United States
Office of the EPA 100-R-01-003
—^ uuuwu oiaici>
^0 I— Ll/V Environmental Protection Administrator December 2001
\/tlM Agency (1807) www.epa.gov/projectxl
2001 Co 1^epoK
Project XL:
Directory o| Project
£x pediments and "Results
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CZ-ov\\ew\s
Program Accomplishments 1
Project Status and Results
Andersen Corporation, Minnesota . 11
Anne Arundel County Bioreactor, Maryland 15
Atlantic Steel Site, Jacoby Development Corporation, Georgia 18
Autoliv ASP, Inc., Utah 23
Buncombe County Bioreactor, North Carolina 26
Chicago Regional Air Quality and Economic Development Strategy, Illinois 30
City of Albuquerque, New Mexico 34
City of Columbus XLC, Ohio 37
City of Denton, Texas 41
City of Fort Worth, Texas 45
Clermont County XLC, Ohio I' 48
Crompton Corporation Sistersville Facility (formerly Witco), West Virginia i.51
Department of Defense Elmendorf Air Force Base, Alaska 57
Department of Defense Naval Station Mayport, Florida 61
Department of Defense Puget Sound Naval Shipyard, Washington 65
Department of Defense Vandenberg Air Force Base, California 69
Eastman Kodak Corporation, New York 75
ExxonMobil Corporation, West Virginia 80
Georgia-Pacific Corporation, Virginia 85
HADCO Corporation, New Hampshire and New York (project to be closed out) 88
Imation Corporation, California 91
Intel Corporation, Arizona 95
International Business Machines East Fishkill Facility, New York 100
International Business Machines Semiconductor Manufacturing Facility, Vermont 103
International Paper Effluent Improvements, Maine 106
International Paper Predictive Emissions Monitoring System, Maine 109
Jack M. Berry Corporation, Florida (project closed out) 112
Labs21, Nationwide 115
Lead Safe Boston, Massachusetts — 118
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Louisville and Jefferson County Metropolitan Sewer District, Kentucky
121
Lucent Technologies, Florida and Pennsylvania 124
Massachusetts Department of Environmental Protection Environmental Results Program 126
Merck & Company, Inc., Virginia 135
Metropolitan Water Reclamation District of Greater Chicago, Illinois 140
Molex Incorporated, Nebraska (project completed) * 144
Narragansett Bay Commission, Rhode Island 149
National Aeronautics and Space Administration White Sands Test Facility, New Mexico 152
New England Universities' Laboratories, Massachusetts and Vermont ..Mkjjpi 155
New Jersey Department of Environmental Protection Gold Track Program 161
New York State Department of Environmental Conservation 163
Ortho-McNeil Pharmaceutical Company, Pennsylvania 165
Pennsylvania Department of Environmental Protection Coal Remining and Reclamation Project.. 169
PPG Industries. Inc., Pennsylvania 172
Progressive Auto Insurance Company, Texas 176
Steele County XLC, Minnesota jjj L 178
United Egg Producers, Nationwide
U.S. Postal Service, Denver, Colorado
m
187
USFilter Recovery Services. Inc., Minnesota 190
Waste Management, Inc., Virginia Landfills Bioreactors Project, Virginia 192
Weyerhaeuser Company. Flint River Operation, Georgia 195
Yolo County Bioreactor, California 203
Appendices
A. Information Sources and Methodology "MH 209
B. Focus Group Highlights 211
C. Glossary 224
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Location of^-L Projects
4.
5.
6.
1. Andersen Corporation, Bayport, MN
2. Anne Arundel County Bioreactor, Severn, MD
3. Atlantic Steel Site, Jacoby Development Corporation,
Atlanta, GA
Autoliv ASP, Inc., Promontory, UT
Buncombe County Bioreactor, Buncombe County, NC
Chicago Regional Air Quality and Economic
Development Strategy, Chicago, 1L
7. City of Albuquerque, Albuquerque, NM
8. City of Columbus XLC, Columbus, OH
9. City of Denton, Denton, TX
10. City of Fort Worth, Fort Worth, TX
11. Clermont County XLC, Clermont, OH
12. Crompton Corporation Sistersville Facility (formerly
Witco), Sistersville, WV
13. Department of Defense Elmendorf Air Force Base,
Anchorage, AK
14. Department of Defense Naval Station Mayport,
Jacksonville, FL
15. Department of Defense Puget Sound Naval Shipyard,
Bremerton, WA
16. Department of Defense Vandenberg Air Force Base,
Santa Barbara County, CA
17. Eastman Kodak Corporation, Rochester, NY; Windsor,
CO; Peabody, MA; White City, OR
18. ExxonMobil Corporation, Fairmont, WV
19. Georgia-Pacific Corporation, Big Island, VA
20. HADCO Corporation, Derry and Hudson, NH; Owego,
NY (project to be closed out)
Imation Corporation, Camarillo, CA
22. Intel Corporation, Chandler, AZ
23. International Business Machines East Fishkill Facility,
Hopewell Junction, NY
24. International Business Machines Semiconductor
Manufacturing Facility, Essex Junction, VT
International Paper Effluent Improvements, Jay, ME
International Paper Predictive Emissions Monitoring,
Jay, ME
27. Jack M. Berry Corporation, LaBelle, FL (project closed
out)
21
25.
26.
28. Labs21, Nationwide
29. Lead Safe Boston, Boston, MA
30. Louisville and Jefferson County Metropolitan Sewer
District, Louisville and Jefferson County, KY
31. Lucent Technologies, Allentown and Reading, PA;
Orlando, FL
32. Massachusetts Department of Environmental Protection
Environmental Results Program, Commonwealth of
Massachusetts
33. Merck & Company, Inc., Elkton, VA
34. Metropolitan Water Reclamation District of Greater
Chicago, Chicago, IL
35. Molex Incorporated, Lincoln, NE (project completed)
36. Naragansett Bay Commission, Providence, RI
37. National Aeronautic Space Administration White Sands
Test Facility, Las Cruces, NM
38. New England Universities' Laboratories, Boston
College, University of Massachusetts-Boston,
University of Vermont
39. New Jersey Department of Environmental Protection
Gold Track Program, State of New Jersey
40. New York State Department of Environmental
Conservation, State of New York
41. Ortho-McNeil Pharmaceutical Company, Spring House,
PA
42. Pennsylvania Department of Environmental Protection
Coal Remining and Reclamation Project, Common-
wealth of Pennsylvania
43. PPG Industries, Inc., Pittsburgh, PA
44. Progressive Auto Insurance Company, State of Texas
45. Steele County XLC, Steele County, MN
46. United Egg Producers, Nationwide
47. U.S. Postal Service Denver, Denver, CO
48. USFilter Recovery Services, Inc., Roseville, MN
49. Waste Management, Inc., Virginia Landfills Bioreactors
Project, King George and Amelia Counties, VA
50. Weyerhaeuser Company, Flint River Operation,
Ogelthorpe, GA
51. Yolo County Bioreactor, Yolo County, CA
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PVoject X-L 2001
Comprekervsive Report CMdex
Directory of Project Experiments and Results
Related Industry
or Public Sector
Location
Relevant
Statutes
Core
Function
Featured
on page
Andersen Corporation
wood windows
manufacturing
Bayport, MN
CAA
permit reform
11
Anne Arundel
County Bioreactor
solid waste
management facility
Severn, MD
RCRA
regulations
15
Atlantic Steel Site,
Jacoby Development
Corporation
brownfields
redevelopment,
former steel mill site
Atlanta, GA
CAA
regulations
18
Autoliv ASP, Inc.
automobile safety
product manufacturer
Promontory, UT
RCRA
regulations
23
Buncombe County
Bioreactor
solid waste
management facility
Buncombe
County, NC
RCRA
regulations
26
Chicago Regional
Air Quality and
Economic Development
Strategy
smart growth zone
Chicago, IL
CAA
regulations
30
City of Albuquerque
publicly owned
treatment works, city
industries and businesses
Albuquerque, NM
CWA
regulations
34
City of Columbus XLC
Division of Water
Columbus, OH
RCRA
environmental
stewardship
37
City of Denton
publicly owned
treatment works,
vehicle maintenance
facilities, recycling
centers, junkyards,
salvage yards,
construction sites
Denton, TX
CWA
regulations
41
City of Fort Worth
substandard facilities
with asbestos-containing
building materials
Fort Worth, TX
CAA
environmental
stewardship
45
Clermont County XLC
Little Miami watershed
Clermont
County, OH
CWA
environmental
stewardship
48
Crompton Corporation
Sistersville Facility
(formerly Witco)
specialty chemical
manufacturing
Sistersville, WV
CAA,
RCRA
regulations,
environmental
stewardship
51
Department of Defense Air Force Base Anchorage, AK CAA permit reform 57
Elmendorf Air
Force Base
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Related Industry
or Public Sector
Location
Relevant
Statutes
Core Featured
Function on page
Department of Defense
Naval Station Mayport
Naval Station
Jacksonville, FL
MPRSA
environmental
stewardship
61
Department of Defense
Puget Sound
Naval Shipyard
naval shipyard,
industrial facility
Bremerton, WA
CWA
enforcement
compliance
65
Department of Defense
Vandenberg
Air Force Base
military installation
Santa Barbara
County, CA
CAA, RCRA,
PPA
environmental
stewardship
69
Eastman Kodak
Corporation
imaging systems
and media
manufacturer
Rochester, NY
Windsor, CO
Peabody, MA
White City, OR
TSCA
environmental
stewardship
75
ExxonMobil
Corporation
Superfund site
redevelopment
(former coke works site)
Fairmont, WV
CERCLA
regulations
80
Georgia-Pacific
Corporation
pulp and paper mill
Big Island, VA
CAA
enforcement
and compliance
85
HADCO Corporation
(project to be
closed out)
printed wiring
board manufacturing
Owego, NY
Derry, NH
Hudson, NH
RCRA
regulations
88
Imation Corporation
magnetic data storage
cartridges manufacturing
Camarillo, CA
CAA
permit reform
91
Intel Corporation
semiconductor
manufacturing
Chandler, AZ
(Maricopa
County)
CAA,
multimedia
permit reform,
information
management,
environmental
stewardship
95
International Business
Machines
East Fishkill Facility
cement production
Hopewell
Junction, NY
RCRA
regulations
100
International Business
Machines Semiconductor
Manufacturing Facility
semiconductor facility
Essex Junction, VT RCRA
regulations
103
International Paper
Effluent Improvements
paper mill
Jay, ME
CWA
regulations
106
International Paper
Predictive Emissions
Monitoring
paper mill
Jay, ME
multimedia
enforcement
and compliance
109
Jack M. Berry
Corporation
(project closed out)
citrus juice processing
(small business)
LaBelle, FL
multimedia
permit reform,
environmental
stewardship
112
Labs21
laboratory owners,
operators and designers
nationwide
CWA
environmental
stewardship
115
Lead Safe Boston
federally funded
de-leading
assistance program
Boston, MA
RCRA
regulations
118
Louisville and Jefferson
County Metropolitan
Sewer District
Chenoweth Run
watershed
Louisville and
Jefferson County,
KY
CWA
regulations
121
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Related Industry Location Relevant Core Featured
or Public Sector Statutes Function on page
Lucent Technologies
Massachusetts
Department of
Environmental
Protection
Environmental
Results Program
microelectronics
manufacturing
dry cleaning,
photo processing,
printing
(small business)
Allentown, PA CAA, CWA, environmental 124
Reading, PA SDWA, stewardship
Orlando, FL RCRA, other
Commonwealth multimedia enforcement 126
of MA and compliance
Merck & Company, Inc.
pharmaceutical
manufacturing
Elkton, VA
CAA,
multi-media
permit reform,
information
management,
enforcement
and compliance
135
Metropolitan Water
Reclamation District
of Greater Chicago
Publicaly Owned
Treatment Works
Chicago, IL
CWA
regulations
140
Molex Incorporated
(project completed)
electroplating facility
Lincoln, NE
RCRA
regulations
144
Narragansett Bay
Commission
publicly owned
treatment works
treats domestic,
commercial and
industrial wastewater
Providence, RI
CWA
regulations
149
National Aeronautics
and Space
Administration
White Sands
Test Facility
test facility
Las Cruces, NM
multimedia
information
management
152
New England
Universities'
Laboratories
university laboratories
Boston College RCRA
University of
Massachusetts-Boston,
University of Vermont
regulations,
environmental
stewardship
155
New Jersey Department
of Environmental
Protection
Gold Track Program
regulatory flexibility
offered to regulated
community based
on the level of
environmental
commitment and
environmental
performance
State of NJ
multimedia
environmental
stewardship
161
New York State
Department of
Environmental
Conservation
public utilities
State of NY
RCRA
regulations
163
Ortho-McNeil
Pharmaceutical
Company
pharmaceutical
research and
development facility
Spring House, PA
RCRA
environmental
stewardship
165
Pennsylvania
Department of
Environmental Protection
Coal Remining and
Reclamation Project
abandoned coal mines
Commonwealth
of PA
CWA
permit reform
169
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Related Industry
or Public Sector
Location
Relevant
Statutes
Core
Function
Featured
on page
PPG Industries, Inc.
global supplier of
coatings, fiberglass,
glass, and chemicals
Pittsburgh, PA
TSCA
environmental
stewardship
172
Progressive Auto
Insurance Company
auto insurance
State of TX
CAA
environmental
stewardship
176
Steele County XLC
industrial facilities
Steele County, MN
CWA
regulations,
information
management
178
United Egg
Producers
farmer cooperative
representing egg
producers nationwide
nationwide
CWA
enforcement
compliance
182
U.S. Postal Service
Denver
vehicle emissions
(postal)
Denver, CO
CAA
environmental
stewardship
187
USFilter
Recovery
Services, Inc.
commercial
hazardous waste
treatment and
recovery facility
Roseville, MN
RCRA
regulations
190
Waste Management,
Inc., Virginia Landfills
Bioreactors Project
bioreactor landfill
King George
and Amelia
Counties, VA
RCRA
regulations
192
Weyerhaeuser
Company, Flint
River Operation
pulp and paper
manufacturing
Oglethorpe, GA
CAA,
CWA
multimedia
regulations, 195
permit reform,
information
management,
enforcement and
compliance,
environmental
stewardship
Yolo County Bioreactor
bioreactor landfill
Yolo County, CA
RCRA
regulations
203
-------
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IP^ogrcxm y\ccompl ishmervfs
Project .XL: y\rv ^Arvrvual Look
at tKe. Program's PVo0^ess
Project XL is an experimental program designed to improve
America's environmental protection system, in particular the
regulations under which the system operates. It does so by
allowing businesses, communities, and other organizations to pilot
test environmental strategies that promise better results than what
would be expected under existing requirements. The goal is to iden-
tify new ideas and approaches that work and to then put them to use
on a broader scale so the environment, and more facilities and com-
munities, can benefit.
Project XL is an important part of a much broader strategy designed
to promote environmental innovation to achieve better environmen-
tal results. That strategy has just been updated, and it calls for contin-
ued testing of new ideas and approaches that can help address a
growing and increasingly complex set of problems. It also calls for
strengthening EPA's critical partnership with states and tribes, focus-
ing innovation efforts on a set of high-priority problems, and creating
a culture and organizational system that supports innovation through-
out the Agency. These priorities provide a strategic framework for
innovation efforts, and going forward, they will guide EPA's efforts
to expand and improve our environmental protection system.
D
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PiorveeHrv0 Projects
Weyerhaeuser and Intel
Making Progress
Project XL's potential for bringing about im-
portant advances in environmental protection
is particularly evident in projects that have
been underway for several years.
Weyerhaeuser, which signed a final project
agreement (FPA) in 1997, is investing in a
number of aggressive pollution prevention
measures for its pulp and paper manufactur-
ing plant in Oglethorpe, Georgia. Innovations
are being tested to minimize the facility's
impact on the environment and surrounding
community, one of which provides an alter-
native to the end-of-pipe control for address-
ing hazardous air pollutant emissions that is
an option under EPA's "cluster rule," which
was promulgated in 1998. The potential ap-
plication of this option to other pulp and pa-
per facilities became more evident as a result
of the Weyerhaeuser XL project experience.
Weyerhaeuser is advancing environmental
protection in many other ways. A facility-
wide cap for controlling national ambient air
emissions of pollutants, such as particulate
matter, sulfur dioxide (SO,), and nitrogen
oxides (NOx), is expected to cut total allow-
able emissions by 60 percent below require-
ments. New technology being tested has the
potential to cut bleach plant effluent in half.
Likewise, by modernizing its pulp process
and by recycling and reusing certain materi-
als that were previously treated as waste,
Weyerhaeuser expects to reduce its solid
waste generation by 50 percent.
EPA's latest innovation strategy is based on years
of experience in pursuing new tools and approaches
for improving environmental results. That experi-
ence grew considerably in the 1990s when EPA
and others began to realize that our nation's tradi-
tional environmental protection system alone could
not fully address complex environmental chal-
lenges such as global climate change, polluted run-
off, and loss of habitat and biodiversity. Flexibility
in EPA's operations and regulatory management is
one tool in our environmental protection toolkit
that goes a long way to harnessing the creative
problem-solving capacity of experienced environ-
mental managers. New scientific and technologi-
cal advances that have occurred since many
existing laws were passed also provide new op-
portunities for transformation and improvements.
In response to these and other factors, EPA and
the states launched a wave of innovative initiatives,
and Project XL has been one of the most far-reach-
ing.
Testing promising innovations to improve environ-
mental protection is what Project XL is all about,
but the real benefit of the program will come from
identifying improvements that can be adopted on
a much broader scale. That benefit can only be
realized once an experiment proves successful
through evaluation. Prior to each project, EPA
works with the project sponsors to develop moni-
toring and reporting criteria that can be used to
determine how well projects are working. EPA
reports the project results in an annual report, and
this latest one shows 2001 was a very active, pro-
ductive year.
As of December 2001,51 projects are in various
stages of implementation, and the results—mea-
sured at different stages for the projects—are en-
couraging. They show benefits for the
environment, for the project sponsor, and for the
communities where these projects are located.
Looking ahead, EPA expects that Project XL's re-
sults will grow considerably. They will do so at
the individual test sites as projects mature, the in-
tended benefits are realized, and new opportuni-
ties—not foreseen at the time of development—are
revealed. One example of how one innovation can
lead to another is seen at the International Paper
-------
(IP) plant along the Androscoggin River in Maine.
There, the company is testing ways to improve the
quality of its effluent rather than using the best
management practices required under EPA's pulp
and paper rule. After making an improvement in
pulp screening, the company was able to remove
its pulp in a cleaner manner, cutting energy costs
by $147,000 a year. But that was only the begin-
ning of even bigger cost savings. In the course of
making this change, the company determined that
it could meet specific heating needs by using al-
ready heated wastewater rather than producing
fresh steam. IP invested $15,000 to upgrade its
heating pump and cut its annual energy costs by
$500,000. Another process improvement that re-
sulted in more consistent pulp washing increased
those savings to $647,000 a year. Along with cost
savings, the effluent improvements have also re-
duced the plant's chemical oxygen demand (COD)
discharge by about 36 percent.
Such benefits are clearly good for IP and the sur-
rounding area. But they may also be available for
many more pulp and paper companies and com-
munities in the years ahead. That is because the
results from this project may help clarify the ap-
plication of new effluent technologies at other mills
and inform EPA's future rule making regarding
COD and color at pulp and paper mills. Therein
lies the true value of Project XL—revealing im-
provements that can be applied either voluntarily
or through regulatory change to achieve better re-
sults on a much broader scale.
Project XL's benefits for the environment, for
project sponsors, and for communities through
2001 are highlighted below.
T3enej"ifs fKe
<£Vvvi ro lament
Before getting approval, all project sponsors must
explain how their approach will produce better
results for the environment. The projected ben-
efits cover a range of issues, such as reducing air
emissions, water discharges, or hazardous waste.
But they also cover issues that have not typically
been addressed through regulation, such as
PioKveeHrvg Projects
Continued
Weyerhaeuser's pollution prevention efforts
are paying off for the environment and the
company's bottom line. For example,
biological oxygen demand and total sus-
pended solids in wastewater effluent have
been reduced by 27 percent and 20 percent,
respectively. Solid waste has fallen by 30
percent, and emissions of particulate matter,
total reduced sulfur, NOx, and SO,, are down
anywhere from 8 to 18 percent. Along with
these environmental benefits, Weyer-
haeuser's recycling and reuse of lime mud is
saving the company $200,000 a year. Longer
term, Weyerhaeuser expects to avoid $10
million in future capital spending on envi-
ronmental investments.
Intel, which signed an FPA in 1996, has
avoided millions of dollars in production de-
lays—a real competitive advantage in the
quick-to-market semiconductor industry—by
eliminating 30 to 50 annual permit reviews at
its Chandler, Arizona, facility. It has done so
by replacing individual permits for each air
emission source with a single, facility-wide
permit that caps the facility's total emissions.
This approach streamlines regulatory transac-
tions and allows Intel to make equipment and
process changes. It also enables the company
to expand its operations as long as the overall
air quality limits are met, as evidenced by a
decision in 2000 to invest $2 billion for con-
struction of a new high-volume production
manufacturing facility at the site.
Intel has made a number of precedent-setting
moves in its approach to handling environ-
mental information. By agreeing to place all
of its environmental data on the Internet, Intel
provided local citizens and other interested
parties with a quick, easy means of tracking
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Pioneering PVojec+s
Continued
its environmental performance. The
company's consolidated report for federal,
state, county, and local environmental re-
quirements may serve as a reporting model
for other semiconductor manufacturers, and
it is already influencing the development of
environmental information systems at the
national level. In addition, by integrating its
emergency planning and preparedness infor-
mation with the local fire department's com-
puter-based emergency management system,
Intel is ensuring better coordination and pre-
paredness.
Environmental benefits continue to accrue.
Intel has stayed well under the criteria and
hazardous air emissions limits specified in
its facility-wide cap. In addition, the com-
pany has exceeded its waste management
goals, recycling 84 percent of solid waste and
55 percent of hazardous waste in 2001. Rec-
ognizing the importance of water conserva-
tion in the southwest, Intel also followed
through on an aggressive commitment to re-
use treated effluent for its cooling and land-
scaping needs. While a 100 percent water
reuse system did not prove economically fea-
sible, stakeholders supported the company in
using a system that enables consistent reuse
of at least 95 percent.
The current project agreement expires at the
end of the year. However, based on the
project's successful operation, Intel, EPA, the
state and local agencies and other involved
parties are interested in extending it for an-
other five-year term. Discussions concern-
ing this action are underway. While some
minor adjustments are expected, Intel is pro-
posing to leave much of the existing agree-
ment intact. The goal is to have a renewed
agreement in place by December 31, 2001.
reducing the life cycle impact of products, improv-
ing energy efficiency, or promoting smart growth.
Some of the more recent projects show promise
for achieving results just as strong as those seen
with some of the earlier projects, such as Intel and
Weyerhaeuser. For example:
• Imation Corporation found that a plant-wide
emissions cap for controlling volatile organic
compounds (VOCs) worked extremely well.
The cap was set at 150 tons per year, and yet
actual emissions were only 22 tons in 2000,
an 85 percent reduction below what was al-
lowable.
• USFilter Recovery Services, Inc., expects
that over the next three years an integrated
waste management system will enable it to
recover 2,250 pounds of copper, nickel, and
zinc that would otherwise go into landfills.
• Georgia-Pacific Company's Mill in Big
Island, Virginia, anticipates that an innovative
system for recovering chemicals from its pulp
and paper operations will reduce emissions of
hazardous air pollutants from 2.97 pounds to
0.02 pounds per ton of resulting evaporated
solids.
• International Business Machines (IBM)
estimates that using a more efficient plating
process for its Essex Junction, Vermont, facil-
ity will virtually eliminate the use and emis-
sion of perfluorinated compounds, one of the
most potent greenhouse gases. And an allow-
ance to recycle and reuse rather than treat and
landfill a certain type of waste will cut haz-
ardous waste from its East Fishkill, New York,
facility by 300 tons a year, or 35 percent.
Table 1 shows the cumulative environmental ben-
efits of 19 projects that reported data for the pe-
riod 1997 to 2001. These benefits highlight the
many ways that innovations developed through
Project XL can benefit the environment.
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Q
5
—f-
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o'
5
Table "1: C-umulative Environmental Benefits for Select Project Sponsors:
1997—2001*
ELIMINATED: 28,319 tons of emissions of criteria air pollutants-NOx, SOz, particulate matter,
carbon monoxide
REDUCED:
2,467 tons of VOCs emissions
REDUCED:
¦HMaaaMaa
RECYCLED:
¦¦¦MM
RECYCLED:
RECYCLED:
REUSED:
467 tons per year of hazardous air pollutant emissions
20,540 tons of solid waste
2,170 tons of nonhazardous chemical waste
1,450 tons of hazardous waste
1,237 millions of gallons per day of water
* This summary is based on 1997-2001 data reported by Andersen, Autoliv, Crompton, Department of Defense Elmendorf AFB, Depart-
ment of Defense Vandenberg AFB, ExxonMobil, Georgia-Pacific, IBM East Fishkill, IBM Vermont, Imation, HADCO, Intel, Massachu-
setts Department of Environmental Protection, Merck, Molex, New England Universities' Laboratories, Steele County, USFilter, and
Weyerhaeuser. The data includes projected results for 2001. They are cumulative and based on varying degrees of project implementa-
tion. Some facilities have reported since 1997, while others began reporting more recently.
Sene-fils 1~Voje.c+
As the name implies, firms participating in Project
XL gain recognition for environmental excellence
and leadership. This recognition can be very help-
ful in improving relations with regulatory agen-
cies and communities and in meeting the
expectations of environmentally conscious con-
sumers and shareholders.
Beyond recognition, firms participate in Project
XL for other reasons. Some see a chance to use a
promising new technology that can cut costs and
improve efficiency. Others want to make a pro-
cess change that has long seemed sensible for their
operation, but they have been unable to do so given
traditional regulatory requirements. Whatever the
motivation, EPA encourages firms to view the flex-
ibility offered by Project XL not as a regulatory
"break" but as an opportunity to create incentives
that in the short-term compensate the project spon-
sor for its exploratory efforts and in the long-term
provide encouragement for many more facilities
to improve environmental performance.
As Project XL continues, the significance and va-
riety of operational and economic benefits for
project sponsors will expand and accrue over time.
For example, the New England Universities' Labo-
ratories project has been designed to develop a
more cost-effective plan for regulating university
laboratories. It will implement programs to en-
hance laboratory safety and illustrate better sys-
tems to manage laboratory environmental impacts.
In doing so, it also can serve as a model for other
colleges and universities throughout the country
that are committed to improving environmental
performance.
Table 2 highlights a number of actual and antici-
pated economic benefits from individual projects
through 2001.
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Table 2: Economic Benefits Select 1-Voject Sponsors
Crompton Corporation, a specialty chemical manufacturer, continues to add up cost savings for its
Sistersville, West Virginia Plant. The company saved $228,000 in 1997, $25,000 in 1998, $1,179,000 in 1999,
$1,262,000 in 2000, and $940,000 in the first half of 2001 from new waste minimization and pollution
prevention activities. Crompton estimates these activities will save approximately $1 million a year in
recurring costs, while a related deferral gained for a Resource Conservation and Recovery Act requirement
will save an additional $800,000 over a five year period.
Eastman Kodak Corporation found economic benefits from using a risk-management tool in its selection of
new chemical candidates for its imaging operations. That tool—a Pollution Prevention Framework
developed by EPA—enabled the company to identify chemicals with less harmful environmental effects
much earlier in the product development cycle and avoid carrying problem candidates through later stages
of development. As a result of this pre-screening, Kodak was able to avoid between $13,500 and $100,000
of additional costs for each $100,000 typically invested in the research, development, and regulatory review
of new chemical candidates.
The National Aeronautics and Space Administration (NASA) estimates cost savings from implementing a
consolidated and streamlined environmental compliance information collection and reporting system.
NASA anticipates that reducing paper, postage, and personnel requirements will produce annual cost
savings of $186,500, or approximately $932,500 over a five-year period. These savings will be invested in
site-specific environmental remediation projects at the Agency's White Sands Test Facility.
Autoliv ASP, Inc., a manufacturer of automobile safety products, expects to save an estimated $316,000 in
hazardous waste disposal costs. It will do so by adapting the technology and pollution-control devices
currently used in its metals recovery facility to process its pyrotechnical waste materials on-site rather then
sending them off-site for open burning. In addition to recovering and recycling certain materials, such as
copper, this approach will also cut air emissions significantly.
