The Elmendorf
            AFB project seeks to reduce air pollution loadings
            of CO  and NOx through pollution prevention ap-
            proaches. Although the base is in CAA attainment,
            Anchorage,  which the base borders,  is currently
            classified as a nonattainment area for CO. The base
            will pursue its pollution prevention efforts through
            a two-fold process of regulatory flexibility.

            7As part of the Administration's reinvention initiative, EPA
            and DoD signed a Memorandum of Agreement in 1995 that
            established how the two agencies will interact during imple-
            mentation of DoD's Environmental Investment (ENVVEST)
            program. The ENVVEST program emphasizes regulatory
            compliance through pollution prevention and provides an
            alternative to prescriptive regulatory requirements through a
            performance-based environmental management system de-
            signed to attain superior environmental results.
•   First, Elmendorf AFB and EPA will use the
    EPA policy document entitled "Major Source
    Determinations for Military Installations under
    the Air Toxics, New Source Review, and Title
    V Operating Permit Programs for the Clean
    Air Act" (Major Source Guidance). This policy
    document recognizes that many military instal-
    lations possess characteristics warranting flex-
    ibility in CAA major source determinations.
    Major Source Guidance allows military instal-
    lations to divide themselves into functionally
    distinct emitting activities. Based on a poten-
    tial to emit (PTE), a select number of emis-
    sions sources on a given installation could
    potentially be considered major stationary
    sources. For Elmendorf AFB, only the central
    heating and power plant (CH&PP) is a major
    stationary source based on actual emissions of
    CO and NOx.

•   The second part of the regulatory flexibility will
    be limiting the PTE of other emissions sources
    on the base so they will not be considered ma-
    jor sources. Actual emissions  from these
    sources are currently below major source
    thresholds, and the base  will obtain limits on
    the emissions from these sources.  These  al-
    ternative emissions standards create enforce-
    able standards and are a critical part of the
    project's permitting scheme.

These flexibilities will streamline Elmendorf AFB's
Title V permit process, placing the CH&PP (and a
number of other sources subject to  new source
performance standards) in the revised permit. This
change will simplify monitoring and recordkeeping
requirements and result in cost savings that will be
applied to pollution prevention projects. By being
able to target specific emission sources, Elmendorf
AFB will be able to make more cost-effective use
of its resources. Through reduced monitoring and
recordkeeping, Elmendorf AFB estimates that its
permit management costs will decrease by 80 per-
cent, saving the base $1.5 million over six years.
These cost savings will be redirected toward pollu-
tion prevention opportunities on the base.

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

CNG, as well as the  procurement of dedicated
CNG fuel vehicles. The CNG fleet should help to
reduce the levels of CO on the base and bolster
Anchorage's efforts to reduce CO levels.

Transferability:  The Elmendorf AFB project ex-
plores ways to alleviate regulatory burdens at fed-
eral facilities and could serve as a model for other
Department of Defense (DoD) installations deal-
ing with emissions from multiple major sources. A
demonstration of achievable and superior environ-
mental benefits could  spur the transfer of similar
activities to other DoD installations. In addition, the
conversion to alternative fuel vehicles will assist in
demonstrating the feasibility of CNG technology in
Anchorage as well as the potential to transfer this
technology to other installations.

Tailoring NPDES Effluent Improvements

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

IP considers its existing practices—including ex-
isting spill prevention procedures and process con-
trol technologies—to  be advanced enough to be
functionally equivalent to the BMPs. In exchange
for a waiver of the BMP requirements, IP is imple-
menting a series of effluent improvement projects
tailored to its Androscoggin mill operations. The
improvement projects will be specifically designed
to improve the mills' effluent quality for chemical
oxygen demand (COD) and color. IP will also ac-
cept new NPDES permit limits for effluent dis-
charge once the effluent improvement projects are
completed. The regulatory flexibility of the IP-El
project will enable IP to reallocate estimated cost
savings to select and implement effluent improve-
ment projects at the facility.

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

1.   knot liquor recovery system;
2.   pulp screening liquor recovery system;
3.   pulp digester heater drains recovery;
4.   complete recycle of "A" pulp mill wash
5.   alternative knot and screening conveyance
6.   power house sump drains collection system;
7.   computerized mill  sewer conductivity display.

Results/Anticipated Outcomes: At this stage in
the IP-El project, it is  too early to see changes in
environmental performance, but it is anticipated that
implementation of these effluent improvement
projects will yield greater environmental benefit for
COD and color reduction than compliance with the
Pulp and Paper Cluster Rule BMPs. Numeric lim-
its will ultimately be placed in the facility-specific
NPDES permit that is expected to reflect a 50 per-
cent reduction of current discharges of several key
pollutants [BOD, COD, AOX, TSS].

Transferability: The IP-El proj ect provides an op-
portunity to explore how water quality improve-
ment projects tailored to a mill's specific operations
can achieve environmental results superior  to what
would be attained by adherence to existing  regula-
tions. It will serve as an opportunity to gain faster
familiarity with new effluenttechnologies that may
be transferable to other mills. This proj ect may also
help to inform future Agency rulemaking as regu-
lations are under consideration for COD and color.

Water Effluent Limits
                                  Comprehensive Operating Permit (COP)
The Experiment(s):  As part  of its project.
Weyerhaeuser revised its Flint River Plant's
NPDES permit to include more stringent effluent
limits on BOD, TSS, and AOX. Weyerhaeuser has
modernized several components of the pulping pro-
cess, which has reduced the BOD and TSS levels
in bleach plant wastewater, as well as maintained
the  AOX levels.

Results/Anticipated Outcomes:  The company's
1998 NPDES permit was revised under the
Weyerhaeuser project. Weyerhaeuser modernized
several components of the pulping process and has
met the more stringent effluent limits on BOD, TSS,
and AOX per air-dried metric ton (ADMT) of fin-
ished product. Table 9 describes the Weyerhaeuser
permit limits.

Transfer ability:  In Aiming for Excellence (July
1999), EPA commits to identifying and implement-
ing improvements within the NPDES permitting
program. The Weyerhaeuser project's piloting of
NPDES permit alternatives have the potential to
influence Agency permitting initiatives. For ex-
ample, case studies about these alternatives might
prove useful in the development of permit writer
training materials for any of the cross-agency per-
mitting initiatives.
                                  The Experiment(s): The Berry citrus juice pro-
                                  cessing plant has been required to obtain multiple
                                  permits from multiple regulatory agencies. Air qual-
                                  ity, water quality, and consumptive-use regulations
                                  govern the plant's boilers, feed mill dryers, drinking
                                  water, industrial wastewater, and water use opera-
                                  tions. The Berry project intended to consolidate
                                  these individual permitting requirements into a single
                                  comprehensive operating permit (COP). The COP
                                  would have offered the opportunity for co-regula-
                                  tors (in this case EPA, the Florida Department of
                                  Environmental Protection, and the South Florida
                                  Water Management District) to eliminate Berry's
                                  burdensome requirements for preparing multiple
                                  permit applications on differing and sometimes con-
                                  flicting schedules.

                                  The COP would have consolidated selected oper-
                                  ating permits and requirements, maintained all en-
                                  vironmental standards, and committed Berry to
                                  superior environmental performance. The stream-
                                  lined permitting approach was also expected to re-
                                  sult in cost savings to  the facility operator by
                                  reducing administrative burdens. In turn, Berry had
                                  agreed to invest these cost savings into the instal-
                                  lation of updated equipment and implementation of
                                  updated procedures used in citrus processing to
                                  reduce air emissions of VOCs, SO9,  and NO .
"Cable.  9'   WeyerKaeuser "Permit (S
 Permit Limits
 Discharge of 3.8 pounds of BOD
 per ADMT of finished product.
 Discharge of 4.09 pounds of TSS per
 ADMT of finished product.
 Discharge of 0.15 kilograms of AOX
 per ADMT of finished product.
                    Reduced the amount of BOD in its effluent from a 1997 level of 3.01
                    pounds per ADMT to a 1998 level of 2.13 pounds per ADMT. In 1999,
                    BOD levels in facility effluent increased to 2.83 pounds per ADMT.
                    Reduced the amount of TSS in bleach plant wastewater. Weyerhaeuser
                    reduced the amount of TSS in its effluent from a 1997 level of 3.13
                    pounds per ADMT to a 1998 level of 2.8 pounds per ADMT. In 1999,
                    TSS levels in facility effluent increased to 3.87 pounds per ADMT.
                    Unreliable operation  of a facility process during 1999 caused increased
                    production of off-grade pulp, which is recycled through the pulp
                    manufacturing process. This increased the amount of water used,
                    effluent produced, BOD levels per ton of finished product, and TSS
                    levels per ton of finished product.
                    The AOX limit under the project is 4 percent beyond the best available
                    technology standards proposed by EPA. AOX levels were 0.10 kilo-
                    grams per ADMT in 1996,1997, and 1998. In 1999, levels of AOX in
                    facility effluent remained at 0.10 kilograms per ADMT.

Results/Anticipated Outcomes:  During the initial
phase of COP development Berry employees and
the State of Florida worked together on the devel-
opment of detailed work procedures. However, after
the Berry project had been underway for almost a
year, Cargill, Inc., (an international marketer, pro-
cessor, and distributor of agricultural products) took
over as the operator but not as the owner of Berry's
LaBelle, Florida, facility. Although  some project
commitments had been met, EPA and the State of
Florida chose to terminate the agreement after at-
tempts to engage Cargill in the process failed. The
COP was not submitted, and the project was ter-
minated on June 2, 1999.

Transferability: Should an opportunity arise,
Project XL could potentially test the  COP concept
at another facility. In March 1999, EPA approved
a detailed plan for "The Next Generation in Per-
mitting." The COP concept is  an integral part of
this plan and is expected to be a key concept in the
Agency's ongoing permit improvement process.

          rmati o v\
Demands for high-quality and readily accessible
environmental information has never been greater.
To meet these needs, EPA, like many other organi-
zations, has worked to take advantage of the op-
portunities created by new information technologies.
This new capability brings new challenges, such as
public access, information security, and protection
of proprietary business information.  EPA's new
Office of Environmental Information, working with
                 many different internal and external stakeholders
                 and partners, is working to develop information-
                 related policies and procedures that reflect the con-
                 cerns of EPA managers and staff; local, state, and
                 federal governments; tribes; the regulated commu-
                 nity; interest groups; and the general public. As
                 part of this national effort, Project XL is experi-
                 menting with approaches that seek to (1) improve
                 public access to information through the Internet,
                 (2) gain more stakeholder input into data presenta-
                 tion, (3) build performance-based incentives into
                 reporting requirements, and (4) eliminate obsolete,
                 duplicative,  and  unnecessary monitoring,
                 recordkeeping, and reporting requirements from the
                 federal, state, tribal, and local levels. Table 10 be-
                 low describes the projects' environmental informa-
                 tion innovations.
           Lable  "1 0:  c^nvi ronmentcil  iZJnToc'mcition yVvcmcige.me.nt
                              and  .Access
 Steele County     Water
 Intel           Multi-media
 Alternative Reporting Strategy: Alternative significant noncompliance
 reporting for POTWs. Qualifying pretreatment violations may be posted
 on Minnesota Pollution Control Agency Web site in lieu of being
 published in local newspaper.
 Internet Reporting and Stakeholder Input:  Improving public access to
 information; making community participation more meaningful; Project
 XL guide to project tracking and reporting.
 Tiered Reporting: Incentive-based reporting and record-keeping
 requirements determined by levels of emissions control
 (through a PSD permit).
 Consolidated Reporting:  Reducing reporting burdens through report
 streamlining and consolidation; one-stop reporting.

Alternative Reporting Strategy

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

Results/Anticipated Outcomes: The intent of this
Web-based approach is to provide prompt and ap-
propriate assistance  for identifying and correcting
violations. Violations that qualify under this alter-
native approach are available  for a sponsor facility
that is  responsive, and where the violation(s) did
not cause a pass-through or interference  violation
at the POTW. For a SNC event qualifying under
this provision, a  description  of the event and the
corrective action taken will  be published on the
MPCA Web site as  the violation is reported. All
SNC violations, whether published in a newspaper
or not, would eventually be posted on the MPCA
Web site. The Web site will also explain how SNC
is determined and will have  contact information
about violations which are not SNC.

All noncompliance events will be investigated by a
peer review committee established under the Steele
County project. This committee would include two
or three sponsor facility representatives not con-
nected to the noncompliance event under review
along with any stakeholder wishing to participate.
The peer review committee would investigate non-
compliance events,  make recommendations  and
provide assistance to expedite the return to com-
pliance. Peer review recommendations are not bind-
ing, and the city will continue to implement its En-
forcement Response Plan. Newspaper publication
of SNC will be used at the discretion of the
Owatonna POTW, where the previously discussed
criteria are met. The Owatonna POTW would con-
tinue to be required to provide newspaper publica-
tion of any violation that is not corrected within 30
calender days or that results in pass-through or in-
terference. Sponsor facilities in Owatonna will take
steps to ensure that public outreach on the avail-
ability of information regarding SNC events through
this alternative publication approach is conducted.

Transfer ability: A Web-based, alternative  SNC
reporting approach could have application in other
municipalities seeking to provide real-time and
"meaningful" public notice of SNC events while
continuing to provide a deterrent for industrial us-
ers. The Steele County project also provides an
opportunity to test how a community-based ap-
proach can provide prompt and appropriate assis-
tance in identifying and correcting violations. EPA
is already contemplating opportunities to further
apply this innovation under the new Performance
Track program. Performance Track offers admin-
istrative streamlining benefits in the major program
areas such  as air, water, and waste. In  addition,
EPA will propose a set of changes in its regula-
tions to accommodate Performance Track facili-
ties, including expanding the options for POTWs to
report certain compliance information through the
Internet instead of through the newspaper. These
changes will be formally proposed by EPA for pub-
lic review and comment later this year.

Internet Reporting  and Stakeholder  Input

The Experiment(s):  The Intel project has two in-
novations designed to improve public access to in-
formation: (1) using  stakeholder input to help
redesign the format and content of the reports on
the environmental performance of the Ocotillo
semiconductor facility in Chandler, Arizona, and (2)
making these reports available on the Internet. The
facility's new reporting format was designed in
conjunction with the stakeholder team that included
EPA, the Arizona Department  of Environmental
Quality, the Maricopa County Bureau of Air Pollu-
tion Control, the City of Chandler, and members of

the Community Advisory Panel (CAP). Based on
input from the stakeholder team, Intel agreed to
put routine environmental reporting requirements
and accountability measures into a single, integrated
report that is publicly available on the Internet via
Intel's Project XL Web site, http://www.intel.com/
intel/other/ehs/projectxl/index.htm. Now citizens,
as well as regulatory officials, can routinely moni-
tor progress toward the facility's  environmental
commitments. This approach tests the value of
getting comprehensive environmental information
directly from the company. Currently, all data must
be reentered,  although  the long-term goal is for
Intel's Internet form to be merged directly into the
state and local agency information systems.8

Results/Anticipated Outcomes: Intel established
a precedent for making facility-based environmen-
tal information publicly available on the Internet.
Co-regulators and public stakeholders involved with
the Intel project have universally endorsed this ap-
proach. Project regulators and public stakeholders
have described the report as citizen-friendly, con-
cise, and easy to use.
      Graph from Intel's 1999 Annual Report

                                  J  Goal - 50%
Intel Ocotillo Site


                                  ] Goal - 25%
  g   50%  H
Tiered Reporting

The Experiment(s): The Merck project provides
an innovative three-tiered approach to monitoring.
recordkeeping, and reporting linked to its air qual-
ity permit. A site-specific rule and new prevention
of significant deterioration (PSD) permit provide
alternative methods for complying with applicable
state implementation plan air quality rules, NSR air
emission regulations, and certain provisions of
RCRA relating to air emission controls on hazard-
ous waste equipment. The new PSD permit includes
a facility-wide cap for total criteria air pollutants
and subcaps for SO2, NOx, and PM with a diam-
eter of less than 10 microns. The requirements for
monitoring, recordkeeping, and reporting increase
in stringency as the facility's actual total criteria
air emissions approach the sitewide emissions cap.
Annual reporting is required when facility-wide
emissions are less than 75 percent of the cap. Semi-
annual reporting is required when facility-wide
emissions are between 75 percent and 90 percent
of the cap. Monthly reporting is required when
emissions are equal to or greater than 90 percent
of the total emissions cap. In addition,  as actual
emissions approach the  cap, more precise moni-
toring methods for certain emission units, such as
stack tests, must me used in place of emissions
calculations based on generalized emissions fac-
tors. This provides an incentive for Merck to pur-
chase the  cleanest available technologies and to
maintain low air emission levels.
                             Results/Anticipated Outcomes: The three-tiered
                             monitoring, recordkeeping, and reporting require-
                             ments will become effective no later than 12 months
                             after Merck completes the installation of new equip-
                             ment that converts its coal-fired powerhouse to
                             natural gas. This lag time is due to the fact that
                             actual emissions will be measured using a 12-month
                             rolling total. This total will be larger at the outset,
                             reflecting the coal burning  prior to powerhouse
                             conversion. Powerhouse conversion is required to
                             be completed no later than 30 months after the
                             permit's effective date.

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

                             Consolidated  Reporting

                             The Experiment(s):  A number of proj ects are test-
                             ing new approaches for consolidated reporting of
                             the environmental information required by Federal,
                             state, and local regulations. The approaches are
                             detailed in Table 11.
            :  iScmsolidated
                                                                    in ,X.L
Intel has consolidated recurring and routine
reports into four quarterly reports and one
annual report. The consolidated reporting
format was designed in conjunction with the
EPA, the Arizona Department of Environmen-
tal Quality, the Maricopa County Bureau of
Air Pollution Control, the City of Chandler,
and a CAP consisting of area residents.
                                         Programs Affected
Internet reports cover air quality, water
quality, and solid and hazardous waste
reporting requirements, with the
exception of the Toxic Release Inven-
tory (TRI) reports required under the
Emergency Planning and Community
Right-to-Know Act (EPCRA), which "
must be prepared and submitted

                          iScmsolidated  "Reporting  in  ,X.L
The requirements for monitoring, record
keeping, and reporting become more strin-
gent as the facility's actual emissions approach
the facility-wide cap under Merck's air quality
permit. Monitoring, record keeping and
reporting will be performed by Merck
according to the reporting tier determined by
the current 12-month rolling total. Tier I has
the least stringent requirements; more
frequent reporting is required when Tier II or
Tier III requirements are in effect.
                                           Programs Affected
The tiered reporting covers air quality
emissions specified by the innovative
PSD permit.
 Weyerhaeuser      The Weyerhaeuser project allows the facility
                    to consolidate reporting into two annual
                    comprehensive reports for some of the
                    Federal, state, and local permitting and
                    regulatory programs that apply to the facility.
                    The reports eliminate some sampling require-
                    ments and allow annual compliance self-
                    certification in lieu of periodic discharge
                    monitoring reporting.

 NYSDEC           Participating utilities will produce one biennial
                    report on all the hazardous waste generated
                    at remote locations. Under the  current
                    system, a separate EPA identification number
                    is assigned to each remote location reporting
                    hazardous waste production and a biennial
                    report must be produced for each location.
                    This change will bring about significant
                    reduction in paperwork and savings in time
                    and labor, both for the public utilities and
                    environmental regulatory agencies. The
                    change will also provide the public with
                    clearer and easier to use information about
                    waste generated at remote locations.
                                            The comprehensive, less frequent
                                            reports cover drinking water, water
                                            quality discharges, groundwater and
                                            surface water use, and air quality. Self-
                                            certification covers discharge monitor-
                                            ing reporting for the NPDES permit.
                                            NYSDEC will receive fewer reports
                                            with more information from participat-
                                            ing utilities, reducing the number of
                                            reports that require separate tracking
                                            and review under the Resource
                                            Conservation and Recovery Informa-
                                            tion System.
The Berry project had been designed to have
a multimedia consolidated permit in place,
and the State of Florida would have allowed
Berry to use nonstandard forms in reporting
environmental performance.
The nonstandard forms would have
applied to air quality, drinking water,
industrial wastewater, groundwater
monitoring, and fresh water use
reporting. Also, the State of Florida
may not have required Berry to
provide certification of environmental
reports by a professional engineer,
because the COP would have been
more extensive than a certified
professional engineer's application.
Results/Anticipated Outcomes:  The  Intel and
Weyerhaeuser projects' reporting mechanisms
have been underway since  1997. The companies.
regulators, and stakeholders involved believe that
the Intel and Weyerhaeuser projects have gener-
ally resulted in detailed, value-added  reporting.
However, stakeholders' comfort with this approach
                               is not absolute; e.g., one stakeholder for the Intel
                               project wants more technical details to be avail-
                               able to the public, as well as the technical assis-
                               tance to interpret the information, so that  the
                               community can better evaluate the potential  im-
                               pacts on health and the environment and then in-
                               fluence the company's decision-making process for

choosing among different available technologies or
chemicals. This desire has been echoed by other
national interests. The Merck project's reporting
mechanisms are projected to start in 2001. Berry
had not initiated the reporting mechanisms before
that project was terminated in June  1999.