Department of Defense's Elmendorf Air Force Base (AFB) aims to streamline the application, implementa-
tion, management, and renewal process for its Title V Clean Air Act permit by reducing monitoring and
record keeping. Elmendorf AFB estimates that total monitoring, record keeping, reporting, and permit
management costs will decrease by about 80 percent, yielding about $1.5 million in savings over six years.
These savings will be used to reduce emissions of hazardous air contaminants and other pollution preven-
tion projects.
Buncombe County's Bioreactor Project has been researching a new method for operating sanitary land-
fills—the bioreactor method. Buncombe realized a significant economic benefit, saving nearly $400,000,
when constructing Cell 3 of the landfill using the alternative liner rather than the standard composite
system. The county estimates that it will save a total of $5 million through the build out of the facility if the
alternative liner system is used on all the cells. Increased landfill disposal capacity due to rapid settlement
during the operational period of the landfill will lead to more economical operations. Buncombe County,
North Carolina, estimates a potential cost savings of $5 to $10 million in reduced construction costs for
additional landfill capacity if the anticipated increase of 20 to 30 percent in additional waste volume can be
achieved due to rapid waste decomposition. The county is also estimating a savings of $9 million over the
life of the landfill if leachate hauling and off-site treatment can be eliminated due to recirculation.
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Benefits for tKe
Community
Project XL is benefiting communities in a variety
of ways, and as Table 3 shows, the benefits may
take many different forms. For example, allow-
ing firms to redesign standard reporting mecha-
nisms provides an opportunity to respond more
specifically to citizen concerns about environmen-
tal management and performance issues. Simi-
larly, the emphasis placed on transparency means
that citizens have more opportunity to provide
input during project development and implemen-
tation.
One project that reflects a variety of community
benefits is located in Steele County, Minnesota.
There, nine industrial facilities are working to-
gether to reduce the levels of industrial pollutants
and wastewater flowing to local wastewater treat-
ment facilities. The ultimate goal is to work to-
ward a multimedia permit that covers all the
facilities' air emissions, solid and hazardous
waste, effluent discharges, and chemical storage.
Under the current agreement, the participants have
agreed to have any notices of significant noncom-
pliance posted on the state environmental agency's
Web site, which means the community will have
access to that information for a longer period of
time—in a very visible spot—than it would with
a one-time newspaper notice. In addition, the con-
servation elements of the project are expected to
increase the life span of the local wastewater in-
frastructure, delaying infrastructure investments
and saving taxpayers millions of dollars in the pro-
cess. Those elements will also free up capacity
that may be needed in order for any new develop-
ment to occur. Finally, the project will promote
greater cooperation and creativity among regulated
facilities in the area and provide a strong example
of environmental stewardship for others to fol-
low.
In Fort Worth, Texas, a more cost-effective ap-
proach for demolishing asbestos-tainted buildings
could pave the way for brownfields redevelopment
to occur at a faster pace, improving the quality of
life and economic opportunity for all those living
in and around the affected areas. The city is test-
ing an alternative demolition procedure that re-
sults in lower exposure risks and a savings of
$20,000 per building. By reducing the costs and
regulatory paperwork associated with each project,
the city believes that more demolitions can be ac-
complished in a shorter amount of time.
Table. 3t Benefits for Community Stakeholders
A cleaner local environment.
Direct community and stakeholder involvement in environmental decision-making and planning for
facilities through collaborative teams.
Greater community input into local development and economic planning through issues such as site reuse
and "smart growth."
Access to environmental data and reports that are in an easy-to-read format.
Opportunity to forge real and informed trust with the project sponsor.
Easier and faster access to companies' environmental information—via the Internet or local libraries, or
directly from the facility.
Regularly scheduled forums for getting updates on environmental progress and company performance.
Better understanding of a local facility's operations, and of issues facing an industry as a whole.
Community enhancements, such as computer donations and improved landscaping in project buffer zones.
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Project XL is providing communities with oppor-
tunities to identify the approaches that work most
effectively for them and to build on or establish
constructive relationships with facilities that im-
pact the local environment and quality of life. The
results will increase the number of tools and ap-
proaches that other facilities and communities can
use in addressing priority problems, build capac-
ity for problem-solving at the local level, and reaf-
firm the importance of public involvement in
environmental decision making.
Project Status av\c\
Results
The section that follows summarizes objectives and
results for all 51 projects with signed FPAs. The
results are based on data collected between Au-
gust and November 2001, and they are presented
alphabetically by project sponsor. The projects are
also sorted thematically—by sector, location, and
relevant statute—in the index (on page iv).
• Andersen Corporation—Bayport, Minnesota
• Anne Arundel County Bioreactor—Severn,
Maryland
• Atlantic Steel Site, Jacoby Development Cor-
poration—Atlanta, Georgia
• Autoliv ASP, Inc.—Promontory, Utah
• Buncombe County Bioreactor—Buncombe
County, North Carolina
• Chicago Regional Air Quality and Economic
Development Strategy—Chicago, Illinois
• City of Albuquerque—Albuquerque, New
Mexico
• City of Columbus—Columbus, Ohio
• City of Denton—Denton, Texas
• City of Fort Worth—Fort Worth, Texas
• Clermont County—Clermont County, Ohio
• Crompton Corporation Sistersville Facility (for-
merly Witco)—Sistersville, West Virginia
• Department of Defense Elmendorf Air Force
Base—Anchorage, Alaska
• Department of Defense Naval Station
Mayport—Jacksonville, Florida
• Department of Defense Puget Sound Naval
Shipyard—Bremerton, Washington
• Department of Defense Vandenberg Air Force
Base—Santa Barbara County, California
• Eastman Kodak Corporation—Rochester, New
York; Windsor, Colorado; Peabody, Massachu-
setts; and White City, Oregon
• ExxonMobil Corporation—Fairmont, West Vir-
ginia
• Georgia-Pacific Corporation—Big Island, Vir-
ginia
• HADCO Corporation (project to be closed out)
— Derry and Hudson, New Hampshire; Owego,
New York
• Imation Corporation—Camarillo, California
• Intel Corporation—Chandler, Arizona
• International Business Machines East Fishkill
Facility—East Fishkill, New York
• International Business Machines Semiconduc-
tor Manufacturing Facility—Essex Junction,
Vermont
• International Paper Effluent Improvements—
Jay, Maine
• International Paper Predictive Emissions Moni-
toring—Jay, Maine
• Jack M. Berry Corporation (project closed
out)—LaBelle, Florida
• Labs21—Nationwide
• Lead Safe Boston—Boston, Massachusetts
• Louisville and Jefferson County Metropolitan
Sewer District—Louisville and Jefferson
County, Kentucky
• Lucent Corporation—Allentown and Reading
Pennsylvania; Orlando, Florida
• Massachusetts Department of Environmental
Protection Environmental Results Program—
Commonwealth of Massachusetts
• Merck & Company, Inc.—Elkton, Virginia
• Metropolitan Water Reclamation District of
Great Chicago—Chicago, Illinois
• Molex Incorporated (project completed)—Lin-
coln, Nebraska
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• Narragansett Bay Commission—Providence,
Rhode Island
• National Aeronautics and Space Administration
White Sands Test Facility—Las Cruces, New
Mexico
• New England Universities' Laboratories—Bos-
ton College, University of Massachusetts-Bos-
ton, University of Vermont
• New Jersey Department of Environmental Pro-
tection Gold Track Program—State of New Jer-
sey
• New York State Department of Environmental
Conservation Coal Remining and Reclamation
Project—State of New York
• Ortho-McNeil Pharmaceutical Company—
Spring House, Pennsylvania
• Pennsylvania Department of Environmental
Protection Coal Remining and Reclamation
Project—Commonwealth of Pennsylvania
• PPG Industries, Inc.—Pittsburgh, Pennsylvania
• Progressive Auto Insurance Company—State of
Texas
• Steele County, Steele County, MN
• United Egg Producers—Nationwide
• U.S. Postal Service Denver—Denver, Colorado
• Waste Management, Inc., Virginia Landfills
Bioreactors—King George and Amelia Coun-
ties, Virginia
• Weyerhaeuser Company, Flint River Opera-
tion—Oglethorpe, Georgia
• Yolo County Bioreactor—Yolo County, Califor-
nia
The following format is used to provide a full and
consistent description of each project.
Background: Who is the project sponsor? What
is the main experiment of the pilot project? What
is the flexibility that is given to the project spon-
sor by the regulatory agencies (federal, state, tribal,
and local)? In addition to the main experiment,
what other innovations are key components of the
pilot project? What is the expected superior envi-
ronment performance of this project?
Progress in Meeting Commitments: What is the
progress in meeting the overall commitments by
the project sponsor and regulatory agencies that
were agreed to and specified in the FPA?
Benefits for the Environment: Based on the
project's progress, what has been the actual ben-
efit or improvement to the local environment?
Benefits for Stakeholders: What benefits have the
local community and general public received
through project implementation?
Benefits for the Project Sponsor: What cost sav-
ings or other benefits have the project sponsor
gained?
Information Resources: What are the sources of
information for this project's summary?
Appendix A: "Information Sources and Method-
ology" describes the information sources and meth-
odologies used in collecting data for each project.
Appendix B: "Focus Group Highlights" contains
information collected from focus group sessions
conducted for thirteen of the projects.
Appendix C: "Glossary" provides a glossary of
terms used throughout this report.
For more information about Project XL and the
individual projects, go to EPA's Web site at http://
www.epa.gov/projectxl.
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Project Status
cxnd Results
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j\v\de~rse,v\
(Corporation
Final Project Agreement Signed June 30, 1999
Background
The Project Sponsor: The Andersen Corporation
is a leading manufacturer of durable, energy-effi-
cient, high-performance windows and patio doors.
Andersen's main manufacturing plant is located
in Bayport, Minnesota, along the St. Croix River,
a federally designated "Wild and Scenic River,"
which forms a large portion of the border between
Minnesota and Wisconsin. Existing manufactur-
ing facilities are located on Andersen's 110-acre
Fourth Avenue site, which consists of 78 build-
ings, most of which are interconnected. Manufac-
turing and related processes at Andersen include
wood cutting and milling, wood preservative ap-
plication, painting, vinyl processing, adhesive op-
erations, byproduct transfer, wood-fired boilers,
assembly operations, technology development,
production support, and maintenance functions.
The Experiment: The Andersen project is test-
ing an innovative experiment to reduce air emis-
sions per unit of production and provide to the
public information on the plant's environmental
efficiency. This reduction will be achieved by us-
ing performance-based regulatory approaches
based on volatile organic compound (VOC) emis-
sions per standard measure of production, referred
to as the "performance ratio." While providing
incentives for better performance, the tiered per-
formance ratio system, with both rewards and
penalties, will essentially prevent a return to tradi-
tional solvent-based coating and wood-preserva-
tive processes, while allowing the company the
flexibility to research even greater efficiencies and
emissions improvements. The company will be
allowed to increase production levels without un-
dergoing case-by-case reviews prompted by VOC
emission changes, as long as its VOC emissions
per unit of production remain below the perfor-
mance ratio and its overall emissions remain be-
low a facility-wide VOC cap.
The Flexibility: In return for superior environ-
mental performance, EPA, the Minnesota Pollu-
tion Control Agency (MPCA), and Washington
County intend to offer Andersen Corporation regu-
latory flexibility under this XL project. The project
will allow modification and addition of
preapproved sources without additional review by
EPA or MPCA. In the FPA, EPA agreed to de-
velop both a site-specific rule under the Clean Air
Act's (CAA's) Prevention of Significant Deterio-
ration (PSD) program and a streamlined Minne-
sota Project XL multimedia permit (Minnesota XL
Permit). The Minnesota XL Permit will, to the
extent possible, combine air, hazardous waste, and
water discharge conditions at the Bayport Facility
into one permit, and it will incorporate the federal
air permit as required by 40 CFR Part 70 for the
Bayport Facility. The Minnesota XL Permit will
be a consolidation of Andersen's various environ-
mental obligations. It will contain the CAA Title
V, minor New Source Review, and PSD permits,
and it will be issued subject to public notice and
comment and the opportunity for EPA review and
public petition. During the permit's development,
overlapping or conflicting conditions from exist-
ing permits will be combined or reconciled, as al-
lowed by applicable requirements. The flexibility
granted to Andersen Corporation includes relief
from specific applicable synthetic minor air emis-
sion limits with the condition that Andersen com-
plies with the site-specific permit limits for
particulate matter (PM) and VOCs. The new per-
mit establishes emission caps for VOCs on a "per
standard measure of production" basis and on a
facility-wide basis and a facility-wide cap on PM.
This regulatory flexibility grants preapproval for
emission increases that would otherwise require
permit modification approval by the regulatory
agency. The Minnesota XL Permit will, to the
extent possible, reduce the administrative burden
through simplified monitoring, reporting, and
record keeping.
Other Innovations: (1) Air emissions per mea-
sure of production. This project represents an in-
novative approach to allowing changes in
manufacturing processes that may result in reduced
air emissions per standardized measure of produc-
tion. (2) Performance-based air emission ratio
system. The project also provides an opportunity
to test whether a tiered air emission ratio system,
with both rewards and penalties, can provide a
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better incentive for reducing air emissions. If suc-
cessful, the project will result in a new, flexible,
performance-based approach designed to achieve
superior environmental results and cost savings.
In addition, if this approach is adopted more widely,
it will allow the public to compare the environ-
mental efficiency of different facilities for the first
time ever, a profound change to how environmen-
tal information is approached.
The Superior Environmental Performance:
The project establishes an innovative, incentive-
based per unit emission measure that should drive
down Andersen's per unit emission of VOCs. In
addition to the per unit measure, emission caps on
VOCs and PM ensure that the facility's overall
emissions will not exceed those from normal op-
erations. Andersen will be able to manufacture
more of its windows from recycled wood fiber and
vinyl than in the past, reducing both its use of vir-
gin materials and its air emissions. Andersen will
also decrease its reliance on high-solvent processes,
further reducing air emissions at the facility.
Progress in Meeting Commitments
(As of November 2001)
• Current activities are primarily focused on fi-
nalizing the permit, which is expected in mid-
2002. The following commitments have been
targeted and are expected to be incorporated
into the Andersen Minnesota XL Permit (the
first six Andersen commitments are currently
being met):
Andersen
• Conduct a health risk analysis for toxic air
emissions (completed and reviewed by
MPCA).
• Limit VOC emissions to 2,397 tons per year
for the entire Bayport Facility (see Figure 1).
• Combine the existing diptank VOC synthetic
minor limits into a single rolling average limit
of 1,573.9 tons per year (see Figure 1).
• Limit non-milling PM emissions for the
Bayport Facility to 209.1 tons per year (see
Figure 2).
Andersen - Volatile Organic Compounds
Facility-wide Actual
- TBD 2002
Facility-wide Cap
2,397
Facility-wide
Past Performance
- TBD 2002
Diptank Actual
- TBD 2002
Diptank Rolling
Average Limit
1.573.9
Diptank Past Performance
- TBD 2002
1 1 1
0 1,000 2,000 3,000
Tons per Year
Pigw^e *1
Andersen's VOC emissions.
Andersen - Particulate Matter
- TBD2002
209.1
- TBD2002
1 1 1 1
0 50 100 150 200
Tons per Year
Pigure 2
Andersen's PM emissions.
Bayport Facility
Non-milling PM Actual
Bayport Facility
Non-milling PM Cap
Bayport Facility
Non-milling PM Past
Performance
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Continue to control the door plant paint line
emissions with a catalytic oxidizer until the
company implements low VOC collating(s)
and receives approval to discontinue the use
of the control equipment from the MPCA.
• Control all existing and future milling opera-
tions with best available control technology
(BACT) (currently believed to be baghouse fil-
ters), and meet all PSD requirements for PM
and PM less than 10 microns (PM-10).
Andersen will be allowed to modify or add
VOC units and certain PM and PM-10 units
as long as they remain below the caps estab-
lished in the permit. An Air Dispersion Mod-
eling Report for particulate emissions was
completed by Andersen and reviewed by the
MPCA.
Andersen - Paintline and Preservation Application
VOC Emission Rate
Paintline Actual - TBD2002
Paintline
VOC Cap
Paintline Past _ jqq 2002
Performance
Preservative Actual - TBD2002
Preservative „ 0
VOC Cap
Preservative Past _ JBD 2002
Performance (t{{ ( ,
0 1 2 3 4 5 6
Pounds per Gallon
Figufe 3
Anderson's paint line and preservations application VOC
emission rate.
• Ensure that any new or reconstructed paint line
equipment does not emit at a rate greater than
4.5 pounds of VOCs per gallon of coating ap-
plied (see Figure 3).
• Ensure that any new or reconstructed preser-
vative application process does not emit VOCs
at a rate greater than 2.0 pounds per gallon of
preservative used (see Figure 3).
• Continue to investigate the possibility of re-
cycling windows as feedstock for the Fibrex
composite process.
• Attempt to cease operation of the west diptank.
• Finalize calculations on the performance ratio
and implement the emissions caps.
- The above data will be collected and re-
ported as the project is implemented.
MPCA
• Finalize and issue the Andersen Minnesota
Project XL multimedia permit.
EPA
• Promulgate a final rule that will allow regula-
tory flexibility for this XL project.
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Washington County
Benefits for the Project Sponsor
• Amend its hazardous waste management or-
dinance.
Benefits for the Environment
• VOC emissions and PM emissions will have a
facility-wide cap. VOC emissions will be re-
duced on a per unit basis.
• Baghouse filters, or any other pollution-con-
trol devices found to be the best available tech-
nology will be installed on suitable milling
equipment.
• Andersen will continue to seek ways to en-
hance the performance of processes at the fa-
cility through its Environmental Management
System and the Corporate Pollution Preven-
tion Plan.
• Andersen will continue to produce more of its
window and door components out of environ-
mentally friendly materials, expediting the re-
ductions in its use of virgin materials.
Benefits for Stakeholders
• Stakeholders are encouraged to provide input
on the project by participating in the Commu-
nity Advisory Committee (CAC) and by keep-
ing informed of project status through a local
newsletter, Internet postings, news media con-
tacts, open houses, and local displays. The
CAC also has the opportunity to review and
comment on the various environmental reports
being generated by the project. Playing such
a high-profile role in project development and
implementation increases the participation in
and ownership of the entire process.
• CAC members will be able to stay informed
about Andersen's operations under the XL
Permit during Andersen's semiannual compli-
ance status presentations to the CAC.
• Using the performance ratio allows Andersen
greater flexibility to investigate innovative
methods for emissions reductions. As long as
VOC emissions per unit of production are be-
low the performance ratio, through this XL
project Andersen has the leeway to identify
and test new processes, pollution control de-
vices, and recycling concepts and can cease
operation and remove old equipment that re-
sults in high VOC emissions.
Information Resources
The information in this summary comes from the
following sources: (1) the FPA for the Andersen
Corporation Project, June 30, 1999; and (2) the
2000 Project XL Comprehensive Report, Volume
2: Directory of Project Experiments and Results,
November 2000.
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j\nn& y\mndeJ
(Z^Di\\r&y Bioreactor
Final Project Agreement Signed December 7, 2000
Background
The Project Sponsor: The Millersville Landfill
and Resource Recovery Facility is located on 565
acres in Severn, Maryland, approximately 15 miles
south of Baltimore. The facility is owned and op-
erated by Anne Arundel County and is the only
active municipal solid waste (MSW) landfill in the
county. The facility handles about 390 tons per
day of solid waste, of which 130 tons per day is
recovered for reuse and recycling. The facility
serves about 660 customers, including businesses
and residents.
The Experiment: Anne Arundel County proposes
to operate a small-scale, controlled, fully moni-
tored and evaluated bioreactor pilot project at the
Millersville landfill. Bioreactors provide acceler-
ated waste biodegradation, a means for recovery
of air space capacity, enhancement of landfill gas
(LFG) generation rates and leachate (which is liq-
uid percolated from the landfill material) quality,
and reduction of long-term risks associated with
landfills. Bioreactors minimize long-term risk, en-
vironmental risk, and liability due to the controlled
settlement of the solid waste during landfill op-
eration, reduced potential for leachate migration
into the subsurface environment, and the recovery
of LFG during operation. Through the recircula-
tion of leachate, the bioreactor landfill will facili-
tate microbiological processes to transform and
stabilize the decomposable organic waste within 5
to 10 years. This is expected to shorten the length
of time that the landfill liner is exposed to the
leachate and reduce the long-term threat of ground-
water contamination from the leachate.
The main goal of this project is to develop infor-
mation regarding the degree to which different
methodologies for liquid introduction could bring
about the following environmental benefits:
• Reduced need for construction of new land-
fills and corresponding reduction (or elimina-
tion) of the land, air, and water impacts
associated with landfill construction;
• Decreased concentration of most leachate con-
stituents as recycling of leachate removes or
reduces contaminants;
• Reduction in the amount of leachate requiring
pretreatment;
• Reduction in the amount of leachate that the
facility discharges to the local wastewater treat-
ment plant, and subsequent discharge of efflu-
ent to the Patuxent River; and
• Reduction in post-closure care, maintenance,
and risk (bioreactor landfills minimize long-
term environmental risk and liability due to
the controlled settlement of the solid waste
during landfill operation, low potential for
leachate migration into the subsurface envi-
ronment, and the recovery of LFG during op-
eration).
The Flexibility: The county is requesting specific
flexibility under the Resource Conservation and
Recovery Act (RCRA) that restricts application of
bulk liquids in landfills and prohibits the place-
ment of liquid waste other than leachate/gas con-
densate and non-septic household waste in any
MSW landfill. The county proposes to recirculate
the 8,000 gallons of leachate that accumulates daily
at the landfill and stormwater runoff in addition to
the leachate if the amount is determined to be in-
adequate for the purposes of the project.
Because the liner with which the facility was con-
structed meets the performance but not the design
standard set forth in CFR 258.40(a)(2), regulatory
flexibility is needed to allow the county to recir-
culate the liquids over the liner.
Additionally, the county has agreed to request and
incorporate certain changes in its Title V air per-
mit under the Clean Air Act applicable to the fa-
cility due to LFG issues that may arise because of
the bioreactor. The county and the Maryland De-
partment of Environment have negotiated an Al-
ternate Operating Scenario (AOS), which allows
LFG collection via the existing leachate collection
system, rather than from separate LFG extraction
wells and/or trenches. The county has agreed to
incorporate the AOS in their Title V permit and do
additional monitoring that was not required by the
AOS.
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Other Innovations: Testing the Bioreactor Ap-
proach. This project provides EPA with the op-
portunity to obtain data on the differing impacts
that geography, climate, construction, design, main-
tenance, and waste streams may have on the per-
formance of a bioreactor system. Also, the
Millersville Landfill Bioreactor pilot project will
provide EPA with information about the potential
for leachate recirculation and potential liquids ad-
ditions to increase landfill waste settlement rate.
The Superior Environmental Performance: The
bioreactor should provide accelerated waste bio-
degradation, a means for recovery of air space ca-
pacity, enhancement of LFG generation rates and
leachate quality, and reduction of long-term risks
associated with landfills. The Millersville
bioreactor also should minimize long-term envi-
ronmental risk and liability due to the controlled
settlement of the solid waste during landfill op-
eration, reduced potential for leachate migration
into the subsurface environment, and the increased
recovery of LFG during operation.
Progress in Meeting Commitments
(As of September 2001)
This project is in the planning stages. The follow-
ing is the status of commitments that were out-
lined in the FPA:
• EPA will propose for public comment and take
final action on a site-specific rule amending
40 CFR 258.28 applicable to the Millersville
Landfill to allow leachate recirculation.
- In September 2001 EPA provided a draft
of the rule to the county and Maryland De-
partment of the Environment (MDE) for
their input. EPA expects to publish the
proposed rule in 2001.
• The State of Maryland under its authority will
modify any permits necessary to implement the
FPA.
- The Title V Permit for the Millerville
Landfill was signed on August 29, 2001.
• The county will submit an amendment to its
Title V permit application, issued by the State
of Maryland under the Clean Air Act, which
will incorporate its obligations to monitor and
control LFG generated by this project.
- The Title V Permit issued in August 2001
contains the LFG monitoring and control
obligations of the county for the FPA of
the Anne Arundel Bioreactor Pilot project.
• The county committed to collecting, reporting,
and providing the following information to
project stakeholders, EPA, and the state as the
project is implemented:
- Semiannual reports of quantities of
leachate and other bulk liquids circulated.
- Semiannual reports on changes in the qual-
ity of the leachate.
- Semiannual reporting on settlement as
measured against monuments installed for
this purpose.
- Annual reporting and assessment of the
settlement in the test area based on topo-
graphic surveys.
- Quarterly monitoring of surface methane
emissions.
Benefits for the Environment
• Leachate recirculation can increase landfill
waste settlement, which means that the life of
a landfill can be extended and fewer landfills
need to be built.
• Any leachate from the bioreactor that ulti-
mately does require off-site disposal should be
substantially less contaminated with pollutants.
Benefits for Stakeholders
• Leachate recirculation can increase landfill
waste settlement and extend the life of a land-
fill for the local communities.
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Benefits for the Project Sponsor
• Because leachate recirculation can increase
landfill waste settlement, the project sponsor
can extend the life of its landfill.
Information Resources: The information sources
used to develop this summary are: (1) the FPA for
the Anne Arundel XL Project, signed December
7, 2000; and (2) 2000 Project XL Comprehensive
Report, Volume 2: Directory of Project Experi-
ments and Results, November 2000.
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T^flakAfic S+eel Si+e,
^Jcxc-oby Development
(Co v- po raf i o rv
Final Project Agreement Signed September 7, 1999
Background
The Project Sponsor: Started in 1979, Jacoby
Development, Inc., is a privately held real estate
company located in Atlanta, Georgia. It special-
izes in property development, financing, broker-
age, leasing, and management. Jacoby has
proposed redevelopment of a 138-acre closed steel
mill formerly owned by Atlantic Steel, located near
Atlanta's central business district. This project will
combine typical brownfield redevelopment, the
cleanup and redevelopment of a potentially con-
taminated industrial site, with transportation de-
velopment encouraging modes of transportation
beyond single-occupancy vehicles. The proposed
redevelopment, named Atlantic Station, will be a
mix of residential and business uses and will in-
clude a multimodal bridge, accommodating cars,
pedestrians, bicycles, and mass transit. The bridge
will provide access to Interstates 75/85 from the
site and connect it to a nearby Metropolitan At-
lanta Rapid Transit Authority (MARTA) station.
The Experiment: The Atlantic Steel project will
test whether brownfield redevelopment strategies
can be applied to transportation projects as part of
an overall community revitalization plan, such that
air quality and other environmental performance
can be improved. The Atlanta region is currently
not in compliance with the National Ambient Air
Quality Standards (NAAQS) for ground-level
ozone. Between January 1998 and July 2000, the
Atlanta region was out of compliance with trans-
portation conformity requirements under the fed-
eral Clean Air Act (CAA) because it could not
demonstrate that its transportation activities would
not exacerbate its air quality problem. The CAA
generally prohibits construction of new transpor-
tation projects that use federal funds or require fed-
eral approval in areas that are in a transportation
conformity lapse. However, projects that are ex-
pected to provide an air quality benefit, called
Transportation Control Measures (TCMs), can pro-
ceed even during a conformity lapse if they are in
a federally approved State Implementation Plan
(SIP), which is used to address how the region will
conform to the NAAQS. If the Atlantic Steel site
is not redeveloped, the development planned for
the site will likely occur at another site or sites in
the Atlanta region. Alternate development would
most likely occur in a greenfield area, thus pro-
moting urban sprawl. The redevelopment of the
Atlantic Steel site will encourage "smart growth"
design principles such as pedestrian-friendly and
transit-oriented access between centers of residen-
tial entertainment, cultural, employment, and rec-
reational uses, thus reducing vehicular traffic and
encouraging a neighborhood environment. EPA
believes that the planned redevelopment of the
Atlantic Steel site, including the bridge, will lead
to less air pollution than an equivalent amount of
development at other likely sites in the region.
The Flexibility: Under the Atlantic Steel project,
EPA is considering the entire redevelopment
project to be a TCM. For the Atlantic Steel site to
qualify as a TCM, EPA is offering flexibility in
two areas:
(1) EPA views the site's location, design transit
linkage, and other transportation components
(e.g., provisions for bicyclists, participation in
a transportation management association) to-
gether as the TCM. While the CAA lists sev-
eral types of projects that can be TCMs, the
statute does not limit TCMs to these measures.
Specific types of TCMs listed in the CAA in-
clude projects that improve public transit, em-
ployer-based transportation management
plans, projects that limit certain metropolitan
areas to non-motorized and pedestrian use, and
programs to provide both travel and storage
facilities for bicycles. The plan for the Atlan-
tic Steel redevelopment incorporates many el-
ements that could be TCMs by themselves. For
example, improved public transit, bicycle and
pedestrian paths, and the requirement that
employers at the site will join or form a trans-
portation management association. EPA be-
lieves that the combination of these elements
will have a positive effect on reducing emis-
sions from single occupancy vehicles by en-
couraging the use of alternative modes of
transportation.
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(2) This project is testing an innovative approach
to determining the air quality benefit of the
Atlantic Steel site redevelopment. EPA has
modeled the site development's potential air
quality benefit relative to an equivalent level
of development at other sites in the region.
This type of comparison to support a TCM is
available only to this particular redevelopment
project through the Project XL process. The
site's SIP-TCM designation is possible because
a 1998 study conducted by EPA's Urban and
Economic Development Division, titled
"Transportation and Environmental Impacts of
Infill and Greenfield Development," demon-
strated that the Atlantic Steel brownfield re-
development, with its mixed-use and transit
components, would generate a relative air qual-
ity benefit when compared to a similar devel-
opment located some distance outside of the
central business district, in a greenfield loca-
tion. To analyze the transportation and air
emissions impacts of locating new develop-
ment at the Atlantic Steel site, EPA used mod-
eling analysis to compare the site to three other
possible locations for similar-scale develop-
ment in the Atlanta region. EPA's evaluation
of the site's impacts was driven by two facts:
(1) that Atlanta will continue to grow over the
next 20 years and (2) that without redevelop-
ing the 138-acre Atlantic Steel site, more of
this growth will occur in outlying areas. The
analysis of regional transportation and air
emissions impacts shows that absorbing a por-
tion of Atlanta's future growth at the Atlantic
Steel site would result in fewer vehicle miles
traveled and fewer emissions than would de-
veloping those alternative sites.
1 he Superior Environmental Performance:
Without designation as a TCM, this project could
not move forward as currently conceived and the
Atlantic Steel mill could remain an industrial blight
in midtown Atlanta. As a former steel mill, envi-
ronmental contamination exists within the buildings
and in surrounding soils. The Atlantic Steel project
provides the means to clean up these contaminants
and return the site to a beneficial role in the com-
munity. Jacoby has proposed using environmen-
tally friendly building practices, which will
minimize both the environmental impact made dur-
ing construction and the long-term impact of the
building by reducing waste water and increasing
energy efficiency. The mixed-use component of the
proposed redevelopment (bringing together residen-
tial, recreational, and commercial buildings nearby
to each other), in conjunction with its proximity and
linkages to mass transportation and the pedestrian
and bicycle access that will be provided by the new
17lh Street bridge, will encourage use of modes of
transportation other than vehicular travel. This will
reduce not only annual vehicle miles traveled in
Atlanta, but also the air pollutants produced by those
vehicles. Because of its design, use of existing trans-
portation infrastructure, and location, redevelopment
of the Atlantic Steel site can improve rather than
exacerbate current air quality problems in the re-
gion. Jacoby Development has renamed the site
"Atlantic Station" to capture the historical legacy
of the site and also to create a new identity for the
unique multi-use environment. An interactive
t
I-iguee
An artist's rendering of what Atlantic Station may look like.
Atlantic Station will combine residential, business, and
recreational spaces.
(Photo from http://www.atlanticstation.com)
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media presentation of Atlantic Station, including
drawings and potential layout designs of the future
site, can be accessed at http://www.atlantic
station.com. (See Figure 4.)
Progress in Meeting Commitments
(As of July 2001)
Jacoby Development Corporation
• Jacoby committed to redeveloping the Atlan-
tic Steel site into a mixed-use development,
providing transportation links to MARTA.
- A detailed site plan was completed Febru-
ary 2, 1998. The mayor of Atlanta ap-
proved the required zoning changes in
April 1998.
- Jacoby completed demolition of the old
Atlantic Steel mill structures during the
summer of 2000.
- Metals, oxidized steel products, concrete,
used oil, lead acid batteries, power trans-
formers, and railroad crossties were re-
cycled from the demolition site.
- Jacoby began remediation of the most con-
taminated soils ("hot spots") and an exist-
ing small Resource Conservation and
Recovery Act (RCRA)-permitted facility
using excavation and disposal at off-site
landfills in January 2000. The slag that re-
mains on-site will be covered by at least
two feet of clean fill material. A long-term
groundwater collection and monitoring
system is part of this remediation.
Remediation and infrastructure improve-
ment will continue through the first quar-
ter of 2002.
- Jacoby intends to work with builders and
users of the property to encourage their
participation in the Green Building
Council's "Leadership in Energy and En-
vironmental Design" (LEED™) program
and attain the requirements for the LEED
Building Bronze™ designation. To reduce
the use of water, Jacoby is promoting the
use of water flow restrictors, innovative
uses of "gray water," the use of drought-
tolerant indigenous plant species, and the
use of the Hemphill Water Plant backwash
water to reduce irrigation needs at the site.
- Jacoby plans to install separate stormwater
and sanitary sewer systems on-site, using
best management practices, to reduce fu-
ture impacts on water quality. An on-site
erosion and sediment control facility will
be built to control all surface water runoff
from the site.
- Vertical construction of the first phase of
the redevelopment project will begin con-
currently with infrastructure development
and is expected to be completed in Octo-
ber 2002.
• The short-term transit linkage from the Atlan-
tic Steel site to the MARTA Arts Center Sta-
tion will consist of shuttle buses circulating
between the Arts Center Station and the At-
lantic Steel site. Jacoby is working to acquire
the initial shuttle buses, which will begin op-
eration when the 17th Street bridge is open to
traffic. MARTA is still considering the long-
term transit linkage, which could include a
light rail system traversing the Atlantic Steel
site and the 17,h Street bridge.
• Data collection will begin the year following
the opening of the 17lh Street bridge to single
occupancy vehicles and continue until 10 years
following redesignation by EPA of the Atlanta
area to attainment under the NAAQS for
ozone. Data will include (1) average daily
vehicle miles traveled per resident, (2) aver-
age daily vehicle miles traveled per employee
working at the site, (3) the percentage of all
trips by mode made to and from the site by
residents and employees, and (4) origin and
destination data for trips made to, from, and
on the site by residents and employees. The
data will be submitted annually to the City of
Atlanta.
• The first XL public meeting was held in Sep-
tember 1998, in conjunction with the rezon-
ing process. An annual summary of the project
was completed in February 2000. A
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stakeholder meeting and Periodic Performance
Review Conference were also held in Febru-
ary 2000 to inform local stakeholders of the
progress and status of the project.
• The Baltimore (Maryland)-based Development
Design Group was chosen to design Atlantic
Station's street-oriented retail and entertain-
ment sections. Preliminary plans call for a
large public town center with sidewalk cafes,
fountains, and a central park feature.
Georgia Environmental Protection Division
• Georgia Environmental Protection Division
(EPD) committed to playing an active role in
this project.
- The site remediation plan was approved
in December 1999.
- The TCM was approved by the Atlanta Re-
gional Commission in June 1999 and
passed to Georgia EPD. The revised SIP,
incorporating the TCM, was submitted to
EPA in March 2000.
- Georgia EPD has approved a conservation
easement meant to ensure that both the bar-
riers to contaminated slag and the ground-
water collection and monitoring system
remain intact. The site owner will be re-
sponsible for any required mitigation mea-
sures.
EPA
• EPA committed to playing an active role in
this project.
- EPA approved the revised SIP on August
28, 2000. It became effective September
27, 2000.
- EPA issued a Finding of No Significant
Impact in December 2000 based on an en-
vironmental assessment of the impacts of
the redevelopment project, including the
proposed 17
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demolition of the existing structures on the
property.
• Jacoby will comply with state laws and build-
ing codes that require all newly constructed
properties to reduce water use.
Benefits for Stakeholders
• Stakeholders have been involved throughout
the evolution of the project and have been en-
couraged to share their ideas and concerns
through written comments and meetings open
to the general public.
• Stakeholders are enabled to participate in the
planning of a residential village incorporating
smart growth design principles promoting pe-
destrian-friendly walkways, transit links, shop-
ping, entertainment, office, recreation, and
open park spaces.
Stakeholder needs and values are an integral
part of the 17,h Street bridge/extension. URS
Greiner will design a bridge that serves to ac-
commodate various modes of transportation,
the demands of the site, as well as an architec-
turally pleasing structure to all the users. The
bridge is anticipated to include (1) two 11 -foot-
wide lanes in each direction for general use
traffic; (2) two 16-foot-wide dedicated bicycle
and transit lanes; and (3) a 24-foot-wide pe-
destrian park and thoroughfare, complete with
elevated walkways, landscaping, and acrylic
panels rather than metal fencing.
Benefits for the Project Sponsor
• Jacoby will be granted regulatory flexibility
under Project XL by receiving approval of the
redevelopment and its associated transporta-
tion projects as a TCM, a step taken to reduce
vehicular emissions and improve air quality.
In return, Jacoby is working to bring a con-
taminated site back to productive use and, in
turn, examine whether the basis for consider-
ing the entire redevelopment project a TCM
can leverage environmental benefits in air qual-
ity.
Information Resources: The information in this
summary was obtained from the following sources:
(1) the February 15,2000, Atlantic Steel XL Sum-
mary Report; (2) the September 7, 1999, Atlantic
Steel FPA; (3) the December 1999 XL Project
Progress Report—Atlantic Steel Redevelopment
(EPA 100-R-00-014); (4) Project XL Stakeholder
Involvement Evaluation, Draft Final Report (April
2000); (5) news articles from the Atlanta Journal
Constitution: "Steely Determination: Green Light
is Given for Design Work on 17th Street Bridge"
(August 25, 2000), "Designer Sees 17th Street
Bridge as Unique Gateway into Atlanta" (August
25, 2000), "Development Plan Falls into Place"
(August 25, 2000); (6) news article from
Bizjournals.com/atlanta: "Designer Picked for 17lh
Street Bridge" (August 24,2000); and (7) the 2000
Project XL Comprehensive Report Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
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y\u+oliv ;AS"F/ vUkvc.
Final Project Agreement Signed September 20, 2000
Background
The Project Sponsor: Autoliv ASP, Inc.,
(Autoliv) is a manufacturer of automobile safety
products. Autoliv's Pyrotechnic Processing Facil-
ity is located in Promontory, Utah, a remote area
of Box Elder County. The Promontory facility
manufactures pyrotechnic products (explosives) for
airbags and pretensioners, which tighten a seatbelt
during the first fractions of a second in a crash.
Both items depend on pyrotechnics to be activated.
The facility consists of 75 storage and manufac-
turing buildings concentrated on a 53-acre site. The
only bordering neighbors are another business and
a winter cattle range. The extended surrounding
area consists of the small farming/ranching com-
munities of Howell, located approximately 10
miles to the north, and Promontory, located eight
miles to the west. In its facility, Autoliv currently
operates a highly advanced, metals recovery facil-
ity (MRF) designed to process and recover alumi-
num and steel from previously fired airbag inflator
units. The MRF collects emissions created during
the incineration process and significantly reduces
release of gases and particulate matter to the at-
mosphere. In addition, certain metals, such as alu-
minum, steel, and copper can be recovered during
processing in the MRF and recycled.
The Experiment: During the manufacturing of
pyrotechnic materials, reactive hazardous wastes
are generated. These wastes are currently treated
off-site at a treatment, storage, and disposal facil-
ity that is permitted to accept hazardous waste from
outside sources and treats it via open burning. Al-
though open burning is a safe and effective treat-
ment method for reactive wastes, it allows for no
pollution controls.
In this XL Project, Autoliv is currently in the pro-
cess of adapting the technology and pollution-con-
trol devices used in the MRF to process its waste
pyrotechnic materials on-site rather than sending
the materials off-site for open burning. The emis-
sions from the pyrotechnic materials, if processed
at the MRF, would pass through the air pollution-
control train rather than being emitted, thus achiev-
ing a significant reduction of air pollutants released
to the environment. Additionally, Autoliv expects
to recover and recycle additional materials, such
as copper, from the MRF-processed pyrotechnic
materials. Autoliv will reinvest a percentage of
the savings achieved by this project into additional
pollution prevention activities at their facility.
The Flexibility: Although the Resource Conser-
vation and Recovery Act (RCRA) classifies pyro-
technic waste as a reactive hazardous waste, the
material produced at the Promontory facility does
not contain hazardous materials. Autoliv is re-
questing regulatory flexibility to allow the treat-
ment of pyrotechnic waste on-site instead of
transferring it to a separate facility for open burn-
ing. EPA published a site-specific rule on May 9,
2001, which exempted Autoliv from certain RCRA
Part B requirements that regulate hazardous waste
treatment, storage, and disposal, and permitted it
to process the waste in the MRF.
Before Autoliv can proceed with this project, the
Utah Department of Environmental Quality must
amend state standards applying for hazardous
waste disposal. The Utah Division of Air Quality,
which regulates the processing operations of airbag
inflators and their components, will issue an Ap-
proval Order for this innovative pyrotechnic waste
disposal process. With the requested federal and
state regulatory flexibility, Autoliv can safely and
effectively dispose of their pyrotechnic material
in the MRF while reducing emissions/pollutants
to the environment.
The Superior Environmental Performance:
With this project, Autoliv expects that the follow-
ing superior environmental benefits will be
achieved:
• Reduction of air emissions as a result of the
minimization of open pit burning of pyrotech-
nic waste;
• Elimination of the open burning of 158,000
pounds of pyrotechnic material per year, which
in turn eliminates 22,876 pounds per year of
particulate emissions;
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• Recycling of copper and other materials found
in the slag of MRF-processed pyrotechnic
materials, which can then be recycled back to
Autoliv's raw material suppliers, reducing the
demand for additional raw materials; and
• Elimination of the risk associated with trans-
porting hazardous pyrotechnic materials to an
outside processor.
Progress in Meeting Commitments
(As of September 2001)
The Autoliv FPA includes the following commit-
ments:
• EPA and the State of Utah committed to issu-
ing a site-specific rule exempting the pyrotech-
nic waste generated at the Autoliv Promontory
facility from being classified as a hazardous
waste subject to RCRA regulation.
- EPA finalized the site-specific rule and
published the rule in the Federal Register
on May 9, 2001. The State of Utah Divi-
sion of Solid and Hazardous Waste com-
pleted the state rulemaking
(R315-2-4(b)(16) of the Utah Administra-
tive Code) on September 4, 2001.
• Autoliv has committed to characterizing all
waste materials processed and conducting an
initial stack test to evaluate the safety and ef-
ficiency of the MRF system. Autoliv will
maintain an MRF Operating Record, includ-
ing waste feed composition, feed rates, tem-
peratures, pressures, upset conditions, spills
and releases, and so forth at the Promontory
facility.
• Autoliv will confer with stakeholders at a Pe-
riodic Performance Review Conference to be
held at least every six months.
• Autoliv will provide EPA and the State of Utah
semiannual reports by January 30 and July 30
of each year.
Benefits for the Environment
• During 1998 and 1999,183,557 pounds of py-
rotechnic waste was disposed of by open burn-
ing. Autoliv aims to eliminate the open
burning of 158,000 pounds of pyrotechnic
waste during the first year of the project, which
would eliminate approximately 22,876 pounds
of particulate emissions.
• Recovery and recycling of metals in the pyro-
technic materials will be a significant benefit
for the environment. Copper and other mate-
rials found in the slag of the MRF-processed
pyrotechnic materials could be recovered and
recycled by Autoliv's raw materials suppliers.
• The recovery of materials from the MRF slag
results in a minimized waste stream. With the
volume of waste generated reduced and the as-
sociated recovery of heavy metals, less waste
will be sent to landfills.
• Part of Autoliv's cost savings from the XL
project will be used to fund pollution preven-
tion activities through an Environmental Re-
investment Project. The type and extent of
these activities will be specified after the first
year's cost savings are calculated.
Benefits for Stakeholders
• This project eliminates the risk associated with
transporting hazardous pyrotechnic materials
to an outside processor. Pyrotechnic waste
would no longer be transported across public
roads, resulting in increased public safety and
reductions to Autoliv's liability.
Benefits for the Project Sponsor
• The MRF is already functioning at the Autoliv
Promontory facility. Additional operating
costs for disposing of pyrotechnic wastes in
the MRF will be minimal. With onsite dis-
posal, Autoliv expects to save an estimated
$316,000 in disposal costs in the first year be-
cause wastes will not have to be transported
off-site for open burning.
-------
• In addition, paperwork will be minimized by
the reduction in hazardous waste manifests and
shipping papers.
Information Resources: The information sources
used to develop this progress report include: (1)
the Final Project Agreement for the Autoliv XL
Project, signed September 20, 2000; and (2) the
2000 Project XL Comprehensive Report Volume
2: Directory of Project Experiments and Results,
November 2000.
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3urvcombe C^our&y
Bi o^e.acfor
Final Project Agreement Signed September 18, 2000
Background
The Project Sponsor: Buncombe County oper-
ates a Solid Waste Management Facility
(BCSWMF) on a 600-acre site along the French
Broad River in the Blue Ridge Mountains in west-
ern North Carolina. It is owned and operated by
the Buncombe County General Services Depart-
ment. The facility serves only Buncombe County,
which has six municipalities: Asheville, Biltmore
Forest, Black Mountain, Montreat, Woodfin, and
Weaverville. The municipal solid waste (MSW)
landfill was opened in September 1997 and was
designed to accommodate up to 10 separate dis-
posal cells that could be constructed sequentially
over the estimated 30-year life of the facility.
BCSWMF is one of the 10 largest publicly owned
MSW landfills in the state. It accepts approxi-
mately 100,000 tons of waste per year from the
area's 200,000 residents, a population that contin-
ues to grow at a rate of 2 percent per year. In addi-
tion to the approximately 100-acre MSW landfill,
Buncombe operates a construction and debris land-
Fill, a wood waste mulching facility, a convenience
center for residential waste disposal and recycling,
and a drop-off area for certain goods and tires on
the remainder of the 600-acre site.
The Experiment: Over the past two years, Bun-
combe County has been researching a new method
for operating sanitary landfills—the bioreactor
method. The bioreactor method involves the re-
circulation of leachate during the operational phase
of the landfill to enhance and accelerate waste de-
composition and landfill gas generation. Leachate
is the liquid that drains from the waste. Through
this XL project, Buncombe County will construct
and operate a bioreactor on the 100-acre MSW
landfill area at BCSWMF. Using the bioreactor
system, controlled quantities of liquid will be added
and circulated through the waste, as appropriate,
to accelerate the natural biodegradation process and
composting of solid and liquid waste components.
This process significantly increases the biodegra-
dation rate of waste and, thus, decreases the waste
stabilization and composting time (5 to 10 years)
relative to what would occur within a conventional
landfill (30 to 50 years or more). Likewise, as the
biodegradation rate is increased, the amount of
landfill gas produced will be concentrated in 5 to
10 years, as opposed to smaller amounts of meth-
ane over 30 to 50 years. Research suggests that
when different portions of the landfill are com-
pared, an alternative liner offers 50 percent more
protection to the underlying aquifer than the stan-
dard composite liner.
The primary goal of this XL project will be to dem-
onstrate that leachate can be recirculated safely
over an alternate liner system at a full-scale level,
something not currently allowed under Resource
Conservation and Recovery Act (RCRA) Subtitle
D landfill regulations. The Buncombe County
Landfill project is composed of five basic compo-
nents: (1) a combined leachate circulation and gas
collection system, (2) horizontal trenches, (3) a
pressure injection system, (4) active gas collec-
tion, and (5) an alternative liner system.
The Flexibility: Currently, under both federal and
state regulations, leachate recirculation is allowed
using only the RCRA standard Subtitle D com-
posite liner system. BCSWMF proposes recircu-
lating leachate over an alternative liner. This
project will require federal and regulatory flexibil-
ity for the full-scale experiment to proceed. EPA
proposed and issued a site-specific rule amending
40 CFR Part 258.28 (RCRA Criteria for Munici-
pal Solid Waste Landfills, Liquid Restrictions),
allowing Buncombe County to recirculate leachate
into its landfill units constructed with an alterna-
tive liner system. North Carolina's Department of
Environment and Natural Resources (NCDENR),
Division of Waste Management, is the statutorily
designated agency for permitting and regulation
of municipal solid waste landfills in North Caro-
lina. The Division of Waste Management will re-
view Buncombe County's application for the
proposed leachate recirculation and gas recovery
system in accordance with state statutes and with
the EPA site-specific rule. Upon approval of the
application, NCDENR will issue Buncombe
County a permit to construct the first five-year
-------
phase of the project. EPA and the State of North
Carolina will also allow Buncombe County to
supplement the leachate flow with water from the
French Broad River to maintain moisture levels
within the landfill. In the future, the county may
seek a delay in the federal and state closure rule
requirements, allowing it to continue to recircu-
late leachate even after a cell has reached its per-
mitted final grade, so that it may return and place
additional waste when the expected settlement
occurs.
Other Innovations: (1) Testing Bioreactor and
Liner Performance. By allowing BCSWMF to
conduct a bioreactor project with the alternative
liner, Buncombe County, the State of North Caro-
lina, and EPA will receive important information
about the performance of the alternative liner. In
addition to this information, data collected through-
out the project will help environmental engineers
and scientists understand the important parameters
in bioreactor functioning, such as leachate quality
and quantity, recirculation techniques, temperature,
moisture content, and stabilization. The Buncombe
County project is important in this field since, as a
long-term project, it has the potential to dramati-
cally increase the understanding of and opportu-
nity for bioreactors. Buncombe County will
generate a baseline of current landfill performance
to compare against future bioreactor results. (2)
Testing the Potential of Gas as Energy. Because
bioreactor projects increase the rate and quantity
ol methane gas generated, it can make gas-to-en-
ergy projects more feasible. Buncombe County is
currently in the initial stages of evaluating the pos-
sibility of converting captured landfill gas to a fuel
usable by county vehicles. (3) Providing Examples
to EPA for Potential Rulemaking Changes. On
April 6, 2000, EPA published a document in the
Federal Register considering whether and to what
extent the Criteria for Municipal Solid Waste Land-
tills, 40 CFR part 258, should be revised to allow
for leachate recirculation over alternative liners in
MSW landfills. The Buncombe County project,
in conjunction with other XL bioreactor projects,
will allow EPA to evaluate benefits of alternative
liners and leachate recirculation systems under
various terrains and operating conditions. (4) Ad-
aptation to Changes in Waste Streams Over Time.
As market preferences shift and consumer inter-
ests change, the overall characteristics of waste
going into the landfill over time may change as
well. This project, lasting the lifetime of the land-
fill, permits Buncombe County and EPA to gauge
the behavior and effectiveness of bioreactors over
time and changes in inputs. (5) Lessened Long-
term Risk and Needfor Monitoring. The bioreactor
method of landfill operation offers potential for
substantial reductions in post-closure care needs
and costs. This project will study whether, as pre-
dicted, rapid decomposition will reduce long-term
risk of groundwater contamination and gas migra-
tion.
The Superior Environmental Performance:
Buncombe County's commitment to develop and
test bioreactor technologies at their solid waste
management facility demonstrates a commitment
to pursuing innovative pollution prevention strat-
egies for dealing with MSW, which have been
shown to provide increased protection above and
beyond that sought by existing RCRA regulations.
Leachate recirculation and other bioreactor tech-
nologies provide a high degree of innovation for
managing leachate and environmental quality at
MSW landfills. Although not new technologies,
they are not widely used in the United States. This
project will enable BCSWMF the ability to docu-
ment and test the results of these technologies and
provide EPA and the waste disposal industry with
data supporting the use of bioreactors and promote
the use of bioreactors as an integral part of long-
term operations at these and other municipal solid
waste landfill sites.
Progress in Meeting Commitments
(As of August 2001)
EPA and Buncombe County committed to the fol-
lowing in the FPA:
EPA committed to propose and issue a site-
specific rule amending 40 CFR Part 258.28 for
Buncombe County to allow recirculation of
leachate over cells constructed with an alter-
native liner.
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- The rule was proposed on April 16, 2001.
The final rule was promulgated on August
22, 2001.
• NCDENR, Division of Waste Management,
committed to review Buncombe County's per-
mit application for the first five-year phase of
the proposed leachate recirculation and gas re-
covery system at the landfill in accordance with
applicable state statutes and rules and consis-
tency with the site-specific rule promulgated
by EPA. If the Division determines that the
application meets all of the applicable require-
ments, the Division will issue a permit to con-
struct the first five-year phase of the project.
• Buncombe County committed to having the fi-
nal design of the combined leachate recircula-
tion and gas recovery system completed by the
end of 2000.
• Buncombe County committed to prepare semi-
annual reports that will include all monitoring
data. These reports will be provided to EPA
and stakeholders.
• Buncombe County committed to hold an an-
nual meeting to review the project progress and
results to date for as long as Buncombe County
continues to recirculate leachate at the site
under the provisions of the site-specific rule.
Benefits for the Environment
• The Bioreactor system is expected to maxi-
mize landfill gas control and capture and mini-
mize fugitive methane and volatile organic
compound emissions into the environment.
• Leachate recirculation promises more rapid
leachate stabilization in terms of pollutant load,
reduced leachate environmental impact, and
elimination of the need for most discharges to
treatment facilities. Improvements in leachate
quality are expected to consist of organic com-
pound reduction through increased biological
activity and inorganic reductions by adsorp-
tion to the waste mass and soil and by chemi-
cal reactions, such as metals precipitation.
Benefits for Stakeholders
• Throughout the evolution of the project, stake-
holders have been involved in and informed
about this project and have been encouraged
to share their ideas and concerns through writ-
ten comments and meetings open to the gen-
eral public.
• Because leachate from the Buncombe County
facility is hauled by tanker truck from the fa-
cility to the publicly owned treatment works,
the reduction in the amount of leachate requir-
ing treatment resulting from the bioreactor sys-
tem will result in fewer tanker trucks on the
road, creating a safer situation for nearby resi-
dents.
• The recirculation of leachate and other liquids
has been demonstrated to increase the rate and
quantity of gas generation. Increased quanti-
ties of gas can make a gas-to-energy project
more feasible, which provides added potential
economic opportunities to the community and
BCSWMF by providing an alternative form
of energy.
Benefits for the Project Sponsor
• Buncombe County realized a significant eco-
nomic benefit, saving nearly $400,000, when
constructing Cell 3 of the landfill using the al-
ternative liner rather than the standard com-
posite system. The county estimates that it will
save a total of $5 million through the build out
of the facility if the alternative liner system is
used on all the cells.
• Increased landfill disposal capacity due to
rapid settlement during the operational period
of the landfill will lead to more economical
operations. Buncombe County estimates a
potential cost savings of $5 to $10 million in
reduced construction costs for additional land-
fill capacity if the anticipated increase of 20
to 30 percent in additional waste volume can
be achieved due to rapid waste decomposition.
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• The county is also estimating a savings of $9
million over the life of the landfill if leachate
hauling and off-site treatment can be elimi-
nated due to recirculation.
• The rapid waste stabilization that occurs
through bioreactor system will result in a re-
duction in the post-closure care, maintenance,
and risk burden felt by Buncombe County.
Rapid decomposition of the waste during and
shortly after disposal operations cease will
likely reduce the potential for the facility to
generate significant quantities of high-strength
leachate.
Informational Resources: The information in
this summary comes from the following sources:
(1) the FPA for the Buncombe County Bioreactor
Project, signed September 18, 2000; (2) the 2000
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000; and (3) final rule published on
August 22, 2001.
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(Skicago Regiov\cx \Air
Qualify and (Scorvomic
Development Strategy
Final Project Agreement Signed December 8, 2000
Background
The Project Sponsor: The Chicago Department
of Environment (DOE) is working with other met-
ropolitan communities to address the area's desig-
nation of severe ground-level ozone nonattainment.
This, in part, means that the region exceeds the
ozone levels necessary to protect human health and
the environment. The Chicago metropolitan ozone
nonattainment region comprises six counties and
parts of two additional counties in the northeast-
ern section of the State of Illinois. At more than 9
million inhabitants, the six-county area, with Chi-
cago at its core, contains approximately two-thirds
of Illinois' residents. The region's nonattainment
status impacts regional health as well as regional
economic development by increasing the cost for
an industry that wishes to locate or expand in the
nonattainment area.