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

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

In recent years, national efforts have centered
around identifying and addressing environmental
problems using innovative and integrated initiatives
that combine compliance assistance, incentives,
monitoring,  and enforcement. These compliance
incentives include incentives to self-disclose, includ-
ing the audit and small business policies promoting
supplemental environmental projects and providing
compliance assistance through electronic centers.
In particular, self-certification is being explored by
states as an opportunity to deliver better compli-
ance assurance while EPA is exploring promoting
Environmental Management Systems. Self-certifi-
cation approaches vary, but they typically ask fa-
cilities to report on a specified set of environmental
performance measures (such as sampling actions,
sampling results, regulatory compliance, and regu-
latory violations). States have used self-certifica-
tion strategies in a variety of ways: to reduce
reporting burdens, to reduce the need for resource
intensive individual permits for small sources, to
reduce the amount of labor-intensive inspections
and/or prioritize them to allow states to reinvest
resources into higher priority problems, and to in-
crease the number of facilities addressed by states'
enforcement and compliance systems. Also, states
and EPA are trying new procedures to measure
compliance on a facility and sector level. The mea-
sures may assist  in identifying  problem areas that
could be improved through new technology or pol-
lution prevention. Additionally, EPA is willing to
offer flexible options under regulations that encour-
age facilities to choose compliance alternatives that
are better economically and environmentally.
Project  XL has been one venue for testing these
innovations, which are described below in Table 12.
          "12:  (Snj-orcement and  (Sompliance Assurance  Innovations
 Massachusetts DEP
 Massachusetts DEP
              Media                     Innovation
           Multi-media    Business Self-Certification: In lieu of state permits, self-
                         certifications are used to comply with or exceed state performance
                         standards; Weyerhaeuser performs compliance self-certification in
                         lieu of periodic discharge monitoring report for facility NPDES
                         permit based on 16 years of compliance.
           Multi-media    Predictive Emissions Monitoring: Reduce the frequency of stack
                         testing and replace a CEM system with a predictive computer-based
                         system that will correlate operating parameters with air emissions.
           Multi-media    Environmental Business Practice Indicators (EBPIs): Use of EBPIs to
                         supplement or replace traditional measures of compliance allows
                         regulatory agencies to review compliance as well as encourage
                         beyond compliance techniques for industry leaders.
               Air        Alternative Compliance Flexibility under Emissions Cap: Flexibility to
                         reduce air emissions cap as an alternative to directly complying
                         with newly applicable criteria pollutant regulations (through the
                         PSD permit).

          "12:  (Snj-orcement  and 
            The Weyerhaeuser project allows the facility to
            eliminate some sampling activity and to provide
            annual compliance self-certification in lieu of peri-
            odic discharge monitoring reporting for the NPDES
            permit. This limited self-certification process was
            allowed due to the company's 16-year history of
            meeting all required discharge levels combined with
            the project's commitment to superior environmen-
            tal performance. Weyerhaeuser is still required to
            maintain required sampling and laboratory analysis
            records, and all upset, malfunction, or noncompli-
            ance reporting will continue as required by appli-
            cable regulations. These records are available upon
            request by regulators and the public. Weyerhaeuser
            will remain subject to the State of Georgia's stan-
            dard enforcement protocol, as required by the state's
            NPDES permit program.

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

            The  ERP project has been underway since late
            1996, and the results of the ERP approach and self-
            certification are still being evaluated. In May 2000,
            Massachusetts DEP presented its own preliminary
            assessment of the ERP program to EPA. DEP is
            using EBPIs, compliance inspection findings, and
            data reported on the self-certification forms, as well
            as statistical sampling techniques to measure and
            evaluate the environmental results of ERP. Feed-
            back from preliminary state evaluations has been
            largely positive. In the fall of 1997, participating
            dry cleaners and photo processors completed their
            first annual certification. Participating printers com-
            pleted their first certification in 1998. These certi-
            fication statements have increased the identification
            and understanding of small businesses not other-
wise included in a regulatory framework. Before
ERP, only 10 percent of dry cleaning facilities were
"in the system." By 1999, that number had in-
creased to  95 percent. Altogether, nearly 2,400
companies  representing three sectors have self-
certified  under  the ERP since 1997. Massachu-
setts DEP has begun expanding this approach to
two additional sectors—industrial wastewater and
combustion sources (boilers)—which will signifi-
cantly increase  the number of Massachusetts fa-
cilities self-certifying under ERP.

Preliminary evaluation has also demonstrated that
converting permit requirements into comprehensive
and stringent industry/sector-wide performance
standards has improved corporate accountability
toward annual compliance. For 1997,  80 percent
of dry cleaners  and photo processors  completed
their certifications accurately. Ten percent of sub-
mitted certification statements have "Return to
Compliance Plans" (a 10 percent compliance in-
crease). Thirty-five percent of these Return to
Compliance Plans will result in a decreased envi-
ronmental impact. Massachusetts DEP has esti-
mated that increased compliance will lead to a
program-wide decrease in VOCs by 10  percent,
an estimated 43  percent reduction in perchloroeth-
ylene emissions (a total of 500 tons) from Massa-
chusetts dry cleaners each year, and a reduction in
wastewater discharges of silver by 99 percent from
photo processors. Increased compliance is also
anticipated to yield significant reductions in the use
of smog-forming solvents and alcohol used by com-
mercial printers.

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

Transfer ability: The Massachusetts DEP and
Weyerhaeuser  projects are testing  alternative
mechanisms that enhance accountability while pro-
viding flexibility. In particular, Massachusetts DEP's
ERP approach has been designed to increase sec-
tor understanding while focusing limited resources

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

The extent to which the ERP approach will prove
transferable in practice will depend in large part on
the ability to  measure and document the anticipated
results of the project. Three potential opportunities
for transferability are being investigated. (1) De-
velopment of a "tool kit" and communications ma-
terials could  help expand  the availability of
information about the benefits and limitations of the
ERP program as program data become available.
(2) Sectors have already expressed an interest in
participating in innovative programs and could be
interested in participating in a self certification pro-
gram if it could provide them with reduced burdens
or regulatory flexibility. (3) The concentration of
large and  small businesses in certain geographic
regions may  provide an opportunity to address sec-
tor- or place-based issues on a local level.

Predictive Emissions Monitoring

The Experiment(s): The International Paper (IP)
predictive emissions monitoring (IP-PEM) project
is seeking to  develop, test, and implement a sophis-
ticated, computer-based, alternative emissions moni-
toring system that can accurately predict pollutant
emissions on a continuous basis at IP's Jay, Maine,
pulp and paper mill. IP will replace stack testing
and the  continuous emissions monitoring (CEM)
system on the mill's waste fuel incinerator (WFI)
with a predictive emissions monitoring (PEM) sys-
tem. The PEM system would be a computer-gen-
erated model that would predict air emissions (PM,
SO2, NOx, CO2, and CO) from WFI operations on
a continuous basis. A PEM system would provide
real-time feedback and would allow IP to make
operational adjustments when predicted pollutant
emissions approach permitted limits. IP is also
making  a  voluntary commitment to maintain its
emissions from the WFI at a level equal to or less
than 90 percent of its license limit once the PEM
system is implemented.

The IP waste fuel incinerator produces steam from
the combustion of fossil  fuel, wood residue,
papermill sludge, and waste paper. CEM systems
are required for SO2 and NOx emissions from the
WFI, but currently, WFI PM emissions are subject
only to annual stack tests. Development, testing,
and implementation of a computer-generated PEM
system will determine if IP can predict emissions
from a complex, saturated stack on a continuous
basis. Current stack testing and CEM systems are
designed to record compliance and noncompliance
with permit limits when a violation occurs. They
do not provide an opportunity to prevent or lower
emissions at the time of measurement. A success-
ful PEM system would allow IP to be proactive,
correlating the relationship between operating pa-
rameters and emissions, enabling the facility to pre-
dict emissions in advance and adjust their operations
prior to exceedances actually occurring.

To fully develop the computer model, the IP-PEM
project has the flexibility to allow a number of short,
controlled exceedances above the current WFI
emission limits to formulate the model's emission
prediction capabilities. The exceedances would be
needed for model development, since, unless the
model was programmed to identify the operating
conditions which caused an exceedance during a
test, the PEM system would be unable to accu-
rately predict such a situation should it arise during
regular operations.

Results/Anticipated Outcomes: The IP-PEM
project seeks to provide assurances of pollutant
emissions compliance on a continuous basis. Any
permitted exceedance granted for computer model
development will be agreed upon beforehand and
will be limited to days when the potential to exceed
ambient air quality standards would be minimal.
Successful development of a PEM model would
provide continuous information on particulate emis-
sion rates for sources that,  to date, have had no
federally approved methods to monitor PM on a
continuous basis from saturated stacks. If the PEM
system is successful for PM, a State Implementa-
tion Plan amendment could allow the system to be

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

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

            Transferability: The IP-PEM project offers the
            potential for technology transfer to other emission
            sources at the IP facility as well as to other facili-
            ties. PEM systems have previously been developed
            for simple stacks and  gas-fired boilers, but have
            had very limited application for complex stacks with
            high moisture content. This project will help dem-
            onstrate if this technology can be transferred to
            "complex" boilers, kilns, and incinerators. PEM
            systems can provide a meaningful linkage between
            emission rates and the operational parameters that
            affect them and could have application for other
            sources of pollution or operations seeking to opti-
            mize operation controls while reducing emissions.
            PEM systems-generated information can be used
            by operators to decrease emissions while maximiz-
            ing production.

            Environmental  Business Practice Indicators

            The Experiment(s): As part of its  ERP, Massa-
            chusetts DEP has developed EBPIs, in collabora-
            tion with EPA and industry,  to  evaluate the
            performance of three industry sectors—dry clean-
            ers, printers, and photo processors. EBPIs will play
            a key role in the evaluation of ERP. EBPIs are
            industry-specific performance measures that pro-
vide a snapshot of a facility's environmental per-
formance. The concept is to "benchmark" facility/
sector performance and potentially shift compliance
assurance strategies based on how EBPIs track
compliance and beyond compliance activities.

The use of EBPIs rather than traditional "single
dimension" measures of compliance (e.g., in com-
pliance, out of compliance, significant noncompli-
ance) allows regulatory agencies not only to look
at compliance more comprehensively and  on an
annual basis, but also to recognize and potentially
encourage "beyond compliance" strategies for in-
dustry leaders. The number of EBPIs developed
for each sector is different. Printers have 16 EBPI
measures (including nine pollution prevention-spe-
cific measures), dry cleaners have 16 EBPI mea-
sures, and photo processors have eight EBPIs. The
number is based on the complexity of the industry
and the number of multimedia discharges. Currently,
beyond-compliance and pollution prevention oppor-
tunities are being tracked only for printers.

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

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

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

For ERP, EBPI measures include using low VOC
cleanup solutions (printers), degree of silver recov-
ery (printers and photo processors), perc recovery
(dry cleaners), and other pollution prevention mea-
sures  for printers. Massachusetts DEP is  using
EBPIs to measure and evaluate the results of the
ERP approach, and while results are still forthcom-
ing, preliminary  findings have been  positive.
Baseline data collected during random inspections
before the first round of certification has been com-
pared to data collected during  random inspections
after certification and  outreach under ERP. For
photo processors, preliminary EBPI evaluation has
revealed an increase in aggregate EBPI score from
the before baseline score (5.7 to 7.1), indicating an
increase in compliance for the sector. For dry clean-
ers, the aggregate EBPI score remained constant,
but there was a statistically significant increase.
Additionally,  the dry cleaning sector did exhibit a
small  increase in aggregate score for all  certifica-
tion questions (not just EBPI questions) after pro-
gram  implementation. In addition to calculating
sector-side scores, DEP has sought to measure the
overall level of accuracy of the certification data
by comparing data collected during random inspec-
tions after ERP certification with data presented
on the certification forms  of those facilities. Al-
though compliance is a single point in time, initial
analysis of dry cleaners in ERP has revealed agree-
ment between certification forms and state inspec-
tions  76 percent  of the  time. By measuring
compliance rates by firm, sector, media, and com-
pliance requirement, DEP anticipates being able to
focus its scarce  resources for compliance assis-
tance and inspections based on how EBPIs track
sector-specific performance measures.

Transfer ability:  Given that the EBPIs are spe-
cific to each industry, it is too early to determine
broader sector-wide applicability. Nevertheless, the
use of EBPIs rather than the traditional "single di-
mension" measures of compliance (e.g., in compli-
ance,  out  of  compliance,  or  significant
noncompliance) not only allows regulatory agen-
cies to look at compliance more comprehensively
but it also offers the opportunity to recognize and
potentially encourage beyond compliance tech-
niques for industry leaders. Massachusetts DEP
has already agreed to expand its ERP effort to two
additional, cross-sector activities—firms discharg-
ing industrial wastewater (the industrial wastewa-
ter sector) and firms installing or modifying boilers
(the combustion sector). Massachusetts DEP esti-
mates that the addition of these new sectors could
quadruple the number of Massachusetts facilities
that ERP could impact. This would provide an even
more comprehensive database of EBPIs and would
enable further evaluation of this innovative perfor-
mance measurement and  tracking system.

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

Alternative Compliance Flexibility under
Emissions Cap

The Experiment(s):  Emissions caps provide an in-
centive for a site to minimize emissions to ensure
compliance and  to preserve a sufficient margin
under the cap  to  accommodate growth. Merck's
Stonewall Plant criteria pollutant cap has been con-
structed so that the facility has the ability to make
many common changes at the site without prior

approval from the permitting authority. A unique
aspect of this project is that Merck also has the
flexibility to reduce their emissions cap instead of
directly complying with a newly applicable criteria
pollutant regulation. Specifically, when the Stone-
wall Plant becomes newly subject to a regulation.
they may choose to comply with the regulation di-
rectly or reduce their criteria pollutant cap by the
amount of emissions reduction expected from di-
rect compliance. Thus, to achieve compliance with
a new air pollutant regulation, the plant may install
new control equipment and maintain the  existing
facility-wide criteria pollutant limit or they may keep
the existing equipment and establish a permanent
reduction in their emissions cap. Figure 1 provides
a graphic depiction  of this alternative compliance
mechanism. Only regulations addressing one or
more of the criteria pollutants covered by the emis-
sions caps (i.e., CO, VOCs, SO2, PM-10, andNOx)
can qualify for this alternate compliance mecha-
nism. For example, anew rule establishing emis-
sion standards for VOCs from storage tanks would
qualify; however, if the purpose of the rule was to
control F£APs, alternate compliance via  cap ad-
justment would not be available.
        re  "1 :  Prevention  of
       Deterioration (PSD)  Permit
  yMternative  Compliance  AAecka
         Install new
         control equipment
Maintain facility-
wide cap limits
  New criteria
           Reduction in
         Keep existing
Reduce facility-
wide cap limits
Results/Anticipated Outcomes: This cap adjust-
ment and regulatory compliance scenario is based
on the premise that facilities operating  under an
emissions cap practice "up-front" compliance to
future rules that would require emission reductions.
Merck's commitment, for example, to convert the
site powerhouse from burning coal to natural gas
allows the facility to offer an environmental ben-
efit in advance of any regulation. This is because
the cap adjustment "locked in" a portion of the re-
ductions from that project, preventing the site from
increasing its emissions back to the cap level prior
to adjustment. This approach focuses facility ef-
forts on finding emission reductions in the most cost-
effective manner, rather than attempting to achieve
compliance through a generic "one size fits all" ap-
proach or the mandated installation of air pollution
control equipment.

Transfer ability:  The flexibility offered to Merck
under this emissions cap adjustment  scenario is
related to their site-specific prevention of signifi-
cant deterioration permit. Similar opportunities for
flexibility under an emissions cap are possible based
on site-specific conditions. Merck's ability to oper-
ate its Stonewall facility in this manner represents
an approach that may be applied to other plants
who are facing similar business issues.

Major Source Emissions Tiered Compliance

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

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

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

                         "13:  WeyerKaeuser TTiered  (Somplicmce
 Monitoring Results
 When parametric monitoring has shown that
 control of emissions are less than 25
 percent of the allowable limit
Testing Frequency
Major source compliance testing will be performed every
four years
 When control of emissions are greater than 25
 percent and less than 50 percent of the
 allowable limit
Major source compliance testing will be performed every
three years
 When control of emissions are greater than 50
 percent and less than 75 percent of
 the allowable limit
Major source compliance testing will be performed every
two years.
 When control of emissions are greater than
 75 percent of the allowable limit
Major source compliance testing will be performed
Transferability: The opportunity to use this ma-
jor source emissions compliance test flexibility was
provided under the dual emission cap system in-
corporated into the Flint River modified air quality
permit. Other facilities  that face comparable cir-
cumstances could benefit from a similar compli-
ance-based, tiered approach designed to achieve
criteria pollutant emissions reductions. This provi-
sion of a facility-wide permit modification may also
have the potential to influence other Agency per-
mitting initiatives. This project will also present an
opportunity to analyze how state air pollution moni-
toring and reporting requirements can be coordi-
nated with federal compliance testing flexibility to
ensure compliance while achieving superior  envi-
ronmental performance.

Gasification of Pulping Liquor Under

The Experiment(s):  The Georgia-Pacific Big  Is-
land, Virginia, pulp and paper mill is seeking to dem-
onstrate a new recovery technology under section
112 of the CAA. The Big Island facility, a semi-
chemical mill,  is subject to the air emissions re-
quirements of the Pulp and Paper Cluster Rule of
the CAA, which requires the installation of maxi-
mum achievable  control technology (MACT). A
second MACT standard (MACT II), applicable to
pulp and paper mills, was proposed in 1998 specifi-
cally to address emissions from combustion sources
associated with the recovery of pulping chemicals.
The recovery process is an integral component of
   mill operations. Chemicals used in the pulping pro-
   cess are recovered and spent liquor organic solids
   are converted to energy (process steam). Currently,
   the mill takes spent liquor (black liquor) from wood
   pulping, reduces its water content through an evapo-
   ration train, and combusts the resultant concentrated
   liquor in two smelters (type of recovery furnace).
   The smelters  recover  sodium carbonate from a
   molten smelt that is then dissolved in water to pro-
   duce new pulping liquor.

   MACT II does not specify a particular technology
   to meet the emission standard. However, to com-
   ply with the proposed standard, the current Geor-
   gia-Pacific  system would require a substantial
   upgrade. Georgia-Pacific would have to either (1)
   upgrade these smelters and add additional control
   devices or (2) replace the smelters with a new re-
   covery boiler that uses conventional technology. As
   an alternative, Georgia-Pacific has proposed install-
   ing a black  liquor gasification system to recover
   pulping chemicals. The current smelter recovery
   furnace would be replaced with a PulseEnhanced™
   Steam-Reforming chemical recovery system.9
   Under this alternative  system, organics from the
   concentrated spent liquor would be pyrolyzed to a
   hydrogen rich fuel. In turn, this fuel would be burned
   as an energy source for the gasification unit and as
   9The PulseEnhanced™ Steam-Reforming gasification system
   was developed by StoneChem, Inc. The process produces an
   endothermic reaction converting black liquor organics to a gas
   in the absence of air or oxygen at temperatures below those
   required for smelt formation.

            an alternative boiler fuel to produce steam used
            elsewhere in the Big Island facility. Sodium bicar-
            bonate pellets would be recovered during this pro-
            cess for reuse in fresh pulping liquor.

            Recognizing that the existing smelters would not
            meet the performance  standard of the proposed
            MACTII, Georgia-Pacific sought regulatory flex-
            ibility in working to bring the gasification technol-
            ogy on line. Given that this technology is
            comparatively new, Georgia-Pacific pursued an
            extension to operate the existing smelters or con-
            ventional recovery boiler for a set period of time
            past the MACT II compliance date (once that date
            is established). This flexibility would provide the
            facility with additional time for commissioning or,
            in a worst case scenario, replacing a failed gasifi-
            cation system with a conventional recovery boiler.
            Georgia-Pacific also requested flexibility to use
            steam generated by the new process in place of
            steam currently generated from a natural gas boiler.

            Results/Anticipated Outcomes: The final project
            agreement for the Georgia-Pacific project was
            signed on  May 31,  2000. The Big Island black li-
            quor gasification system would be the first com-
            mercial application of this innovative technology in
            the  United States. General benefits of this gasifi-
            cation technology are expected to include increased
            energy conversion  and chemical recovery effi-
            ciency, elimination  of the smelt-water explosion
            hazard, and lower emissions of criteria pollutants
            (PM, SO2, NOx, VOCs, CO) and HAPs. Georgia-
            Pacific believes that use of this system will allow
            the  Big Island facility to reduce HAP emissions
            below the proposed MACT II standard. Criteria
            pollutant emissions would also be reduced since
            the  gasification system  does not require auxiliary
            fuel to maintain a stable liquor combustion  as op-
            posed to a conventional recovery boiler. Such emis-
            sions reductions are attractive to pulp mills such as
            Big Island that use a semi-chemical non-sulfur pro-
            cess requiring auxiliary fossil fuel to combust black

            Transferability: This project  offers the opportu-
            nity to demonstrate and analyze the energy con-
            version, safety, and environmental performance
            benefits of a new technology.  The Big Island mill
            will test the effectiveness of the PulseEnhanced™
Steam-Reforming gasification technology in pro-
viding full chemical recovery capacity for a semi-
chemical mill. Other pulping facilities that face
comparable circumstances  could benefit from a
similar approach to make their energy conversion
systems more efficient and less capital intensive
while achieving emissions reductions. With the Big
Island facility similar in characteristic to 12  other
mills in the United States, successful demonstra-
tion  of this technology could contribute substan-
tially to its transfer and implementation at a larger
number of kraft mills.  This technology could also
have applications for the conversion of non-wood
liquors, sludges, and agricultural wastes to energy.

Additionally, as the project proceeds, there will be
a need to analyze the energy efficiency potential
of this technology in producing steam  as a
byproduct of the chemical recovery process, which
can be used to offset steam generated with fossil

ew a
Environmental stewardship is a way of identifying
and pursuing good business strategies that are con-
sistent with environmental protection: choosing en-
vironmentally benign raw materials; improving the
financial and environmental efficiency of manufac-
turing processes; and employing effective environ-
mental management systems (EMSs). The ultimate
value of stewardship is deriving economic value
from environmental excellence. Recognizing the
need to promote environmental stewardship, EPA
recently announced the National Environmental
Performance  Track to motivate and reward top
environmental performance. Several states  have
their own programs as well. Also through Project
XL, regulated facilities can further their commit-
ment to stewardship approaches with pollution pre-
vention, recycling, and EMSs.
Pollution prevention and recycling provide multiple
pathways to sustainable development and environ-
mental stewardship. EPA has defined pollution pre-
vention as "source reduction" (which is explained
under the 1990 Pollution Prevention Act) and pro-
tection of natural resources through conservation
or increased efficiency in the use of energy, water.
and other materials. Recycling shares many of the
advantages of pollution prevention; it can reduce
the  need for treatment or disposal and conserve
energy and natural resources. Many facilities use
a broad definition of pollution prevention that in-
cludes recycling.