The Experiment: This XL project establishes an
innovative approach that integrates clean air and
economic growth goals. By sharing the burden of
emissions reductions among industrial point
sources and non-industrial mobile and area sources,
communities and industry can work together to
reduce emissions beyond what would be achieved
by industry alone and retire some of those emis-
sions capacities permanently, creating cleaner re-
gional air. Under the Clean Air Act (CAA), in
order for a new major facility or major modifica-
tion to an existing facility to occur in a
nonattainment region, the new source must achieve
the lowest achievable emissions rate (LAER) and
obtain emission offsets by purchasing emissions
capacity from other industrial facilities at a ratio
of 1.3 tons reduced to 1 ton permitted. Under this
project, new or expanded industrial sources would
still be required to meet LAER requirements but
would not be required to obtain traditional offsets
from other industrial point sources as described
under 173(a)(1)(A) of the CAA. Instead, the City
of Chicago and surrounding regional municipali-
ties will reduce emissions at the local non-indus-
trial level, including mobile source reductions
(e.g., by way of environmentally friendly commut-
ing and alternative fuels) and localized area sources
(e.g., by banning small incinerators). The emis-
sions reduction will be generated by individuals
and communities and then quantified, tracked, and
submitted to the Illinois EPA and EPA. These re-
ductions will be used to create a "growth allow-
ance," which, in turn, will be used in lieu of
traditional CAA industrial offsets at the same 1.3
to 1 ratio. The growth allowance would be avail-
able to companies who locate in proposed "devel-
opment zones" as defined by EPA in consultation
with the Secretary of Housing and Urban Devel-
opment. The criteria identify zones that promote
environmentally sound development and the pres-
ervation of open space and sites that have adequate,
existing infrastructure. Although it is extremely
difficult to predict how many emissions reductions
will be generated, it is estimated that three to seven
tons of emissions reductions per day of volatile
organic compounds (VOCs), an ozone precursor,
may be realized under this project.
The Flexibility: While no federal site-specific
rule will be required for this project, the Chicago
DOE will utilize the flexibility that is present in
Section 173(a)(1)(B) of the CAA. This flexibility
has never been tested and will allow Chicago DOE
to generate new types of emissions reductions that
have not previously been pursued and count them
towards a growth allowance for new and expand-
ing business and inclusion in the State Implemen-
tation Plan (SIP) under the CAA. All emission
reduction programs credited in this XL program
must be surplus and excess to what is already in
the SIP and to what Illinois needs to reach attain-
ment of the one-hour ozone standard. The exist-
ing Emissions Credit Banking and Trading
Program, as authorized in Section 11-4-575 of the
Chicago Municipal Code will ensure that any re-
cipient of growth allowance credits is located or
will be located in an approved development zone.
Other Innovations: (I) Testing Section
173(a)(1)(B) of the Clean Air Act. This project is
testing whether this seldom used flexibility in the
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CAA shows promise as a tool to create incentives
for a community or group of communities to ad-
dress its air quality issues in a comprehensive fash-
ion, including flexibility between point and
non-point source reductions and creating a more
favorable environment for job-creating economic
activity in areas where it is needed most, the urban
core. (2) Quantifying the Emissions Reductions of
Individuals and Communities. This project at-
tempts to quantify emission reductions created by
the actions of individuals, communities, and busi-
nesses and not simply large industrial sources. By
taking these more diffuse and individualistic emis-
sion reduction activities out of the realm of "in-
tangible benefits" and placing them in the realm
of real economic benefits, this project is testing
whether demand will be created and a positive ef-
fect on the environment gained. (3) Preservation
of Open Space. Using development zone criteria
that provide financial incentives to businesses for
locating in areas where infrastructure such as utili-
ties and transportation exist may result in preser-
vation of open space and farmland in the outer
suburban rings of the Chicago metropolitan area.
The Superior Environmental Performance: The
superior environmental benefits that are expected
to accrue from this project include (1) exceeding
emission reductions beyond what is necessary to
demonstrate attainment of National Ambient Air
Quality Standards; (2) retiring some percentage of
the emissions capacity generated by emissions re-
ductions above what is needed to demonstrate at-
tainment; (3) creating an incentive to direct new
economic growth to largely urban development
areas, thereby reducing urban sprawl and related
negative environmental factors such as traffic con-
gestion and development of open space and farm-
land; and (4) creating an incentive for communities
and individuals to work hard to achieve reductions
in mobile and area pollution sources above fed-
eral and state goals.
Progress in Meeting Commitments
(As of September 200J)
Chicago DOE
* Generating and keeping data on emissions re-
ductions with other participants and stakehold-
ers in the Campaign for Clean Air and Devel-
opment.
- Chicago DOE has begun and will continue
to generate and keep data on emissions re-
ductions.
Following the processes described in the Stake-
holder Participation Plan for the duration of
the project.
- This is an ongoing regional effort to in-
clude public input into emissions reduc-
tion strategies. Stakeholder participation
will continue as reduction plans are fully
implemented.
• Working with EPA, Illinois EPA, and interested
parties to implement emission reduction pro-
grams, including the quantification and track-
ing of emission reductions (the tracking system
must be approved by EPA prior to implemen-
tation of this project).
- Chicago DOE is working with EPA and
Illinois EPA to develop and implement
emissions reduction programs. A formal
process for tracking reductions has not yet
been implemented.
• Permitting the use of the growth allowance
only for sources located in a development zone
identified under this project.
- Emissions reduction programs are in de-
velopment, but the project has not reached
the stage of issuing permits for sources
using growth allowances.
EPA
• Using Section 173(a)(1)(B) of the CAA as the
basis for identifying zones to which economic
development should be targeted (development
zones).
- Criteria for development zones follow Sec-
tion 173(a)(1)(B) and have been outlined
in the FPA.
• Working with Chicago DOE, other participat-
ing municipalities, and interested parties to
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establish, track, and enforce the growth allow-
ance prior to implementation of this project.
- This is an ongoing process.
• Ensuring that no emissions reductions used in
the SIP to demonstrate attainment of the one-
hour ozone standard will be used as credits in
the growth allowance.
- Illinois EPA submitted an attainment dem-
onstration for one-hour ozone standard that
did not rely on the emission reductions as-
sociated with the XL project. EPA ap-
proved the demonstration.
• Ensuring that the system for verifying and
tracking emissions reductions is made avail-
able to the public, that the public has suffi-
cient information to independently verify the
reductions, and that the public receives timely
and detailed information on the use of the
growth allowance.
- EPA will continue to use existing regional
public outreach efforts to get input on
emission reduction activities being devel-
oped. This includes input from commu-
nity groups, businesses, nonprofit
organizations, and other government agen-
cies.
Illinois EPA
• Working with the Chicago DOE, other partici-
pating municipalities, and interested parties to
establish, track, and enforce the growth allow-
ance prior to implementation of this project.
- This is an ongoing process.
• Submitting a SIP that demonstrates attainment
of the one-hour ozone standard.
- Illinois EPA submitted an attainment dem-
onstration for one-hour ozone standard that
did not rely on the emission reductions as-
sociated with the XL project.
• Reviewing terms of this project and their rules
to ensure that the project is allowable under
the Illinois SIP.
- Illinois has completed its review.
• Ensuring that no emissions reductions used in
the SIP to demonstrate attainment of the one-
hour ozone standard will be used as credits in
the growth allowance.
- This is an ongoing commitment. Illinois
has ensured that no emissions reductions
used in the SIP will be used as credits in
the growth allowance.
• Establishing accounting mechanisms for track-
ing emissions reductions above and beyond the
attainment plan.
- Illinois EPA is working with Chicago DOE
and EPA to develop and implement emis-
sions reduction programs. A formal pro-
cess for tracking reductions has not yet
been implemented.
• Ensuring that the system for verifying and
tracking emissions reductions is made avail-
able to the public, that the public has suffi-
cient information to independently verify the
reductions, and that the public receives timely
and detailed information on the use of the
growth allowance.
- Illinois EPA will continue to use existing
regional public outreach efforts to get in-
put on emissions reduction activities be-
ing developed. This includes input from
community groups, businesses, nonprofit
organizations, and other government agen-
cies.
Benefits for the Environment
It is estimated that 3 to 7 tons of emissions
reductions per day of VOCs may be realized
under this project. Because 40 percent of the
emissions capacity allowed under the CAA
will be retired after reductions in actual emis-
sions are achieved, this project may result in
an estimated 1.2 to 2.8 tons of VOC reduction
per day.
• On October 1, 2000, the City of Chicago
banned all small incinerators from burning
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waste and ordered they cease operation by
January 1, 2001. Twenty-seven small incin-
erators were closed in the city and resulted in
the following emissions reductions: 0.015 tons
per day of VOCs; 0.022 tons per day of NOx;
and 0.075 tons per day of CO.
• The city has conducted two lawnmower buy-
back programs. The first was a regional buy-
back held in April to June of 2000 and resulted
in 567 gas-powered lawnmowers being retired.
Emission reductions for this program totaled
0.024 tons per day of VOCs. The second buy-
back was conducted in the City of Chicago in
the summer of 2001. This buy-back resulted
in the retirement of 246 gas-powered
lawnmowers and emissions reductions total-
ing 0.012 tons per day of VOCs.
• Due to the fact that the excess emissions ca-
pacity created will be given to businesses that
locate or expand in development zones, which
are largely in urbanized areas, open space and
farmland in more rural areas will be saved from
development.
Benefits for Stakeholders
• This project offers the opportunity for the pub-
lic at large and local governments to partici-
pate in a meaningful way in improving air
quality in their region as it focuses on reduc-
ing emissions from mobile and area sources
by individuals and communities. By chang-
ing individual behaviors such as fuels used and
changing driving patterns, stakeholders can
create emissions capacity for targeted eco-
nomic activity that will create jobs in their
community.
Stakeholders will be the direct beneficiaries
of new economic activity created by new and
expanded businesses in development zones in-
cluding job creation, brownfields and blighted
area redevelopment, crime reduction, and
greater urban vitality.
Benefits for the Project Sponsor
• In addition to coming into attainment under
the CAA for ground-level ozone and having
cleaner regional air, the City of Chicago will
be able to remove barriers to companies want-
ing to locate within the nonattainment area,
thereby opening up greater economic oppor-
tunity in the city's most needy neighborhoods.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Chicago Regional Air Quality and
Economic Development Strategy, July 19, 2001;
and (2) the 2000 Project XL Comprehensive Re-
port, Volume 2: Directory of Project Experiments
and Results, November 2000.
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City of yAlbucjuerque.
Final Project Agreement Signed February 3, 2000
Background
Project Sponsor: The City of Albuquerque Pub-
lic Works Department's Wastewater Utility Divi-
sion is responsible for maintaining Albuquerque's
wastewater collection system and wastewater rec-
lamation plant, which includes one publicly owned
treatment works (POTW) facility—the Southside
Water Reclamation Plant. All Albuquerque area
homes, businesses, and institutions—about
500,000 people, 100 major industries, and 12,000
commercial customers—are connected to the
POTW sewer system. The Albuquerque POTW
is the largest wastewater treatment facility in New
Mexico. The plant design capacity is 76 million
gallons/day (MGD). Present flows average about
57 MGD. Fifteen percent of the wastewater treated
comes from industrial users.
The Experiment: Albuquerque plans to shift re-
sources from certain less productive requirements,
such as monitoring facilities that have excellent or
very good records of compliance, to pollution pre-
vention activities that promise greater environmen-
tal results. Specifically, the city will attempt to
initially reduce the amount of aluminum, cadmium,
chromium, copper, cyanide, fluoride, lead, mer-
cury, molybdenum, nickel, selenium, silver, and
zinc that are being treated in the POTW by 10 to
25 percent. In addition to reducing these 13 pol-
lutants and improving the area's overall water qual-
ity, this project will reduce the mass and
concentration of influent, effluent, and biosolids.
The city also plans to make changes to its Indus-
trial Waste Survey by focusing on sewer system
subbasins at key manholes to learn if it is possible
to identify where in the city certain pollutants pre-
dominate. This replaces current National Pollu-
tion Discharge Elimination System (NPDES)
requirements that call for predicting pollutant load-
ings based on industrial inputs. Under the new
survey, certain subbasins will receive more focused
and intense pollution prevention outreach efforts
and activities depending on the types and amounts
of pollutants identified in their sector of the city.
In the case of potentially harmful discharges, the
city will have the ability to track discharges up-
stream by increasing sample collections, as well
as the ability to visit the industries, institutions,
and commercial operations within the subbasin to
determine potential sources. If high pollutant lev-
els occur in a subbasin that cannot be tied to a spe-
cific institutional or industrial source, the city will
address the issue through educational outreach in
the specific area.
The Flexibility: The City of Albuquerque's
POTW is covered under EPA's NPDES. This XL
project proposes to modify otherwise required ac-
tivities under NPDES in three general categories:
changing the permitting requirements, revising the
definition of "significant non-compliance" (SNC),
and implementing a pollution prevention program
in the city's Industrial Pretreatment Program.
Changing the Permitting Requirements. Accord-
ing to the city's Industrial Pretreatment Program,
many of the industrial user permittees have excel-
lent waste management programs and compliance
records or represent non-significant discharges of
pollutants. The city proposes to delete approxi-
mately 13 permits due to their non-significant
wastewater discharge while maintaining annual in-
spections, monitoring, and reporting requirements.
The city also proposes to modify approximately
32 permits for industries with good performance
histories while maintaining annual inspections,
monitoring, and reporting requirements. The city
will create general permits where appropriate to
simplify permitting procedures.
Revising the Definition of SNC. Under Project XL,
the definition of "chronic violation" under SNC
will be changed to a basis of whether an adminis-
trative assessment has been issued to a permittee
under the city's Enforcement Response Plan. Tech-
nical Review Criteria under 40 CFR
403.8(f)(2)(vii) will not be used, and the require-
ment for rolling quarter determinations of SNC will
be replaced with annual determinations. The city's
approved Enforcement Response Plan will be
modified to delete the presently required SNC
tracking and administration in favor of the above
approach.
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Pollution Prevention Program. The city proposes
to modify its next NPDES permit to reflect its par-
ticipation in Project XL by requiring a pollution
prevention component to its Industrial Pretreatment
Program. The pollution prevention component in-
volves changes in the city's survey, monitoring,
and reporting requirements. Specifically, the city
will make changes in its Industrial Waste Survey
by focusing on sewer system subbasins at key man-
holes to learn if it is possible to identify where in
the city certain pollutants predominate.
Other Innovations: (1) Testing Subbasin Moni-
toring as a Tool. EPA and the POTW will be able
to determine the usefulness of subbasin monitor-
ing as a less resource-intensive compliance tool
and targeting mechanism for pollution prevention
outreach. Once baseline data are established within
the city's wastewater collection system subbasins,
the POTW will be able to target certain businesses
for pollution prevention activities, rather than pre-
dicting outputs from industrial process inputs. (2)
Fundamental Change in Approach Toward Indus-
trial Waste Generation. The Southside Water Rec-
lamation Plant is testing a suite of new methods
for preventing discharge of pollutants and freeing
up resources for outreach and education by attempt-
ing to permanently integrate pollution prevention
principles, promotion, and recognition as part of
the city's required Industrial Pretreatment Program.
Superior Environmental Performance: 1 lie
goal of the project is to reduce the amount of pol-
lutants released into the environment from indus-
tries and businesses through pollution prevention
activities. With the flexibility, the city will be able
to shift limited resources from certain NPDES re-
quirements, such as monitoring industries that have
excellent or very good records of compliance, to
more proactive pollution reduction strategies, such
as focusing on sewer system subbasins at key man-
holes to learn if it is possible to identify where in
the city certain pollutants predominate. This more
focused plan will enable the city to reduce the
amounts of pollutants in the water; reduce mass
and concentration of influent, effluent, and
biosolids; improve stonnwater runoff; and improve
the overall water quality in Albuquerque. The city
estimates reductions in the range of 10 to 20 per-
cent for the 13 targeted pollutants.
Progress in Meeting Commitments
(As of October 2001)
• On October 3, 2001, EPA promulgated a rule
amending the National Pretreatment Program
regulations to allow POTWs that have com-
pleted the Project XL selection process, includ-
ing FPA development, to modify their
approved local pretreatment programs. These
POTWs will be allowed to modify their pro-
grams and implement the new local programs
as described in their FPAs.
This project is newly underway. The following
commitments for the project are detailed in the
FPA:
• The city will provide semiannual updates
posted to the Web site for the project on the
city's home page at http://www.cabq.gov/
wastewater/projectxl.html. Hard copies will
be provided upon request. The updates will
describe local pilot pretreatment program ac-
tivities and accomplishments, including activi-
ties and accomplishments of participating
agencies and public involvement. The report
also will include an analysis of environmental
data collected over the reporting period and
activities conducted to reduce pollutant load-
ings to the environment and any other activi-
ties that address the objectives of the local
pretreatment program.
• The city has begun sampling to establish a
baseline for the city's wastewater collection
system from which the city will measure
progress toward its goal of reducing targeted
pollutants by 10 to 20 percent.
• To increase public awareness, Albuquerque
has opened its Technology Resources Center
(TRC) office, which is underwritten by the
Waste Management Education and Research
Consortium (WERC) and cooperates with the
New Mexico Green Zia Environmental Excel-
lence Program. The TRC is set up as a clear-
inghouse to address businesses environmental
waste management issues and problems. The
city's Web site also is set up with direct links
to the pollution prevention program.
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Benefits for the Environment
• The city expects declines in subbasin pollut-
ants by 10 to 20 percent. There should be a
reduction in mass and concentration of influ-
ent, effluent, and biosolids.
• Pollutant releases at a majority of businesses
will be expected to decline where pollution
prevention promotion has been addressed.
• The project should result in overall water con-
servation by industrial users.
• Stormwater runoff quality improvements will
be expected as more businesses implement
stormwater pollution prevention plans.
Benefits for Stakeholders
• Increased public awareness of the importance
of pollution prevention will be a tangible re-
sult of increased promotion and education ef-
forts.
Benefits for the Project Sponsor
• The city will be able to shift limited resources
from certain less productive requirements, such
as monitoring industries that have excellent or
very good records of compliance, to more pro-
active pollution reduction strategies, such as
focusing on sewer system subbasins at key
manholes to learn if it is possible to identify
where in the city certain pollutants predomi-
nate.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the City of Albuquerque Public Works
Department XL Project, signed February 3, 2000;
and (2) the 2000 Project XL Comprehensive Re-
port, Volume 2: Directory of Project Experiments
and Results, November 2000.
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Ci+y of {Solumbus
XLC' Final Project Agreement Signed September 26,
2000
Background
The Project Sponsor: The City of Columbus
project focuses on an area within Columbus, Ohio,
where 84 percent of all elevated blood lead levels
in the city have been found. The area of concern
for this project falls within a 10 zip code area lo-
cated in predominately low-income minority neigh-
borhoods, where the housing is generally much
older than in the remainder of the city. Testing
done in parts of this area between 1995 and 1997
indicated that as many as 20 percent of the chil-
dren living in this area of the city had elevated
blood lead levels.
The City of Columbus operates a public water sys-
tem that must comply with regulations under the
Safe Drinking Water Act (SDWA) and is currently
maintaining optimal treatment for lead. However,
in the past, Columbus made certain changes to its
water treatment process to meet other water qual-
ity standards and inadvertently caused an increase
in the lead levels in the water. Columbus is con-
cerned that it may need to make treatment changes
in the future that may likewise affect lead levels.
The Experiment: This project takes a multime-
dia approach to controlling lead by allowing the
city to utilize some of its drinking water resources
to focus on and abate health hazards due to house-
hold lead paint and dust. The City Division of
Water has agreed to fund a Lead-Safe Columbus
Program (LSCP) at an annual level of $300,000
tor 15 years for lead poisoning prevention.
Programs initiated by the LSCP include free blood
screening, public education, medical intervention
tor children with lead poisoning, and grants or
loans for lead abatement projects in high-risk ar-
eas. The free blood screening will occur at the
'Project XLC, excellence and Leadership for Communities,
encourages local public sector and community organizations
to come forward with new approaches to demonstrate com-
munity-designed and directed strategies for achieving greater
environmental quality consistent with community economic
goals.
LSCP monthly clinic. In addition, the LSCP will
offer to test all children under the age of six at
sites where lead levels in the tap water exceed 15
micrograms per liter (pg/1), as well as all children
under six living in a building where elevated blood
lead levels have been detected. Children with el-
evated blood lead levels greater than, or equal to,
15 micrograms per deciliter (pg/dl) will receive
medical case management and lead hazard risk
assessments from the LSCP. Lead hazard risk as-
sessments will also be performed at all privately
owned residences built prior to 1978 whose own-
ers apply for rehabilitation activity funding from
the City of Columbus Department of Trade and
Development (DTD). Another component of the
project involves grants and loans for the abatement
of lead hazards in high-risk homes. Up to 20 grants
will be given to low- to moderate-income
homeowners, at an average amount of $5,000 to
address lead hazards. More expensive lead haz-
ard-reduction projects will be financed through
low-interest loans from the DTD.
The Flexibility: EPA identified a SDWA variance
as the appropriate federal mechanism for imple-
menting this project. The legal provisions found
at Section 1415(a)(3) of the SDWA give EPA the
authority to grant a variance from a treatment tech-
nique if an alternative treatment technique is de-
termined to be at least as efficient in lowering the
level of the contaminant with respect to the pre-
scribed requirement. EPA's issuance of a variance
to Columbus based on the city's implementation
of an alternative treatment technique, which was
determined to be at least as efficient in lowering
the level of lead as lead service line (LSL) sam-
pling and replacement, represented the first time
this SDWA authority had ever been used. In ex-
change for providing funding to the LSCP, the Co-
lumbus Water Division will receive flexibility,
should it become necessary, from lead and copper
regulations promulgated under the SDWA. The
city is concerned that future changes to its treat-
ment processes could result in temporary increases
in drinking water lead levels. Although at this time
the city does not anticipate any such increases, if
temporary increases do occur, the city is seeking
regulatory flexibility until lead levels can be re-
duced.
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Under the federal and state drinking water regula-
tions, if the drinking water in customers' homes
exceeds the "Action Level" (AL) of 15 |jg/l of lead
in more than 10 percent of drinking water tap
samples (i.e., exceeds the AL as a 90th percentile
value), the city must begin sampling LSLs imme-
diately and replace those lines that contribute more
than 15 pg/1 of lead. The flexibility under this XL
project will suspend the LSL sampling and replace-
ment requirements for up to three years if and when
the city exceeds the lead limit, provided the in-
crease occurs within six years of making a treat-
ment change.
Prior to making any treatment change that could
affect the lead levels in the system, the Columbus
Water Division will consult with the Ohio Envi-
ronmental Protection Agency (OEPA) and EPA.
Once OEPA approves the proposed treatment
change, Columbus will monitor the lead levels in
the water. Should the tap monitoring indicate a
trend of increasing lead levels, the Columbus Di-
vision of Water will consult with OEPA and EPA
and take steps to reverse the trend.
This project would not allow flexibility from the
public education provisions of the lead and cop-
per regulations; the city would still be required to
conduct public education in accordance with fed-
eral and state regulations should the lead AL be
exceeded at any time.
Other Innovations: (1) Testing the first-time use
ofSDWA legal mechanism. EPA's use of a SDWA
variance to implement an alternative treatment
technique has proven to be so cost effective to EPA
and all of the stakeholders involved in this XLC
project that EPA's Region 5 office is now working
to employ the same legal mechanism in two pilot
projects to be tested in Michigan under the Joint
EPA/State Agreement to Pursue Regulatory Inno-
vations.
The Superior Environmental Performance:
The LSCP aims to yield superior environmental
performance through greater public health protec-
tion by addressing all sources of lead exposure in
the Columbus community. The project will pro-
vide public education and outreach materials and
issue lead hazard and abatement grants with the
funding received ($300,000 a year for 15 years)
from the City Water Division. If the city employs
an alternative treatment technique for drinking
water, the effort will be coordinated between the
city, EPA and OEPA. The treatment technique
would involve joint management of water treat-
ment changes while allowing the city to adjust
drinking water treatment to establish the most ef-
fective level of lead treatment in conjunction with
other water treatment processes.
Progress in Meeting Commitments
(As of July 2001)
• Although ALs have not been exceeded since
the FPA was signed, the City of Columbus has
committed to a series of actions if the lead AL
is exceeded. Should any new water treatment
begin which could adversely affect lead lev-
els, the city Division of Water will initiate ad-
ditional sampling. If the lead AL is exceeded,
the Columbus Division of Water will take
measures to lower lead levels at the tap.
• The Columbus City Council and City Auditor
approved the transfer of $300,000 in Water
Division funds to the LSCP beginning Janu-
ary 1,2001.
• The LSCP will target a 10 zip code area for
priority program activities.
- LCSP will provide free blood screening
at its monthly clinics and conduct probe
screens within the community.
- The LSCP will offer to test the blood lead
levels of all children under age six who
reside in the same building as a child who
has been tested at the monthly clinic and
found to have an elevated blood lead level.
- The LSCP will conduct lead hazard risk
assessments for all privately owned, low-
income residences built before 1978 when
owners apply for rehabilitation activity
funding from the DTD, and will issue up
to 20 lead hazard identification and abate-
ment grants (up to a total of $ 100,000) per
year.
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- The LSCP will also work with community
groups that serve the target neighborhoods
to distribute educational materials.
* EPA committed to take final action on the pro-
posed variance under Section 1415(a)(3) of the
SDWA after considering public comments.
- EPA's Region 5 Administrator signed the
final variance on December 27, 2000.
Should the flexibility provided by the vari-
ance be needed by the city and the vari-
ance become effective, EPA and OEPA
will review the city's compliance with its
terms.
* Treatment changes will be subject to OEPA
review and approval. Should treatment
changes be approved, OEPA will designate
new monitoring requirements. OEPA will re-
view requests from the Columbus Water Divi-
sion for a reduction in the frequency of
monitoring for lead or other constituents if
necessary.
Benefits for the Environment
* All aspects of childhood lead poisoning are
addressed in this XLC project. In addition to
traditional screening and risk assessment func-
tions, the project will provide a comprehen-
sive education effort that encourages individual
responsibility, long-term maintenance, preven-
tion, and corrective measures. It will address
the issue of lead in drinking water with lim-
ited flexibility and provide up to $100,000 per
year in targeted funding for abatement from
lead paint, dusts, and other sources.
Benefits for Stakeholders
* This XLC project will proactively remediate
lead hazards to children. The city will seek
properties within high-risk areas, offer to per-
form free lead assessments, and provide up to
20 grants, at an average of $5,000 each (for a
total of $100,000 per year), for lead hazard
abatement.
• The comprehensive education program used
by the LSCP will provide direct training to
those most at risk and who can have the great-
est impact on reducing and/or eliminating lead
hazards in a child's environment.
• Public education and outreach materials are
another component of the LSCP program
funded by the $300,000 annual commitment.
Three areas of public outreach and education
will be stressed in this XLC project. Lead in-
formation packets will be provided to parents
of all children tested with a blood level of 10
pg/dl or greater to help reduce lead hazards in
the home. Brochures will be distributed to
medical providers and clinics in high-risk
neighborhoods. LSCP staff will also distrib-
ute materials to community groups, at fairs,
and to social service agencies that serve resi-
dents of the target neighborhoods.
Benefits for the Project Sponsor
• Under this XLC project, the Columbus Water
Division will receive regulatory flexibility
from LSL sampling and replacement regula-
tory requirements under the SDWA, should a
change in treatment technology cause an in-
advertent rise in drinking water lead levels.
• LSLs are expensive to replace. There are
28,802 LSLs in Columbus, with average costs
for line replacements ranging from $1,200
(EPA average estimate) to $3,000 (City of Co-
lumbus estimate) per line. The city projects
that monitoring for lead in 7 percent of the
lines, as required by SDWA regulations would
cost the city $360,000 in the first year, with
costs increasing in subsequent years.
• The Columbus Division of Water will be ad-
dressing an environmental and health issue be-
yond their traditional purview. The $300,000
annual commitment from this project, in addi-
tion to a small Center for Control Disease and
Prevention grant and larger U.S. Department
of Housing and Urban Development grant
($1.1 million), will all be used to achieve over-
all city lead program goals, maximizing avail-
able resources on the local level to address a
serious environmental and health issue.
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• The Columbus XLC project has the potential
to affect the way that water systems across the
country approach lead reduction. Any other
supplier wishing for similar regulatory flex-
ibility must first demonstrate superior environ-
mental or public health benefits and commit
to comply with appropriate state and federal
regulations. The funding of the LSCP is an
essential component of this XLC project. The
experiences of the Columbus XLC project will
assist EPA in determining whether to grant
future variances of the SDWA for water sys-
tems facing similar circumstances.
Information Resources: The information used to
develop this progress report include (1) the FPA
for the City of Columbus XLC Project, dated Sep-
tember 26, 2000; (2) the EPA Office of Ground
Water and Drinking Water Web site (http://
www.epa.gov/safewater); (3) the EPA Office of
Pollution Prevention and Toxics Lead Web site
(http://www.epa.gov/lead); (4) the City of Colum-
bus Lead Safe Columbus Web site (http://
hcs. td. ci. columbus. oh. us/Housing/Lead/
Lead%20Web/); and (5) the 2000 Project XL Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
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O-fy oj- Den+cm
Final Project Agreement Signed February 22, 2000
Background
The Project Sponsor: The City of Denton, Texas,
has a rapidly growing population of more than
72,867 (1998) and is located approximately 30
miles north of Dallas/Fort Worth. The City of
Denton has a publicly owned treatment works
(POTW) that collects wastewater from homes,
commercial buildings, and industrial facilities and
transports it via a series of pipes, to the Pecan Creek
Water Reclamation Plant. Here, the reclamation
plant removes harmful organisms and other con-
taminants from the sewage so the resulting efflu-
ent can be discharged safely into Pecan Creek. The
City of Denton Department of Water Utilities is
responsible for water quality in the city, including
the water that enters the reclamation plant. The
City of Denton Environmental Services Division
is responsible for implementing the pretreatment
program.
Generally, POTWs are designed to treat domestic
sewage only. However, POTWs also receive
wastewater from industrial users. The industrial
flow entering the Pecan Creek Water Reclamation
Plant in Denton represents approximately 9 per-
cent of the average total daily flow (1.0 million
gallons per day of 11.1 million gallons per day,
total flow). The City of Denton currently provides
wastewater services to 12 significant industrial us-
ers (SlUs); seven are "major" users, and five are
classified as "categorical industrial users' under
the Clean Water Act because they are metal fin-
ishing and electric power generating facilities.
Denton will reduce its monitoring and annual in-
spections for certain individually approved facili-
ties and focus on pollutants in the urban stormwater
drainage.
The Experiment: The City of Denton, through
the XL program, is exploring the potential of inte-
grating publicly accessible, near-real-time moni-
toring, a pilot pretreatment project, and an early
warning system for stormwater drainage into a
state-of-the-art integrated monitoring system and
watershed protection program. This project tests
an innovative and comprehensive system that will
provide the capability to detect contaminants with
the potential to impact water quality and ultimately
the aquatic environment and drinking water reser-
voir for the City of Denton. The City of Denton
also plans to create buffer zones in undeveloped
drainage basins within the boundaries of the wa-
tershed. These creek-side buffer zones or conser-
vation easements will help reduce the runoff of
agricultural and suburban pollutants.
Discharge permits are issued to all SIUs. The dis-
charge permit application requires the industrial
user to provide a description of the manufacturing
processes, water consumption, and the volume and
potential pollutant concentration in wastewater
discharged from the facility. Each permitted in-
dustrial user is inspected, and its wastewater dis-
charge is sampled and analyzed annually. For this
XL project, the City of Denton will modify the
industrial user inspection and monitoring sched-
ule required by issued National Pollutants Dis-
charge Elimination System (NPDES) permits. This
XL project will test reducing the frequency of in-
spections and monitoring for SIUs that have con-
sistently met NPDES permit standards. Inspection
of industrial users that have demonstrated compli-
ance will be conducted biennially (every two
years), instead of annually. The four-day moni-
toring period required under standard NPDES
monitoring schedules will be reduced to two days
during unannounced randomly scheduled visit.
Annual efforts to inspect small quantity genera-
tors (SQGs) will be reduced from 10 percent of
SQGs to less than 5 percent. The SQGs will be
selected for inspection based on their potential to
contribute contaminants to the POTW.
Through this inspection and monitoring program,
the city plans to ensure environmental compliance
with fewer resources expended by the city. Re-
sources are primarily in the form of city staff time
and activities. As a result, City of Denton Envi-
ronmental Services personnel can redirect their
efforts to addressing issues at problem sites such
as recycling centers, junk yards, and salvage yards,
which have a greater potential to contribute pol-
lutants directly to receiving streams through
stormwater runoff and non-point source pollution.
-------
City personnel can also direct their efforts toward
identifying previously undetected contributors to
influent loading. To identify the sources, the city
will have to backtrack from the POTW to local lift
stations to potential source contributors. Both of
these activities satisfy components of the
stormwater management plan being developed in
Denton and will result in a significant environmen-
tal improvement over current conditions.
The city estimates that the most significant envi-
ronmental benefit associated with the project will
be derived from the implementation of a water-
shed protection program including modified ele-
ments of the NPDES Phase II Storm Water
compliance activities. The NPDES Phase II Storm
Water Program requires the implementation of best
management practices (BMPs) to measure and con-
trol the runoff of pollutants from parking lots, re-
cycling centers, junkyards, and salvage yards,
which should improve the water quality of receiv-
ing streams. The stormwater program also requires
installation of erosion control measures at construc-
tion sites. The city will recommend the BMPs to
developers. The city is also establishing creek-
side buffer zones or conservation easements, which
should reduce the concentration of nitrogen and
phosphorus fertilizers, pesticides, and herbicides
contributed by runoff. Additional resources can
be directed to public education, including outreach
on the proper use and disposal of pesticides, her-
bicides, and automotive fluids. Finally, this XL
project will enable the City of Denton to develop
its watershed protection program years earlier, and
much more effectively, than would have occurred
otherwise.
The Flexibility: In order to achieve these objec-
tives, the City of Denton will modify the indus-
trial user inspection and monitoring schedule
required by issued NPDES permits. According to
the approved NPDES permit schedule, all SIUs and
minor users are inspected once per year and the
wastewater discharged from the facilities is
sampled and analyzed at least once per year. Sam-
pling at each industrial user is performed during a
four-day period. This XL project will test reduc-
ing the frequency of inspections and monitoring
for SIUs that have consistently met NPDES per-
mit standards in the past. Inspection of industrial
users that have demonstrated compliance will be
conducted biennially (every two years), instead of
annually. The four-day monitoring period will be
reduced to two days during an unannounced ran-
domly scheduled visit. Annual efforts to inspect
SQGs will be reduced from 10 percent of SQGs to
less than 5 percent. The SQGs will be selected for
inspection based on their potential to contribute
contaminants to the POTW. The City of Denton is
requesting flexibility from Clean Water Act regu-
lations to reduce the frequency of industrial user
compliance inspections and monitoring. This
project is being implemented under a policy appli-
cation contained in a memo titled, "Revision to
Inspection Coverage and Frequency Criteria of
Clean Water Act Permittees," signed by Elaine
Stanley and Bob Van Heuvelen, dated September
11, 1995. This policy allows for the reduction of
inspections to a less than annual basis to allow the
Agency and states to shift inspection resources
from lower risk sources to higher risk sources. The
Texas Natural Resources Conservation Commis-
sion (TNRCC) will promulgate a rule adopting the
site-specific measures granted by EPA. This will
allow Denton to redirect resources to the develop-
ment of a comprehensive watershed protection
program, resulting in the support of site-specific
watershed protection activities.
Other Innovations: (I) Effectively Targeting
Monitoring and Inspection Schedules to Maintain
Environmental Quality. Only SIUs and minor us-
ers that have been in compliance will qualify for
less frequent inspections and monitoring by city
personnel. (2) Generating Greater Environmen-
tal Benefit by Reducing Programmatic Burdens.
By reducing the frequency of inspections and moni-
toring on those industrial users who are already in
compliance, this project aims to make more re-
sources available to city personnel to work to
achieve greater environmental results through fo-
cused activities. (3) Remote Monitoring and Wa-
tershed Protection. This project will test the
application of real-time, remotely deployed moni-
toring devices that will provide continuous, pub-
licly accessible water quality data while creating
minimal demand on personnel. Monitoring and
annual inspection will be reduced, while greater
focus will be placed on reducing non-point source
pollutants in urban storm water drainage. Resource
-------
savings from regulatory flexibility will be reap-
portioned to watershed protection activities.
The Superior Environmental Performance:
This project tests an innovative and comprehen-
sive system, which will provide the capability to
detect contaminants with the potential to impact
water quality and ultimately the aquatic environ-
ment and drinking water reservoir for the City of
Denton. The City of Denton also plans to create
buffer zones in undeveloped drainage basins within
the boundaries of the watershed. These creek-side
buffer zones or conservation easements will reduce
the runoff of agricultural and suburban pollutants.
The three main areas addressed to achieve supe-
rior environmental performance are:
1 • The pretreatment program;
2. Wastewater collection system monitoring; and
3. Watershed protection.
The resources saved by the flexibility and the ex-
periment will be used in watershed protection ac-
tivities, including inspections of vehicle
maintenance facilities, recycling centers,
junkyards, salvage yards, municipal and school
district fleet service operations, and construction
sites; establishment of a remote creek monitoring
network; and incorporation of pollution preven-
tion best management practices into the local code
of ordinances.
Progress in Meeting Commitments
(As of October 2001)
The City of Denton FPA includes the following
commitments:
* EPA expected to promulgate a site-specific
rule, amending 40 CFR 403. EPA will work
with TNRCC to issue the necessary permits,
orders, or other actions to be undertaken to
implement this project.
- On October 3, 2001, EPA promulgated a
rule amending the National Pretreatment
Program regulations to allow POTWs that
have completed the Project XL selection
process, including FPA development, to
modify their approved local pretreatment
programs. These POTWs will be allowed
to modify their programs, and implement
the new local programs as described in
their FPAs.
TNRCC has committed to promulgating a rule
adopting the regulatory flexibility granted by
EPA. The agency will work with EPA to issue
the necessary permits, orders, or other actions
to be undertaken to implement this project, and
propose for public comment any permit or per-
mits needed by the City of Denton under this
project.
> The City of Denton will request a modified
Phase II stormwater permit from the TNRCC
(issued on effective date of Phase II program)
that takes into account the watershed protec-
tion efforts being put forth through this project.
• The City of Denton will collect and analyze
environmental data from the area being moni-
tored and submit periodic reports tracking the
progress of the project. The city will continue
to submit regulatory reports on the non-waived
requirements of its pretreatment program.
• Along with other watershed protection activi-
ties, the City of Denton will either purchase
property or encourage the implementation of
protective practices in predominantly undevel-
oped drainage areas within the city boundaries.
• As one activity to reduce pollutant loading in
the POTW influent, the City of Denton will
attempt to backtrack from lift stations to po-
tential source contributors in an attempt to
identify the sources of nickel and lead in the
wastewater.
Benefits for the Environment
• City of Denton personnel will be able to redi-
rect their efforts to those sites that have a
greater potential to contribute pollutants di-
rectly to receiving streams through runoff and
non-point source pollution.
-------
• City personnel can also direct their efforts to-
ward identifying previously undetected con-
tributors to influent loading and address high
levels of lead and nickel in the influent waste-
water.
• Water quality in Denton streams will be im-
proved by watershed protection activities,
ranging from real-time monitoring, to estab-
lishing stream buffers, to enhancing public
education, all of which are facilitated by this
pilot project.
Benefits for Stakeholders
• Increased monitoring efforts in association
with the development of a watershed manage-
ment plan, the Environmental Condition
Online DFW Metroplex (ECOPLEX) project,
will allow the public to track water quality
throughout the watershed online (http://
www. ecoplex. unt. edu).
Benefits for the Sponsor
• Reduced requirements for conducting inspec-
tions and monitoring at industrial user facili-
ties will allow the City of Denton to redirect
its personnel resources toward other projects,
including developing a modified Phase II
Storm Water Management Program, and a
watershed protection plan.
Information Resources: The information used to
develop this progress report were (1) City of
Denton Pilot Pretreatment Program FPA, signed
February 22, 2000; and (2) Project XL Compre-
hensive Report, Volume 1: Directory of Regula-
tory, Policy, and Technology Innovations, and
Volume 2: Directory of Project Experiments and
Results, November 2000.
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City o| Fort WorfK
Phase 1 Monitoring Plan Agreement Signed Septem-
ber 29,2000
Background
The Project Sponsor: The City of Fort Worth was
established in 1849 in north-central Texas as an
Army outpost. It is now a home rule municipality
and the seat of Tarrant County with an estimated
population of 471,125. Historically, the city's in-
dustry was primarily cattle ranching, which has
given way to the more manufacturing, distribution,
and technology-related industries of today. The
flux of business in the urban areas has created
blight in Fort Worth, and in recent years the city
has become concerned with these areas and has
begun taking tangible steps towards redeveloping
and reusing many abandoned and substandard
properties. In 1999, the city was awarded an EPA
Brownfields Assessment Demonstration Pilot2 to
assist with redeveloping and reusing some of the
city's blighted, or brownfields, properties. Fort
Worth has also been granted numerous national and
regional awards for its stormwater and wastewa-
ter programs. The city has the premier household
hazardous waste collection center in the state of
Texas and is recognized for its strides in environ-
mental education.
The Experiment: Fort Worth seeks to demolish
substandard, abandoned structures using an alter-
native method in lieu of the current Asbestos Na-
tional Emissions Standards for Hazardous Air
Pollutants (NESHAPs) requirements. As part of
its attention to blight and attendant crime and pub-
lic safety issues, the city has identified a number
°f structures for demolition that contain asbestos-
bearing materials and are subject to demolition re-
quirements specified in an asbestos emission
standard issued by EPA under the Clean Air Act
2EPA's Brownfields Assessment Demonstration Pilots seek
to assess brownfields sites and to test cleanup and redevel-
opment models. Communities are awarded grants up to
$200,000 to implement their Pilot, usually over a two-year
period. This pilot program is intended to provide EPA, states,
tribes, municipalities, and communities with useful informa-
tion and strategies as they continue to seek new methods to
promote a unified approach to brownfields site assessment,
environmental cleanup, and redevelopment.
(CAA). Currently, the city follows the require-
ments established by the Asbestos NESHAPs to
demolish substandard structures that are not in
danger of imminent collapse. Through the XL
project, the city is attempting to demonstrate that
using an alternative demolition method can pro-
tect human health to the same degree as the method
specified in the Asbestos NESHAPs under the
CAA, while also reducing demolition costs. The
alternative "Fort Worth Method" integrates "wet"
demolition methods, air monitoring, and proper
handling/disposal techniques. In a recent example,
the city demonstrated that demolition using the Fort
Worth Method achieved a nearly $20,000 savings
over the traditional method of abatement under the
Asbestos NESHAPs. This project will test whether
using the Fort Worth Method reduces abatement
contractors' personnel costs, material costs, and
personnel time.
To use the Fort Worth Method in place of the tra-
ditional method described in Asbestos NESHAPs
legally, the city must prove that its method is
equivalent to the one specified in the NESHAPs.
The City of Fort Worth and EPA will execute two
agreements for this project to accommodate a three-
phased approach under this XL project. The first
agreement, the Monitoring Plan Agreement, was
signed in September 2000 and lays out the phased
approach for the project and the asbestos monitor-
ing plan for Phase 1. The second agreement, the
FPA, will be developed using stakeholder input and
will address the last two phases of the project. The
development of the FPA and initiation of the Phase
2 demolition is anticipated in the next six months.
Phase 1 consists of monitoring asbestos emissions
from the demolition of a structure containing as-
bestos but not subject to the federal asbestos stan-
dard because of its residential classification
(residential buildings containing four or fewer
dwellings are not subject to the Asbestos
NESHAPs). Phase 2 consists of demolishing two
additional structures and monitoring asbestos emis-
sions while comparing the federally mandated
method to the alternative method. If testing in
Phases 1 and 2 is successful, the city will be per-
mitted to conduct a specific number of demolitions
using its alternative method during Phase 3.
-------
The Flexibility: Fort Worth seeks relief from the
requirements of the Asbestos NESHAPs and the
Texas Asbestos Health Protection Rules to the ex-
tent that these regulations require the removal of
regulated asbestos-containing building materials
(ACBM) from substandard structures prior to
demolition. In general, demolishing a structure
containing asbestos requires federal compliance
with the Asbestos NESHAPs, as provided under
section 112(h)(3) of the CAA, and state compli-
ance with the Texas Asbestos Health Protection
Act.
The structure demolished in Phase 1 was not a regu-
lated structure (i.e., not subject to the Asbestos
NESHAP due to its residential classification); and
therefore, the city only requires regulatory flex-
ibility to conduct Phases 2 and 3.
Other Innovations: Wet Demolition of Structures
with ACBM. The primary innovation in the Fort
Worth Method is the wet demolition method used
in handling structures containing ACBM. In the
traditional method. ACBM is removed from the
structure prior to demolition. In the Fort Worth
Method, ACBM remains in place. It is believed
that through proper handling and wetting of this
demolition debris, the city can control asbestos fi-
ber release at least to the level of the existing As-
bestos NESHAP.
The Superior Environmental Performance:
Implementation of the proposed Fort Worth
Method will provide environmental performance
superior to that which is realized under traditional
approaches and will serve to improve the commu-
nity at large. The Fort Worth Method aims to main-
tain the level of environmental protection currently
dictated by the Asbestos NESHAPs, as well as
worker protection dictated by the Occupational
Safety and Health Administration, while reducing
the costs of demolition of substandard structures.
In a recent example, the city demonstrated that
demolition using the Fort Worth Method achieved
a nearly $20,000 savings over the traditional
method of abatement under the Asbestos
NESHAPs because of the reduced personnel time
and material costs for abatement contractors.
Progress in Meeting Commitments
(As of August 2001)
• In Phase 1, the city committed to demolish a
structure that was within city boundaries and
contains asbestos-bearing materials, but one
that was not subject to Asbestos NESHAPs.
- The first structure selected for the Phase 1
demolition was a two-unit residential struc-
ture located at 2615 Ennis Avenue, in the
City of Fort Worth (see Figure 5). Because
the regulated asbestos-containing materials
levels were low at this structure, it was con-
sidered a good test case for the alternative
Fort Worth Method. It was a vacant build-
ing of approximately 1,126 square feet, with
a long history of code violations dating back
to the 1980s. The Fort Worth Building Stan-
dards Commission declared the structure to
be substandard at a hearing on November
27,2000. The owner was given 30 days to
fix the structure or to demolish it, but failed
to do so. The City of Fort Worth Code Com-
pliance Division chose to move forward
with the demolition, the Department of En-
vironmental Management performed an as-
bestos survey, and the site was approved as
a test structure for a Phase 1 demolition.
The property was demolished in April 2001.
The city monitored asbestos emissions dur-
ing the demolition process according to a
monitoring plan, which was approved by
all those involved in this XL project.
The city committed to perforin asbestos moni-
toring specified in a detailed Quality Assur-
ance Project Plan during demolition and
demolition debris removal.
Piquce 5
The first structure demolished under Phase 1 of the City of
Fort Worth XL Project at 2615 Ennis Avenue.
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- The structure was successfully demolished
over a two-day period using the Fort Worth
Method. Asbestos monitoring occurred
during the demolition, and sampling was
taken for water, soil, moisture, and air and
produced only minor detection. Water
(e.g., from the hose at the structure) was
non-detect for asbestos. The soil before
the demolition was non-detect for asbes-
tos and contained trace amounts (i.e., not
quantifiable) after demolition. Moisture
samples of demolition debris ranged from
39 percent to 147 percent.
- Air samples were taken at both the demo-
lition site and the landfill site, in an up-
wind/downwind configuration. The Fort
Worth Method monitors airborne concen-
trations of asbestos upwind (comparative
environmental background) and down-
wind of the site and compares the samples
to determine if the project is successful.
For each demolition, the city collected one
sample at each corner of the demolition
area, one sample per heavy equipment unit,
and one personal sample (at a minimum)
on workers in the work area that are not
dedicated to a piece of machinery. The
city also performed air monitoring while
landfilling demolition debris. They col-
lected samples at 10 locations for two to
three consecutive days during landfilling
of the demolition debris from each of the
facilities. Five sampling locations were
established upwind and downwind from
the landfill. Most of the air samples
showed a reading below detection limit for
asbestos; there was one asbestos fiber
found at the landfill and one at the demo-
lition site.
The Phase 2 demolitions will involve two iden-
tical structures that are subject to the Asbes-
tos NESHAPs. One structure will be
demolished using the Fort Worth Method and
one using the method prescribed by the As-
bestos NESHAPs.
The city has committed to monitoring asbes-
tos emissions for each demolition, and these
data will provide a basis for EPA to determine
whether Fort Worth's alternative method is
equivalent to the NESHAPs method for the
purpose of demolishing the remaining struc-
tures identified by the project sponsors. In or-
der to proceed to Phase 3, EPA must find that
the Fort Worth Method is equivalent to the
NESHAPs method. Phase 3 will consist of
using the Fort Worth Method on a number of
additional buildings.
Benefits for the Environment
• Using the alternative method in buildings with
ACBM will protect the environment from the
release of asbestos during the demolition.
Benefits for Stakeholders
• Stakeholders such as the local residents, busi-
nesses, chambers of commerce, government
entities, and organizations benefit from the re-
duction in blighted properties in their commu-
nity. Through working to rid the city of its
abandoned, substandard structures, the city
will become more beautified, property values
will rise, and in some cases public safety will
be restored.
• The reduction in demolition costs will allow
the city to accelerate urban renewal, thereby
eliminating havens for drug use and other
criminal activities and reducing safety hazards
often associated with the abandoned structures.
Benefits for the Project Sponsor
• The alternative method may create significant
cost savings for performing environmentally
sound proactive nuisance demolitions. This
allows Fort Worth and other local municipali-
ties to tackle the problem of urban blight more
successfully by being able to perform more
demolitions.
Information Resources: The information in this
summary comes from the following sources: (1)
the Phase 1 Monitoring Plan Agreement for the
City of Fort Worth, signed September 29, 2000;
and (2) the Project XL Comprehensive Report,
Volume 2: Directory of Project Experiments and
Results, November 2000.
-------
(Sle^mcmt (County
XLC' Final Project Agreement Signed September 6,
2000
Background
The Project Sponsor: Clermont County is a tran-
sitional community east of Cincinnati and one of
Ohio's fastest growing counties. The county is
experiencing significant changes in population
density and rural demographics. In 1990 the popu-
lation was 150,000; it is expected to reach 255,000
by 2020. The county is particularly concerned
about the impacts of rapid development on its sur-
face water resources. The Clermont County Project
focuses on the East Fork of the Little Miami River
(EFLMR) watershed. The specific waters within
the county considered under this agreement include
the EFLMR mainstream and tributaries and Harsha
Lake, which is located centrally within the EFLMR
basin. The EFLMR is a major tributary to the Little
Miami River, which is a designated State and Na-
tional Scenic River and is the State of Ohio's larg-
est Exceptional Warmwater Habitat stream.
The Experiment: The Clermont County XLC
project seeks to create a comprehensive watershed
management plan for the EFLMR. The watershed
plan will address environmental management of
the county's watershed resources with an aggres-
sive and innovative community-based approach so
that the county can maintain that necessary bal-
ance between economic growth and the preserva-
tion of its rural character and environment and,
where possible, strive to improve the environment
and protection of the area's resources. Due to its
comprehensive scope, the plan will also encom-
pass other development issues closely tied to wa-
ter quality, including land use, development
procedures, open space and farmland preservation,
and economic development. It is expected that this
approach will achieve more environmental objec-
tives and meet more performance standards than
'Project XLC, excellence and Leadership for Communities,
encourages local public sector and community organizations
to come forward with new approaches to demonstrate com-
munity-designed and directed strategies for achieving greater
environmental quality consistent with community economic
goals.
could be achieved using current federal and state
standards. The development of such a holistic plan
will empower the local community to work with
the Ohio Environmental Protection Agency
(OEPA) on reviewing current water quality stan-
dards and establishing meaningful measures of en-
vironmental conditions that are based on the
specific characteristics of the EFLMR and its tribu-
taries. The plan involves the following key com-
ponents: development of a Watershed Quality
Management Plan (QMP), collaborative goal set-
ting, sampling and monitoring, development of a
computer-based set of watershed monitoring tools,
development of a County Environmental Protec-
tion Plan, and the development of a community
framework for local permitting and public policy
formulation that improves the quality of the local
watershed.
To develop this innovative watershed management
plan Clermont County has developed an ongoing,
multiphased approach. Phase I of the project com-
prises the agreement between Clermont County,
OEPA, and EPA for this XLC project. The pri-
mary goal of Phase I is to focus on the overall plan-
ning aspects of the project, including (1) setting
conditions and criteria for assessing the project's
successes, milestones and schedules, and report-
ing requirements and (2) establishing the involve-
ment and commitments of Clermont County, EPA,
OEPA, and other participants and stakeholders in
the watershed development process. Phase I of
the project is near completion and involves imple-
menting the Watershed QMP and developing wa-
tershed modeling tools.
The Flexibility: For Phase 1, the initial planning
phase, no regulatory flexibility is needed. As the
project moves to subsequent phases, more specific
details regarding necessary regulatory flexibility
will be identified.
Although no specific regulations have been iden-
tified, the following potential areas that focus on
managing and protecting water resources may need
regulatory flexibility in the future:
• Implementation of a pollution trading system
within the watershed;
-------
• Management of land use and development
regulations;
• County and state oversight of local water qual-
ity objectives and standards;
• Operation rules for the Harsha Lake Reservoir;
and
• Discretion in allocation of funding to support
implementation of control measures.
Other Innovations: (1) Innovative Watershed
Management Approaches. Innovative watershed
management approaches include those that prevent
pollution in the first place, such as small diameter
gravity sewers, seasonal discharging/non-discharg-
ing small community wastewater sewage systems,
creative farming practices, or alternative small
business operations to help manage the amount of
pollution entering the watershed. (2) Increasing
County Responsibility for Monitoring. By adopt-
ing monitoring standards that meet or surpass the
state standards, the county will take greater respon-
sibility for the protection of its own watershed and
the state will become more focused on oversight.
(3) Transferring Lessons Learned to Other Com-
munities. The transfer of power from state to
county will put the county in a better position to
make informed decisions about how best to pro-
tect water quality. Sharing the lessons learned may
assist other communities facing the similar chal-
lenge of balancing economic growth with environ-
mental quality. (4) Community-based
Environmental Decision Making. The project
brings community-planning efforts related to
wastewater management and land use planning/
zoning together under water quality protection.
Ultimately, the county hopes to achieve collabora-
tive goal setting for its water resource management
by placing decision-making responsibility at the
local level.
The Superior Environmental Performance: A
major goal of this XLC project is to achieve supe-
rior environmental performance through greater
local responsibility and management of point and
non-point sources of water pollution. Further, this
project is comprehensive in scope and includes
development issues closely tied to water quality
such as land use, development procedures, open
space and farmland preservation, and economic de-
velopment. Most importantly, the county is being
proactive—investing in watershed management
controls not currently regulated by National Pol-
lutant Discharge Elimination System permits and
much sooner than would otherwise be required
under a waste load allocation and total maximum
daily load developed by OEPA.
Clermont County committed to the following four
project environmental performance goals in order
to achieve superior environmental performance
with this project: (1) no adverse trends in water
quality indicators; (2) maintenance of flow regime;
(3) support of high-quality fishery; and (4) im-
provement in trophic state of Harsha Lake.
The baseline used to measure superior environmen-
tal performance of this project will be comparing
the goals mentioned above to projected water qual-
ity conditions if this project were not imple-
mented—current control measures, unchecked
development, and reasonably anticipated future
regulations. Given the current rate of development
in the county, it is likely that if no new measures
or controls are developed for the watershed, the
water quality will decline over time. Consequently,
this innovative project should result in enhanced
environmental benefits sooner than would be real-
ized under current and anticipated regulations.
Progress in Meeting Commitments
(As of October 2001)
• Many of Clermont's commitments are ongo-
ing activities. Clermont is working with EPA
and OEPA to (1) implement the QMP (2) iden-
tify and describe potential watershed model-
ing management options, (3) identify and
verify monitoring and sampling methodolo-
gies, and (4) develop and implement water-
shed modeling tools.
• Clermont is also working with stakeholders
and the appropriate local, regional, and state
agencies.
• Clermont will work with EPA and OEPA to
identify and describe potential rules, permits,
-------
or other mechanisms that will be implemented
when necessary.
To date, no regulatory requirements have been
needed, but Clermont will comply with all nec-
essary requirements when they are needed.
Benefits for the Environment
• The Clermont XLC project will help improve
the EFLMR aquatic habitat through implemen-
tation of a comprehensive watershed manage-
ment plan that will improve surface water
quality throughout the county.
Benefits for Stakeholders
• Stakeholders and project sponsors are work-
ing to identify problems, establish goals, de-
termine data needs, review monitoring results,
and identify potential management actions.
One project goal is to involve the local com-
munity in establishing a relevant and specific
watershed management plan for the EFLMR
and place decision making at the local level.
Clermont County's Stakeholder Involvement
Program fosters a collaborative goal-setting
environment for water resources management.