An EMS applies standard business principles to the
management of an organization's  environmental
issues. An EMS does not determine a company's
legal obligations; rather, it is a sophisticated tool
used by companies to manage compliance and
other environmental concerns. An EMS can help a
company boost efficiency, cut waste, and improve
worker safety. It also can bring attention to envi-
ronmental matters that are  not directly addressed
through regulation, such as energy use.

Table 14 identifies several projects that are testing
EMS, pollution prevention, and recycling options
that demonstrate these facilities' commitments to
sustainable development.

Linking EMSs to Standard Operating

The Experiment(s):  Weyerhaeuser is striving  to
minimize the environmental impact of its manufac-
turing processes on the surrounding environment
by pursuing a long-term vision of its Minimum Im-
pact Mill. Weyerhaeuser has voluntarily instituted
an EMS at the Flint River facility that conforms to
the  International  Standard Organization (ISO)
14001 standard. The EMS will include operational
procedures, record keeping, auditing, quality assur-
ance, and permit requirements. Weyerhaeuser is
also developing a comprehensive manual of stan-
dard operating procedures for plant employees. The
Berry project had also committed to using an EMS
based on ISO 14000. The project was designed to
test the EMS approach as a means of promoting
continuous improvement in environmental perfor-
mance, pollution prevention, and source reduction
Results/Anticipated Outcomes:  For Weyer-
haeuser, the overall process of developing ISO
14001 documentation originally was scheduled for
completion in mid-1997. Due to a company focus
on other aspects of the Minimum Impact Mill vi-
sion, documentation  has proceeded slower than
expected and is now scheduled for completion late
in 2000. For Berry, the work on the EMS itself had
not begun before the  project ceased implementa-
tion; the company had intended for the standard
operating procedures and work instructions devel-
oped for the potential comprehensive operating
permit to  be compatible with ISO 14000. Both
Weyerhaeuser and Berry believe that the strate-
gies they have used to develop the EMSs have re-
sulted in a more  environmentally aware workforce.
For example, in 1997 Berry reported that develop-
ing the standard operating procedures and work
instructions helped the company reduce the cost of
training and improved day-to-day compliance by
focusing on how employees should perform their
specific job responsibilities. Weyerhaeuser reported
in 1998 that engaging their employees in the imple-
mentation of the revised EMS had begun to increase
staff education and awareness of the environmen-
tal aspects of their jobs.

Transferability: When the implementation of the
Weyerhaeuser project is  further along, EPA plans
to evaluate the benefits and challenges of the EMS
approach. EPA will look to work with Weyerhaeuser
personnel to collect data assessing the improve-
ment in day-to-day compliance with environmental
regulations attributable to the EMS. This will assist
EPA in meeting a charge by the 1999 Innovations
Task Force to report,  by  2002, on the use and ef-
fectiveness of EMSs in improving environmental
performance and achieving results. Also, on March
12,1998, EPA issued apolicy statement in the Fed-
eral Register,10 describing  a number of pilot projects,
including Project XL, which will provide data on
the actual compliance and environmental benefits
of EMS approaches. The Federal Register Notice
describes how a group of Federal and state offi-
cials involved in  EMS pilot projects have been
working together to set up a common national da-
tabase of information gathered through the pilot
projects. As part of that process, EPA and  states

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

developed a series of data protocols that provide
instructions and survey instruments to guide the
actual collection of data for the database. Future
analysis of the Weyerhaeuser project also will be
designed to support the EMS database.

Multi-facility EMSs

The Experiment(s): The Lucent project tests
whether a corporate EMS can be the basis for
streamlining the implementation of state and Fed-
eral regulations, consolidating permits, and improv-
ing Lucent's facilities' day-to-day compliance. The
goal is  to have more cost-effective  systems that
raise  facility managers' awareness of their envi-
ronmental obligations before they make decisions
about modifying equipment and operations (rather
than at the end of a long, expensive regulatory or
permitting process) and allow regulators to  focus
more on compliance assurance and technical as-
sistance. Table 15 below describes the project ap-
proach and goals.

Results/Anticipated Outcomes: Specific results
for the  Lucent project are not  yet available. The
FPA for the Lucent project is an "umbrella" agree-
ment and is based on an existing, third-party-certi-
fied  ISO 14001  EMS for the entire, global
microelectronics business unit of Lucent Technolo-
gies. The FPA contemplates the  development of
specific proposals for regulatory flexibility and su-
perior environmental performance at individual fa-
cilities. The umbrella FPA outlines a process that
allows Lucent to use its EMS as a framework for
developing facility-specific proposals to simplify per-
mitting, recordkeeping, and reporting requirements,
while driving continual improvement and pollution
prevention programs.

Transferability: The EMS Federal Register No-
tice states that it is critical to measure any change
in a facility's environmental performance that might
be attributable to implementation of an EMS. Project
XL can collect information on types, amounts, and
properties of regulated and nonregulated pollutants
that are reduced as a result of an EMS. In particu-
lar, the Lucent project will be able to provide this
information on a multi-facility basis. EPA's EMS
Federal Register Notice also states that Federal
and state regulators are interested in understand-
ing the involvement of local communities and other
stakeholders in the EMS process. The  Lucent
project can collect data to  assess the amount and
degree of stakeholder and  regulator participation
in both the development and implementation of an
organization's EMS, and the effect that participa-
                       "15:  Lucent  Project  T^pproacK  and
  Develop a third-party-certified, high-quality EMS
  framework that can be used to:

  • identify significant, site-specific regulated and
    non-regulated activities, substances, or processes
    such as water usage, wastewater discharge, air
    emissions, energy usage, chemical consumption,
    raw material consumption, and land use that
    interact with the environment;

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

  • ultimately, integrate critical information and
    performance goals into a single, companywide
    matrix that facilitates understanding and
    accessibility for stakeholders, assists in measur-
    ing performance and accountability, and poten-
    tially serves as the core of a companywide
    consolidated permit.
 To develop site-specific flexibilities that would lead
 to superior environmental performance and
 improved environmental management at each
 Lucent facility.

 The ultimate goal is to use the EMS as a platform
 from which the company can, over time, consoli-
 date all Federal and state permits for its domestic
 facilities into a single companywide multi-media
 permit. This permit would be based on objectives
 and targets set annually and jointly by the company
 and regulators. Involving regulators in this EMS
 approach would result in a de facto annual review  of
 the permit, eliminating multiyear renewals of
 individual permits.

            tion has on the public credibility of the facility's
            EMS implementation. EPA plans to evaluate the
            benefits and challenges of these EMS approaches
            designed to support the  Innovations Task Force
            report and the goals of the  EMS database.

            Waste Minimization and  Pollution Prevention

            The Experiment(s):  The  Crompton (formerly
            Witco) project conducted a comprehensive waste
            minimization/pollution prevention (WM/PP) study
            for its Sistersville, West Virginia, facility. The fol-
            lowing focuses  on this WM/PP study and
            Crompton's commitment to methanol recycling.

            Instead of occurring as a single event outside the
            purview of routine business operations, the
            Crompton WM/PP study was an employee-driven
            effort that sought to identify and integrate pollution
            prevention approaches into the company's standard
            operating practices using a third-party contractor
            to conduct the study. The WM/PP opportunity as-
            sessment facilitated employee involvement in the
            process and implemented an  approach tailored to
            the specific needs of the facility. Crompton used a
            multiphased process to conduct the study: (1) iden-
            tifying and characterizing  plantwide wastes and
            emissions, (2) screening and prioritizing  these
            wastes and emissions, (3) identifying pollution pre-
            vention options, (4) screening and prioritizing pollu-
            tion prevention options, (5) examining the technical
and economic feasibility of these options, and (6)
developing an implementation plan.

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

Another aspect of the Crompton project is the com-
mitment to recycle methanol. Previously, excess
methanol produced in Crompton's Sistersville fa-
cility was condensed, collected, and either disposed
of in the facility's wastewater treatment unit or in-
cinerated. Under the project, Crompton is reusing,
recycling, or thermally treating 95 percent of the
collected methanol. This  will minimize  the
biotreatment of methanol in  the facility's waste-
water treatment units and reduce sludge genera-
tion. Table 16 describes the project approach and
potential savings from the  Crompton project.
                         Table  16:  
Results/Anticipated Outcomes: A final report
was published in December 1998 as a result of the
WM/PP study. This report laid out 330 pollution
prevention options that were determined to be tech-
nologically and economically feasible. Crompton's
Annual Project XL Report (July 31, 2000) lists a
total of 370 pollution prevention opportunities that
have been identified. Of these, 26 are at some stage
of study and 67 have been implemented. Table 16
is a summary of some of the potential cost savings
and potential waste or emissions reductions to be
gained by the pollution prevention options identi-
fied by the Crompton WM/PP study.

The most promising identified opportunities are re-
viewed and selected by an internal Pollution Pre-
vention Council, which was established in 1998 as
a result of the WM/PP  study.  The Pollution Pre-
vention Council, representing many plant functions,
meets monthly. Council members choose the most
promising opportunities identified in the final report
to pursue, including options originally deemed not
feasible, as well as offering other ideas. The Pollu-
tion Prevention Council maintains an "evergreen"
list of ideas—a  list of prioritized waste problems
along with a list of pollution prevention projects that
have been proposed to resolve those problems—
which are reviewed at each monthly meeting.

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

Transferability:  The Crompton project approach
toward pollution prevention and recycling may of-
fer an innovative model for other chemical inter-
mediate-product manufacturers. Some pollution
prevention approaches can be implemented through
modifications to existing standard operating proce-
dures  combined  with careful training on the new
procedures and  follow up to ensure those proce-
dures  are carried out. Involving facility-level per-
sonnel "up-front," even in the development of the
process itself, has proven valuable and could have
application at other facilities. Including  a broad
spectrum of employees representing many plant
functions has helped to instill a facility-level culture
in which individual employees are trained and em-
powered to continuously identify and implement
new pollution prevention opportunities and strate-
gies. This approach has required a clear manage-
ment commitment on the part of Crompton to
commit resources and institute technically and eco-
nomically feasible pollution prevention measures.

Timberland Resource Strategies

The Experiment(s): Weyerhaeuser manages over
300,000 acres of timberland in Georgia, with im-
pacts on more than half of the river basins in the
state. As a component of the  Weyerhaeuser
project's Minimum Impact Mill vision and as a
means to further protect the Flint River, neighbor-
ing wildlife habitats, and unique parcels on its for-
est  land,  Weyerhaeuser  has  undertaken
management changes to enhance its Forestry Man-
agement System. These methods are expected to
improve water quality and wildlife habitat, soil sta-
bility and increase soil productivity while sustainably
producing wood and forest products. Weyerhaeuser
has incorporated its forestry  management strate-
gies into  the Flint  River facility-wide EMS.
Weyerhaeuser is also engaging in cooperative ef-
forts to ascertain how company forest lands can
contribute to the conservation of threatened and
endangered  species.

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

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

             addition, the project provides the opportunity to
             explore how performance and management objec-
             tives and principles can serve as leverage points
             with vendors and contractors.

             Variability in environmental performance in the for-
             est products industry could serve as a potential bar-
             rier to broader scale transfer and application of an
             enhanced   forestry   management  system.
             Weyerhaeuser manages its operations to reduce
                             the ecological footprint of the Flint River facility.
                             Compared to similar pulp and paper operations, the
                             Flint River facility produces only 10 percent of the
                             air emissions and uses only 20 percent of the for-
                             est land needed for an equivalent unit of produc-
                             tion. Diversity of forest types and growth rates
                             across the country and differing forest land man-
                             agement desires and systems could also impact the
                             applicability of atimberland resources strategy.
                                   'IT7:    VveyerKaeuser TTimbencmd
                                               Forestry Management System
Improvements have been seen in:

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

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

Identification and management of forestland wildlife habitats.
              Internal Process
Weyerhaeuser has worked to integrate the forestry management system into the
facility-wide EMS. The Flint River facility's total quality management system is ISO
9000 certified and the facility has implemented an EMS that complies with the ISO
14001 standard, although the facility is not ISO 14001certified at this point.

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

The forestry EMS has been significant from a forest stewardship and sustainability
perspective and has created economic benefits as well.
To broaden the application of responsible practices and sustainable forestry,
Weyerhaeuser has taken a lead role in updating the forestry best management
practices (BMPs) for the State of Georgia. Under the direction of the Georgia Forestry
Commission, work was conducted with nonprofit organizations, government
agencies and private landowners to develop comprehensive guidelines designed to
improve wildlife habitat and water quality in the state's private forests.

Weyerhaeuser has undertaken other cooperative, outreach, and public education
activities to empower landowners and other forest managers with the tools to
advance responsible forestry practices.
              Resource             Weyerhaeuser's forestry practices lead to forests that produce two to three times as
              Management          much wood per acre as unmanaged forests. In addition to increased productivity,
              Practices              harvested sites are prepared for prompt reforestation. In 1998, over 78 percent of its
                                   harvested lands were replanted within one year.

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

University Laboratory Pollution Prevention
and Recycling

The Experiment(s):  The New England Universi-
ties Laboratories project includes several provisions
designed to result in increased pollution prevention.
One of the objectives of the laboratory environ-
mental management plan (BMP) and the overall
project is to erase the distinction between unused
chemicals and waste chemicals in the laboratory
setting so that the value in reusing chemicals can
be realized. Thus, all laboratory waste in this project
will be managed under a single standard in the labo-
ratory. The determination whether a  laboratory
waste can be  reused within the university will be
made at a central accumulation facility within the
university by environmental health and safety pro-

According to a 1996 survey of about 100 academic
institutions by the Campus, Safety, Health,  and
Environmental Management Association, less than
1 percent of the hazardous chemical waste other-
wise destined for disposal was reportedly redis-
tributed or reused on-site. Under this project, the
participating universities will be able to more easily
facilitate the reuse of chemicals on a university-
wide  basis. For example,  chemicals that are no
longer of sufficient purity for use in a research labo-
ratory could be used by teaching laboratories, or if
a researcher in one department no longer needs
certain raw material chemicals, rather than dispos-
ing of them as waste, these chemicals could be
available to other departments in the university for
use. Waste reduction will be encouraged as a re-
sult of the more comprehensive waste exchange
systems throughout the institution.

Results/Anticipated Outcomes: The New England
Universities Laboratories project  is expected to
result in increased pollution prevention. The par-
ticipating universities have set specific pollution
prevention goals including a 10 percent reduction
in the overall amount of hazardous waste gener-
ated from participating laboratories  (from the
baseline), and a 20 percent increase (from the
baseline) in reuse of laboratory waste over the life
of the project. The universities will report each year
on their progress in meeting these goals.
One element of the Laboratory EMP is a require-
ment to define a list of "hazardous chemicals of
concern" and annually conduct a risk assessment
survey of these chemicals in the laboratory. This
list will be developed on an institution-by-institution
basis because the types of hazardous chemicals at
a particular institution will vary with the type of
work done  there. This list will be reviewed on an
annual basis and adjusted to ensure that it covers
an adequate breadth of hazardous materials. This
documented assessment will enhance both waste
and risk minimization efforts and move laboratory
personnel/inspectors away from discussions as to
whether a  hazardous material on the shelf is a
RCPvA hazardous waste.

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

Transferability: Laboratory waste management
currently accounts for the most substantial expense
for environmental, health, and safety (EHS) pro-
grams at the participating universities. This project
is intended to allow these institutions to more ef-
fectively promote and implement pollution preven-
tion programs in their laboratories. It is intended to
reduce waste disposal costs and reduce chemical
purchasing costs without diminishing the level of
environmental protection associated with the proper
handling and/or disposal of hazardous laboratory

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

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

Process Modifications and Waste

The Experiments): The Intel project seeks to mini-
mize the use and generation of hazardous waste
while exploring the value of incorporating non-regu-
lated (voluntary) items into its BMP. While Intel is
not legally required to recycle the solid, hazardous
and non-hazardous wastes generated at its Fab-12
facility, it has committed itself to specific recycling
goals. Notwithstanding its voluntary recycling tar-
gets, Intel's goal is to  reduce the total amount of
hazardous waste generated and used at the facility
and to shift as much hazardous waste as possible
into the non-hazardous waste category. To affect
this switch, Intel is applying a design for the envi-
ronment (DfE) approach to its manufacturing pro-
cess development. Intel develops new chip-making
processes every two years and incorporates envi-
ronmental improvement into manufacturing pro-
cesses through process and technology design and
chemical screening. These process design and tech-
nology improvements enable Intel to continuously
refine  the management of its waste resources.
Intel's waste management goals will also reduce
the impact of the Ocotillo facility on waste treat-
ment or disposal facilities. Intel has committed to
report its waste recycling activities in its consoli-
dated report to equip stakeholders with informa-
tion to evaluate Intel's progress toward attainment
of these recycling goals.

Results/Anticipated Outcomes:  Through its de-
velopment and implementation of more environmen-
tally compatible manufacturing processes, Intel has
integrated environmental considerations into its
decision-making process to lessen the environmental
burden of waste generation at its Ocotillo facility.
Intel is seeking to spur source reduction of hazard-
ous waste use with an front-end manufacturing
process design approach based on the DfE model
of continuous process improvement. This model
incorporates environmental improvement into pro-
cess development before these manufacturing pro-
cesses are implemented at Intel facilities. The DfE
approach will (1) reduce the total amount of haz-
ardous wastes used and generated during manu-
facturing processes and (2) employ chemical
screening to shift manufacturing processes towards
increased use of non-hazardous materials. These
materials shifts complement one another, and Intel
expects that they will lead to a decrease in the per-
centage of hazardous waste available for recycling
while increasing the percentage of non-hazardous
waste available for recycling. Intel is increasing
the amount of solid waste recycled by looking out-
side the scope of typical solid waste streams at its
facility. Intel's progress towards attaining its recy-
cling goals is outlined in Table 18 on the following

Transfer ability: Intel's focus on  using process
design and development to drive source reduction
and improve environmental management could have
applications for other technologically dynamic firms
facing comparable rapid evolution of manufactur-
ing process technologies. The continuous improve-
ment DfE approach offers a model of how up-front
consideration of environmental goals can be incor-
porated into traditional business decisions and prod-
uct/process development cycles to achieve superior
environmental performance. The Intel project of-
fers the opportunity to analyze (1) the value of in-
corporating voluntary targets into an environmental
management strategy, (2) barriers to effectively
interfacing environmental goals and process devel-
opment to create environmentally compatible prod-
ucts and processes, and (3) how chemical selection
protocols might affect process design and reduce
the amounts and toxicity of hazardous materials
used in manufacturing processes.

                         "18:  Jntel  Project (^\oals  and Progress
                                      Waste Minimization
             Intel Goals
    Intel Progress
 Hazardous   1997— recycle 60% of hazardous
 Waste       waste generated
             1999—recycle 50% of hazardous
             waste generated
             2001—recycle 40% of hazardous
             waste generated
    1997—67% of hazardous waste recycled

    1998—53% of hazardous waste recycled

    1999—65% of hazardous waste recycled
 Non-        1997—recycle 25% of non-
 hazardous   hazardous waste generated
 Chemical    1999—recycle 50% of non-
 Waste       hazardous waste generated
             2001—recycle 70% of non-
             hazardous waste generated
    1997—58% of non-hazardous
    waste recycled
    1998—49% of non-hazardous
    waste recycled
    1999—78% of non-hazardous
    waste recycled
 Solid        1997—recycle 40% of solid
 Waste       waste generated
             1999—recycle 55% of solid
             waste generated
             2001—recycle 60% of solid
             waste generated
    1997—42% of solid waste recycled

    1998—67% of solid waste recycled

    1999—67% of solid waste recycled
Alternative Technological Solutions for
Preventing Air Emissions

The Experiment(s): The Vandenberg AFB project
is testing new budgetary approaches that will al-
low the DoD to spend resources on pollution pre-
vention programs,  innovative technologies,  and
other approaches that will cost-effectively reduce
environmental impacts.  The Memorandum of
Agreement established a framework for develop-
ing ENVVEST11  pilot programs at three to five
DoD facilities. The Vandenberg AFB in Santa
Barbara County, California, was selected as the
first DoD facility to pilot the ENVVEST program
and implement cost-effective environmental pro-

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

11 As part of the Administration's reinvention initiative, EPA
and DoD signed a Memorandum of Agreement in 1995 that
established how the two agencies would interact during imple-
mentation of DoD's Environmental Investment (ENVVEST)
program. The ENVVEST program emphasizes regulatory
compliance through pollution prevention and provides an
alternative to prescriptive regulatory requirements through a
performance-based environmental management system de-
signed to attain superior environmental results.
sion controls using resources that would otherwise
be spent complying with Title V of the CAA re-
quirements, such as permitting, record keeping,
monitoring, and training. When Vandenberg AFB
reduces ozone-precursor emissions to agreed-upon
levels, its designation under Title V as a major
source of ozone-precursor emissions (primarily
NOx) will be reduced to a designation as a minor
source, resulting in a substantial reduction in air
emissions and compliance costs for Vandenberg
AFB. Near term, obtaining reductions has focused
on boilers, furnaces, and process heaters.

Result(s): Vandenberg AFB has committed to re-
ducing annual emissions of ozone precursors by
two tons per year by April 30, 2000, and by ten or
more tons per year by November 30, 2002. NOx
reductions will be accomplished by retrofitting or
replacing those boilers with the highest potential
for emission reductions, and VOC reductions will
be accomplished by assessing the emission reduc-
tion potential from solvents, surface coatings, and
other VOC emission sources. To date, actual NO
emission data has  been collected from nearly 30
preselected candidate boilers to determine baseline
emission levels and the potential emission reduc-
tion  resulting from a boiler retrofit/replacement

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

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

            •   using internal combustion engine control tech-
               nologies to reduce NOx emissions from aero-
               space ground equipment;

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

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

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

            •   implementing an electric vehicle (EV) fleet pro-

            On August 25, 1999, Vandenberg AFB presented
            a proposal to the Santa Barbara County Air Pollu-
            tion Control District for investing the balance of
            ENVVEST funds in an EV fleet pilot program. This
            program will help achieve the remaining reduction

            Transfer ability:  The Vandenberg AFB  project is
            testing ways to reduce regulatory burdens at Fed-
            eral facilities. Likewise, the Vandenberg AFB could
            be a  model  and  benchmark for other DoD facili-
            ties. This innovative approach in applying resources
            toward high-priority environmental problems that,
            in turn, will result in lower costs and reduced envi-
            ronmental emissions from the facility, should offer
            useful data for other DoD applications.
Flexible Fuel Vehicle Replacement

The Experiments):  The United States Postal Ser-
vice (USPS) Denver project will reduce its impact
on air emissions in the Denver, Colorado, area by
replacing high-emission vehicles with low-emission
ones.  USPS has  committed to (1) using at least
794 new, alternative fuel vehicles in Denver and
(2) helping support the development of an infra-
structure to support these vehicles. As part of the
Colorado Environmental Leadership Program and
Project XL, USPS will remove 794 delivery ve-
hicles used in Denver and replace them with tran-
sitional low-emitting vehicles (TLEVs). In exchange
forthese commitments, the USPS will receive cred-
its from the State of Colorado that can be used to
satisfy the vehicle purchase  requirements of the
Colorado Clean Fuel Fleet Program (CFFP).

This delivery vehicle replacement project will re-
duce the USPS's contribution to mobile  source
emissions in the Denver area. While  it is  in the
process of redesignating for CAA attainment, the
Denver  metropolitan area is currently  in
nonattainment for CO. The CAA requires states
with ozone and CO nonattainment areas to  revise
their State Implementation Plans  (SIPs) to  incor-
porate a CFFP. Section 246 of the CAA provides
that a SIP submission must require fleet operators
with ten or more vehicles that are or are capable
of being centrally fueled, to include a specified per-
centage of clean-fuel vehicles in their new vehicle
purchases each year. In the Denver area, compli-
ance with the Colorado CFFP requires 50 percent
of the new vehicle purchases to be low-emitting
vehicles (LEVs).

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

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

chase involved TLEVs, which would not meet LEV
requirements. TLEVs are capable of using unleaded
gasoline with up to 85 percent ethanol (E-85) and
meet or exceed California TLEV certification stan-
dards. Flexibility under the Colorado CFFP will al-
low aging postal delivery vehicles to be replaced
with TLEVs. For each E-85 vehicle that the USPS
deploys in Denver, it has agreed to remove either a
pre-1984 route vehicle  or  a  long-life-vehicle
(LLV—1987-1991 vintage)  from service  in the
Denver area. The USPS  project commits  to de-
stroying 512 pre-1984 delivery vehicles and relo-
cating 282 LLVs to other western cities where they
will replace aging fleet vehicles. The destruction
and relocation of vehicles is planned for comple-
tion by July 31,2001. As each of the vehicles to be
scrapped emits approximately  250 pounds more
CO2 per year than an E-85 vehicle, this replace-
ment program is anticipated to significantly de-
crease USPS's  contribution to mobile  source
emissions in the Denver metropolitan area.

USPS has developed technical specifications for
modifying an existing underground storage tank to
properly  house E-85 fuel. This modified under-
ground storage tank will serve as a demonstration
project for public evaluation of alternative fuel stor-

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

Experiment: The Progressive Auto Insurance
(Progressive) project supports a unique voluntary
insurance program that will base automobile insur-
ance rates on specific driving factors such as mile-
age driven, time of day, and geographic location, in
addition to more  customary factors such as age,
sex, and marital status. This new program is made
possible through the use of a global positioning sys-
tem (GPS) device installed in customers' vehicles.
There are plans underway for a number of auto-
mobile manufacturers to incorporate progressive's
technology in their GPS units for new vehicles. The
information recorded by  the device ensures that
the cost of insurance is based on the usage of the
vehicle. The focus of this project is an analytical
study that will determine the extent to which the
Progressive program has an effect on environmental
quality. EPA is interested in determining the de-
gree to which people who sign up for Progressive's
usage-based insurance program reduce their total
driving or their driving during congested periods,
which could result in lower mobile source emis-
sions. According to EPA's Indicators of the Envi-
ronmental Impacts of Transportation report
released in October of 1999, U.S. travel is respon-
sible for a substantial portion of U.S. ozone pre-
cursor emissions (31 percent of VOCs  and  36
percent of NOx), 61 percent of nationwide CO
emissions, and 31 percent of CO2 emissions. Al-
though Progressive is not currently requesting regu-
latory relief, if future analysis shows that the project
is environmentally beneficial, some  alternatives
might be explored that will offer regulatory flexibility.

Anticipated Results:  Progressive's system, which
has already been piloted in Texas, is designed not
only to lower costs for its customers, but also to
encourage positive driving behaviors that may lead
to a reduction in accidents and harmful air emis-
sions. By measuring and integrating factors that
relate to vehicular use into insurance rates, Pro-
gressive is providing its customers with a financial
incentive to drive less and choose alternate forms
of transportation, which could reduce negative en-
vironmental impacts from automobile usage. Thus
far, Progressive has not directly measured the en-

            vironmental impacts of this program. However, if
            consumers respond to the increased per mile costs
            of a usage-based insurance program in the same
            way as they do to the variable costs associated
            with rising  fuel prices, a significant reduction in
            vehicle usage could result.

            The possibility of offering SIP credits in those states
            that enable  this program to move forward is one
            alternative for offering regulatory flexibility in the
            future. In 1997, EPA adopted a policy to allow credit
            in SIPs for Voluntary Mobile Emissions Programs
            designed to reduce emissions. The policy allows 3
            percent of the total reductions needed for attain-
            ment in a local or regional geographic area to be
            from voluntary mobile source reduction programs.

            Transferability Potential: As  the Progressive
            project proceeds, it will analyze the extent to which
            usage-based auto insurance can positively impact
            vehicle miles traveled and associated air quality
            impacts.  This unique approach has already been
            made available in the state of Texas and could ben-
            efit other states concerned with transportation and
            air quality problems. Progressive has taken steps
            to begin pilot programs in the states of Ohio, Illi-
            nois, and California. A potential difficulty involved
            in expanding the program is the limited availability
            and high expense of GPS technology. Facilitating
            the retrofitting of GPS systems in older vehicles to
            enable participation in Progressive's program is
            necessary to  ensure that the benefits extend to
            consumers in all income brackets and that drivers
            of older, more pollution prone vehicles can be re-
            warded for driving less. Expansion of the program
            will also be dependent in part on the insurance regu-
            lations in specific states.

            Partnership for Water  Reclamation and

            The Experiment(s): The  Intel project, an innova-
            tive partnership between the company and the City
            of Chandler, has created opportunities to (1) reuse
            treated city wastewater at the Intel facility for use
            in cooling towers and on landscaping (Figure 2)
            and (2) reclaim rinsewater used during manufac-
            turing processes for reverse  osmosis (RO) treat-
            ment and reinjection into the local aquifer (Figure
            3). Intel needs high-quality water for semiconduc-
tor operations, thus the two water use streams are
not connected and are used in different processes.
City of Chandler-
Ocotillo Wastewater
Facility treats water from
sewage treatment plant
Treated city
_^. wastewater 	
is sent to Intel
Intel Fab- 12
	 ^ cooling tower
and landscaping
Use of Treated City Wastewater: Intel has com-
mitted to voluntarily minimize its consumption of
freshwater by using treated city effluent for con-
sumptive uses of semiconductor manufacturing
cooling tower makeup and landscaping. Intel will
purchase water from the  Ocotillo Management
Group that has been treated by the City of Chan-
dler. Intel's initial goal was to achieve 100 percent
use of treated water by January 1997.
Intel facility
Select streams of
rinse water from
— ^- manufacturing
processes are treated
on site
Water sent to
Chandler RO
— *~ facility for
additional treatment
and aquifer reinjection
Reclamation of City Water: Intel's core manu-
facturing processes need high-quality water, but
Intel has arranged for the treatment of some of the
rinsewater from its manufacturing processes for
reuse or reinjection into the groundwater to help
replenish the local aquifer. The rinse water is first
treated within the facility and is then treated at an
off site facility using RO filtration. The City of
Chandler can either recharge the treated water into
the groundwater to replenish the aquifer or reuse
the water. The city recharges the local aquifer un-
der an Aquifer Protection Permit issued by the State
of Arizona.

Results/Anticipated Outcomes: Although there is
no regulatory requirement or standard to serve as
a baseline, Intel will significantly reduce its fresh-
water demands through its water reclamation and
reuse goals.

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

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

Reclamation of City Water:  The RO filtration
process treats the process rinse water to applicable
drinking water standards before  it is returned to
the local aquifer. Intel's  reclamation results are
shown in Table 20.

As a result of the Intel project commitment to use
treated wastewater from  the City of Chandler's
POTW, the city  received a grant to  study  reuse
options for industrial process water. The study ex-
amined the selective use of manufacturing process
                                       effluent in cooling tower applications and the use
                                       of cooling tower effluent for specific irrigation
                                       needs. The study has led to the development of a
                                       model that portrays the representative  quality of
                                       cooling tower effluent to help determine if it can be
                                       reused in other applications.

                                       Transfer ability: The water conservation partner-
                                       ship between Intel and the City of Chandler pro-
                                       vides an innovative model for arid regions that are
                                       increasingly faced with low groundwater replen-
                                       ishment rates and for areas of where  municipal
                                       water suppliers need to conserve water in both
                                       domestic and non-domestic activities. In Arizona.
                                       the 1980 Groundwater Management Act provided
                                       such a requirement  for the City  of Chandler. As
                                       water cost and scarcity increases, treated effluent
                                       is one "source of water" that is expected to con-
                                       tinue to increase and could provide future  water
                                       supplies through reclamation and reuse.
                          Table  19:  Jntel  Reuse Results
                                  Reuse of Treated City Water
Treated Effluent Reuse Performance Goal
Treated Effluent Reuse Achieved
100 percent use of treated city water for
landscaping and cooling tower uses
Ocotillo facility achieved 80 percent use of
treated effluent. (132 million gallons of water)
 1998     100 percent use of treated city water for
          landscaping and cooling tower uses
                                            Ocotillo facility achieved 97 percent use of
                                            treated effluent (183 million gallons of water)
 1999     * Revised goal to achieve 95 percent use of
          treated city water for landscaping and cooling
          tower uses
                                            Ocotillo facility achieved 98 percent use of
                                            treated effluent (205 million gallons of water)
                              20:  Jntel  Reclamation  Results
                                   Process Water Reclamation
Reuse Performance Goal
Reuse Achieved
 1997     45 percent of the total volume of freshwater
          purchased from the city will be sent to the city's
          effluent treatment plant for recycling
No goal established for 1998
55 percent of the total volume of freshwater
purchased from the city will be sent to the city's
effluent treatment plant for recycling
66 percent of water purchased from the city
was returned for RO treatment and re-injection
into the aquifer (355 million gallons)

61 percent of the water purchased from the city
was returned to the city for treatment
(399 million gallons)
61 percent of the water purchased from the
city has been returned to the city for treatment
(422 million gallons)

            The Intel project also explores the importance of
            tailoring environmental performance to an issue
            relevant to a local community (water conservation)
            and serves as the foundation for a model to iden-
            tify potential  cooperative water conservation
            projects between industries and their neighbors. In
            addition to identifying technical and economic op-
            portunities to conserve and reuse treated water.
            there will be a need to examine any technical and
            economic barriers to reclamation and reuse. Issues
            to further explore include (1) the costs of RO tech-
            nology and the opportunities  as well as costs to
            design systems from the ground up to allow them
            to use treated effluent; (2) the potential cost barri-
            ers of retrofitting facilities to enable them to reuse
            treated effluent; and (3) the potential technical limi-
            tations and high cost of treating and reusing pro-
            cess effluent.  (Cooling towers can experience
            problems with microbial growth and solid precipi-
            tates from treated POTW effluent.)

            Dredged Material Pollution Prevention

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

            EPA and USAGE share responsibility for manag-
            ing  ocean  disposal of dredged materials. Permits
            for disposing dredged material into ocean waters
            are issued by USAGE, subject to EPA concurrence.
            NS  Mayport is currently required to obtain three
permits with three different durations to dredge and
dispose of its maintenance sediment—two permits
from USAGE and one from the State of Florida.
The naval station has sought flexibility to adjust the
lengths of these permits to synchronize their dura-
tion and combine their testing and evaluation re-
quirements. Through Project XL, NS Mayport,
EPA, USAGE, Florida Department of Environmen-
tal Protection, and the City of Jacksonville are cre-
ating a partnership to provide flexibility by
streamlining the dredging and ocean disposal pro-
cess by means of extending the length of one per-
mit to synchronize permit cycles. Anticipated savings
from the streamlining process and the reduction in
paperwork from synchronized or extended permits
will be reinvested into development of the benefi-
cial reuse applications for the dredged material.

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

Initially, the dredged material for construction of
the building blocks and artificial reef material will
be derived from the existing upland storage cells.
During this time, ocean disposal of freshly dredged
material will continue. After these storage cells are
emptied, dredged material will be stored tempo-
rarily in one of the upland storage cells, thereby
eliminating the  need  for ocean disposal. The sec-
ond storage cell  will be used for constructing build-
ing blocks and artificial reef material. By establishing
a procedure and cycle for using the two storage
cells for reuse  projects and temporary  dredged
material storage, NS Mayport anticipates it would
be able to continue to use the cells in perpetuity
without reaching capacity. In addition, NS Mayport
has proposed using excess fly ash from the local
electric authority as a solidification material for the
construction blocks (not for reef material). If fly
ash is not suitable, another solidification agent will
be used in the construction blocks.

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

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

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

                     o I v e. HA e. n t1
            The American public has demanded active involve-
            ment in community decisions that affect their health
            and the quality of their environment. In response.
            EPA is increasing public participation in its pro-
            grams and providing more environmental informa-
            tion to help the public understand critical, and often
            complex, issues. EPA also hosts  forums like the
            National Community Involvement Conference to
            support public participation in environmental issues.
            In addition,  EPA is revising the  regulations that
            guide  public participation efforts and  providing
            models to help staff learn how to get the public
            involved in their work. Project XL is an opportu-
            nity to test new stakeholder involvement ap-
            proaches that give  communities  a clearer, more
            coordinated voice in crafting environmental solu-
                                Stakeholder involvement is one of the eight Project
                                XL selection criteria. Because the projects involve
                                innovative strategies that differ from what would
                                be allowed under regulation, this ensures that the
                                public has ample opportunity to review and influ-
                                ence actions first. However, stakeholder involve-
                                ment in these experiments has also been very
                                challenging. Project XL, as a program, has sought
                                out approaches (through principles, tools, and pro-
                                cesses) that support collaborative working relation-
                                ships  with  project  sponsors,  government
                                representatives, and stakeholders. Table 21 identi-
                                fies these approaches.
                                  2*1   :  StaUeKolder  involvement  Innovations
             Program-wide     Multimedia
 Waste Site
 and Reuse

             Program-wide     Multimedia
             Program-wide     Multimedia
Enhanced Stakeholder Involvement: Unique approach by working
closely with stakeholders to plan the cleanup and determine the
future uses for the contaminated site; to ensure that the site will be
redeveloped for business or commercial use after cleanup.

Stakeholder Involvement in Experimental Projects:  Identifying models for
stakeholder involvement; evaluation of models linking public
participation to environmental decision-making.
                 Multistakeholder Involvement in "Reengineering": Manual for EPA
                 Project XL Teams, Project XL Stakeholder Involvement
                 Guide and Project XL—Best Practices for Proposal Development:
                 Using a corporate sector tool called "work process reengineering" to
                 engage stakeholders in major redesign and restructuring of core
                 program practices.

                 Project XL Stakeholder Involvement Guide: Developing a clear, plain
                 language guide that provides helpful ideas and tools to project
                 sponsors and stakeholders for successful interactions.

                 Capacity and Trustbuilding: Providing technical assistance and
                 professional facilitation to improve trust among stakeholder groups
                 and to build local stakeholder participation.
             12 To avoid duplication, this section does not cover innova-
            tions in other core functions that address stakeholder involve-
            ment issues such as "Internet Reporting and Stakeholder
            Input" (environmental information management and access).

Enhanced Stakeholder Involvement:
Facilitating Site Redevelopment

The Challenge(s): To facilitate the likelihood that
the Fairmont Coke Works Site will be redeveloped
for business or commercial use after cleanup.
ExxonMobil has committed to (1) involve stake-
holders and community groups  in planning the
cleanup and determining future uses for the site.
(2) demolish and dispose of all on-site structures.
and (3) seek interested developers for property re-
development. Public involvement in the traditional
Superfund process can vary from site to site.
ExxonMobil, EPA, and West Virginia DEP have
agreed to go beyond the minimum Superfund com-
munity relations requirements in the National Oil
and Hazardous Substances Pollution Contingency
Plan (NCP) and involve the community through its
representative, the Fairmont Community Liaison
Panel (FCLP), in the planning and implementation
of the site cleanup. ExxonMobil, the state and the
FCLP have resolved to work together to build a
process geared  toward achieving a consensus on
major aspects  of the cleanup and incorporating
potential reuse opportunities into the cleanup

Although commercial redevelopment is typically not
addressed in the Superfund process, the Fairmont
community has expressed a strong interest in re-
developing the site. The site is suitable for redevel-
opment due to its location and size. ExxonMobil,
beyond its statutory responsibility to clean up the
site, has committed to actively seek interested de-
velopers and to facilitate a productive reuse for the
site. To stimulate interest, ExxonMobil has conducted
an extensive on-site building demolition program
that  will enhance the market and redevelopment
potential of the property. On-site building demoli-
tion  is typically required only at Superfund sites
where it has been demonstrated that hazardous
substances are or have the potential to migrate from
such buildings or if the buildings impede a response
action. ExxonMobil is implementing a site-wide
demolition plan to increase the redevelopment po-
tential of the site and provide aesthetic benefits to
the site and the community even if there is no pres-
ence of hazardous substances.
Results/Anticipated Outcomes:  Substantial in-
volvement and support of project stakeholders are
important catalysts in the planning and implemen-
tation of the ExxonMobil project. The project en-
hances community  and other  stakeholder
participation in the Superfund cleanup process by
providing citizen participation in the process through
solicitation of stakeholder input into cleanup alter-
natives and future use  determinations for the site.
Establishment of a community panel along with
routine communications with the project team re-
sulted in consistently supportive local media cover-
age and support from the  community in  project
decisions. This project will also demonstrate how
the consideration of future  uses of a contaminated
site in the early cleanup planning stages can be a
practical and valuable component of the Superfund

ExxonMobil's completion  of an on-site building
demolition and facilitation of redevelopment will
provide additional environmental benefits to the
community not found  in a typical Superfund pro-
cess. ExxonMobil also purchased the site  to help
facilitate development. As property owner and the
party responsible for cleanup, ExxonMobil has con-
trol over redevelopment preparation and final dis-
position of the site. ExxonMobil will provide EPA a
plan that outlines the strategy for facilitating site
redevelopment that goes beyond planning  and as-
sessment  stages.

Transferability: By considering and integrating fu-
ture use opportunities  into  the cleanup plan for a
Superfund site, the ExxonMobil project will serve
as a model for returning Superfund sites back to
productive economic use. The project provides an
opportunity to analyze an atypical approach to
partnering with local community members and other
stakeholders to solicit their input throughout the
process of selecting and implementing a cleanup
remedy and determining future use plans for the
site. For communities  situated near similarly dis-
tressed properties, the ExxonMobil project will ex-
plore the potential to improve the health and
productivity of a local  community by remediating
environmental hazards and allowing those commu-
nities to reclaim distressed properties as valuable
and productive assets.

Stakeholder Involvement in Experimental
Projects: Identifying Basic Models

The Challenge(s):  Since the inception of Project
XL, EPA has stated that meaningful and organized
participation on the part of community and national.
nongovernmental organization representatives is an
important criterion for selecting projects. However.
when Project XL was first announced in 1995, EPA
did not give specific guidelines for the design of the
stakeholder processes. Since the project sponsor,
not EPA, is responsible for initiating and maintain-
ing the stakeholder involvement process for projects,
EPA left the responsibility for creating models that
would meet the stakeholder criterion to those proj ect
sponsors. Though sometimes difficult, the experi-
ences of these early projects proved critical to the
Agency's understanding of the approaches and
resources needed to make the stakeholder process

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

The  first report found that different models of
stakeholder involvement resulted from the original
call from EPA for project sponsors to design pro-
cesses for stakeholder participation.  Specifically,
the report identified two early models used by the
project sponsors: consensus decision making with
stakeholders (used by Intel and Merck) and public
consultation and information sharing (used by
HADCO and Weyerhaeuser).  Weyerhaeuser's
project was rated as most effective by survey re-
spondents; this project used a public consultation
process that relied heavily on longstanding com-
munity-company relationships to establish support
for the regulatory experiment. The HADCO project
was rated least satisfactory on most measures; this
project also used the consultation and information
sharing process. The two projects using consensus
decision-making  processes  were ranked in be-

In the September 1998 evaluation, neither the con-
sensus decision-making model nor the public con-
sultation and information sharing model was clearly
determined to be a superior method of involving
stakeholders in the project development process.
However, the results did show that clarity of struc-
ture and objectives for the process are more im-
portant to success and credibility than the type of
stakeholder involvement process. The processes
that were rated as highly effective, that is, clearly
structured with adequate resources, had a combi-
nation of broad distribution of benefits (financial,
environmental, and public access) among all of the
participants and high individual/organizational sat-
isfaction with the outcome of the negotiation. The
processes with barriers to participation (such as
lack of technical information, unclear objectives,
inadequate resources to participate) were rated less
satisfactory regarding the distribution of benefits
and the outcome. Thus, process satisfaction and
substantive results are closely linked—both are
critical elements of the success of future projects.