Benefits for the Project Sponsor
• The development of the watershed manage-
ment plan will empower Clermont County to
work with OEPA on reviewing current water
quality standards and establishing meaningful
measures of environmental conditions that are
based on the specific characteristics of the
EFLMR and its tributaries.
• Clermont County will benefit through the de-
velopment of a computer-based set of water-
shed monitoring tools, a County
Environmental Protection Plan, and a commu-
nity framework for local permitting, and
through collaborative goal setting, sampling
and monitoring, and public policy formulation
that improves the quality of the local water-
shed.
• The development of the QMP is significant to
Clermont County because it provides a blue-
print for the Clermont XLC process that de-
scribes how they can select from a combination
of optimum watershed management options
and establishes a basis of sufficient informa-
tion for their decision making. It identifies
how decisions will be made, how data will be
managed, how situations will be evaluated, and
how information will be fed back into the sys-
tem, making the entire process collaborative
and specific to the EFLMR.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Clermont County Project, signed
September 6, 2000; and (2) the 2000 Project XL
Comprehensive Report, Volume 2: Directory of
Project Experiments and Results, November 2000.
-------
Cromp+cm
Corpora+ioia
Sistersville Facility
(¦formerly Witco)
Final Project Agreement Signed October 17, 1997
Background
The Project Sponsor: Crompton Corporation's
Sistersville facility (formerly Witco) is a specialty
chemical manufacturer. This project focuses on
Crompton's 50-acre chemical manufacturing plant
located six miles south of Sistersville, West Vir-
ginia, where Crompton produces a broad range of
silicone and silane products, including surfactants,
emulsions, antifoams, and oils. The facility is lo-
cated along the east side of the Ohio River in a
rural setting near the border of Tyler and Pleasants
Counties. Crompton employs nearly 600 residents
of these two and other nearby West Virginia and
Ohio counties at the Sistersville plant.
The Experiment: The Crompton project tests
whether regulatory flexibility will lead to reduc-
tions in air emissions and waste greater than what
would be achieved by otherwise required emissions
controls for the two wastewater surface impound-
ments located onsite. The project strives to re-
duce pollution through a combination of air
pollution control, waste minimization, and pollu-
tion prevention (P2) activities.
The Flexibility: EPA and the State of West Vir-
ginia have agreed to a deferral of Resource Con-
servation and Recovery Act (RCRA) organic air
emission standards through a site-specific rule ap-
plicable to two Crompton surface impoundments.
EPA is in the process of promulgating National
Emission Standards for Hazardous Air Pollutants
(NESHAPs) under the Clean Air Act (CAA). EPA
plans to propose NESHAPs applicable to miscel-
laneous organic processes in the first quarter of
fiscal year 2002; this standard is called "the MON."
Production activities at the Sistersville facility will
be regulated under the MON. The MON is antici-
pated to require process vent controls similar to
the vent incinerator installed by Crompton under
the XL project. Therefore, the project will pro-
vide superior environmental performance only
until the MON is in effect. The project provides
for a reevaluation following the proposal of the
MON. Crompton will prepare a project reevalua-
tion report within 90 days following the close of
the comment period for the new standards. If EPA,
West Virginia, and other stakeholders agree to con-
tinue the project, the FPA will be amended to
achieve superior environmental performance in a
different way and to go beyond the MON require-
ments.
Other Innovations: (1) Waste Minimization and
Pollution Prevention. Crompton committed to
conducting a waste minimization/pollution preven-
tion (WM/PP) study to identify opportunities for
additional reductions in waste generated by the fa-
cility. (2) Case-by-Case Deferrals. EPA and West
Virginia consider the WM/PP initiatives to be an
important contribution to the superior environmen-
tal performance offered by the Crompton project.
The applicability of the WM/PP initiatives could
be limited if they are subject to the requirements
proposed in CAA Subpart YYY. Subpart YYY, as
proposed, would apply to a process unit that gen-
erates wastewater and produces one or more of the
chemicals listed as a product, co-product,
byproduct, or intermediate product. If promul-
gated, CAA Subpart YYY would apply if
Crompton begins recovering substances listed in
the proposed CAA Subpart YYY. If Crompton
starts recovering these substances, EPA and West
Virginia will then consider issuing a limited scope
"allowable exclusion/allowable increase" deferral
of the regulations on a case-by-case basis. This
deferral would be issued with the provision that
EPA and West Virginia find that it will not cause
an increase in actual emissions of volatile organic
compounds or cause a net adverse environmental
impact. Further, Crompton must remain in com-
pliance with the provisions of the XL project. If
such a deferral is granted, EPA and West Virginia
will consider proposing regulations implementing
the deferral. /
The Superior Environmental Performance:
Crompton has realized significant decreases in
methyl chloride, dimethyl ether, and methanol
emissions, as well as decreases in wastewater
-------
treatment sludge generated at the Sistersville fa-
cility. Crompton has installed a process vent in-
cinerator that destroys 98 percent by weight of
"capper unit" air emissions. The performance test
has shown that the oxidizer is reducing total or-
ganics in the vent stream by 99.99 percent. Ap-
proximately 602,484 pounds of methyl chloride,
dimethyl ether, and methanol emissions have been
reduced as a result. Since 1998, 100 percent of
methanol collected from the capper unit has been
reused, a total of 1,292,834 pounds of methanol.
As a result of Crompton's methanol recovery and
reuse efforts, the amount of sludge generated by
the wastewater treatment system from capper op-
erations, and disposed of in an onsite hazardous
waste landfill, has been reduced by 1,914,873
pounds. Finally, WM/PP activities at the facility
have resulted in 400 identified opportunities for
waste minimization and pollution prevention.
Twenty-two of these are currently being imple-
mented. Eighty-seven implemented projects since
1998 have resulted in a reduction of 5,200,000
pounds of wastes generated, as well as a cost sav-
ings to the facility of $3,651,000.
Progress in Meeting Commitments
(As of July 2001)
• Crompton is required to purchase, install, test,
and monitor a process vent incinerator on its
methyl capper unit that will reduce the organic
compounds in the process vent streams by 98
percent.
- The unit has been installed and is reduc-
ing the total organics in the waste stream
by 99.99 percent (see Figure 6). This ex-
ceeds the 98 percent control efficiency re-
quirement.
• Crompton is required to implement a metha-
nol recovery operation and ensure that a mini-
mum of 95 percent by weight of the methanol
collected is utilized for reuse, recovery, or ther-
mal recovery/treatment.
- The 95 percent methanol reuse, recovery,
or thermal recovery/treatment has been ex-
ceeded, as 100 percent of the methanol
collected has been reused (see Figure 7).
Crompton-Air Emission Reductions from Capper Unit
4/1/98-6/30/01 Actual
Performance Goal
0 20 40 60 80 100
Percent of Capper Unit Air Emissions Oxidized
Pignre 6
Crompton air emission reductions from capper unit.
-------
Crompton is required to implement a WM/PP
project, conduct a WM/PP study, deliver a fi-
nal report on the study, and implement the tech-
nically and economically feasible WM/PP
opportunities identified in the study.
- Crompton completed the final report for
the WM/PP study on December 11, 1998.
In addition to the progress reported above,
Crompton has achieved the following environ-
mental benefits since 1998:
- Total emissions have been reduced by
more than 600,000 pounds. Wastewater
treatment sludge generated has been re-
duced by nearly 2 million pounds. Nearly
1.3 million pounds of methanol have been
reused (see Table 4).
- A total of 602,000 pounds of methanol was
generated from July 2000 to June 2001,
of which 321,000 pounds were reused.
The Sistersville plant undertook two major P2
efforts to develop P2 opportunities in 2001.
- First, an Energy Conservation Team was
formed in Spring 2001 to identify and
implement ideas and methods that will re-
duce the plant's energy use and expenses.
The Team is focusing on use of electric-
ity, natural gas, nitrogen and water. The
Team is trying to increase awareness of
the costs of unnecessary electricity usage
and leaks. Several focus groups gathered Crompton air emissions from wastewater treatment system.
Crompton-Collected Methanol Reuse
4/1/98-6/30/01 Actual
Performance Goal
1995 Baseline
20 40 60 80 100
Percent of Collected Methanol Reuse
"igu^e 7
Crompton collected methanol reuse.
Crompton - Air Emissions from
Wastewater Treatment System
Performance Goal
Estimated without XL
_J L_
140
0 20 40 60 80 100 120 140 160
Thousands of Pounds per Year
•This goal Is not specified in the FPA; it Is an informal estimate.
Fiq
"Table 4: jAnnual Total Emissions y\nalysis
Emissions Analysis 1998
1999
2000
Total Air Emissions 152,217
Reductions (pounds)
205,350
244,917
Wastewater Treatment 542,783
Sludge Reductions (pounds)
676,930
695,160
/
Methanol Reused (pounds) 424,254
428,520
440,060
Total Reductions In 1,119,254
Emissions And Waste (pounds)
1,310,800
1,380,137
-------
to discuss ways to increase energy effi-
ciency and developed more than 200 ideas
for energy conservation in the four follow-
ing areas: (1) conservation, (2) waste re-
covery, (3) process energy reduction and
improvements, and (4) operating effi-
ciency improvements. The Energy Con-
servation Team is reviewing these ideas
and categorizing and prioritizing them.
The next steps for the Team are to imple-
ment those ideas where possible and then
to share them more broadly with those who
can more adequately address the sugges-
tions.
Second, the plant convened an Innovation
Workshop in July 2001 to help gather ideas
for improving business. Participants were
organized into four subject areas, one of
which was dedicated to waste minimiza-
tion, management, and treatment. Over 50
ideas from that group were identified and
prioritized. Crompton has begun pursu-
ing the most attractive ideas.
Table 5 highlights the P2 opportunities imple-
mented and the associated environmental and
cost savings benefits accrued by P2 activities.
As a main part of the XL project and its WM/
PP study, Crompton implemented air emissions
and sludge reduction plus methanol recycling.
The environmental benefits and cost savings
of these two efforts for the 2000 calendar year
are displayed in the first row of Table 5. In
addition to these two efforts, Crompton has
implemented a number of other waste man-
agement and P2 opportunities from the time
that the project has been in implementation.
Key focus areas for successful implementation
of the FPA over the next six months include
the fourth semiannual project report due Janu-
ary 31, 2002; the fourth annual project report
due July 31,2002; and the ongoing implemen-
tation of options identified in the WM/PP. EPA
is expected to propose new MON standards in
the first quarter of 2002. As per the FPA,
Crompton will prepare a project reevaluation
"Cable 5i Ccompton (ZorporaY\ov\ Sistersville Facility
WM/PP Study Results
Year Opportunity was
Implemented
Number of New P2
Opportunities
Implemented
Recurring Wastes
Prevented,
Latest Estimates,
Ibs/yr
Recurring Cost
Savings*,
Latest Estimates,
$/yr
Air Emissions and Sludge Reduction
Plus Methanol Recycle (excludes
capital savings from XL project)
Actual for Calendar Year 2000
2
1,380,137
$17,000
1997
9
376,000
$228,000
1998
10
111,000
$25,000
1999
34
1,698,000
$1,179,000
2000
21
529,000
$1,262,000
Jan.-June 2001
11
1,138,000
$940,000
Total
87
5,232,137
$3,651,000
Data presented are based upon information found in Crompton Sistersville Plant Project XL Annual Report, July 2001.
'Note that these savings do not consider the expense of implementing them. Hence net savings will be less. It is often
difficult to assign that expense. For example, a totally new process unit may cost millions of dollars to construct. If that new
process produces less waste, how much of the design and construction expense ought to be assigned to the P2 benefits? In
the case of a process change being done explicitly for P2 reasons, the expense is more easily determined.
-------
report within 90 days following the close of
the comment period for the new standards. If
EPA, West Virginia Division of Environmen-
tal Protection (WVDEP), and other stakehold-
ers agree to continue the project, the FPA will
be amended to include new approaches to pro-
viding superior environmental performance.
Benefits for the Environment
* In 1998, Crompton reduced air emissions by
152,217 pounds, reduced wastewater treatment
sludge by 542,783 pounds, and recovered for
reuse 424,254 pounds of methanol. In 1999,
Crompton reduced air emissions by 205,350
pounds, reduced wastewater treatment sludge
by 676,930 pounds, and reused 428,520 pounds
of methanol. In 2000, Crompton reduced air
emissions by 244,917 pounds, reduced waste-
water treatment sludge by 695,160 pounds, and
reused 440,060 pounds of methanol. (See Fig-
ures 8 and 9.)
* The final report of the WM/PP study (Decem-
ber 11, 1998) states that of the 290 P2 options
identified, 19 have been deemed "not feasible,"
87 "are feasible," and 184 still have their "fea-
sibility undetermined." The report includes
51 recent P2 initiatives that are in various
phases of implementation from "scoping" to
"complete." The P2 options that have already
been determined to be technically and eco-
nomically feasible are underway. To date, 400
P2 options have been identified, of which 22
are at some stage of study and 87 have been
implemented. The implemented "P2" oppor-
tunities have prevented a total of 5,232,137
pounds of waste and provided $3,651,000 of
cost savings.
Benefits for Stakeholders
* A Sistersville plant Project XL contact at the
facility has been appointed to serve as a re-
source for the community, as well as to an-
swer community inquiries about the XL
project.
Crompton - Wastewater Treatment Sludge
Generated from Capper Unit Methanol
Estimated without XL
1,177
1,425
200 400 600 800 1,000 1,2001.400 1,600
Thousands of Pounds per Year
Figure 9
Crompton wastewater treatment sludge generated from
capper unit methanol.
-------
• Public files on the project have been estab-
lished at both the Sistersville Public Library
and the EPA Region 3 (Philadelphia) office.
• Crompton participated in a workshop spon-
sored by EPA, WVDEP, and the West Virginia
Manufacturers' Association, where they led a
roundtable discussion and presented a paper
entitled "Waste Minimization for the 21st Cen-
tury: A Dialogue with West Virginia Business
and Industry Leaders."
• Crompton continues to keep stakeholders in-
formed of project status by providing copies
of semiannual and annual project reports.
Benefits for the Project Sponsor
• Asa result of WM/PP efforts, Crompton saved
$228,000 in 1997, $25,000 in 1998, $1,179,000
in 1999, $1,262,000 in 2000, and $940,000 in
the first half of 2001 and identified potential
future cost savings of over $1 million per year.
• As a result of the RCRA deferral, Crompton
expects savings of about $700,000 over the life
of the project.
Information Resources: The information in this
summary comes from the following sources: (1)
Project XL Second Annual Report, July 31, 2000;
(2) Project XL Stakeholder Involvement Evalua-
tion—Final Draft Report, May 2000; (3) the De-
cember 1999 Project XL Progress Report—CK
Witco Corporation (EPA 100-R-00-009); (4) the
March 1999 XL Project Progress Report—OSi
Specialties (EPA-100-F-99-009); (5) Witco's Janu-
ary 31, 1999, and July 30, 1999, reports; (6) focus
group discussions in December 1998 with repre-
sentatives of the federal and state regulatory agen-
cies, Witco, and public stakeholders involved in
the project; (7) the final report from Witco's WM/
PP study dated December 1998; (8) Project XL
Third Annual Report, July 31, 2001; and (9) EPA
OAQPS Web site: Air Toxics Web site: Upcoming
10 year MACT Standards, http://www.epa.gov/ttn/
atw/mactupd.html.
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Depa^tmervt of
l^ejervse £lme.Kvdor|-
jAi^ Porce Base
XL/ENVVEST4 Final Project Agreement Signed De-
cember 15,1999
Background
The Project Sponsor: Elmendorf Air Force Base
(AFB) is located just north of Anchorage, the larg-
est city in Alaska. Elmendorf AFB covers approxi-
mately 13,000 acres; it has more than 800
buildings, two runways, 150 miles of roads, and
more than 7,500 personnel from all branches of
the United States and Canadian armed forces. With
civilian workers, retirees, and their families, the
number of people associated with Elmendorf rises
to nearly 25,000. The southern boundary of the
base borders the Anchorage nonattainment area for
carbon monoxide (CO) under the Clean Air Act
(CAA) National Ambient Air Quality Standards.
Elmendorf is not included in the nonattainment
area, and therefore reductions in pollution levels
for Elmendorf AFB are not required under Title V
requirements, a national permit system that applies
to major stationary sources of air pollution. Nev-
ertheless, one of the goals of this project is emis-
sion reductions on the base, including CO emission
reductions.
The Experiment: The Elmendorf AFB project
aims to promote pollution prevention (P2) activi-
ties by using cost savings and paperwork reduc-
tion associated with simplified Title V
requirements. Under the simplified requirements,
the Elmendorf AFB central heating and power
plant (CH&PP) will be permitted as the base's only
major stationary source, based on its emissions of
nitrogen oxides (NO ) and CO. The statutory pro-
EPA and the Department of Defense (DoD) signed a Memo-
randum of Agreement in 1995 that established how the two
agencies would interact during implementation of DoD's En-
yironmental Investment (ENVVEST) program. The
l-NVVEST program emphasizes regulatory compliance
through pollution prevention and provides an alternative to
Prescriptive regulatory requirements through a performance
based environmental management system designed to attain
superior environmental results.
grams affecting the Elmendorf XL/ENVVEST
project are the CAA programs administered by
EPA's Office of Air Quality Planning and Stan-
dards and regulations of Alaska Department of
Environmental Conservation (ADEC). ADEC and
EPA will approve potential to emit (PTE) limits
for Elmendorf AFB's remaining sources of emis-
sions of NO and CO. In total, these administra-
x '
tive changes are expected to result in savings of
approximately $ 1.5 million over a six-year period.
These savings will be invested in P2 activities on
base, with an emphasis on hazardous air contami-
nant (HAC) emissions reduction. This XL/
ENVVEST project will demonstrate the feasibil-
ity of alternative-fuel vehicles in the Anchorage
area and reduce air pollution base-wide through
pollution prevention at multiple minor sources.
The Flexibility: The XL/ENVVEST project will
provide Elmendorf AFB with relief from ADEC's
operating permit program for major stationary
sources. The traditional Alaska operating permit
program would treat the entire Elmendorf AFB in-
stallation as a single air contaminant emission
source, with 106 sources of regulated contaminants
addressed in its Title V permit. Under these cir-
cumstances, the costs of obtaining and maintain-
ing a Title V permit would be substantial. Under
this XL project, the Title V permit would apply to
only a small segment of Elmendorf AFB, includ-
ing one source that is a major stationary source,
the CH&PP, and several others that are subject to
new source performance standards. ADEC will
establish PTE limits for the other sources at
Elmendorf AFB to ensure that they are not con-
sidered major sources. To enable the regulatory
changes under this XL/ENVVEST project, ADEC
will work toward inclusion of the major source
guidance for Elmendorf AFB into the Alaska Air
Quality Control regulations.
Most of the flexibility provided by this project
could have been obtained without Project XL
through an August 2, 1996, policy guidance docu-
ment entitled. Major Source Determinations for
Military Installations under the Air Toxics New
Source Review, and Title V Operating Permit Pro-
grams for the Clean Air Act, and with the imposi-
tion of PTE limits on Elmendorf AFB. However,
by participating in this project, Elmendorf AFB
-------
obtains the flexibility to redirect money that would
have been spent on Title V costs into P2 projects.
Elmendorf AFB has agreed to invest the expected
savings of $1.5 million into projects that will re-
sult in actual emission reductions. Without the XL/
ENVVEST project, those programs probably
would not have occurred.
The Superior Environmental Performance:
Elmendorf AFB is committed to spending the sav-
ings derived from streamlining its environmental
management costs on P2 opportunities. The ac-
tivities undertaken by Elmendorf AFB thus far are
detailed in the Progress in Meeting Commitments
section. A supplemental agreement setting forth
the specific additional P2 opportunities to be imple-
mented will be developed with the assistance of
stakeholders.
Other Innovations: (/) Federal Budget Process.
ENVVEST is testing new approaches to the fed-
eral budgeting process. In the past, DoD's bud-
geting process allowed resources meant for
environmental protection to be used only for meet-
ing legally mandated environmental protection lev-
els. New approaches are being tested to create a
budget process that allows DoD to spend resources
on P2 programs, innovative technologies, and other
approaches that will cost-effectively reduce emis-
sions below legally mandated levels.
Progress in Meeting Commitments
(As of August 2001)
• Elemendorf's primary P2 project is the intro-
duction of a compressed natural gas (CNG)
fleet and fueling program. The program is be-
ing phased over a six-year period and has two
primary activities: (1) design and construc-
tion of the CNG fueling station and (2) con-
version of gasoline and/or diesel-fired vehicles
to CNG-burning vehicles.
- The construction of a CNG fueling station
was completed in summer 2000 and was
celebrated with a ribbon-cutting ceremony
in September 2000 (see Figures 10 and 11).
The station is located on the southwest
corner of the base, and canopies for the
dispenser island and compressor/storage
units will be constructed in fiscal year
2002 to provide protection from the ele-
ments. Elmendorf has earmarked
$100,000 for construction of the canopy
for the CNG station. Additional slow-fill
hookups may also be added to locations
across the base if warranted.
- Elmendorf AFB purchased CNG conver-
sion kits for 15 vehicles in 2000. The to-
tal number of vehicles to be converted to
CNG is not defined as it depends upon per
vehicle cost of conversion, which varies
based on vehicle make and model. The
approximate per vehicle cost for conver-
sion is $9,000. In 2001, Elmendorf AFB
converted nine additional vehicles and has
a contract in place to install conversion kits
on 20 more vehicles. Fiscal year 2001
added another $ 100,600 to the conversion
program. ENVVEST has allocated
$30,000 for conversion of a 28-passenger
bus from diesel to CNG. Elmendorf
Figure 10
Construction of the CNG fueling station at Elmendorf AFB.
Figure *11
Fueling a vehicle at the CNG fueling station at Elmendorf
AFB.
-------
mechanics are trained and certified in the
CNG conversion process.
In addition to using alternative fuel vehicles,
Elmendorf AFB is pursuing other P2 measures.
Elmendorf AFB has assembled a list of the fol-
lowing other feasible P2 opportunities avail-
able at the base, along with the estimated costs
and environmental benefits of each opportu-
nity.
- Clean cam technology systems (CCTSs);
- A base-wide HAP emissions reductions
program;
- Block or headbolt heaters/plug-ins; and
- Road paint truck replacement.
Elmendorf AFB is considering the implemen-
tation of CCTSs. By replacing engine parts in
diesel-powered engines, CCTS can dramati-
cally reduce air emissions, including CO, NOx,
and particulate matter (PM).
- The CCTS was tested on a limited basis at
Brooks Air Force Base, Texas, where the
CCTS modifications resulted in a reduc-
tion of hydrocarbon emissions (HC) by 44
percent, CO emissions by 43 percent, NOx
emissions by 77 percent, and PM emis-
sions by 52 percent.
- A CCTS demonstration project will be
conducted at Elmendorf AFB during the
winter of 2002.
In 1999, Elmendorf contracted the Air Qual-
ity Branch of the Institute for Environment,
Safety and Occupational Health Risk Analy-
sis to conduct a comprehensive HAP emissions
reduction survey for the base. The survey iden-
tified a number of initiatives for source-groups
on the base that include surface coating op-
erations, internal combustion engines, incin-
erators, gasoline distribution, and aircraft
engine testing.
- Surface coating operations, which involve
the application of paints and primers at the
Corrosion Control facility, are a large con-
tributor to the base's HAP emissions, and
have received the greatest attention to date.
Elmendorf AFB purchased a spray gun
parts washer and seven high-volume/low-
pressure spray guns for the Corrosion Con-
trol facility. These two technologies mean
that lower levels of HAC solvents, such
as toluene, xylene and methyl ethyl ketone,
are released to the environment. A train-
ing class for all shop personnel was pro-
vided. In addition, Elmendorf AFB has
allocated $150,000 for construction of
three-stage filtration and carbon adsorp-
tion equipment in corrosion control paint
booths. The construction will be complete
in fiscal year 2002.
- In 2001, Elmendorf AFB installed a steam
and pressure sterilization unit at the base
hospital. The new system replaces a medi-
cal waste incinerator and produces no HAP
emissions. After treatment in the steril-
ization unit, waste can be handled as solid
waste, instead of the hazardous waste it
was before treatment.
- Public comments submitted by the Trust-
ees for Alaska requested ENVVEST funds
be used to quantify the air emissions from
airfield operations. A takeoff and landing
emissions inventory was completed in July
2001. The study was based on actual 1999
flying data and included aircraft stationed
at Elmendorf as well as transient aircraft
(see Table 6).
In the future, Elmendorf may propose the use
of ENVVEST funds to pursue the installation
of headbolt or block heater infrastructure. A
study presented in 1997 demonstrated a size-
able reduction in both CO and volatile organic
compound (VOC) emissions with the use of a
headbolt or block heater during cold weather
starts. At minus 15 degrees Celsius, the re-
searchers reported a reduction in cold-start CO
and VOC emissions ranging from 45 percent
and 87 percent with the use of block heaters.
Road and airfield painting operations are a sig-
nificant source of HAPs for Elmendorf AFB.
A HAPs Emission Inventory prepared in De-
cember 2000 documented that actual emissions
during the 1998 season was nearly six tons.
New paint and application technologies are
-------
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Table 6: (Calendar Veaf "1999 Takeoff and .Landing
Emissions fo^ Elmendorf ^AT~B
NOv
CO
HC
PM-10
so2
(tons/year)
(tons/year)
(tons/year)
[particulate
[sulfur
matter less
dioxide]
then 10
(tons/year)
microns in size]
(tons/year)
Winter mixing height (952 feet)
332.16
519.42
172.56.
100.94
46.1
Summer mixing height (1908 feet) 372.10 527.49 172.68 104.77 48.08
available that would allow Elmendorf AFB to
drop these emissions to nearly zero. Water-
based paints with low to no VOC content are
available and require new application trucks
that are estimated to cost $225,000.
- If Elmendorf is not successful in obtain-
ing funds through federal Air Force P2 pro-
grams, EN WEST stakeholders approved
the purchase of a new truck with
ENVVEST funds in the last stakeholder
meeting in August 2001. The purchase of
an aqueous road paint truck is estimated
to reduce HAP emissions by six tons per
year.
Benefits for the Environment
• The use of CNG-powered vehicles in place of
gasoline-powered vehicles will contribute to
reduced CO, NO, non-methane organic gases,
PM, and CO, emissions for Elmendorf. Ve-
hicles will be tested before and after conver-
sion to ensure that emissions are reduced.
• Elmendorf AFB has implemented a base-wide
switchover to high-solids/low-VOC paints
where technically feasible. These paints have
significantly lower levels of HAC solvents,
such as toluene, xylene, and methyl ethyl ke-
tone.
Elmendorf AFB has purchased an automatic
paint gun washer that recycles cleaning sol-
vents otherwise released to the atmosphere.
• Elmendorf AFB is undertaking a number of
P2 opportunities with the cost savings associ-
ated with this project.
Benefits for Stakeholders
• The use of CNG-powered vehicles at
Elmendorf AFB will demonstrate to the gen-
eral public that this level of technology is
achievable and beneficial. Elmendorf AFB has
also had discussions with Anchorage and the
State of Alaska about the possibility of the two
governments' CNG vehicles using the CNG
infrastructure on the base.
• Regular meetings of the Restoration Advisory
Board inform community members of pollu-
tion prevention activities resulting from this
project.
Benefits for the Project Sponsor
• Elmendorf AFB will experience $1.5 million
in cost savings as a result of the regulatory flex-
ibility that decreases total monitoring, record
keeping, reporting, and overall management
costs by about 80 percent.
• Elmendorf AFB is able to leverage the con-
struction of a CNG fueling station on base for
the acquisition of additional new CNG-capable
vehicles.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Elmendorf AFB XL/ENVVEST
project, December 1999; (2) supplementary pro-
posal materials; (3) the Initial ENVVEST Progress
Report, March 24,2000; (4) the ENVVEST Annual
Report, September 2001; and (5) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000.
-------
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Department oj
Defense 7\)aval
Station ^Vlayport
XL/EN WEST5 Final Project Agreement Signed May
30,2000
Background
The Project Sponsor: The Naval Station (NS)
Mayport is located in Jacksonville, Florida, and
encompasses more than 3,400 acres on the north-
ern end of a peninsula bounded by the Atlantic
Ocean to the east, the St. John's River to the north,
and the Intracoastal Waterway to the west. The
station is a home port for more than 14,000 sailors
and civilians, making it the third largest fleet con-
centration in the United States, and serves as a base
for Navy ships, airplanes, and helicopters, as well
as a training and repair station for the Atlantic fleet
of the U.S. Navy. NS Mayport has nearly 1 mile
of beachfront and 4.5 miles of river shoreline, and
almost half of its 3,400 acres are classified as wet-
lands, brackish marshlands, or beaches. The Navy
shares the area with numerous animal species,
some being threatened or endangered (e.g., mana-
tees, sea turtles, and northern right whales).