The August 2000 evaluation built upon the original
stakeholder evaluation and considered (1) the early
dynamics of stakeholder processes in projects de-
veloping their FPA, (2) stakeholder satisfaction and
effectiveness of stakeholder involvement for
projects that  had recently signed their FPA, and
(3) stakeholder involvement in project implemen-
tation for projects that had signed their FPA at least
one year before the evaluation. The analysis is based
on case studies developed for eight projects. In the
projects analyzed, project sponsors developed stake-
holder models that centered mainly around public
consultation and information. In four projects, spon-
sors engaged stakeholders in some form of joint-
problem solving or consensus, often done in addition
to public consultation and information sharing.
These included Atlantic Steel, ExxonMobil, Intel,
and the national stakeholder process used in New
England Universities Laboratories.  However, of
these, only the Intel project based its stakeholder
process on consensus.

•   Of those interviewed, most stakeholders were
    satisfied with the project outcomes and their
    level of involvement in the stakeholder process
    regardless of the type of process used. In
    projects where interviewees were less satis-
    fied with the stakeholder process, the stake-
    holders' expectations about opportunities to
    participate went  beyond the avenues of par-
    ticipation made available.

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

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

Project XL continues to emphasize the principles
and process by which stakeholder involvement in
projects should be governed, rather than advocat-
ing that projects  use  a single model. By focusing
on principles, the sponsors, as the "managers" of
the process, can tailor the stakeholder involvement
process to reflect the  scope and complexity of the
project. EPA expects  that the design of each stake-
holder process adequately reflect a proper balance
between the  complexity and uncertainty of the
project, the stakeholders' desire to participate and
have  influence over  the project, and the project
sponsors' ability  to direct resources towards stake-
holder process development. This also allows the
stakeholders themselves to have a say in how the
process is structured and conducted.

In addition to emphasizing principles, EPA is be-
ginning to focus on additional resources needed to
better ensure the design of effective stakeholder
processes. The August 2000 evaluation makes clear
that neither project sponsors nor Project XL staff
always have the proper experience to effectively
design or oversee a stakeholder process. In such
instances, project sponsors may design participa-
tion processes that lack clear structure and objec-
tives, are reactive rather than proactive, and do not
allow stakeholders to participate to the extent they
think they should be able. By directing resources
to enable the development of more effective stake-
holder processes, EPA hopes to ensure that in the
future, these pitfalls will be avoided.

Transferability: Project XL's goal is to promote
continuous learning and develop  a more compre-
hensive understanding  of the factors that contrib-
ute to the success of, and that pose challenges to,
involving stakeholders in experimental projects. The
lessons  learned in managing the stakeholder as-
pects of Project XL are increasingly being shared
with other EPA programs and Federal agencies
struggling with similar issues. Most recently, Project
XL's stakeholder involvement guide was highlighted
in EPA's Public  Participation  Policy  Review
Workgroup's Report to the Administrator. The pre-
vious year, Project XL stakeholder involvement
tools and  experiences were discussed at the
President's Council on Environmental Quality's
workshop, "Linking Public  Participation to Envi-
ronmental Decision Making:  An Exploratory Work-
shop." In addition, the program continues to share
information throughout the  network of EPA staff
that have responsibility for various stakeholder in-
volvement efforts.

Multistakeholder Involvement in

The Challenge (s): Based on strong feedback from
Project  XL participants, EPA recognized that it
needed a more user-friendly process that would be
quicker and more cost effective, produce a consis-
tently superior result, and provide more focused
stakeholder involvement and information ex-

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

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

"Business process reengineering as developed by the corpo-
rate sector refers to the major redesign and restructuring of
core business processes.
14The participating organizations were: Citizens for a Clean
Environment; City of Portland, Oregon; Dow Chemical;
Florida Department of Environmental Protection; Environ-
mental Defense Fund; Environmental Law Institute; Massa-
chusetts Department of Environmental Protection; and Union
Carbide. In particular, Union Carbide and Dow Chemical
played a leadership role in describing and helping EPA apply
the reengineering approach.
make all aspects of the Project XL process trans-
parent to all Project XL participants, thus promot-
ing understanding, trust, and realistic commitments
and expectations. These documents include:

•   Project XL Stakeholder Involvement:  A
    Guide for Project Sponsors and Stakehold-
    ers. This provides helpful ideas and tools to
    project sponsors and stakeholders for success-
    ful interactions. (This guide is further described
    in the next section below titled "Guidance for
    Sponsors and Stakeholders.")

•   Manual for EPA Project XL Teams. This in-
    structs EPA on how to build effective internal
    teams to  develop proposals. (This manual  is
    further described as an Project XL innovation
    in the section on the core function of "Agency
    Culture Change.")

•   Project XL:  Best Practices for Proposal De-
    velopment. This helps project  sponsors create
    effective  Project XL proposals. (While very
    important for Project XL, this type of guidance
    is not considered an innovation.)

Transfer ability: The lessons learned  from the
overall reengineering process, as well as the spe-
cific documents produced, are being shared
Agency-wide as part of the Stakeholder Action
Plan. For example, the Manual for EPA Project
XL Teams has been distributed to the Reinvention
Action Council and shared with the state's envi-
ronmental commissioners as  a model of accom-
plishing cross-Agency multimedia decision making.
In order to share the information with Agency pro-
fessionals and stakeholders, the stakeholder guide
is on EPA's Stakeholder Involvement Web site at

Guidance for Sponsors and Stakeholders

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

expected benefits. At least two private surveys of
project sponsors (including project sponsors that
were not successful in gaining FPAs) show that
their Project XL stakeholder involvement with en-
vironmental organizations and community groups
has been beneficial to the companies in the long
run. The results from one study found that the ex-
pense of the stakeholder involvement process is an
average of 20 percent of the total transaction cost
for the  project sponsor—a far smaller proportion
than originally  assumed.15 Still, project sponsors
looked to EPA for improved guidelines to reduce
the early confusion about, and time-consuming na-
ture of, stakeholder involvement procedures.

Another early challenge was that the participation
of national NGOs received mixed reviews from
the other stakeholders. In some projects, the par-
ticipation of the national  NGOs was consistent,
timely, and helped to move the project development
process forward. Local stakeholders often gave
the national environmental NGOs high praise for
being very helpful to local citizens and bringing sub-
stantive expertise to the table  that local citizens
themselves may lack. In other  projects, however,
the participation of the national NGOs was consid-
ered by local citizens to be inconsistent, late, and
difficult to predict. In these cases, the NGOs' ap-
proach was considered "intervention" and discon-
nected from local citizen involvement.

In the April 23, 1997, Federal Register Notice,
Clarifying the XL Process, EPA took steps to ad-
dress these issues for the project sponsors, NGOs,
and local citizens. In particular, EPA defined three
levels of public participation in Project XL16 to bring
uThe Cost of Developing Site-Specific Environmental Regu-
lations: Evidence from EPA's Project XL, Blackman and
Mazurek, Resources for the Future, Discussion Paper 99-35.
April 1999.
16"Direct participants"  are involved  in the day-to-day as-
pects of project negotiations; they influence the design of
projects; and their views strongly influence the details and
development of the project as well as EPA's ultimate decision
to approve or disapprove it. "Commentors" are stakeholders
who have an interest in the project but do not participate in
day-to-day negotiations; EPA requires sponsors to provide
information to potential commentors and create periodic fo-
rums in which they can express their comments. The "general
public" is involved by having clear access to information on
the  development and environmental  results of the project;
EPA expects the project sponsor to arrange public meetings
when the information is available, allowing the public oppor-
tunities to influence decision making.
clarity to the roles of public stakeholders, to move
away from "local citizens versus national environ-
mentalists" clashes, and to enable industry project
sponsors to be more responsive. The Federal Reg-
ister Notice also covered the importance of well-
defined and transparent ground rules.17 However,
while  the  Federal Register Notice helped define
the policy issues, project sponsors and stakehold-
ers still sought clear, plain guidelines that could help
lead them to successful interactions.

Result(s):  A product of the reengineering process,
Project XL Stakeholder Involvement:  A Guide
for  Sponsors and Stakeholders, clarifies roles
and responsibilities of sponsors and stakeholders,
suggests guiding principles, and provides ideas and
tools to help develop, negotiate, and implement suc-
cessful projects. It explains the potential benefits
of stakeholder involvement to the sponsor as well
as to the potential stakeholders. It also explains the
EPA and state government roles in assessing the
stakeholder involvement process.18 Ultimately, the
stakeholder involvement guide provides general in-
formation about the  project development process
and advice to both stakeholders and potential spon-
sors regarding how to determine what type of pro-
cess is appropriate,  stakeholder needs regarding
time commitment and technical assistance, and the
appropriate scope and complexity of the involve-
ment process.
 17Key ground rule topics for consideration include the level
 of the participant's role (advisory, consultative, or decisional)
 and how that input should be expressed (i.e., by consensus or
 majority vote). These topics, as well as other ground rules,
 must be discussed and consented to by the direct partici-

 18While the sponsor has the primary responsibility for the
 stakeholder group, experience shows that in the most suc-
 cessful processes, the sponsor and the stakeholders share in
 the process creation. EPA will participate as a member of the
 overall stakeholder group. This participation is important to
 help  ensure that these processes are transparent; it should
 not be confused with EPA's ultimate role of guaranteeing an
 adequate stakeholder process to meet Project XL's criterion
 for public participation. EPA  also retains the authority to
 approve or disapprove a project—based on how well the
 criteria are met. States also share the ability to veto projects
 that do not meet the criteria. While this authority is not del-
 egated to stakeholder groups,  the views and recommenda-
 tions of direct  participant groups strongly influence the
 decisions of the regulators.

            Transferability:  The Project XL Stakeholder
            Involvement:  A Guide for Project Sponsors and
            Stakeholders is specifically designed to help less
            experienced project sponsors grasp the essential
            principles of designing and managing a stakeholder
            involvement process. Thus, the Guide is featured.
            along with other documents such as the Construc-
            tive Engagement Resource Guide (March 1999).
            in the Agency's Stakeholder Involvement Action
            Plan (December 1998). Similarly, the Guide is
            prominent on the EPA Stakeholder Web site. The
            Web site, a product of the EPA Stakeholder In-
            volvement Action Plan, is designed to share les-
            sons, information,  and tools  on stakeholder
            involvement,  throughout EPA and with external
            stakeholders. The Guide is now being widely used
            by Project XL teams. However, EPA is continuing
            to encourage the other programs to use the Guide
            as a model for initiating stakeholder involvement,
            and will seek to evaluate its usefulness to project
            stakeholders and sponsors, other industry repre-
            sentatives, and EPA staff

            Capacity and Trustbuilding Resources to
            Improve Stakeholder Involvement

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

            Result(s):  EPA  strongly suggests that newly
            formed stakeholder  groups perform a "needs as-
            sessment" to determine whether training or tech-
            nical assistance is needed to ensure interest and
            understanding of all stakeholders in Clarifying the
            XL  Process  and  Project  XL  Stakeholder
            Involvement:  A Guide for Project Sponsors and
            Stakeholders. There  can be a number of means
            for local stakeholders to receive technical assis-
tance. For example, the project sponsor, the state
government, a national environmental organization
or an academic institution might provide technical
information or assistance  to local stakeholders.
However, when these means are not available or
appropriate, EPA has set up a mechanism to pro-
vide task-specific technical assistance to Project
XL stakeholders:  the Institute for Conservation
Leadership, manages this service under a coop-
erative agreement with EPA. This assistance is
available up to $25,000 per project when requested
by the direct participant stakeholder group. This
past year, two stakeholder groups involved in the
International Paper projects (IP-El and IP-PEM)
accessed the technical assistance grants. In addi-
tion, the stakeholder group involved the Andersen
project plans to use the technical assistance grant
once the project is further along in implementation.

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

Transferability: A key action in the Innovations
Task Force Report is to "build leadership capacity
in communities to participate in local environmen-
tal problem solving." EPA will work with the Task
Force to incorporate the  lessons learned from
Project XL regarding how and when  to provide
key resources into the analysis and recommenda-
tions for building local capacity.

A new emphasis on innovation has changed the
way EPA thinks and operates, leading to real envi-
ronmental improvements and real reductions in
costs. Regulatory and enforcement programs are
still at the core of our environmental system, but
innovation has provided new tools to meet future
demands.  The challenge ahead  is to make these
innovative ideas a permanent part of EPA's cul-
ture. Project XL is one venue through which EPA
is learning to change its organizational behavior,
particularly to encourage cross-Agency support for
innovation. Project XL has led to discreet changes
in EPA's planning and  operational procedures.
These changes support EPA's commitment to test
and incorporate innovative solutions to environmen-
tal problems. Table 22 describes the planning and
management innovations that are leading to change
in the Agency's culture.
                            Senior Management Support and Involvement
                            through the Reinvention Action Council

                            The Challenge(s): Each of the projects has  had
                            varying levels of management involvement at dif-
                            ferent junctures in the projects' development and
                            implementation. In fact, EPA found that there were
                            many instances where a lack of senior manage-
                            ment participation in a project hindered or stopped
                            progress. For projects to develop and system
                            change to occur, there is a need for active support
                            from senior Agency management. This support in-
                            cludes personally championing individual projects,
                            empowering Agency staff that participate in nego-
                            tiations, giving clear direction to Project XL teams,
                            and providing resources.

                            Results/Anticipated Outcomes:  In early 1996, EPA
                            established the Reinvention Ombudsmen, later
                            called the Reinvention Action Council (RAC), to
                            assist in reaching the Agency's goal of 50 projects.
                            Chaired by the Associate  Administrator for the
                            Office of Policy,  Economics and Innovation, the
                           2.2.  :  Culture  (Z-\\ancje.  Innovations
 Program wide    Multi-media
 Program wide    Multi-media
 Program wide    Multi-media
 Program wide    Multi-media
              Reinvention Action Council: Build and maintain support,
              empowerment, and accountability for projects and innovations

              ECOS-EPA Innovations Agreement: Expand the potential for state and
              tribal partnerships for innovative projects.

              Cross-Agency Project Teams—the Manual for EPA Project XL Teams:
              Offers a model to guide cross-Agency teams in project planning,
              management, and monitoring.
              Compliance Screening Guidance: Creation of guidelines for Agency
              screening process for regulatory flexibility projects.

            RAC consists of the senior Agency managers
            (Deputy Assistant Administrators and Deputy Re-
            gional Administrators) from each of the Headquar-
            ters and regional offices. Originally, the RAC served
            as a resource to Project XL teams when they faced
            either disagreements or difficult technical, legal, or
            policy issues. Since then, RAC members have com-
            mitted to working directly with Project XL Coordi-
            nators within their offices to support quick decision
            making and ensure that Project XL teams have
            suitable resources. Involving senior managers has
            proven to be effective in identifying and resolving
            problems for Project XL. Building on the Project
            XL experience, in 1997, the Administrator ex-
            panded the RAC responsibilities to support the
            Agency's overall commitment to reinventing envi-
            ronmental protection.

            Transferability: To date, the RAC has taken a
            hard  look at reinvention efforts throughout the
            Agency and has addressed a broad array of rein-
            vention issues including incentives, permitting, and
            environmental management systems and continues
            to set new reinvention priorities. For example, the
            RAC is the key implementing body of the recom-
            mendations from the 1999 EPA Task Force on In-
            novative Approaches. The RAC's expanded
            agenda also calls attention to RAC  endorsement
            of innovations throughout the Agency and ultimately
            serves as encouragement for  staff to experiment.
            The RAC will play a vital role in designing a sys-
            tematic approach for evaluating and adopting new
            ideas and building innovation into the work of the

            Managing Experiments in Partnership with
            State and Tribal Governments

            The Challenge(s): Federal sharing of environmen-
            tal  responsibilities requires that each project have
            the full support of the appropriate state and tribal
            government. In fact, the state or tribal government
            is a signatory to most projects. Within the frame-
            work of Project XL, EPA, states, and tribal gov-
            ernments are innovatively working together through
            uncharted territory. In particular, the challenge of
            developing, refining, and implementing Project XL
            together has magnified EPA-state, as well as state-
            state, similarities, differences, agreements, and dis-
            agreements. States and tribal governments are, and
will continue to be, primary partners with EPA in
both regulating public health and the environment
and designing and applying innovative approaches.
Therefore, it is incumbent that EPA, and state and
tribal governments rectify differences and produce
agreements that satisfy  each  entity. Project XL
serves as a testing ground for managing experi-
ments to the satisfaction of Federal, state, tribal,
and local authorities.

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

Transferability: As Project XL closes in on its 50
project milestone, two things  are clear: (1) EPA
will continue to test innovative ways of achieving
desirable environmental  outcomes that are more
supportive of the marketplace and business needs
than the current system and (2) state and tribal
governments will continue to be partners in achieving
these outcomes. The prominent  role of states  in
the Project XL process, as well as the ECOS In-
novations Agreement, has advanced Federal-state
partnerships in developing and managing innova-
tion strategies for environmental protection. The
experiences of Project XL continue to influence
states as they consider, develop, or expand their
own programs that offer regulatory flexibility  to
facilities or industry sectors. For example, Project
XL is being used as a tool by New Jersey as it
thinks about expanding its regulatory reinvention
program. As the idea of testing tomorrow's solu-

tions today spreads throughout state and tribal gov-
ernments, Project XL will continue to serve as a
viable model. Additionally, in fulfilling the principles
of the Joint State/EPA Agreement to Pursue Regu-
latory Innovation, a number of states have entered
into Memorandums  of Agreement  to pilot and
evaluate innovative environmental regulatory

Effective Cross-Agency Teams for
Multimedia Experimentation

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

Projects require prompt and effective  cooperation
among various EPA  offices in order to properly
address project sponsor proposals. Normally, project
proposals impact multiple Agency functions, so EPA
staff experts are convened who (1)  do not nor-
mally work  together, (2) answer to separate and
independently managed "chains-of-command," and
(3) have different priorities (e.g., responsibilities for
separate statutes and  programs that face very dif-
ferent time,  policy, legislative, and budget con-

Results/Anticipated Outcomes:  To carry out the
Project XL experiments, EPA had to evaluate its
history and effectiveness of working across media
doing a major Project XL reengineering20  effort.

19See Evaluation of Project XL Stakeholder Processes pre-
pared by Resolve, Inc., for EPA (September 1998, EPA-100-
R-98-009) and The Cost of Developing  Site-Specific
Environmental Regulations: Evidence from EPA'sProjectXL,
Blackman and Mazurek,  Resources for the Future, Discus-
sion Paper 99-35, April 1999.
20See page 75 for description of the Project XL reengineering
In order to allow EPA to quickly make decisions
across Program Offices, speak with one voice to
project sponsors, and share a common understand-
ing of the project at hand, EPA created a new para-
digm for Project XL cross-Agency teams. This new
paradigm is defined in the Manual for EPA Project
XL Teams. The Manual has a detailed outline of
the proposal development process, and clarifica-
tion of roles and responsibilities among EPA media
offices, enforcement staff,  and senior managers.
These clarifications are helping new Project XL
teams make decisions faster and communicate with
project sponsors more clearly and decisively. The
Manual also explains that the EPA teams are  re-
quired to have a proj ect schedule for all new proj ects
to help keep the team focused on key milestones
and on track.  In addition, another tool EPA has
designed to assist  each new Project XL team is
the option of having a neutral facilitator kick  off
the proposal development process  and guide  the
EPA staff in  setting the foundation for an open,
productive decision-making process.

These Project XL teams are continuing to make
key decisions in the Project XL process faster. This
is more satisfying to participants both outside and
inside the Agency. For example, involving key
Agency decision makers early in the process and
improving the functioning of the cross-Agency team
has paid off in the complex Atlantic Steel project.
Several of the streamlined techniques were applied
resulting in an agreement on the project's Phase
One signed by the  sponsor and EPA nine months
after initial discussions began—a marked improve-
ment over earlier proposals, some of which lingered
more than 24 months without closure. EPA's track
record for shortening the timeframe involved in
developing agreements after sponsors initially sub-
mit their proposals continues to improve. Examples
of proj ects that have accomplished this in 12 months
or less include Progressive,  Louisville POTW,
Denton POTW, and USPS Denver.

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

            cruing to projects. Ultimately, as part of a sampling
            plan, the information on transaction  costs and
            project benefits for facilities, EPA, and other stake-
            holders will be collected. The sampling plan will
            first focus on the Weyerhaeuser and the NYSDEC
            projects. EPA will use this information to continue
            to improve Project XL and to help design the next
            phase of experimentation in the Agency.

            As EPA continues to test new approaches to solv-
            ing environmental problems, the solutions increas-
            ingly cross traditional media program lines. The
            lessons learned and new tools developed for Project
            XL teams are now widely available for other rein-
            vention initiatives that cross the traditional Agency
            structure and require cross-Agency team building.
            Current and future reinvention efforts can now start
            with a blueprint for avoiding many of the problems
            inherent to cross-Agency team building and use
            tools that focus these new  teams on their  shared
            goal of cleaner, cheaper, and smarter environmen-
            tal protection.

            Compliance Screening for Project XL's
            Voluntary Project Sponsors

            The Challenge (s): Agency guidance on critical
            program components is needed by project spon-
            sors to optimize the effectiveness of the Project
            XL experimental process.  EPA actively encour-
            ages a wide variety of public and private entities to
            participate, but  all project  sponsors must have a
            good history of compliance with EPA regulations.
            A potential sponsor's overall compliance history is
            relevant to ensure the experimental Project XL
            approach will not pose undue risks to human health
            and the environment, and to enable EPA to make
            an informed judgement regarding the likelihood of
            the participants ability to achieve superior environ-
            mental performance.  As the Project XL process
            matured,  compliance screening became more fre-
            quent and time-intensive and the screening process
            continued to lack definition.  Clear compliance
            screening practices and expectations needed to be

            The Result: OECA developed  the Guidance for
            Compliance Screening for Project XL in 1998 to
            standardize and  streamline compliance screening.
            This compliance screen provides the Agency with
useful information on a participant's current com-
pliance status and history. It also provides factors
that could bear on a potential participants eligibility
for Project XL, such as the possibility of a conflict
between  a proposed project and an ongoing en-
forcement effort. The guidance specifies the scope,
criteria, and process for conducting enforcement
screens and indicates that compliance screens will
be updated prior to high-visibility public events.

Transferability: Project XL is one example of a
shift in our national strategy for protecting the en-
vironment. Increasingly, EPA is trying to achieve
its mission through building partnerships with small
and large businesses, citizen groups, state and lo-
cal governments, and institutions. The Project XL
screening guidance is a program-specific applica-
tion of the broader framework, and an example of
a rigorous screening process for a regulatory flex-
ibility program. Project XL has helped lay the
groundwork for testing and establishing guidance
for an increasing number of EPA voluntary pro-
grams requiring compliance screening. In addition
to the Project XL screening guidelines, on April 5,
1999, OECA and the Office of Reinvention issued
the Guidance for Compliance Screening for Vol-
untary Programs, the Agency's comprehensive
screening framework,  applicable to all voluntary
partnership programs.  $


       This section catalogues 23 emerging innovations—promising
       ideas and concepts, that as of November 2000, were in earlier
       stages of exploration. These expected innovations are being
provided here in order that future project sponsors and stakeholders
have a more  complete picture as to the experiments underway. As
these innovations move forward, the Agency will be tracking and as-
sessing the results in future reports.

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

                (Emerging  Innovations  \n  (Sore  functions	
           "Projects  7\)ewly  LAnderway  or  LAnder  Development
               Regulations Permitting   Information  Enforcement  Environmental  Stakeholder Culture
                                      Management  Compliance   Stewardship   Involvement Change
Anne Arundel
Buncombe County
City of Chicago
Clermont County
Crompton TBT
Puget Sound
Fort Worth
IBM Fishkill
Lead Safe Boston

Chicago POTW

New Jersey Gold
Pennsylvania DEP
Port of Houston
United Egg
Virginia Landfills

Yolo County

             "Table  24-:  (Emerging Innovations in  Regulations
 Anne Arundel and Buncombe County —Testing Bioreactor Methods:
 Recirculating Leachate over Alternative Liners
                           Solid Waste
 Autoliv—Enabling Metals Recovery from Pyrotechnic Material
 Chicago Regional Air Quality and Economic Development Project
 IBM Fishkill—Using F006 Wastes as an Ingredient in Cement Production
 Lead Safe Boston—Lead-based Paint Debris Disposal Flexibility
                           Hazardous Waste

                           Hazardous Waste
                           Hazardous Waste
 Chicago POTW—Alternative Effluent Discharge Monitoring
 NBC POTW—Enhancing the Metal Finishing 2000 Program
 US Filter—Encouraging Metals Recycling and Recovery
                           Hazardous Waste
 Virginia Landfills—Testing the Bioreactor Methods: Comparing a Leachate           Solid Waste
 Recirculation System to the Introduction of Additional Liquid Amendments
 in Sanitary Landfills

 Yolo County—Testing a Bioreactor Method: Aerobic versus Anaerobic Technology    Solid Waste
Anne Arundel and Buncombe County—Test-
ing  Bioreactor  Methods: Recirculating
Leachate over Alternative Liners. Both Anne
Arundel County in Maryland and Buncombe
County in North Carolina are seeking flexibility to
recirculate leachate and/or gas condensate over
an alternate composite liner and collection system
not constructed as prescribed in the Resource Con-
servation  and Recovery Act (RCRA). Anne
Arundel County is interested in effectively increas-
ing its landfill waste capacity while decreasing the
concentration of leachate and reducing the amount
of leachate requiring pretreatment and being dis-
charged to the local wastewater treatment plant.
After design and construction of a small bioreactor
test area, liquid will be injected over a four- to
seven-year period through injection devices. To
improve the evaluation of different infiltration sys-
tems, the test area will contain both vertical injec-
tion wells and horizontal  injection trenches.
Settlement resulting from accelerated waste de-
composition will  be monitored using settlement

For its project, Buncombe County is looking to im-
prove leachate  quality and accelerate waste de-
composition and landfill gas generation.  Re-
circulating leachate over a specific section of its
landfill will accelerate decomposition of its waste
and shift that waste to a more benign state. More
rapid decomposition will also compress the time
landfill gas is generated, reducing emissions and
making gas recovery more efficient. To measure
how this alternative approach can provide superior
environmental performance, the county would pro-
vide a baseline estimate of current conventional
sanitary landfill maintenance. It is anticipated that
the county will quantify the benefits of the project
against this established baseline.

Autoliv—Enabling Metals Recovery from
Pyrotechnic Material. Autoliv ASP  (Autoliv)
manufacturers automobile safety products, includ-
ing the pyrotechnic (explosive) materials used to
deploy air bag inflators. During the manufacturing
of these materials, reactive hazardous wastes are
generated. These wastes are  presently treated off
site at a  RCRA  permitted treatment storage and
disposal  facility (TSDF) that accepts hazardous
waste from outside sources and treats it via open
burning.  Autoliv currently operates a highly  ad-
vanced metals recovery facility (MRF) designed
to process and recover aluminum and steel from
unfired air bag inflator units as well as previously

            fired inflator units. The MRF has an extensive air
            pollution control train that is capable of capturing
            emissions produced by the waste pyrotechnic ma-
            terial.  Autoliv proposes that the technology and
            pollution control devices used in the MRF be
            adapted to process their waste pyrotechnic mate-
            rials on-site rather than sending  the materials off-
            site to a TSDF for open burning. Autoliv is seeking
            permitting flexibility under  RCRA to be  able to
            modify their MRF operations and effectively treat
            and dispose of this pyrotechnic material.

            Chicago Regional  Air Quality and Economic
            Development Project. The City of Chicago's
            Department of Environment is seeking to exercise
            a seldom used section [Section 173(a)(l)(B)] of
            the Clean Air Act (CAA) that will create innova-
            tive criteria to promote clean air and economic de-
            velopment in urban areas. Section 173(a)(l)(B)
            allows the EPA Administrator, in consultation with
            the Secretary of Housing and Urban Development.
            to identify zones in which economic development
            should be targeted.  Chicago has dubbed such ar-
            eas "development zones." A development zone
            would generally be defined as an area that needs
            economic development and that advances environ-
            mental improvements, particularly concerning clean
            air. Chicago, U.S. EPA,  and  Illinois EPA will de-
            velop criteria that an area must meet to be desig-
            nated as  a development zone. Under this
            livability-focused proj ect, a new or modified maj or
            stationary source (facility) that locates in a devel-
            opment  zone  (within  the  Chicago  CAA
            nonattainment area) would draw emission reduc-
            tions from a growth allowance generated from the
            state's emission inventory—a structure to be ap-
            proved by the U.S. EPA and Illinois EPA. This
            growth allowance would be used in lieu of obtain-
            ing emission offsets required under CAA—New
            Source Review. The growth allowance would be
            created using emissions reductions generated by
            Chicago and other  municipalities and would be
            made available to companies who locate in the de-
            velopment zones.

            IBM Fishkill—Using F006 Wastes as  an In-
            gredient in Cement Production.  The IBM
            Fishkill project proposal will help examine the need
            for RCRA regulation of a subset of recycling sce-
            narios involving the production of products used on
the land. Through Project XL, IBM Fishkill is seek-
ing an exclusion for the use of the electroplating
wastewater treatment sludge (i.e., F006) as an in-
gredient in the production of cement. Under cur-
rent regulations there is an exclusion for hazardous
secondary materials  that are properly  recycled
through use as an ingredient to produce a product.
However, this exclusion is not available if the prod-
uct being produced is to be used on the land (or
burned for energy recovery). Therefore, even
though the sludge can be recycled as an ingredient
in cement (F006 typically has high concentrations
of calcium, needed in producing cement), it remains
subject to full RCRA regulation, including storage
permits and hazardous waste manifests.

Lead Safe Boston—Lead-based Paint Debris
Disposal Flexibility. Lead Safe Boston is  seek-
ing to allow less expensive handling and disposal of
lead-based paint (LBP) architectural debris from
residential units. The Lead Safe Boston program
currently requires toxicity characteristic leaching
procedure (TCLP) lead testing on architectural
debris before disposal for all projects in accordance
with Massachusetts and EPA regulations. The re-
sults of this analysis determines if waste is to be
classified and disposed of as hazardous or non-haz-
ardous. When lead waste exceeds EPA  limits of
toxicity for disposal as construction debris, it is dis-
posed of as hazardous waste. Disposal for classi-
fied hazardous waste is costly. TCLP testing can
be costly and time consuming as well. Lead Safe
Boston is seeking the flexibility to use provisions of
the RCRA Household Hazardous Waste Exclusion
(HWE) rule for LBP debris. This exclusion would
allow household LBP debris to be disposed of in a
municipal solid waste landfill that meet certain mini-
mum criteria for liners, leachate collection, and
groundwater monitoring. Anticipated cost savings
from the flexibility (270 percent reduction in aver-
age disposal costs per project) would enable Lead
Safe Boston to remove lead from an additional 12
residential units.

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

oversight requirements (i.e., inspection and sam-
pling)  of the General Pretreatment Regulations
pertaining to discharges from small (de minimus)
categorical industrial users (CIUs) into the Chicago
POTW's water reclamation plants. The Chicago
POTW project will test several ideas.  First, Chi-
cago POTW has proposed a new definition of "de
minimus"  significant industrial user (SIU), using
criteria specific to their location. Second, Chicago
POTW, with EPA and Illinois  EPA, will develop
Toxic Reduction Action Plans to identify priority
pollutants  that are present in quantities that may
pose an environmental risk but are not currently
subject to regulation. Third, Chicago POTW would
like to build on its experiences with the Common
Sense Initiative's21 Strategic Goals Program (SGP)
to create  strategic performance  partnerships
(partnerships) with metal-finishing facilities that fully
achieve the individual facility goals outlined in the
SGP. Under these partnerships, Chicago POTW
will work cooperatively with demonstrated sector
leaders to develop, test, and implement an alterna-
tive measurement system for demonstrating envi-
ronmental   performance.   Under   current
pretreatment regulations, SIUs must conduct self-
monitoring according to EPA sampling protocols,
typically involving "end-of-pipe" sampling of efflu-
ent. Possible alternative monitoring in the Chicago
project would use statistical process control data
collected by the SIU that would provide more pre-
cise performance and product quality data than tra-
ditional monitoring data.

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

21EPA launched the Common Sense Initiative in 1994 with
the broad purpose of seeking "cleaner, cheaper, and smarter"
sector-based approaches to protecting human health and the
environment, and has been a primary component of EPA's
regulatory reinvention efforts.
test new approaches to improve environmental
compliance by the local industrial community. Spe-
cifically, NBC POTW proposal asks for the flex-
ibility to reduce self-monitoring requirements and
inspections for top performing industrial users (lUs)
so staff can focus on problem lUs. Problem lUs
would be identified and given increased oversight
in addition to pollution prevention technical assis-
tance. This project would define quantitative per-
formance criteria for NBC POTW's metal finishing
facilities and measure the effect of this new ap-
proach using performance indicators. To implement
the project, NBC POTW is seeking regulatory flex-
ibility that will allow them to (1) replace categori-
cal and mass-based standards with more stringent
local limits specifically designed to protect the fa-
cilities'  operations and (2) eliminate  certain cat-
egorical monitoring requirements for pollutants not
present based on a facility's non-use of certain raw

USFilter—Encouraging Metals Recycling and
Recovery. US Filter Recovery Services (US Fil-
ter), a fully permitted hazardous  waste  treatment
and storage facility in Roseville, Minnesota, is pro-
posing to install its resin regeneration  system in
customer businesses—such as metal  finishers or
printed circuit board manufacturers—that totally
deionizes rinse waters containing F006 wastes,
making it available for reuse. Rather than sending
rinse waters to local POTWs, USFilter's custom-
ers would increase recycling, promote  recovery,
conserve water, and reduce the use of hazardous
chemicals. The resin regeneration system consists
of ion exchange canisters that USFilter  would in-
stall on customer's process lines that contain waste-
waters. Once diverted into the canisters, the metals
in the wastewater will adhere to the resin material
in the canister, rendering the water free of metal
contaminants. The water can then be reused in the
customer's process lines. Once the resins are spent,
these canisters can be  replaced by US Filter, who
then regenerates the resins. This potentially allows
the metals to be reclaimed rather than  land dis-
posed. Excluding ion exchange canisters from some
or all RCRA hazardous waste requirements could
promote improved electroplating sludge manage-
ment. In place of existing RCRA regulatory re-
quirements, the USFilter proposal asks participants
to manage  the  F006 (electroplating sludge)

            wastestreams in accordance with alternative man-
            agement requirements.

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

            Yolo County—Testing a Bioreactor Method:
            Aerobic versus Anaerobic Technology. The
            Yolo County Bioreactor Landfill (Yolo County), lo-
            cated in California, will operate  its next landfill
            module as  a controlled bioreactor landfill. To do
            this, Yolo County is seeking flexibility from RCRA
            restrictions that preclude the addition of bulk or non-
            containerized liquid amendments (graywater, sep-
            tic water)  to landfills. The bioreactor method
            accelerates waste decomposition and leachate
            treatment via the addition  of liquid amendments
            through a network serving the waste  mass. This
            process is designed to accomplish a more rapid
            completion of composting, waste stabilization, and
            methane generation than in a conventional landfill.
            The Yolo County proposal plans to physically sub-
            divide the landfill module and operate it as both an
            anaerobic  and  aerobic bioreactor. The aerobic
            bioreactor differs  from an anaerobic one in being a
            process of "landfill-based composting." For the
            aerobic half of the module,  atmospheric air will be
            delivered to the waste in addition to liquid. This air
            will in effect dry out the waste mass. The amount
of liquid added to the aerobic part of the module
will then be increased to accommodate any drying
effects. The aerobic bioreactor will  not create
methane but will degrade significant waste frac-
tions such as lignin and leachate chemical oxygen
demand (COD) components.

                      25:  (Emerging  Innovations \n  Permitting
 Pennsylvania DEP—Investigating an Alternative Approach to Promoting            Water
 Coal Remining

 United Egg Producers—Environmental Management Systems/Third-Party          Water
Pennsylvania DEP—Investigating an Alterna-
tive Approach to Promoting Coal Remining.
The Pennsylvania Department of Environmental
Protection (Pennsylvania DEP) is exploring an al-
ternative approach to improve  overall in-stream
water quality by reducing mine drainage and re-
claiming scarred lands resulting from abandoned
coal mines in Pennsylvania. Pennsylvania DEP will
develop a new approach to promoting coal remining
based on compliance with best management prac-
tices (BMPs) instead of National Pollutant Dis-
charge Elimination System (NPDES) numeric
effluent limitations. The CWA NPDES permits for
remining currently establish site-specific numeric
effluent limitations representing best available tech-
nology. To implement its alternative permit ap-
proach,  Pennsylvania  DEP is exercising
enforcement discretion to provide that reminors may
comply with non-numeric limitations in the form of
specific BMPs as well as in-stream monitoring re-
quirements to measure the performance of
remediation activities on in-stream water quality.

United Egg Producers—Environmental Man-
agement Systems/Third-Party  Certification.
The United Egg Producers (UEP), a farmer coop-
erative representing egg producers nationwide, is
seeking the capability to operate under a statewide
permit rather than a facility specific NPDES per-
mit as required under the CWA. A significant por-
tion of the farms that the  UEP  represents are
classified as Concentrated Animal Feeding Opera-
tions (CAFO), which must obtain individual NPDES
permits for their activities. If these farms were al-
lowed to operate under a statewide general permit,
it would significantly reduce compliance costs for
these UEP farms. In exchange for the reducing
the permitting burden, these UEP farms would
achieve "zero discharge" status through the devel-
opment of a comprehensive environmental man-
agement system (EMS). Furthermore, UEP pro-
poses to establish an EPA-approved third-party
certification program that would be required to
verify individual EMS's and the zero discharge sta-
tus among CAFO operations. This  new stream-
lined permitting would alleviate the pressure on
states to perform inspections on the  egg industry,
expedite the permitting process for egg producing
facilities, help ensure continuing compliance, and
achieve superior environmental performance.

                      26: (Snj-orcement  and (Sompliance Assurance Innovations
             Puget Sound—Integrated Marine Environmental Compliance Program
             New Jersey Gold Track—Performance-based Approaches to Environmental
             Port of Houston Authority—Port/Tenant Environmental Management Programs
            Puget Sound—Integrated Marine Environ-
            mental Compliance Program. Using the Project
            XL/ENVVEST process, the Puget Sound Naval
            Shipyard (Puget Sound) in Bremerton, Washing-
            ton, is proposing to develop and demonstrate an
            alternative, long-term, cost-effective strategy for
            protecting and improving the health of Sinclair In-
            let. The Puget Sound project is intended to achieve
            its objectives through the use of sound ecological
            science and risk  based management, employing
            approaches consistent with the draft EPA Ecologi-
            cal Risk Assessment Guidelines. It will demonstrate
            concepts  currently under  development for naval
            shipyards by marine scientists at the Naval Com-
            mand, Control, and  Ocean Surveillance  Center.
            While retaining Puget Sound's existing pollution
            control baselines as the floor, existing permits would
            be revised to replace traditional narrowly focused
            monitoring, compliance, and reporting requirements
            with innovative monitoring programs and pollution
            prevention measures that are anticipated to achieve
            better environmental results.

            New Jersey Gold Track—Performance-based
            Approaches  to Environmental Management.
            The New Jersey Department of Environmental
            Protection (New Jersey DEP) envisions the Gold
            Track as a multimedia program that will move away
            from a front-end review and approval process to-
            ward back-end monitoring while tracking and main-
            taining a cost-effective high level of public health
            and environmental protection. Gold Track is as an
            enhancement of the state's Silver Track Program,
            New Jersey DEP's first step toward implementing
            a regulatory structure that is accountable, measures
            environmental performance and provides opera-
            tional flexibility. The premise of Gold Track is that
            different levels of environmental performance war-
            rant varying degrees of regulatory oversight and
            flexibility. The Program is being designed to re-
quire increased levels of commitment in return for
increased regulatory flexibility for qualifying enti-
ties based upon their demonstrated capability and
environmental performance. The New Jersey Gold
Track proposal plans to use media-specific addenda
to define specific state and Federal flexibilities to
be granted to program participants. Each adden-
dum would be negotiated separately—the first ad-
dendum for the project would be air specific—and
would define flexibility granted, superior environ-
mental performance gained, and the evaluation pro-
cess used to judge the effectiveness and benefits
of the flexibility.

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

"Table  27:  (Emer
                                             s  \n  (3-nv\ rcmmental  StewardsKi p
 Clermont County—Community-based Watershed Protection
 Columbus—Enhancing a Local Lead Hazard Program
 Crompton TBT—Flexibility in the Tributyltin Monitoring Program
                                                 Hazardous Waste
 Kodak and PPG—Pollution Prevention Assessment Framework (Developing         Hazardous Waste
 Environmentally Preferable Products In the Chemical Industry Through Technology
 Fort Worth—Proactive Demolition of Structures Containing Asbestos
 Labs21—Increased Efficiency in Lab Operations
 Ortho-McNeil Pharmaceutical—Catalytic Oxidation of "Mixed Waste"
                                                 Hazardous Waste
Clermont  County XLC—Community-based
Watershed Protection. Clermont County, Ohio.
(Clermont County) is developing a community-de-
signed watershed management plan consistent with
its goals of improving water quality in the Little
Miami River Watershed while maintaining oppor-
tunities for economic growth. To improve water
quality and encourage all polluters to share in the
necessary expense, Clermont County seeks to de-
velop and apply locally developed water quality stan-
dards that are based on local environmental
conditions while employing a collaborative goal set-
ting  approach for managing its resources. This
project will develop an environmental protection
plan to integrate Clermont County's watershed
management plan into a broader state plan admin-
istered by the Ohio Environmental Protection
Agency (OEPA). Clermont County will develop a
sampling and monitoring program and a computer-
based watershed model as part of its watershed
management plan. Sampling and monitoring will
allow the compilation of data on existing environ-
mental conditions in the watershed and help assess
the effects of point and non-point source pollution.
Computer modeling will enable predictions of the
impact land management policies will have on the
watershed. As an incentive to encourage non-point
source reductions, Clermont County's watershed
management plan could use an effluent trading sys-
tem in which pollution credits may be exchanged
among point and non-point source polluters.
Clermont County  is seeking flexiblity  under the
                       NPDES permit system to provide time to study and
                       analyze watershed conditions in order to prepare
                       the watershed management plan. Flexibility may
                       also be needed in considering the development of a
                       point/non-point effluent trading system.