NS Mayport has been designated as the East Coast
Navy Environmental Leadership Program base to
help lead the Navy by developing innovative tech-
nologies and management practices to protect the
environment and natural resources.
The Experiment: Every 18 to 24 months, NS
Mayport dredges 600,000 cubic yards of silt and
sand from the mouth of the channel into the St.
John's River and the facility's turning basin in or-
der to maintain adequate depths for the passing of
naval ships. Historically, the dredged material was
5EPA and the Department of Defense (DoD) signed a Memo-
randum of Agreement in 1995 that established how the two
agencies would interact during implementation of DoD's En-
vironmental 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 designed to attain
superior environmental performance.
stored in two upland holding sites; however, the
space in the holding sites was eventually depleted,
resulting in the need for another disposal location.
Since 1993, ocean disposal for the dredged mate-
rial has been approved under the Naval Station's
current U.S. Army Corps of Engineers (USACE)
permits.
NS Mayport is investigating and demonstrating two
innovative methods for beneficially reusing
dredged material: (1) producing construction build-
ing blocks from dredged material and (2) produc-
ing artificial reef material from dredged material.
Reuse of the dredged material would eventually
eliminate the need for ocean disposal of the mate-
rial and/or permanent upland storage. NS Mayport
will also test to see if excess fly ash, a coal com-
bustion byproduct that can be used as a substitute
for Portland cement, from the City of Jacksonville's
Electric Authority serves as a good solidification
material for the construction blocks. By recycling
fly ash, the landfill needs of the Electric Authority
will be reduced.
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. Imple-
mentation will include (1) collecting samples of
dredged material and ensuring it meets all federal,
state, and local building requirements; (2) research-
ing 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 portable equipment to
manufacture products at or near the upland stor-
age sites. If it is determined that the finished prod-
ucts present any risk to human health or the marine
environment, implementation will stop.
The Flexibility: In return for testing possible ben-
eficial uses for dredged material, EPA, under the
XL/ENVVEST process, will create a partnership
with the USACE, the Florida Department of Envi-
ronmental Protection (DEP), the City of Jackson-
ville, and other interested stakeholders that will
facilitate streamlining the permitting process. NS
Mayport is currently required to obtain three per-
mits, with three different time lines, to dredge and
dispose of its dredged material. The USACE
-------
permits require that chemical, biological, and
physical analyses on the dredged material be per-
formed and approved by EPA every three years.
EPA, USACE, Florida DEP, and the City of Jack-
sonville believe that providing NS Mayport with
flexibility on permit renewals would allow them
to focus more on the issues that stem from dredg-
ing and ocean disposal and less on the paperwork
and renewal deadlines. Dredging and disposal are
costly processes, but through Project XL, extend-
ing the frequency of permit renewals to the maxi-
mum extent by law would lower costs and help to
improve the environment and marine habitat.
Other Innovations: (1) Pollution Prevention:
Using dredged materials for constructing build-
ing blocks and artificial reef materials. The goal
of the NS Mayport project is to minimize and even-
tually eliminate the ocean disposal of dredged
maintenance materials by way of innovative tech-
nologies that reuse dredged materials for the cre-
ation of construction building blocks and artificial
reef material. In addition, NS Mayport has pro-
posed using excess fly ash from Jacksonville's
Electric Authority as a solidification material for
the construction blocks (not for reef material). (2)
Federal Budget Process. EN WEST is testing new
approaches to the federal budgeting process. In
the past, DoD's budgeting process allowed re-
sources meant for environmental protection to be
used only for meeting legally mandated environ-
mental protection levels. New approaches are be-
ing tested to create a budget process that allows
DoD to spend resources on pollution prevention
programs, innovative technologies, and other ap-
proaches that will cost-effectively reduce emissions
below legally mandated levels.
The Superior Environmental Performance: The
NS Mayport XL/ENVVEST project provides a
mechanism for EPA, NS Mayport, USACE, Florida
DEP, and City of Jacksonville to explore options
for streamlining and synchronizing permit appli-
cation and processing required for the maintenance
of dredging and ocean disposal permits. This re-
organization will promote superior environmental
outcomes by allowing NS Mayport to focus on
developing two innovative methods for beneficially
reusing dredged material: (1) producing construc-
tion building blocks from dredged material and (2)
producing artificial reef material from dredged
material. Use of the dredged material would even-
tually eliminate the need for ocean disposal of the
material and/or permanent upland storage. Re-
duced ocean disposal of dredging material reduces
the potential for negative impacts on water quality
and benthic communities. A restriction on reef
placement to outside the endangered northern right
whale calving areas will eliminate the crossing of
vessels carrying dredged materials through this
habitat. NS Mayport will also test to see if the
excess fly ash from the City of Jacksonville's Elec-
tric Authority serves as a good solidification ma-
terial for the construction blocks. If it is suitable,
this will reduce the disposal of fly ash in local land-
fills.
Progress in Meeting Commitments
(As of October 2001)
• NS Mayport committed to identify alternative
uses for dredged materials.
- A pilot study to manufacture 1,000 deco-
rative bricks for on-site projects is pro-
jected to begin in December 2001.
• NS Mayport committed to conduct tests and
determine if dredged material and/or fly ash
contain any contaminants.
- Preliminary test results from bricks formed
from one of the dredged material cells
were submitted to EPA on March 2, 2001.
Due to solid waste and hazardous waste
concerns involving the use of dredged ma-
terial, EPA and Florida DEP requested ad-
ditional sampling be performed of the
dredge material before and after the brick
forming process. The contract to perform
that sampling was awarded in September
2001 with sampling expected to begin in
early December 2001.
- The screening test results indicated that
high-quality bricks/blocks could be manu-
factured from NS Mayport dredged mate-
rial with appropriate additives. The study,
conducted by a technical consultant, rec-
ommended two possible brick construction
-------
techniques out of the dredged material and
additives that would produce brick/blocks
that meet building specifications and codes
for the State of Florida.
- The study also completed toxicity charac-
teristic leachate procedure (TCLP) testing,
required under the Resource Conservation
and Recovery Act, on specimens of earthen
block made with dredged material. EPA
has established threshold levels for certain
testing parameters, and all samples tested
during the TCLP were determined to be
less than EPA thresholds. During the du-
ration of the project, EPA must approve
data collected prior to any maintenance
dredging, currently scheduled for Septem-
ber 2002, 2004, and 2006.
NS Mayport committed to concurrently obtain
a Rivers and Harbors Act Section 10 permit
for the dredging from the USAGE; Environ-
mental Resources Permit (ERP) from Florida
DEP; and a Marine Protection Research and
Sanctuaries Act Section 103 Permit for the dis-
posal.
- The current NS Mayport Section 10 per-
mit expires in January 2002, the Section
103 permit expires January 2002, and the
ERP permit expired October 2001. Per-
mits will be issued concurrently in sum-
mer 2002.
NS Mayport committed to obtain from Florida
DEP a Clean Water Act Section 401 Water
Quality Certification (WQC) and a Coastal
Zone Management (CZM) certification prior
to the issue of a Section 10 permit.
- The certification will be issued once the
ERP permit has been obtained. The issu-
ance of an ERP by Florida DEP satisfies
the WQC and CZM requirements.
NS Mayport committed to issue annual sum-
mary reports as outlined in the FPA starting
one year following its signing, through June
2009. Each report will be due the same time
of each year during the life of the FPA.
- The first annual summary report is sched-
uled to be submitted by December 30,
2001, in order to include results of addi-
tional sampling. Annual reports will be
submitted each December through 2009.
• NS Mayport committed to begin using dredged
material from the two existing inland holding
sites for construction blocks and artificial reef
materials until one site has been depleted.
- NS Mayport will construct a pilot plant
for test production of building block ma-
terials beginning in December 2001.
• NS Mayport committed to hold public meet-
ings June of each year from 2001 through 2009.
- The first public meeting was held on No-
vember 18, 1999. A public meeting will
be held in January 2002 following the is-
suance of the first annual report.
Benefits for the Environment
Ocean dumping of dredged materials gener-
ated by NS Mayport will be minimized and
eventually eliminated.
An additional reef ecosystem in the surround-
ing areas will be created through the use of
dredged materials.
• Testing the reuse of dredged materials and us-
ing fly ash may drastically reduce the amount
of waste needing to be landfilled and if suc-
cessful, may be a potential reuse option for
similar dredging operations.
Benefits for Stakeholders
• The City of Jacksonville could benefit finan-
cially from the introduction of an artificial reef.
Artificial reefs have proven to be effective
tools that augment and enhance recreational
opportunities (fishing and diving).
• The City of Jacksonville's Electric Authority
may benefit financially from the use of fly ash
in building blocks versus typical disposal costs.
-------
Benefits for the Project Sponsor
• NS Mayport should realize considerable direct
cost savings through the synchronization of
permits. This project will bring about a sig-
nificant reduction in paperwork, cost, and time
spent on permit renewals. This streamlining
will allow NS Mayport to focus on the issues
that stem from dredging and ocean disposal.
• In setting an environmental management stan-
dard for all Navy installations, this project will
allow NS Mayport to disseminate its lessons
learned from this project throughout the Navy
and DoD.
Information Resources: The information sources
used to develop this project summary include: (1)
the FPA for the NS Mayport XL Project, May 30,
2000; (2) March 2, 2001 report by Norman Murray
& Associates to NS Mayport entitled, "Evaluation
of Building Block Manufacture of Dredged Mate-
rial from U.S. Naval Station Mayport Confined
Disposal Facilityand (3) the 2000 Project XL
Comprehensive Report Volume 2: Directory of
Project Experiments and Results, November 2000.
-------
De.paHmeiaf oj~
Defe.iase Pu0ef Sou^d
A) aval SKipyai^d
XL/EN WEST6 Final Project Agreement Signed Sep-
tember 25, 2000
Background
The Project Sponsor: Puget Sound Naval Ship-
yard (PSNS) is a 750-acre, $1.5 billion industrial
facility located in Bremerton, Washington. Sur-
rounded by evergreen trees and salmon runs,
PSNS's six dry docks, seven piers, and 382 build-
ings are located on Sinclair and Dyes Inlets in the
heart of the Puget basin. PSNS is the workplace
of approximately 7,700 civilian and 50 perma-
nently assigned military employees, with up to
3,000 additional military personnel, depending on
the number of ships being overhauled at any one
time. In continuous operation since it was founded
in 1891, the shipyard serves as the full-service
home port for several U.S. warships and performs
repair, overhaul, conversion, refurbishment, refu-
eling, decommissioning, dismantling, and recy-
cling of Navy submarines and surface ships. Types
of facilities include manufacturing, research, de-
velopment, and testing.
Repair and maintenance activities commonly car-
ried out at shipyards include hull cleaning, repair,
and painting, electrical and machine work, carpen-
try, steel fabrication, pipe fitting, and sand blast-
ing of parts. While smaller vessels can be worked
on beneath shop roofs, larger vessels must be
worked on out of doors in dry docks or hoisted out
of the water on marine railways. In both cases,
hulls are typically cleaned and stripped with high-
and low-pressure water guns and/or dry, abrasive
grit blasting. Painting is done mostly with spray
6EPA and the Department of Defense (DoD) signed a Memo-
randum of Agreement in 1995 that established how the two
agencies would interact during implementation of DoD's En-
vironmental 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 designed to attain
superior environmental performance.
guns. Painting and stripping are significant sources
of pollution from shipyards, and their waterfront
locations increase the potential for pollutants to
reach bodies of water.
The Experiment: This XL/ENVVEST project
aims to develop and demonstrate an alternative
strategy for protecting and improving the health
of surface waters by identifying the stresses and
corresponding point sources and non-point sources
that are adversely affecting the Sinclair Inlet
aquatic ecosystem. Pollution prevention strategies
will then be developed for those sources for which
the Shipyard is responsible in a comparative risk
reduction approach.
Through this XL project, PSNS will develop, test,
and demonstrate an alternative, long-term, and
cost-effective strategy for protecting and improv-
ing the ecological health of the Sinclair Inlet
through the use of sound ecological science and
risk-based management techniques consistent with
the EPA Ecological Risk Assessment Guidelines
(EPA defines an ecological risk assessment as the
process of evaluating the likelihood that adverse
ecological effects may occur or are occurring as a
result of exposure to one or more stresses), national
Clean Water Act (CWA), and State Water Quality
Standards. Specifically, this project will include
a comprehensive watershed assessment that will
provide the technical basis to implement the most
cost-effective strategies to maintain and/or improve
surface water quality.
The project involves two main phases. The first
phase is an extensive research/study project to de-
velop a comprehensive environmental database and
a "watershed contaminant fate and transport"
model. In the second phase, PSNS and stakehold-
ers will use data gathered in the first phase to de-
velop and then propose innovative compliance
approaches within the regulatory framework.
The Flexibility: In Phase I of this project, no com-
pliance flexibility is needed. Rather, PSNS will
conduct a study that may result in a request for
compliance flexibility in Phase II. This "umbrella
FPA'" established the fundamental criteria for as-
certaining and evaluating the existing health of
Sinclair and Dyes Inlets so that the parties can make
-------
informed decisions and make recommendations for
proposed compliance flexibility.
In Phase II, the proposal may seek to reallocate
CWA National Pollutant Discharge Elimination
System (NPDES) leads through consideration of
CWA total maximum daily load (TMDL) analy-
sis, pollutant load allocation options, and pollut-
ant trading potential. Requests for compliance
flexibility (such as establishing a pollutant-trad-
ing program for the Sinclair Inlet watershed) will
be addressed when PSNS and the stakeholders
identify instances where such flexibility would be
beneficial. Such requests will be negotiated with
EPA and the Washington Department of Ecology
(WDOE).
Other Innovations: (1) Transferability of an In-
tegrated Marine Environmental Compliance Pro-
gram. The project will create a process that will,
over time, allow a transition from piecemeal regu-
latory controls to a system of more effective and
integrated pollution prevention and compliance
system for the Sinclair and Dyes Inlets, with docu-
mented results. If proven successful, the tools de-
veloped for this project are anticipated to turn into
a model that would be transferable to shipyards,
both Navy and civilian, or to any governmental or
civilian shoreside industrial facility or stakeholder
community having past or present discharges into
a marine environment. (2) Testing Risk Assess-
ment Concepts and Methodologies. PSNS is test-
ing the use of ecological risk assessment to focus
and prioritize pollution prevention strategies on
those waste streams that have the highest poten-
tial of adversely affecting the Sinclair and Dyes
Inlets aquatic ecosystem. (3) Relevant Measures
of Ecological Effects. The project will investigate
and consider proposing alternative measures of
ecological effects and/or surrogates of compliments
to identified TMDL parameters. (4) Cooperative
TMDL Development Program. This project is test-
ing a new approach to TMDL development by
partnering government with a private entity (the
Navy) that will be impacted by the outcomes of
the TMDL. In addition, participants have worked
closely with the regulated community to help de-
velop a strategy to create basin wide TMDLs. The
goal of this approach is to bring as many local re-
sources to the table so that the TMDLs are as ac-
curate and defensible as possible. (5) Federal
Budget Process. EN WEST is testing new ap-
proaches to the federal budgeting process. In the
past, DoD's budgeting process allowed resources
meant for environmental protection to be used only
for meeting legally mandated environmental pro-
tection levels. New approaches are being tested
to create a budget process that allows DoD to spend
resources on pollution prevention programs, inno-
vative technologies, and other approaches that will
cost-effectively reduce emissions below legally
mandated levels.
The Superior Environmental Performance: The
PSNS's commitment to developing basin and wa-
tershed scale investigations, considered and con-
ducted in a broader ecosystem context, is expected
to produce results that will far exceed less informed
and more piecemeal-type approaches. In addition,
this project seeks to develop information, tools,
and analyses to help regulators more readily link
NPDES permit decisions to protecting aquatic uses
through the development and implementation of
TMDLs. Such an approach, coupled with PSNS's
commitment to partner with other federal, tribal,
state, and local entities, will help build the overall
capacity of resource managers and the public alike
to efficiently improve the water quality of the
Sinclair and Dyes basin.
Progress in Meeting Commitments
(As of August 2001)
• PSNS and stakeholders are currently gather-
ing data and developing the comprehensive en-
vironmental database and watershed
contaminant fate and transport models that will
be used to analyze watershed data using an
environmental risk assessment approach.
Based on the findings, an alternative regula-
tory approach will be developed and proposed
for consideration by both EPA and WDOE.
• PSNS committed to developing a strong out-
reach program, establishing a Technical Work-
ing Group (TWG) composed of representatives
from various governmental agencies, educa-
tional institutions, and research groups and a
-------
Community Working Group (CWG) composed
of public and private interest groups and in-
terested citizens.
- PSNS established a TWG on July 20,2000
to develop, analyze, review and/or advise
on issues within the ENVVEST Project
and within more formal program and de-
cision review processes.
- PSNS is in the process of determining the
full scope of CWG involvement in this
project, but it is anticipated that the CWG
will conduct several major reviews of
documents prepared by the TWG. These
reviews include the Technical Master Plan,
the TMDL Work Plan, and the Watershed
Monitoring Plan.
EPA, PSNS, and WDOE will work together to
draft a report outline within 90 days of the sig-
nature of the FPA outlining stakeholder activi-
ties, important announcements, and a schedule
of activities through the next reporting period. .
- Following the signing of the FPA, it be-
came apparent that the various partners in
the project had different expectations re-
garding the technical steps that needed to
be undertaken to realize the goals and ob-
jectives of the project. At that point, it
was decided that a Technical Master Plan
should be developed outlining the techni-
cal scope of the project. The Technical
Master Plan was drafted distributed for
joint review and comment by EPA, PSNS,
WDOE, and various working groups in
March 2001. It is anticipated that follow-
ing incorporation of EPA and WDOE com-
ments, currently scheduled for December
2001, the CWG will review the plan.
PSNS committed to provide an annual sum-
mary report to EPA and WDOE and, upon re- .
quest, to stakeholders. Each annual report will
provide a summary of environmental perfor-
mance and will describe PSNS's progress to-
ward completing the project as outlined in the
FPA. During the first two years of implemen-
tation, PSNS will also submit a written report
at six-month intervals.
- The first semiannual report was originally
due in March 2001. However, due to dif-
ficulties in initially coordinating the efforts
and expectations of county, state, and fed-
eral entities regarding the project, report-
ing has been delayed until after the
Technical Master Plan has been finalized,
which is expected in early 2002. These
semiannual reports will provide a summary
of the status of the various technical stud-
ies being conducted under this project.
PSNS committed to develop and implement a
comprehensive environmental database.
- PSNS staff and contractors have been de-
veloping information and entering it into
a comprehensive environmental database.
The database is currently in use by the
TWG and access will eventually be pro-
vided to a broader array of users, includ-
ing the CWG.
PSNS committed to develop an integrated
watershed/surface water contaminant fate and
transport model.
- Hydrodynamic models for receiving wa-
ters included in this study have been com-
pleted and linked with water quality
modules. No more work can be done on
this portion of the model until pollutant
loading terms for major creeks and point
sources have been determined using the
watershed monitoring plan and the water-
shed models. Modeling of the major
creeks in the study area is ongoing as well
as development of the linkages between
the watershed and surface water models.
The best estimate for when completion of
these modeling efforts would occur is fis-
cal year 2004.
PSNS committed to utilize the information ob-
tained from the database and modeling efforts
to perform ecological risk assessment on the
Sinclair Inlet.
- Development of an ecological risk assess-
ment framework is still in the problem for-
mulation phase. In order to finish the
-------
problem formulation and move forward,
more water quality data and further defi-
nition of the objectives by our community
and technical working groups will be
needed. Both of these efforts are ongo-
ing.
Benefits for the Environment
• This project seeks to develop tools that can
provide information on the ecological health
of the Sinclair and Dyes basin. This informa-
tion can be integrated with TMDL develop-
ment to help prioritize implementation
activities that most benefit the water quality
and natural function of the basin as a whole.
• The strategies developed as a result of this
project will focus on utilizing a whole picture
of the ecosystem, rather than addressing envi-
ronmental aspects and problems in a piecemeal
approach.
Benefits for Stakeholders
• Building partnerships among local stakehold-
ers will ensure that all stakeholders have in-
creased access to and input into the
environmental decision-making process. This
project involves a high level of integration and
coordination between all involved stakehold-
ers, located both on and off federal lands within
the watershed, and has taken great strides to
include community-level coordination, com-
munication, and representation.
• An integrated monitoring, data collection, and
analysis effort will avoid duplication of effort
and efficiently focus monitoring programs car-
ried out by stakeholder organizations, which
now independently gather marine environmen-
tal data.
It is hoped that this project will provide guide-
lines for the minimum data and criteria neces-
sary to define what all local jurisdictions must
define in respect to TMDLs: data, format, and
analysis needed.
Benefits for the Project Sponsor
• This pilot project could result in at least
$135,000 savings annually through reduced
end-of-pipe sampling, revised analytical meth-
ods, more efficient record keeping and report-
ing and better targeting of permit limitations.
A portion of these savings would be used to
implement the integrated monitoring and data
management elements of the proposed project.
The remainder would be used in targeted ma-
rine pollution prevention initiatives.
Information Resources: The information sources
used to develop this project summary include: (1)
the Phase I FPA for the Puget Sound Naval Ship-
yard, signed September 25,2000; (2) "Large Ship-
yards in Washington: P2 & BMP Opportunities: A
Northwest Roundtable Report," November 6, 1997
(http://www.pprc.org/pprc/sbap/shipyard/wash/
rt_rept.html); and (3) The 2000 Project XL Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
-------
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XL/ENVVEST7 Final. Project agreement Signed No-
vember 3,1997
Background
The Project Sponsor: The 30th Space Wing at
Vandenberg Air Force Base (AFB) conducts and
supports space and missile launches, operates the
Western Test Range, and responds to worldwide
military contingencies. Vandenberg AFB covers
more than 98,000 acres and is the Air Force's third-
largest installation. It is located in Santa Barbara
County on the central coast of California, 150 miles
northwest of Los Angeles.
The Experiment: Through this XL/ENVVEST
project, Vandenberg AFB will use money to
achieve superior environmental performance that
otherwise would be spent complying with the ad-
ministrative requirements of Title V of the Clean
Air Act (CAA)—permitting, record keeping, moni-
toring, and training. Vandenberg AFB will apply
advanced emission control technologies to station-
ary sources to reduce annual emissions of ozone
precursors. In the first two years of the project,
Vandenberg AFB focused on obtaining reductions
from boilers, furnaces, and process heaters. Since
then, Vandenberg AFB has focused on pollution
prevention opportunities from a variety of other
sources of ozone precursors, including internal
combustion engines and solvent and surface coat-
ing applications. Details of the program are speci-
fied in an enforceable emission reduction plan
prepared by Vandenberg AFB and in the annual
and semiannual status reports prepared by
Vandenberg AFB.
EPA and the Department of Defense (DoD) signed a Memo-
randum of Agreement in 1995 that established how the two
agencies would interact during implementation of DoD's En-
vironmental 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 designed to attain
superior environmental results.
The Flexibility: Vandenberg AFB, like other mili-
tary installations, differs from civilian or indus-
trial stationary sources in that the base hosts and
supports a unique and wide variety of functions
and activities. These activities include residential
housing, schools, recreational parks, wildlife re-
serves, shopping centers, industrial maintenance
facilities, airfield operations, and various other
mission-related activities. Therefore, Vandenberg
AFB creates criteria pollutants normally associ-
ated with residential, commercial, and light indus-
trial operations. Boilers, furnaces, process heaters,
and internal combustion engines produce most of
the stationary source ozone precursor emissions,
primarily nitrogen oxides (NOx). For purposes of
permitting under Title V of the CAA, EPA and the
Santa Barbara County Pollution Control District
(the District) historically have considered
Vandenberg AFB and all of its individual emis-
sion units to be a single stationary source. How-
ever, Vandenberg AFB does not fit the single
stationary source definition as generally applied
to civilian or industrial sources. Vandenberg AFB,
in cooperation with the District and EPA Region
9, determined that if the actual emissions that are
used to make a major stationary source determina-
tion for the base could be reduced to minor source
levels, then Vandenberg AFB would be eligible to
comply with rules that entail significantly less of
an administrative burden. Together, the District,
EPA Region 9, and Vandenberg AFB applied EPA's
"Guidance for Major Source Determinations at
Military Installations under the Air Toxics, New
Source Review, and Operating Permit Programs
of the Clean Air Act" (memorandum issued on
August 2, 1996, by John Seitz, Director of EPA's
Office of Air Quality Planning and Standards) to
group different base activities as separate station-
ary sources for purposes of Title V applicability
only. This guidance states that certain personnel-
related activities at military installations (e.g., base
amenities like grocery stores, gas stations, hous-
ing, theaters, shopping centers, etc.) may be con-
sidered not to be support facilities, and therefore
can be considered separate sources. In addition,
the District amended its regulations to exclude
from its major source determination emissions that
meet EPA's definition of "non-road engine," in-
cluding equipment used for tactical support, infra-
structure, and maintenance. The District's Rule
-------
370, Potential to Emit—Limitations for Part 70
Sources, allows stationary sources that emit mi-
nor source levels of criteria pollutants to comply
with Rule 370 requirements rather than having to
obtain a Title V operating permit, thereby decreas-
ing the permit administrative requirements for
Vandenberg AFB.
The Superior Environmental Performance:
Vandenberg AFB will improve the air quality of
Santa Barbara County by using innovative tech-
nologies and pollution prevention to reduce annual
emissions of ozone precursors by 10 tons or more
by November 30, 2002.
Other Innovations: (1) Administrative Burden
Reduction. A number of XL projects are testing
different approaches to reducing the administra-
tive permitting requirements imposed by federal,
state, and local regulations. The Vandenberg AFB
project is a test bed for sector-wide burden reduc-
tion for federally regulated entities. EPA is under-
taking a coordinated permitting reform effort.
Lessons learned from the Vandenberg AFB XL/
ENVVEST permit approach will be used to influ-
ence the Permit Reform Action Plan. (2) Federal
Budget Process. ENVVEST is testing new ap-
proaches to the federal budgeting process. In the
past, DoD's budgeting process allowed resources
meant for environmental protection to be used only
for meeting legally mandated environmental pro-
tection levels. New approaches are being tested
to create a budget process that allows DoD to spend
resources on pollution prevention programs, inno-
vative technologies, and other approaches that will
cost-effectively reduce emissions below legally
mandated levels.
Progress in Meeting Commitments
(As of October 2001)
• Vandenberg AFB met its commitments to
achieve the following milestones: (1) complete
an initial assessment and cost feasibility study
of emission reduction planning and permitting;
(2) complete an evaluation of 24 pre-selected
candidate boilers to determine their feasibil-
ity for retrofit or replacement with low-NOx
technology; (3) implement the boiler retrofit
and replacement program; (4) submit a Rule
1301 emission reduction plan to the District;
(5) implement a program to reduce emissions
from solvents, surface coatings, and other
sources of volatile organic compounds
(VOCs); (6) implement a program to reduce
mobile source emissions of NOx and VOCs by
replacing cars and trucks with electric vehicles
(EVs); and (7) prepare progress reports every
six months.
• In addition to the milestones, the FPA identi-
fied the need for a program plan. Source se-
lection criteria, baseline emission protocols,
technology options, emission measurement
protocols, and emission reduction reporting
protocols were to be included in the plan.
- An initial plan was submitted to the Dis-
trict on November 26, 1997. The plan was
partially approved with the understanding
it would be revised and resubmitted to
demonstrated compliance with Milestone
5. The document was completed on Oc-
tober 31, 2001, and will demonstrate that
the conditions of all milestones were met.
• Vandenberg AFB committed to reducing an-
nual emissions of ozone precursors (NO^ and
VOCs) by 2 tons per year by April 30, 2000,
and by 10 tons per year or more by November
30, 2002. As of April 2000, Vandenberg AFB
had achieved 2.29 tons of emissions reductions
through implementation of the boiler retrofit
and replacement program. An additional 1.92
tons of emissions had been reduced by April
2000 through the implementation of zero-VOC
paint and coating substitution (1.27 tons of
VOC emissions), paint booth consolidation
-------
Vandenberg - Ozone Precursor Emissions
November 30, 2002 Goal
April 30, 2000 Actual
April 30.2000 Goal
Baseline (1996 Levels)
20 40 60 80
Tons per Year
Figure 12
Vandenberg AFB's emissions of ozone precursors.