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

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

            Kodak and PPG —The Pollution Prevention
            Assessment  Framework (Developing  Envi-
            ronmentally  Preferable Products in the Chemi-
            cal Industry Through Technology Transfer).
            Eastman Kodak (Kodak) and PPG Industries
            (PPG) are applying the EPA Pollution Prevention
            Framework (Framework) to design and develop
            new chemicals. Use of the Framework can yield
            safer  new chemicals, stimulate reformulation of
            existing products, and reduce generation of haz-
            ardous wastes.  The Framework is a set of com-
            puter models,  developed by EPA's Office of
            Prevention, Pesticides, and Toxic Substances, that
predicts risk related properties of chemicals where
data are limited. The models derive risk informa-
tion based on chemical structure to promote pollu-
tion prevention and improve product design and
stewardship. The Framework can be used to esti-
mate physical-chemical properties, environmental
fate, and hazard to humans and aquatic life. Use of
the Framework will enable the companies to sub-
mit chemicals that are on average less toxic than
those from  a development cycle with  no assess-
ment feature. Both Kodak and PPG XL projects
involve the use  of this chemical risk screening early
in the product development cycle. Kodak and PPG
are seeking regulatory flexibility under the
premanufacture notice (PMN) provisions of the
Toxic Substances Control Act (TSCA). Under
Project XL, Kodak and PPG will be allowed  to
manufacture PMN chemicals in 45 days, rather
than after 90 days as is currently required under
the TSCA. This flexibility will apply only to lower
risk chemicals  that will generally have been as-
sessed by EPA within 25 to 28 days.  Both PPG
and Kodak will disseminate information about the
Framework to  other chemical companies and in-
dustries. PPG will publish a validation study to verify
the accuracy  of selected Framework models.
Kodak will complete an environmental  cost ac-
counting study  that will describe the economic and
business benefits that result from use of the Frame-
work. Kodak will also complete a study identifying
management practices that facilitate pollution pre-
vention outcomes.

Fort Worth, Texas—Proactive Demolition  of
Structures Containing Asbestos. The City  of
Fort Worth's  proposal features an alternative
method for the demolition of structures that have
asbestos-containing building materials (ACBM) but
that are not in danger of imminent collapse. Essen-
tially, Fort Worth is seeking the regulatory flexibil-
ity to demolish  substandard structures not in danger
of imminent collapse similar to the shortened pro-
cedure that exists for structures that are in immi-
nent danger of collapse. In place of the current
CAA National  Emission Standards for Hazardous
Air Pollutant (NESHAP) requirements for the regu-
lated asbestos-containing materials (RACM)  in
structures, Fort Worth would test its own process
for managing HAPs.  This "Fort Worth" method
integrates "wet" demolition methods, air monitor-

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

Labs21—Increased Efficiency in  Lab Opera-
tions: The Labs21 proposal endeavors to encour-
age laboratory owners, operators, and designers to
improve their energy efficiency and water conser-
vation with  a new laboratory management ap-
proach. This agreement would function as an
umbrella final project agreement (FPA), and does
not describe  any specific federal regulatory flex-
ibility. These flexibilities would be agreed upon at a
later date and would attain measurable superior en-
vironmental performance beyond what is achieved
by labs under current federal and state regulatory
systems.  Using the Labs21 approach, EPA and
DOE estimate that laboratories can decrease en-
ergy consumption by 60 to 75 percent. EPA has
applied the Labs21 approach to an existing EPA
laboratory and expects to reduce its annual elec-
tric demand by 68 percent and its utility costs by
almost 75 percent. Assuming that only 25  percent
of U.S. laboratories achieve a 60 percent reduc-
tion in energy consumption, the United States would
reduce its annual energy consumption by an amount
equivalent to the yearly energy consumption of
840,000 U.S. households and save  $1.25 billion
dollars. In the future, as laboratory energy efficiency
improves, Labs21 will focus on even more aggres-
sive pollution prevention goals and strategies unique
to each type  of laboratory.

Ortho-McNeil  Pharmaceutical—Catalytic
Oxidation of "Mixed Waste." Ortho-McNeil
Pharmaceutical (OMP),  in conjunction with the
R.W. Johnson Pharmaceutical Research Institute
(PRI), uses radio-labeled compounds for pharma-
ceutical research and development. This manufac-
turing process yields a waste solution containing
both radioactive material and an organic compound,
which constitutes a low-level "mixed waste" un-
der RCRA. Ortho-McNeil is proposing to use an
on-site bench-top catalytic oxidation  process to
treat the mixed waste, which would use a more
efficient, environmentally safe process as compared
with current off-site waste management and dis-
posal practices. The oxidation treatment process
destroys the hazardous organic component of the
mixed waste, transforming it into a relatively in-
nocuous low-level radioactive waste that is easily
stabilized. This oxidation process meets the RCRA
definition of "treatment," requiring a TSDF permit
under RCRA. To use catalytic oxidation as an on-
site treatment alternative, EPA will grant OMP and
PRI a conditional exclusion from the RCRA  haz-
ardous waste definition for the organic component
of its process waste solution.

            28:  Jnj~ormation ./Management and Access  Innovations
 NASA—Realtime Web-based Information Management
NASA—Real-time Web-based Information
Management. The National  Aeronautics and
Space Administration (NASA)  White Sands Test
Facility proposes to implement an extensive Web-
based information management and regulatory re-
porting system that will provide EPA and multiple
state agencies from New Mexico real-time access
to reports and information. This system will save
resources, including document preparation time.
white paper usage, and triplicate reproduction re-
quirements. A Web-based system will have sev-
eral benefits over the existing reporting system
which is largely paper-based. Web-based informa-
tion management will provide more real-time, user
friendly data. This will enhance communications
with other agencies by providing immediate access
to detailed environmental compliance information
including graphical illustrations of current conditions,
access  to the groundwater  monitoring database
system, and an electronic archival of historical docu-
mentation.  In turn, NASA seeks regulatory flex-
ibility from certain reporting requirements specified
in site-specific regulatory documentation and per-
mits. The information contained in the NASA Web-
based system would be sufficient to satisfy current
regulatory requirements; only the format, delivery
method,  and data archival procedures would be
modified. $

With experiments now underway, we are carefully watching the re-
sults. This is an important step if we are to progress toward our ulti-
mate goal—scaling up successful concepts and approaches for broader
application. We know that in order for these experiments to realize
their true potential, we must use what we learn to make improvements
in our national programs. In some cases, existing policies and regula-
tions may have to be adapted to reflect more up-to-date knowledge
and technology.
        As highlighted in "Learning From Experiments," some innova-
        tions are already being adopted into our system of environ-
        mental protection for everyone's benefit. Some innovations
are still emerging, yet throughout the process for developing these
experiments, even projects that are very early in the implementation
stages have highlighted opportunities for EPA to adopt fresh, transfor-
mational strategies for achieving cleaner, cheaper and smarter solu-
tions to environmental problems.
Throughout the experimentation process, EPA remains committed to
the basic principles of Project XL. Some projects last for several years,
so EPA will remain engaged with project sponsors to track the evolu-
tion of innovations and gauge the actual environmental performance
against expected outcomes. Experiments must show  superior envi-
ronmental performance and meaningful involvement of interested par-
ties and they must be transferable to other facilities, processes or
technologies. Early Project XL results  indicate that  we can create
better environmental outcomes when all affected parties work together
toward a common goal.

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

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

            EPA plans to explore the application of this theory
            of the innovation process, as well as related theo-
            ries and processes  in an effort to continue building
            our system of innovation for Project XL. This im-
            portant phase of Project XL coincides with a
            Agency-wide effort to learn from this and other
            innovation efforts how to best infuse  the regula-
            tory climate with processes that will address con-
            stantly changing conditions — environmental,
            technical, socioeconomic, and political — through
            new, creative solutions.
            As a vehicle for testing new ideas in environmen-
            tal protection, Project XL is unprecedented. Pre-
            dictably for an experimental program, it has not
            been without some conflict and controversy. But it
            also has yielded important discoveries and insights
            about ways to improve environmental results. Of
            22 Everett M. Rogers. Diffusion of Innovations, 4th Edition,
            New York: The Free Press, 1995.
the many lessons EPA has learned from this unique
program, some of the most important are:

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

    Some businesses and communities are not only
    willing, but eager, to take greater responsibility
    for environmental results if they are given flex-
    ibility in meeting the goals.

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

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

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

We believe that the type of experimentation allowed
under Project XL is fundamental to continued ad-
vances in environmental protection. Indeed, we
believe that sustaining our strong national legacy
of environmental progress depends on innovation—
at EPA, in state environmental programs, in local
governments, in businesses, in communities—in all
parts of our society.  That  is why EPA launched
Project XL, and it is why we will continue support-

ing and encouraging the search to diversify our
environmental protection tools, identify new ap-
proaches, learn about the  keys to their effective
use, and match the right tools to the right problems.

The future will undoubtedly raise new challenging
issues, but we are better prepared than ever to re-
spond. With the results of the full array of projects
at hand, along with the results from the Agency's
other innovative efforts, the greatest challenge will
be selecting among all the available options to de-
sign the most effective  response to existing and
emerging environmental problems. In some cases,
existing laws and regulations will continue to be
the best way to reduce risk. But better results at
lower costs may be realized by applying tailored
strategies that involve pollution prevention, maxi-
mizing the use of new technology, site specific re-
investment, new reporting alternatives, livability and
smart  growth strategies,  and other incentives.
Through Project XL and EPA's other innovative
efforts we will  meet the challenges of tomorrow
by finding, testing and adopting cleaner, cheaper
and smarter environmental management strategies
today.  '£


for mail orv   Sources
      This report relies on the cumulative information from a number of
      sources. The sections below describes these sources with brief de-
      scriptions of the methodologies involved in developing them.
      Sponsor's   Reports

            Project sponsors prepare quarterly, midyear, or annual reports
            as required by the individual project final project agreements
            (FPAs). For more information on these reports, please visit
      EPA's  Project XL Web  site at http://www.epa.gov/ProjectXL.
                  Progress  Reports

      Progress reports completed in March and December 1999 provide an
      overview of the status of projects implementing final project agree-
      ments for one year or more. These reports are developed by EPA
      with the assistance of the project sponsors and co-regulators; and the
      stakeholders who are direct participants in the projects have the op-
      portunity to review them. The progress reports include (1)  a back-
      ground section briefly describing the facility's project and anticipated
      environmental benefits, (2) a description of the regulatory flexibility
      offered by EPA and other regulatory agencies, (3) a summary of inno-
      vations and potential system change, (4) the status of commitments
      made by the facility, (5) a review of the progress in  environmental
      performance, (6) a summary of the stakeholder involvement for the
      project, (7) names and organizations of the project contacts, and (8) a
      six-month outlook section. These progress reports are available on the
      Internet via EPA's Project XL Web site at http://www.epa.gov/
      Project  T^ocus   (groups

      EPA conducted focus groups in December 1998, January 1999, and
      January 2000 for various projects. Focus group participants included
      company employees, co-regulator representatives (typically state and
      local governments), citizen and non-government organization stake-
      holders, and EPA Headquarters and regional staff. Project-specific
      protocols were distributed to participants prior to each focus group
      conference call. During the focus groups, participants gave opinions
      on (1) the ease and effectiveness of the project implementation pro-

            cess, (2) the value of the project to their organiza-
            tion, and (3) the opportunities to apply information
            gained from the projects more broadly. These are
            part of an annual  program evaluation cycle for
            Project XL and serve as an opportunity for project
            participants to  provide feedback to EPA on any
            aspect of their experience in developing and imple-
            menting a project.  A list of the focus groups and
            their participants are in Volume 2:  Directory of
            Project Experiments and Results.
            In September 1998, a report entitled Evaluation
            of Project XL Stakeholder Processes (EPA-100-
            R-98-009) was prepared by Resolve, Inc. This re-
            port provided a review of the design and conduct
            of the stakeholder processes at four of the initial
            projects (Intel, Weyerhaeuser, HADCO, Merck).
            The report described the involvement of stakehold-
            ers in FPA negotiation and implementation, with
            information on national and local stakeholder per-
            spectives about their role. It also outlined the vari-
            ous models developed by company sponsors and
            reported stakeholder perspectives on the processes
            as gathered in a stakeholder  survey.

            In 1999, EPA initiated a second extensive evalua-
            tion, which was conducted by the Southeast Nego-
            tiation  Network. Project XL  Stakeholder
            Involvement Evaluation (August 2000) covers
            eight projects in various stages  of negotiation or
            implementation  (Andersen,  Atlantic Steel,
            Crompton, ExxonMobil, HADCO, Intel, New En-
            gland Universities Laboratories, and Vandenberg
            AFB). It considers the early dynamics  of stake-
            holder processes in projects developing their FPA,
            stakeholder satisfaction and effectiveness of in-
            volvement for projects that had recently signed their
            agreements, and the status of ongoing involvement
            in projects that have been underway for at least
            one year.
The Project XL Preliminary Status Report (Sep-
tember 1998) examined three projects in implemen-
tation for at least a year as of January 1998: Berry.
Intel, and Weyerhaeuser. The report covers the
projects' initial results on innovation and system
change, as well as progress in meeting FPA com-
mitments, stakeholder participation outcomes, en-
vironmental performance, and lessons learned.

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

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

Aerobic: Life or processes that require, or are not de-
stroyed by, the presence of oxygen. (See: anaerobic.)

Aluminum Chemical Vapor Deposition Process:  A dry
process used for the current generation semiconductor
device technologies. Vapor deposition technologies in-
clude processes that put materials into a vapor state via
condensation, chemical reaction, or conversion.

Anaerobic:  A life or process that occurs in, or is not
destroyed by, the absence of oxygen.

Area of Contamination (AOC): A non-discrete land
area on which there is generally dispersed contamina-
tion. Generally, for contaminated soil, considered are
sampling locations that indicate observed contamina-
tion and the area lying between such locations to be an
area of observed contamination. Asphalt or other im-
penetrable materials contaminated by site-related haz-
ardous substances may be considered areas of observed

Asbestos-Containing Waste Materials (ACWM):  Mill
tailings or any waste that contains commercial asbes-
tos and is generated by  a source covered by the Clean
Air Act Asbestos NESHAPS.

Attainment Area:  A designated geographic area con-
sidered to have air quality as good as or better than the
national ambient air quality standards as  defined in the
Clean Air Act. An  area may be an attainment area for
one pollutant and a nonattainment area for others.

Baseline Standard: The measure by which future en-
vironmental performance can be compared.

Best Management Practice (BMP): Methods that have
been determined to be the most effective, practical means
of preventing  or reducing pollution from  non-point

Biochemical Oxygen Demand (BOD):  A measure of
the amount of oxygen consumed in the biological pro-
cesses that break down organic matter  in water. The
greater the BOD, the greater the degree of pollution.
Biodegradable:  Capable of decomposing under natu-
ral conditions.

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

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

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

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

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

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

Chemical Oxygen Demand (COD): A measure of the
oxygen required to oxidize all compounds, both organic
and inorganic, in water.

Chloroform:  A colorless liquid with a sweet odor. It is
used primarily in the production of chlorofluorocarbon
and in the production of plastics.  Its other uses are as
an industrial solvent in the extraction and purification
of some antibiotics, alkaloids, vitamins, and flavors; as
a solvent for lacquers, floor polishes, resins, fats, adhe-
sives, oils, and rubber.

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

             Clean Water Act (CWA): The Clean Water Act sets
             the basic structure for regulating discharges of pollut-
             ants to waters of the United States. The law gives EPA
             the authority to set technology-based effluent stan-
             dards on an industry basis and continues the require-
             ments to set water quality standards for all contaminants
             in surface waters. The CWA makes it unlawful for any
             person to discharge any pollutant from a point source
             into navigable waters unless a National Pollutant Dis-
             charge Elimination System (NPDES) permit is obtained
             under the Act.

             Comprehensive Environmental Response, Compensa-
             tion, and Liability Act (CERCLA): CERCLA is the leg-
             islative authority for the Superfund program funds and
             carries out EPA solid waste emergency and long-term
             removal and remedial activities. These activities include
             establishing the National Priorities List (NPL), investi-
             gating sites for inclusion on the list, determining their
             priority, and conducting and/or supervising cleanup and
             other remedial actions.

             Conditional Delisting:  Use of the petition process to
             have a facility's toxic designation rescinded.

             Conformity:  Conformity is a Clean Air Act requirement
             intended to ensure that new transportation investments
             do not jeopardize air quality in nonattainment and main-
             tenance areas. According to the Clean Air Act, no trans-
             portation activity can be funded or supported by the
             Federal government unless it conforms to the purpose
             of a state's air quality plan. An EPA rule describing the
             criteria and procedures for determining conformity is
             found in 40 CFR parts 51 and 93.

             Consent Decree: A  legal document, approved  by a
             judge, that formalizes an agreement reached between
             EPA and potentially responsible parties (PRPs) through
             which PRPs will conduct all or part of a cleanup action
             at a  Superfund site; cease or correct actions or pro-
             cesses that are polluting the environment; or otherwise
             comply with EPA initiated regulatory enforcement ac-
             tions to resolve the contamination at the Superfund site
             involved. The consent decree describes the actions
             PRPs will take and may be subject to a public comment

             Consumptive Water Use: Water removed from avail-
             able  supplies without return to a water resources sys-
             tem,  e.g., water used in manufacturing, agriculture, and
             food preparation.
Continuous Emission Monitoring (CEM): Continuous
measurement of pollutants emitted into the atmosphere
in exhaust gases from combustion or industrial pro-

Criteria Air Pollutants: The CAA requires EPA to set
National Ambient Air Quality Standards (NAAQS) for
certain pollutants known to be hazardous to human
health. EPA has identified and set standards to protect
human health and welfare for six criteria air pollutants—
ozone, carbon monoxide, total suspended particulates.
sulfur dioxide, lead, and nitrogen oxides. EPA must de-
scribe the characteristics and potential health and wel-
fare effects of these pollutants.

Data Call-in: A part of the Office of Pesticide Programs
(OPP) process of developing key required test data, es-
pecially on the long-term, chronic effects of existing

Dioxin: Any one of a family  of compounds known
chemically as dibenzo-p-dioxins. Concern about dioxin
arises from their potential toxicity as a contaminant in
commercial products. Tests on laboratory animals indi-
cate that dioxin is one of the most toxic of synthetic

Discharge Monitoring Reporting (DMR): Facilities that
discharge  wastewater directly  from point  sources to
surface waters must submit DMRs under National Pol-
lution Discharge Elimination System (NPDES) waste-
water permitting.

Dredge: Dredging: Removal of mud from the bottom
of water bodies.  This can disturb the ecosystem and
causes silting that kills aquatic life. Dredging of con-
taminated muds can expose biota to heavy metals and
other toxics. Dredging activities may be subject to regu-
lation under Section 404 of the Clean Water Act.

Ecological Risk Assessment: The application of a for-
mal framework, analytical process, or model to estimate
the effects of human action(s) on a natural resource and
to interpret the significance of those effects in light of
the uncertainties identified in each component of the
assessment process. Such analysis includes initial haz-
ard identification, exposure and dose response assess-
ments, and risk characterization.

Effluent:  Wastewater or other liquid, raw (untreated).
partially or completely treated, flowing from an indus-
trial user, treatment process or treatment plant.

Electroplating Operations: Involves plating various
metals onto printed wiring boards and computer com-
ponents that provide electronic interconnection.

Emergency Planning and Community Right to Know
(EPCRA): Also known as Title III of SARA, EPCRA
was enacted by Congress as the national legislation on
community safety. This law was designated to help lo-
cal communities protect public health, safety, and the
environment from chemical hazards.

Emissions Cap:  A limit designed to prevent projected
growth in emissions from both existing and future sta-
tionary sources from exceeding any mandated levels.
Generally, such provisions  require  that  any emission
increase from equipment at a facility be offset by emis-
sion reductions from other equipment under the same

End-of-Pipe Controls:  Technologies, such as scrubbers
on smokestacks and catalytic converters on automo-
bile tailpipes, that reduce the emission or discharge of
pollutants to the environment after they have formed.

Engineering Evaluation/Cost Analysis (EE/CA): The
EE/CA is a flexible document tailored to identify and
analyze the scope, goals, objectives, and effectiveness
of a non-time-critical removal action. It contains only
those  data necessary to identify the selection of a re-
sponse alternative and  relies on existing documenta-
tion whenever possible.

Environmental Council of States (ECOS): The mission
of ECO S is to improve  the environment of the United
States by providing for the exchange of ideas, views
and experiences among states and territories, fostering
cooperation and  coordination in environmental man-
agement, and articulating state positions on environ-
mental issues.

F006  Listing: A hazardous waste that  is wastewater
treatment sludge produced from nonspecific electroplat-
ing processes and operations.

Feasibility Study (FS): Analysis of the practicability
of a proposal; e.g., a description and analysis of poten-
tial cleanup alternatives for a site such  as one on the
National Priorities List. The feasibility  study usually
recommends selection of a cost-effective alternative. It
usually starts as soon as the remedial investigation is
underway; together, they are commonly referred to as
the "RI/FS."
Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA): The primary focus of FIFRA was to provide
federal control of pesticide distribution, sale, and use.
EPA was given authority under FIFRA not only to study
the consequences of pesticide usage but also to re-
quire users (farmers, utility companies, and others) to
register when purchasing pesticides.  Through  later
amendments to the law, users also must take exams for
certification as applicators of pesticides. All pesticides
used in the United States must be registered (licensed)
by EPA.

Fenceline Standard: A baseline standard measured at
the property line of a facility.

Flexible Fuel Vehicle (FFV): A vehicle specially de-
signed to use methanol or regular unleaded gasoline in
any combination from a single tank. The vehicles have
a special sensor on the fuel line that detect the ratio of
methanol to gasoline that is in the tank. The vehicle's
fuel injection and ignition timing are adjusted by  an
onboard computer to compensate for the different fuel

Fly Ash: Non-combustible residual particles expelled
by flue gas.

Fugitive Emissions: Emissions not caught by a cap-
ture system.

Gasification: Conversion of solid material such as coal
into a gas for use as  a fuel.

Global Positioning  System (GPS): A precise survey-
ing system based on a set of satellites that orbit about
12,000 miles above the earth. On earth, a hand-held spe-
cialized computer, a  portable GPS receiver, can receive
signal from a GPS satellite above the horizon. The re-
ceiver then calculates absolute position, an accuracy
that is usually within a few feet, or better.

Greenfield: Greenfields are generally parkland, previ-
ously  undeveloped open space and agricultural lands.
located near the outskirts of towns, cities and larger
metropolitan areas. (See: Brownfield)

Hazardous Air Pollutants (HAPs): Airpollutants that
are not covered by the National Ambient Air Quality
Standards but that may have an adverse effect on hu-
man health or the environment. Such pollutants include
asbestos, beryllium, mercury, benzene, coke-oven emis-
sions, radionuclides, and vinyl chloride.

Hazardous Waste: Byproducts of society that can pose
a substantial or potential hazard to human health or the
environment when improperly managed. Hazardous
waste possesses at least one of four characteristics
(ignitability, corrosivity, reactivity, or toxicity), or ap-
pears on special EPA lists.

Hydrogen Chloride: Hydrogen chloride is a non-com-
bustible compound that is highly soluble in water. In
aqueous solution, it forms hydrochloric acid.  Hydro-
chloric acid is used to make and clean metals, to make
chloride dioxide for  the bleaching of pulp and other
chemicals, to make phosphate fertilizers and hydrogen.
for the neutralization of basic systems, in the treatment
of oil and gas wells, in analytical chemistry, and in the
removal of scale from boilers and heat-exchange equip-

Hydrogen Flouride: Hydrogen fluoride, or hydrofluoric
acid, is a colorless gas or fuming liquid. It is a chemical
intermediary forfluorocarbons, aluminum fluoride, cryo-
lite, uranium hexafluoride, and fluoride salts. It is used
in fluorination processes, as a catalyst, and as a fluori-
nating agent in organic  and inorganic reactions.  It is
used to clean cast iron, copper, and brass; remove efflo-
rescence from brick and stone; or sand particles from
metallic castings.

Indirect Discharge:  Introduction of pollutants from a
non-domestic source into a publicly owned waste-treat-
ment system. Indirect dischargers can be commercial or
industrial facilities whose wastes enter local sewers.

Influent:  Wastewater or other liquid, raw (untreated).
partially or completely treated, flowing into a treatment
process or treatment plant.

Industrial User:  Any non-domestic source which in-
troduces pollutants into a municipal wastewater collec-
tion system [40CFR 403.3 (h)]

Interference: A discharge which, alone or in conjunc-
tion with a discharge from other sources, both (1) inhib-
its or disrupts the POTW and (2) therefore is a cause for
violation of any requirement of the POTW's NPDES
permit (including an increase in the magnitude or dura-
tion of a violation).

International Organization for Standardization (ISO)
14000: ISO 14000 is primarily concerned with environ-
mental management.  The ISO 14000 series sets out the
methods that can be implemented in an organization to
minimize harmful effects on the environment caused by
pollution or natural resource depletion.
Kraft Mill: Any industrial operation that uses for a
cooking liquor an alkaline sulfide solution containing
sodium hydroxide and sodium sulfide in its pulping pro-

Land Disposal Restrictions (LDR): Rules that require
hazardous wastes to be treated before disposal on land
to destroy or immobilize hazardous constituents that
might migrate into soil and ground water.

Lignin: Organic substance that acts as a binder for the
cellulose fibers in wood and certain plants and adds
strength and stiffness to the cell walls. It imparts con-
siderable strength to the wall and also protects it against
degradation by microorganisms.

Low-emitting Vehicle (LEV): Avehicle that emits 0.075
g of hydrocarbons per mile.

Maximum Available Control Technology (MACT): The
emission standard for air pollution sources requiring
the maximum reduction of hazardous emissions, taking
cost and feasibility into account. Under the CAA Amend-
ments of 1990, the MACT must not be less than the
average emission level achieved by controls on the best
performing 12 percent of existing sources, by category.
of industrial and utility sources.

Maximum Containment Level (MCL):  The maximum
permissible level of a contaminant in water delivered to
any user of a public system. MCLs are enforceable stan-

Methanol: An alcohol that can be used as an alterna-
tive fuel or as a gasoline additive. Poisonous if ingested.

Methyl Chloride:  A colorless flammable gas. Used in
the production of chemicals, as a solvent and refriger-
ant, and as a food additive. Mildly toxic if inhaled.

Metallization:  The fabrication step in which proper
interconnection of circuit elements is made. The act or
process of imparting metallic properties to something.

Mobile Source: Any non-stationary source of air pol-
lution such as cars, trucks, motorcycles, buses, air-
planes, and locomotives.

"The MON": The National Emission Standard for Haz-
ardous Air Pollutants (NESHAP) for the source category
"Miscellaneous Organic Chemical Production and Pro-
cesses." Some examples of these processes are: explo-
sives production; photographic chemicals production;
polyester  resins production;  and the production of
paints,  coatings and adhesives.

Multimedia: Several environmental media, such as air.
water, and land.

National  Ambient  Air  Quality  Standards
(NAAQS):  Standards established by EPA under the
Clean Air Act applicable to outdoor air throughout the

National Contingency Plan (NCP): The Federal regu-
lation that guides determination of the sites to be cor-
rected under both the Superfund program and the
program to prevent or control spills into surface waters
or elsewhere.

National Emissions Standards for Hazardous Air Pol-
lutants (NESHAPs): Emissions standards set by EPA
for air pollutants not covered by National Ambient Air
Quality Standards (NAAQS), that may cause an increase
in fatalities or in serious, irreversible, or incapacitating
illness. Primary standards are designed to protect hu-
man health,  and secondary standards are designed to
protect public welfare (e.g., building facades, visibility.
crops, and domestic animals).

National Pollutant Discharge Elimination System
(NPDES): A provision of the CWA that prohibits the
discharge of pollutants into waters of the United States
unless  a special permit is  issued by EPA, a  state, or
where delegated, a tribal government on an Indian res-

National Priorities List (NPL): EPA's list of the most
serious uncontrolled or abandoned hazardous waste
sites identified for possible long-term remedial action
under Superfund. The list is based primarily on the score
a site receives from the Hazard Ranking System. EPA is
required to update the NPL at least once a year. A site
must be on the NPL to receive money from the Trust
Fund for remedial action.

New Source Performance Standards (NSPS): Uniform
national EPA air emission and water effluent standards
which limit the amount of pollution allowed from new
sources or from modified existing sources.

New Source Review (NSR): The NSR provisions of the
Clean Air Act strive to ensure that potential new sources
of air pollution (new plants or facilities, or additions to
existing ones) take proper steps to minimize pollution
levels.  The goals of the NSR program are (1) to ensure
that an increase in emissions due to a new source or
modification to an existing source does not significantly
deteriorate air quality; ( 2)  to ensure that source emis-
sions are consistent with applicable State attainment
plans; (3) to ensure that air quality related values are
not negatively impacted in areas that have greater pol-
lution problems; and (4) to establish control technol-
ogy requirements that maximize productive capacity
while minimizing impacts on air quality.

Nitrogen Oxides (NOx): Air pollutants that are the re-
sult of photochemical reactions of nitric oxide in ambi-
ent air. Typically, it is a product of combustion  from
transportation and stationary sources. It is a major con-
tributor to the formation of tropospheric ozone, photo-
chemical smog, and acid deposition.

Nonattainment Area:  A designated geographic area
that does not meet one or more of the National Ambient
Air Quality Standards for the criteria pollutants desig-
nated in the Clean Air Act. (See:  Attainment)

Non-time-critical Removal (NTC): Those removals
where, based on the site evaluation, the lead  agency
determines that a removal action  is appropriate and that
there is a planning period of more than six months avail-
able before on-site activities begin.

Organic Compounds:  Naturally occurring (animal or
plant-produced) or synthetic substances containing
mainly carbon, hydrogen, nitrogen, and oxygen.

Oxygen Delignification: Use of oxygen to remove lig-
nin from pulp after high-density stock storage and prior
to the bleaching system. Oxygen delignification system
equipment includes the blow tank, washers,  filtrate
tanks, any interstage pulp storage tanks, and any  other
equipment serving the  same function  as those previ-
ously listed.

Particulate Matter (PM): Fine liquid or solid particles.
such as dust, smoke, mist, fumes, or smog, found  in air
or emissions.

Phosphine:  Phosphine occurs as  a colorless, flammable
gas that is slightly soluble  in water. It is used as an
intermediate in the  synthesis of flame retardants for
cotton fabrics, as a doping  agent for n-type semicon-
ductors, a polymerization initiator, and a condensation

Plant Site Emission Limits (PSELs):  Plant site emis-
sion limits are facility based emission  caps that allow
production changes and facility expansion without re-
curring air quality permit reviews.

Point Source: A stationary location or fixed facility from
which pollutants are discharged; any single identifiable
source of  pollution; e.g., a pipe, ditch, ship, ore pit.
factory smokestack.

Pollution Prevention:  1. Identifying areas, processes.
and activities which create excessive waste products or
pollutants in order to reduce or prevent them through
alteration, or eliminating a process. Such activities, con-
sistent with the Pollution Prevention Act of 1990,  are
conducted across  all EPA programs and can involve
cooperative efforts with such agencies as the Depart-
ments of Agriculture and Energy. 2. EPA has initiated a
number of voluntary programs in which industrial, or
commercial or "partners" join with EPA in promoting
activities that conserve energy, conserve and protect
water supply, reduce emissions or find ways of utilizing
them as energy resources, and reduce the waste stream.

Pass-through: A discharge which exits the POTW into
waters of the United States in quantities or concentra-
tions which, alone or in conjunction with other discharge
sources, is a cause of a violation of any requirement of
the POTW's NPDES permit (including an increase in the
magnitude or duration of a violation).

Perfluorinated Compounds (PFCs): Compounds in
which all the hydrogen atoms are replaced by fluorine.
PFCs are greenhouse gases and are expected to have
long atmospheric lifetimes.

Point Source: A stationary location or fixed facility
from which pollutants are discharged; any single iden-
tifiable source of pollution; e.g., a pipe, ditch, ship,  ore
pit, factory smokestack.

Potentially Responsible Party (PRP):  A PRP is  the
owner or operator of a contaminated site, or the person
or persons whose actions or negligence may have
caused the release of pollutants and contaminants into
the environment, requiring a remedial action response
under CERCLA and SARA. The PRP is potentially li-
able for the cleanup costs in order to compensate  the
government for its remediation expenditures.

Pretreatment:  Processes used to reduce, eliminate, or
alter the nature of wastewater pollutants from non-do-
mestic sources before they are discharged into publicly
owned treatment works (POTW).

Premanufacture  Notification (PMN): Section 5 of
TSCA regulates anyone who plans to manufacture or
import a "new" chemical substance for commercial pur-
poses. Under section 5, EPA requires notice before
manufacture or importation of non-exempt substances
so that EPA can evaluate whether the chemical sub-
stance poses a threat to human health or the environ-
ment.  This notice is called a premanufacture notice
Prevention of Significant Deterioration (PSD): Stan-
dards aimed at keeping areas that are in compliance with
National Ambient Air Quality Standards from backslid-

Printed Wiring Board (PWB): A device that provides
electronic interconnections and a surface for mounting
electronic components.

Production Unit Factor (PUF):  A production-based
performance measure.

Pyrolyzed: (Pyrolysis): Decomposition of a chemical
by extreme heat.

Radiolabel:  To tag (a hormone, an enzyme, or other
substance) with a radioactive tracer.

Relative Accuracy Test Audits (RATA):  The primary
method of determining the correlation of continuous
emissions monitoring system data to simultaneously
collected reference method test data, using no fewer
than nine reference method test runs conducted as out-
lined in 40 CFR 60, Appendix A.

Regulated   Asbestos-Containing   Material
(RACM): Under the asbestos NESHAP, RACM is de-
fined as: (1) friable asbestos material, (2) Category I
non-friable Asbestos Containing Material (ACM) that
has become friable, (3) Category I non-friable ACM that
will be or has been subjected to sanding, grinding, cut-
ting  or abrading, or (4) Category II non-friable ACM
that has a high probability of becoming or has become
crumbled, pulverized, or reduced to powder by the forces
expected to act on the material in the course of demoli-
tion  or renovation operations.

Remedial Investigation (RI): An in-depth study de-
signed to gather data needed to determine the nature
and extent of contamination at a Superfund site; estab-
lish site cleanup criteria; identify preliminary alterna-
tives for remedial action; and support technical and cost
analyses of alternatives. The  remedial investigation is
usually done with the feasibility study. Together they
are usually referred to as the "RI/FS."

Remining:  The surface  mining of previously-mined and
abandoned surface and underground mines to obtain
remaining coal reserves.

Remote Monitoring  Station:  Self-contained
multidetector electronic instruments installed at remote
locations in creeks and other water bodies to assess
ambient water quality and detect real-time changes  of
dissolved oxygen, pH, conductance and temperature.

Removal Action:  A removal action is a short-term Fed-
eral response to prevent, minimize, or mitigate damage
to the public or the environment at sites where hazard-
ous substances have been released. Examples of re-
moval actions are excavating contaminated soil, erecting
a security fence, or stabilizing a berm, dike, or impound-
ment. Removal actions may also be necessary in the
event of the threat of release of hazardous substances
into the environment such as taking abandoned drums
to a proper disposal facility. Removal actions may take
place atNPL ornon-NPL sites.

Remedial Action:  Remedial actions are actions docu-
mented in the ROD that are taken at NPL sites to elimi-
nate or reduce the pollution to levels which prevent or
minimize the release of hazardous substances so that
they do not migrate or cause substantial danger to pub-
lic health or welfare, or the environment. An example is
to remove  hazardous constituents from groundwater
using pump and treat technologies.

Resource Conservation and  Recovery Act
(RCRA):  Passed in 1976, RCRA gives EPA the author-
ity to control hazardous waste from "cradle-to-grave."
This includes the generation, transportation, treatment.
storage, and disposal of hazardous waste. RCRA also
sets forth a framework for the management of nonhaz-
ardous wastes. RCRA enables EPA to address environ-
mental problems that could result from underground
tanks storing petroleum and other hazardous sub-
stances. RCRA focuses only on active and future facili-
ties and does not address abandoned sites.

Response Action: Generic term for actions taken in re-
sponse to actual or potential health-threatening envi-
ronmental events such as spills,  sudden releases, and
asbestos  abatement/management problems.  A
CERCLA-authorized action involving either a short-term
removal action or a long-term remedial response.

Record of Decision (ROD): A ROD documents the rem-
edy decision for a site or operable unit. The ROD certi-
fies that the remedy selection process has followed the
requirements of CERCLA and the NCP, and discusses
the technical components of the remedy. The ROD also
provides the public with a consolidated source of infor-
mation about the site.

Reverse Osmosis (RO):  Reverse Osmosis is a high-
pressure filtration process which separates dissolved
salt and minerals from water, using a membrane. Clean
water passes through the membrane, and the salt and
minerals are rejected.
Riparian Zone:  Areas adjacent to rivers and streams
with a differing density, diversity, and productivity of
plant and animal  species relative to nearby uplands.

Safe Drinking Water Act (SDWA):  SDWA was es-
tablished to protect the quality of drinking water. This
law focuses on all waters actually or potentially desig-
nated for drinking use, whether from above-ground or
underground sources. The Act authorizes EPA to es-
tablish safe standards of purity and requires all owners
or operators of public water systems to comply with
primary (health-related) standards. State governments.
which assume this power from EPA, also encourage at-
tainment of secondary standards (for example,  water

Semi-chemical Mill: A mill that produces pulp using a
combination of both chemical and mechanical pulping
processes, with or without bleaching.

Sludge: A semi-solid residue from any of a number of
air or water treatment processes; this can be a hazard-
ous or non-hazardous waste.

Sludge Dryers:  A piece of equipment that reduces the
volume and weight of the  semi-solid sludge wastes by
drying and reducing the water content of the  sludge.

Smelter: A facility that melts or fuses ore, often with
an accompanying chemical change, to separate its metal
content. Emissions  cause  pollution. "Smelting"  is the
process  involved.

State Implementation Plan (SIP):  EPA approved state
plans for the establishment,  regulation, and enforce-
ment of air pollution standards.

Stationary Source:  A fixed-site producer of pollution.
mainly power plants and other facilities using industrial
combustion processes. (See: Point Source.)

Sulfur Dioxide (SO2):  SO2 gases are formed when fuel
containing sulfur (mainly coal and oil) is burned and
can be formed during metal smelting and other indus-
trial processes. Sulfur dioxide is associated with acidifi-
cation of lakes and  streams, accelerated  corrosion of
buildings and monuments, reduced visibility,  and such
adverse health effects as inhibition of breathing, respi-
ratory illness, and aggravation of existing cardiovascu-
lar disease.

Sulfuric Acid: Sulfuric acid is a clear, colorless, oily.
and odorless liquid. It is also known as sulphine acid

             and hydrogen sulfate. Its main use is in phosphate fer-
             tilizer production. It is also used to manufacture other
             acids, explosives, dyestuffs, parchment paper, glue.
             wood preservatives, and lead-acid batteries in vehicles.
             It is used in the purification of petroleum, the pickling of
             metal, electroplating baths, nonferrous metallurgy, and
             production of rayon and film; and as a laboratory re-

             Superfund:  The program operated under the legisla-
             tive authority of CERCLA and SARA that funds and
             carries out EPA hazardous waste emergency and long-
             term removal and remedial activities. These activities
             include establishing the National Priorities List, investi-
             gating sites for inclusion on the list, determining their
             priority, and conducting and/or supervising cleanup and
             other remedial actions.

             Sustainable Forestry Initiative (SFI):  The Sustainable
             Forestry Initiative™ is a comprehensive program of for-
             estry and conservation practices designed to  ensure
             the continuing sustainable management of forestlands.
             The SFI was developed nationally through the Ameri-
             can Forest and Paper Association (AF&PA),  whose
             members produce 90 percent of the paper and 60 per-
             cent of the lumber produced in America today. Compli-
             ance with the SFI guidelines is mandatory for AF&PA
             companies to retain AF&PA membership.

             300-millimeter Wafer: Early this year, Intel announced
             it will build its first 3 00-millimeter, high-volume produc-
             tion manufacturing facility at its Chandler site. The 300-
             millimeter wafers represent a technological advance in
             semiconductor chips over the standard 200-millimeter
             (8-inch) wafers that are used in many semiconductor
             manufacturing plants today. 300-millimeter chips offer
             over twice as much surface area over the conventional
             chips and will reduce manufacturing co sts per wafer by
             more than 30 percent.

             Title V of the Clean Air Act: Establishes a Federal
             operating permit program that applies to any major sta-
             tionary facility or source of air pollution. The purpose
             of the operating permits program is to ensure compli-
             ance with all applicable requirements of the CAA. Un-
             der the program, permits are issued by states or, when a
             state fails to carry out the CAA satisfactorily, by EPA.
             The permit includes information on which pollutants
             are being released, how much may be released, and what
             kinds of steps the source's owner or operator is taking
             to reduce pollution, including plans to monitor the
Toxic Release Inventory (TRI): Database of toxic re-
leases in the United States compiled from SARA Title
III Section 313 reports.

Toxic Substances Control Act (TSCA):  TSCA was
enacted by Congress in 1976 to give EPA the ability to
track the 75,000 industrial chemicals currently produced
or imported into the United States. EPA repeatedly
screens these chemicals and can require reporting or
testing of those that may pose an environmental or hu-
man-health hazard. EPA can ban the manufacture  and
import of those chemicals that pose an unreasonable

Total Kjeldahl Nitrogen (TKN): TKN is defined func-
tionally as organically bound nitrogen. TKN is the sum
of free ammonia and organic nitrogen compounds which
are converted to ammonium sulfate.  Organic nitrogen
includes such materials as proteins,  peptides, nucleic
acids, urea and numerous synthetic organic compounds.

Total Suspended Solids (TSS): A measure of the sus-
pended solids in wastewater, effluent, or water bodies.
determined by tests for "total suspended nonfilterable

Transitional Low-Emitting Vehicles: A vehicle that
emits 0.125 g of hydrocarbons per mile.

Transportation Control Measure(TCM): TCMs include
a variety of measures used to reduce motor vehicle emis-
sions, primarily reducing the amount of vehicle miles
traveled (VMTs). These can include carpool and vanpool
programs, parking management, traffic flow improve-
ments, high occupancy vehicle lanes, andpark-and-ride

Tributyltin (TBT): TBT based paints assist in keeping
ship hulls free of marine organisms by acting as both a
biocide and as an agent that imparts a "self-polishing"
quality to marine paints. For ocean going vessels, TBT
serf-polishing copolymer paints are currently the most
effective means of preventing ship hull fouling by ma-
rine organisms.

Variance:  Government permission for a delay or ex-
ception in the application of a given law, ordinance, or

Vehicle Miles Traveled (VMT):  A measure of the total
amount of miles traveled by vehicle within a region.

Volatile Organic Compounds (VOCs): Any organic
compound that easily evaporates  and participates in

atmospheric photochemical reactions, except those des-
ignated by EPA as having negligible photochemical re-

Wastewater: Spent or used water from a home, com-
munity, farm, or industry that contains dissolved or sus-
pended matter.

Wastewater Treatment Sludge: The sludge that is pro-
duced from the treatment and removal of pollutants of

Watershed:  The land area that drains into a stream;
the watershed for a major river may encompass a num-
ber of smaller watersheds that ultimately combine at a
common point.

"Wet" Demolition Method: A demolition technique
specified in the Asbestos National Emissions Standards
for Hazardous Air Pollutants (NESHAP) requirements
to limit the release the asbestos particulates.