Figure 13
Cars charging at one of the sites of the current 29
charging stations installed around Vandenberg AFB. This
particular site supports 12 charging stations along with 10
Ford Ranger EV truck applications for the 30th Civil
Engineering Squadron.
Figure 14
The parking island and charging stations that were
constructed to accommodate Vandenberg AFB's SUVMS.
V A ¦
'' f.i
Figure 15
The SUVMS electrical equipment enclosure, which
provides power to the SUVMS and EVs charging stations
at Vandenberg AFB.
(0.50 tons of VOC emissions), and construc-
tion of a wastewater reclamation system adja-
cent to a satellite launch facility (0.15 tons of
NO^ and VOC emissions). When these l .92
tons of emissions are combined with the 2.29
tons of emissions reductions achieved through
implementation of the boiler retrofit and re-
placement program, this results in a total of
4.21 tons of real and quantifiable emission re-
duction credits (see Figure 12).
However, only the boiler retrofit and replace-
ment program emission reductions are consid-
ered surplus, sustainable, and therefore,
enforceable for purposes of the ENVVEST
Program. Realizing this, Vandenberg AFB re-
evaluated the technical approach and imple-
mented economically viable and sustainable
initiatives and found that the goals of the pro-
gram would not be achieved with the remain-
ing budget and milestone schedule. Therefore,
on August 25, 1999, Vandenberg AFB pre-
sented an alternative proposal to purchase 12
tons of registered NOx emission reduction cred-
its (ERCs) from another source located in
Santa Barbara County in order to achieve Mile-
stone 5. The ERCs were purchased from
Grefco Minerals, Inc., located in Santa Bar-
bara County and within the same north coun-
try air basin. As a result, the purchased ERCs
are permanently removed from Santa Barbara
County's emission bank, given up for the ben-
efit of clean air, and credited to the ENVVEST
program. The application of purchased and
ENVVEST achieved ERCs provides a net air
quality benefit of 17.8 tons per year—consist-
ing of the 12 tons of purchased ERCs, com-
bined with the 4.21 tons of emissions achieved
thus far, and an additional 1.6 tons of emis-
sions reductions with the implementation of
EV pilot program. Approximately 14.2 tons
per year are considered surplus emissions—
consisting of the 12 tons of purchased ERCs
and approximately 2.2 tons from the boiler
retrofit and replacement program.
Even though all milestones have been met,
Vandenberg AFB has obligated the balance of
the ENVVEST funds, approximately $1 mil-
lion, to implement a Mobile Source Reduction
-------
Program. The District approved this revised
approach to the program in November 1999.
As a result, Vandenberg AFB implemented a
series of Mobile Source Reduction initiatives.
The Mobile Source Reduction Measures were
evaluated in a three-part technical approach to
an EV pilot program, the purpose of which was
to assess EV applications on base. (1) The
first part involved establishing an EV loaner
program. To date, the EV loaner program has
reached out to 40 organizations at 17 locations
on base. Nearly 300 base personnel have re-
ceived EV user training. (2) The second step
was obtaining a pilot-scale fleet of four EVs
from a Base Realignment and Closure instal-
lation and the installation of the necessary sup-
port infrastructure. (3) The third step required
that Vandenberg AFB assess the applicability
of phasing in long-term EV use on the base.
Now, with full program implementation,
Vandenberg AFB has 29 charging stations and
a fleet of 26 cars and plans to purchase 20 ad-
ditional EVs and 10 compressed natural gas
vehicles for use in 2002 (see Figure 13). The
new vehicles will be part of Vandenberg AFB's
shared-use vehicle management system
(SUVMS) (see Figures 14 and 15). The
SUVMS is an electronic system for easier use
and sharing of the EV fleet. Vandenberg AFB
anticipates saving over $96,000 over three
years with the EV fleet in the SUVMS (see
Table 7). Applying clean technology vehicles
such as EVs within a shared vehicle system
framework will further lower emissions, fuel
consumption, the fleet size of Vandenberg
AFB, and save money.
The estimated Title V program costs,
ENVVEST program costs, and overall cost
savings to Vandenberg AFB are presented in
Table 8. Although the financial offsets during
the past five years are difficult to measure, it
is estimated that over $1 million was saved.
Vandenberg AFB has reduced record keeping
and reporting, monitoring, and management
costs associated with Title V compliance by
approximately 30 percent. In return,
$2,500,000 was reinvested into this program.
The key focus areas for continued successful imple-
mentation of the FPA over the next six months will
be the following:
• Continue stakeholder meetings.
• Procure 30 new alternative fuel vehicles for
the SUVMS, beta test SUVMS, and continue
enrollment into the SUVMS through the end
of the calendar year.
Benefits for the Environment
• Emissions of the ozone precursor, NO , have
been reduced by retrofitting or replacing those
boilers with the highest potential for emission
reductions.
• Emissions of the ozone precursors, VOCs,
have been reduced by zero-VOC paint and
coating substitution, paint booth consolidation,
construction of a wastewater reclamation sys-
tem adjacent to a satellite launch facility, and
use of alternative fuel vehicles.
• Reduction of ozone precursor emissions may
help to prevent Santa Barbara County from
being reclassified as an ozone nonattainment
area.
Benefits for Stakeholders
• Stakeholders have access to progress reports
from the base and will be invited to public
meetings.
• Vandenberg AFB personnel conduct briefings
on a quarterly basis with the Vandenberg Citi-
zens Advisory Board (CAB) and the Commu-
nity Advisory Council (CAC), a panel
consisting of citizens appointed by the Santa
Barbara County Air Pollution Control District
board members.
• Vandenberg AFB's innovative SUVMS pro-
gram is a model that can be applied at other
bases around the country. Vandenberg AFB
representatives gave a presentation at the 6th
Annual Joint Services Pollution Prevention and
Hazardous Waste Management Conference
held in August 2001 to inform other bases
about the SUVMS project.
-------
"Table 7: Operations and (Zos+ Savings for tke
Vandenberg y\I~T3 <£V Program
Operating Cost Factors
Ranger Electric Vehicle
Ranger Gasoline Vehicle
Total Miles Driven Per Year
10,000
10,000
Fuel Economy
2.52 miles/kWh
21.59 miles/gallon
Fuel Cost
$0.07/kWh
$1.99/gallon
Conversion Factors
3,412.13 Btu/kWh
115,400 Btu/gallon
Energy Consumption
1,355.10 Btu/mile
5,345.07 Btu/mile
Energy Cost
$0.0000205/Btu
$0.000173/Btu
Cost Per Mile
$0.03/mile
$0.09/mile
Total Energy Cost Per Year
$278.00/vehicle
$925.89/vehicle
Annual Operating Cost Savings
(based on operating 26
electric v. gasoline vehicles)
$16,197.33/year
EV Pilot Program Cost Savings
(based on 3-year lease period)
$48,591.99
Maintenance Cost Factors
Ranger Electric Vehicle
Ranger Gasoline Vehicle
Average Monthly Maintenance*
$38.31/vehicle/month
$91.21 / vehicle/month
Annual Maintenance
$459.70/vehicle/year
$l,094.52/vehicle/year
Annual Fleet Maintenance
$ll,492.46/year
$27,363.00/year
Annual Maintenance Cost Savings $15,870.54
(based on maintaining 26
electric v. gasoline vehicles)
EV Pilot Program Cost Savings $47,611.62
(based on 3-year lease period)
*Cost of gasoline vehicle maintenance is based on entire B200 fleet (59 quarter-ton trucks) serviced by
Vandenberg AFB for calendar year 1999. Maintenance cost of EVs is based on Department of Energy (DOE)
Field Operations Program report, How Do Gasoline & Electric Vehicles Compare?
Table taken from Vandenberg AFB's Presentation at the 6th Annual Joint Services Pollution Prevention and Hazardous
Waste Management Conference.
-------
Benefits for the Project Sponsor
• Vandenberg AFB will be able to use resources
that otherwise would be spent complying with
the administrative requirements of CAA Title
V to upgrade combustion technologies to
newer, low-NO,. emission technologies.
• Contingent upon meeting the milestones of the
FPA and reducing annual emissions of ozone
precursors by at least 10 tons by November
30, 2002, Vandenberg AFB will be classified
as a minor stationary source rather than a ma-
jor stationary source for purposes of CAA Title
V. This will result in much less future admin-
istrative work (reporting, monitoring, record
keeping, training) for the base.
• Vandenberg AFB negotiated a protocol for
source testing and validation with the District
that is cheaper ($600 per test) than the stan-
dard EPA test ($3,000 per test). Vandenberg
AFB will also save $96,000 over three years
through implementation of the SUVMS.
Information Resources: The information in this
summary comes from the following sources: (1)
Project XL Stakeholder Involvement Evaluation-
Final Draft Report, May 2000; (2) focus group
discussions in January 2000 with representatives
of the federal and local regulatory agencies,
Vandenberg AFB, and TetraTech, Inc., a contrac-
tor for Vandenberg; (3) the March 1999 XL Project
Progress Report—Vandenberg Air Force Base—
ENWEST, March 1999 (EPA-100-F-99-008); (4)
the December 1999 XL Project Progress Report—
Vandenberg Air Force Base—ENWEST (EPA-
100-R-00-007); (5) focus group discussions in
January 1999 with representatives of EPA, DoD,
the "District," and Vandenberg AFB; (6) inter-
views with members of the CAB and a CAC about
the stakeholder process, Spring 2000; (7) annual
and semiannual status reports through October 31,
2001, prepared by Vandenberg AFB; and (8) the
2000 Project XL Comprehensive Report, Volume
2: Directory of Project Experiments and Results,
November 2000.
"Table 8: Estimated Title V Progfam d-os\s) W(EST Program (Sosts,
and Overall (Z-osi Savings to Vandenberg ;AT-13
Title V Program Requirement
Cost
Cost Element
Prepare Permit Application
$300,000
Environmental Consultant Cost
Permit & Fee Administration
$160,000
Regulatory Cost Reimbursement
Compliance Monitoring
$100,000
Regulatory Inspection Cost
Total First Year Title V Cost
$560,000
Permit Administration
Permit & Fee Administration
$125,000
Regulatory Cost Reimbursement
Environmental Contractor Support
$250,000
Consultant Cost
Compliance Monitoring
Regulatory Compliance Oversight
$100,000
Regulatory Inspection Cost
Source Testing
$150,000
Environmental Consultant
Parametric Monitoring
$125,000
Equipment Cost
Annual Title V O&M Cost $750,000
Title V Program Cost $3,560,000 Compliance Cost Over Five-year Period
ENWEST Program Cost $2,500,000 Pollution Prevention Cost Over Five-year Period
Vandenberg AFB Cost Savings $1,060,000
-------
£astmah Kodak
dovwpcxn y
Final Project Agreement Signed September 14, 2000
Background
The Project Sponsor: The Eastman Kodak Com-
pany (Kodak) is a leader in new technology devel-
opment in the imaging industry. As a result, Kodak
submits many new chemical substances to EPA for
review each year. Kodak employs 46,300 people
in the United States and has manufacturing facili-
ties in Rochester, New York; Windsor, Colorado;
Peabody, Massachusetts; and White City, Oregon.
Kodak's Health and Environment Laboratory in
Rochester, which evaluates materials and equip-
ment involved in manufacturing processes or un-
der consideration for use in new products, is
implementing this XL project.
The Experiment: The EPA Office of Prevention,
Pesticides and Toxic Substances has developed a
set of computerized risk screening tools called the
Pollution Prevention (P2) Framework. These tools
allow companies to (1) calculate or estimate im-
portant risk-related properties based on an analy-
sis of chemical structure and (2) design safer
chemicals, reduce waste generation, and identify
other pollution prevention opportunities. In this
project, Kodak is employing the P2 Framework to
prescreen new chemicals early in its product de-
velopment cycle in order to develop more envi-
ronmentally benign and cost efficient products.
Because new product research and development
can be a very expensive process, it is cost effec-
tive for Kodak to bring only the best chemical can-
didates through later phases of the product
development process. By using the P2 Framework,
Kodak expects to identify problems with the chemi-
cal early on in the development process, thereby
avoiding carrying problem chemicals through prod-
uct development cycles and creating irrecoverable
costs. In addition to instituting full use of the P2
Framework at its facilities, Kodak is conducting
three separate and independent outreach initiatives
designed to make other industrial stakeholders
aware of the source reduction, pollution preven-
tion and economic benefits that result from use of
the P2 Framework. Kodak intends to advocate use
of the P2 Framework among its industry colleagues
in the following ways:
(1) Address the scientific community by demon-
strating how use of the P2 Framework can gen-
erate information previously unavailable to
scientists in the chemical industry.
(2) Address the business community by collabo-
rating with EPA on a rigorous environmental
cost accounting study to quantify the business
and economic benefits gained from using the
P2 Framework.
(3) Address industry senior managers by commu-
nicating the benefits of applying the P2 Frame-
work to chemical development at the highest
levels of management within selected large
companies.
The Flexibility: The Toxic Substance Control Act
(TSCA) governs the manufacture, importation,
processing, distribution, use, and disposal of in-
dustrial chemical substances, including new chemi-
cals. Section 5 of TSCA requires prospective
manufacturers (or importers) to wait 90 days after
submitting a premanufacture notice (PMN) before
they can begin to manufacture (or import) a new
chemical substance. Within the 90-day period,
EPA must evaluate the PMN submission and iden-
tify potential risks of the new chemical substance.
During that 90-day PMN review period, EPA de-
termines whether the substance may present an
unreasonable risk to human health or the environ-
ment. Often, EPA concludes its review of the PMN
after 28 days for chemicals identified as "low-risk
drops" (i.e., the chemical substance is determined
to present no unreasonable risk). Unless the re-
quirements for an exemption are met, a PMN sub-
mitter may not manufacture a new chemical
substance until 90 days after it has submitted a
PMN to EPA.
Under this project, Kodak and EPA have agreed
that PMN substances submitted by Kodak that EPA
views as low-risk materials could be manufactured
prior to day 90 of the review period pursuant to a
test marketing exemption (TME). Additionally,
for chemical substances for which Kodak uses the
P2 Framework, Kodak may submit combination
-------
TME applications and PMNs for concurrent re-
view by EPA. This allows Kodak to begin manu-
facturing for test marketing purposes 45 days after
the TME is submitted and a full-scale nonexempt
commercial manufacture 90 days after the PMN is
submitted. Although EPA generally discourages
simultaneous submittals, for the purposes of
Project XL, EPA will allow such concurrent sub-
missions to be sustained when the TME is granted
and the corresponding PMN is dropped from fur-
ther review during the first 28 days of the review
period.
Other Innovations: (1) Pollution Prevention.
EPA expects that Kodak's use of the P2 Frame-
work to prescreen its product development options
will result in increased opportunities for pollution
prevention by preventing the generation of pollu-
tion rather than controlling pollution once it has
been created. (2) Reducing the Regulatory Bur-
den. Early use of the P2 Framework allows Kodak
and other companies to anticipate and address
EPA's concerns prior to PMN submission, greatly
decreases the probability of adverse regulatory
action later and improves the efficiency of EPA's
PMN review process. (3) Stakeholder Involvement.
Directly involving business and technical stake-
holders in the project is key to the goal of encour-
aging use of the P2 Framework during development
of new chemicals submitted as PMNs to EPA. The
sharing of this new technological tool by EPA and
Kodak's communication of its benefits to other
stakeholders represents an unprecedented coopera-
tive approach to pollution prevention.
The Superior Environmental Performance: The
experiment strives to show that increased use of
the P2 Framework during the early stages of new
chemical research and development, and dissemi-
nation of information about the P2 Framework
within the industry, will improve environmental
decision making, ultimately leading to the produc-
tion of more environmentally friendly chemicals.
The Kodak project anticipates superior environ-
mental performance in the following areas:
• Application of the P2 Framework to screen
new chemicals to be submitted for PMN re-
view;
• Communicating with, reaching out to, and
working with scientific and technical staff from
a variety of chemical companies and stakehold-
ers, to support and promote their implementa-
tion of the P2 Framework;
• Reaching out to the business audience to pro-
mote the use of the P2 Framework as a best
business practice; and
• Reaching out to the senior managers of indus-
try counterparts to assist them in understand-
ing what management structures can facilitate
the implementation of pollution prevention
concepts in their companies.
Progress in Meeting Commitments
(As of August 200J)
Overall, Kodak has been able to meet all of its
environmental commitments to date for the
project.
• Kodak committed to applying the P2 Frame-
work in its new product development program
and to submit PMNs to EPA based on P2
Framework analysis data.
- Of the materials that could have been com-
mercialized, 24 percent were dropped early
in the product development process. Drop
considerations were based on a variety of
factors, including potential health and/or
environmental issues. By applying the P2
Framework early on in the chemical se-
lection process, Kodak was also able to
minimize waste generation, which typi-
cally results from lengthy chemical-devel-
opment programs.
- Of the materials that were carried through
to commercialization as PMN submissions
to EPA, all (100 percent) were cleared by
the Agency through standard review pro-
cesses.
- With each PMN submission, Kodak in-
cluded hard copies of the computerized P2
Framework analysis for review by EPA
staff.
-------
Kodak committed to conduct outreach to sci-
entific, technical, and senior management com-
ponents of the chemical industry.
- Scientific and technical outreach at chemi-
cal industry conferences and workshops:
Kodak gave presentations on the benefi-
cial uses of the P2 Framework at the fol-
lowing chemical industry conferences: (1)
Living with TSCA 1999 and 2000: a ma-
jor annual forum for industry-EPA dia-
logue regarding key issues associated with
industrial chemicals under TSCA; (2)
Globe 98: a biannual international con-
ference focused on pollution prevention
and risk reduction issues, (3) QSAR 98: a
conference series forum for information
sharing relating to advances in the use and
application of structure activity relation-
ships, such as those employed in the P2
Framework, (4) National P2 Workshops:
sponsored by EPA at state and regional lo-
cations; (5) Waste Watch Conference 1997
in Woods Hole, Massachusetts; and (6)
New York State Department of Environ-
mental Conservation P2 Conference: the
12,h Annual Pollution Prevention Confer-
ence sponsored by the New York State
Department of Environmental Conserva-
tion.
- Outreach to business audiences: Kodak
and EPA commissioned a study by the
Tellus Institute in Boston, Massachusetts,
to learn if data generated by the P2 Frame-
work could reduce developmental costs of
new chemicals and processes and lead to
development of environmentally benign
products. The study concluded that the
P2 Framework could substantially affect
the way companies develop new chemi-
cals and approaches to reformulating ex-
isting products. The study found that
application of the P2 Framework early in
product Research and Development sig-
nificantly reduced product development
cost, reduced the generation of waste, sig-
nificantly decreased the probability of
regulation and decreased time to market.
The study by T.J. Votta and A.L. White is
entitled Design for Competitive Advan-
tage: The Business Benefits of the EPA
Pollution Prevention Assessment Frame-
work in New Product Development, Tellus
Institute, Boston, Massachusetts (August
2000).
- Outreach to senior managers of industry
counterparts: Kodak conducted a man-
agement study of pollution prevention pro-
grams in selected large companies with the
assistance of the Bloustein School of Plan-
ning and Public Policy at Rutgers Univer-
sity. The study, entitled Pollution
Prevention and Risk Reduction: Case
Studies of Best Practice Companies, by
Professor Michelle Ochsner, highlights
state-of-the-art pollution prevention initia-
tives within leading firms, including the
business and risk reduction benefits of the
P2 Framework. Kodak and EPA are work-
ing with Professor Ochsner to prepare the
study for publication.
• The results of the August 2000 report pre-
pared by the Tellus Institute indicate that de-
spite up-front costs associated with the P2
Framework, these costs are fairly minimal
when compared to the quantitative and quali-
tative benefits that are accrued when the P2
Framework is employed. These benefits are
described in Table 9.
• Kodak's significant outreach to senior man-
agement of other companies encourages more
businesses to apply the P2 Framework to pro-
duce more environmentally sound products
and achieve cost savings.
• Kodak's use of the P2 Framework to success-
fully screen chemicals has allowed them to
minimize waste generation, increase the num-
ber of environmentally benign chemicals that
make it through the chemical development
cycle, and reduce the number of environmen-
tally harmful chemicals developed.
Benefits for the Environment
-------
Table 9: Summary of Benefits of+ke PS? Framework
Lower Product Development Costs for New Chemicals and Intermediates
Quantitative Benefits • Reduced (avoided) costs spent on technical development and research and
development of new chemicals.
• Decreased resources spent on laboratory tests for human health and
environmental testing.
Qualitative Benefits • A greater number of product combinations and product alternatives can be
evaluated early in concept development. This allows for greater technology
innovations and is due to the quick and cost-effective nature of the P2 Framework.
• Better and earlier information on environmental and health (E&H) impacts allows
the product development team to focus resources on technical performance.
Knowing the E&H profile early allows the team to anticipate any additional E&H
lab testing that may be required for PMN submittal to EPA. Such information may
also alert the team to a chemical candidate that it wants to abandon based on E&H
concerns before significant resources have been spent on investigating its technical
performance.
• Better information allows companies to compare competing product alternatives
and helps them identify environmentally sound technologies.
• Greater awareness of "green design."
Reduced Time to Market for New Products/Chemicals
Quantitative Benefits • Faster time to market for new product information by minimizing the chances that
a lead candidate will fall out of the product development process for health,
environment, or safety concerns.
• Avoid 5(e) regulatory action for PMN review, which may require additional
information or testing, causing delays in getting EPA approval.
• Minimize cycle time for PMN review by submitting an informed and complete
application to EPA.
Qualitative Benefits • Reduced probability that a candidate is dropped at an advanced development stage,
delaying the product team as they evaluate another candidate.
Lower Production Costs for Full-Scale Manufacturing of New Chemicals
Quantitative Benefits • Decreased costs associated with using hazardous chemicals (e.g., environmental
reporting, testing, employee training and personal protective equipment, waste
treatment, disposal, handling spills).
• Reduced probability the submitted chemical will be subject to 5(e) actions by EPA,
which may require either monitoring and tracking or more controls and treatment
during manufacturing.
• Decreased potential for downstream interventions such as product recalls or major
changes to the manufacturing operation (related to unanticipated long-term
toxicological effects of a product or technology).
Qualitative Benefits • Improved performance of the health and environment team is supporting the
overall product development process.
• Enhanced ability to identify and drive pollution prevention outcomes.
Table is taken from the Design for Competitive Advantage: The Business Benefits of the EPA Pollution Prevention Assessment Frame-
work in New Product Development, Tellus Institute (August 2000).
-------
Benefits for Stakeholders
• Kodak has been able to reach senior corporate
managers and others in the scientific and tech-
nical communities through its work with the
P2 Framework. In doing so, Kodak has cre-
ated a new network of companies, academics,
and scientists who are interested in using, test-
ing, and promoting uses of the P2 Framework.
Benefits for the Project Sponsor
• According to the cost accounting study com-
pleted in August 2000, the P2 Framework al-
lowed the product development team to
consider a larger number of chemical candi-
dates for product development. By having a
larger number of candidates to choose from,
Kodak had a greater chance of choosing the
best possible technical and environmentally
preferable chemical candidate. This proved
to be economically efficient as Kodak was able
to avoid between $ 13,500 and $ 100,000 of ad-
ditional costs for each $100,000 that it spent
in testing for a new chemical candidate.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Eastman Kodak XL project, Sep-
tember 14, 2000; (2) the 2000 Project XL Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000; and (3)
Design for Competitive Advantage: The Business
Benefits of the EPA Pollution Prevention Assess-
ment Framework in New Product Development,
T.J. Votta and A.L. White, Tellus Institute, Bos-
ton, Massachusetts, August 2000.
-------
X o v\]\Ao b i I
Co ^po i O KV
Final Project Agreement Signed May 25, 1999
Background
The Project Sponsor: The ExxonMobil Corpo-
ration (ExxonMobil) is responsible for all domes-
tic oil and gas operations in 12 states, the Gulf of
Mexico, and the Pacific Ocean off southern Cali-
fornia and Alaska. The Sharon Steel Fairmont
Coke Works Superfund Site, located in Fairmont,
West Virginia, was placed on the EPA's National
Priorities List (NPL) on December 23, 1996. A
corporate predecessor of ExxonMobil, Standard
Oil of New Jersey, owned the site from 1920 to
1948. ExxonMobil is the only potentially respon-
sible party (PRP) working with EPA and the West
Virginia Division of Environmental Protection
(WVDEP) under an Administrative Order on Con-
sent to address environmental concerns at this site.
ExxonMobil is the first XL project related to the
Comprehensive Environmental Response, Com-
pensation, and Liability Act (CERCLA), also
known as Superfund.
The Experiment: ExxonMobil has committed to
achieve superior environmental performance by
providing site improvements and enhanced com-
munity involvement not typically required by
Superfund, while cleaning up the site in less time
and at lower cost. ExxonMobil is focusing on the
economic redevelopment of the Superfund site to
demonstrate that consideration of future beneficial
uses early in the Superfund site management pro-
cess can help improve the local economy. To fa-
cilitate and increase the likelihood that interested
developers will use the site after cleanup for com-
mercial or industrial development, ExxonMobil
proposes to (1) demolish buildings on-site with-
out a finding of environmental risk, (2) engage the
services of redevelopment consultants and com-
panies to determine how best to make the site most
amenable to development, (3) work with local
stakeholders to identify redevelopment options,
and (4) provide the redevelopment during the
cleanup and restoration of the site.
ExxonMobil has used stakeholder involvement
techniques such as public meetings to explain
project plans and obtain input on future site uses.
In June 1998, ExxonMobil established the
Fairmont Community Liaison Panel (FCLP), which
meets regularly with ExxonMobil, EPA, and
WVDEP to provide input into cleanup and rede-
velopment actions. In addition, ExxonMobil is
employing faster, more efficient cleanup and re-
development processes, such as streamlining the
risk assessment process and reducing the adminis-
trative burden.
The Flexibility: Superfund sites are typically ap-
proached in a phased process. After a site has been
listed on the NPL, a Remedial Investigation/Fea-
sibility Study (RI/FS) is conducted at the site to
assess risk and evaluate alternative technologies
for remediation. The RI/FS culminates in a Record
of Decision (ROD), which outlines the actions to
be taken and documents the rationale behind the
decision to take action at the site. Subsequently,
the remedial design phase determines the specifi-
cations for cleanup actions that are implemented
during the remedial action phase. These phases
involve the submittal and approval of various docu-
ments and public comment periods. It is not un-
common for this process to require several years.
Another cleanup approach in the Superfund pro-
gram is the removal action, which can be completed
in significantly less time. An RI/FS and ROD are
not required for a removal action. ExxonMobil
has proposed to conduct the cleanup of this
Superfund site as a series of removal actions. With
this approach, this project strives to demonstrate a
streamlined Superfund process that results in the
reduction of potential risk to human health and the
environment in a shorter time frame.
EPA and the State of West Virginia will provide
ExxonMobil with flexibility regarding the use of
streamlined removal processes in order to expe-
dite cleanup actions at the site, the mitigation pro-
cesses for wetlands created by EPA during previous
removal actions, the data validation reporting re-
quirements, and the risk assessment criteria and
analyses. Long-term remediation will occur if
deemed necessary. This flexible approach is ex-
pected to almost halve the time and cost needed to
complete the cleanup.
-------
Other Innovations: (1) Extensive Community In-
volvement. The FCLP of local citizens meet with
ExxonMobil, WVDEP, and EPA almost every
month to provide input into decisions made regard-
ing the cleanup and redevelopment of the
Superfund site. (2) Coordinating Redevelopment
Activities with Cleanup Actions. As cleanup ac-
tivities continue, ExxonMobil has been working
with local and state redevelopment agencies to
identify redevelopment options and developers,
soliciting the opinions of the community, and has
improved the site's aesthetics and marketability by
demolishing on-site structures. (3) Expedited
Cleanup. ExxonMobil is streamlining the cleanup
process by implementing a series of removal ac-
tions and obtaining stakeholder input upfront. (4)
Paperwork Reduction. Draft copies of reports re-
quired under the engineering evaluation/cost as-
sessment (EE/CA), conducted under the removal
process, will be electronically transmitted. Final
reports will be distributed on compact disk, and
analytical data made available to EPA and WVDEP,
through the testing laboratory's data management
system. (5) PRP to Fund State Participation in
the XL Process. Direct funding will reduce the
state's financial and administrative burden and in-
crease its ability to participate in Project XL. (6)
Recycling Non-hazardous Waste. ExxonMobil has
access to an innovative technology that is able to
render coal waste non-hazardous. This innovative
process would enable much of the on-site waste to
be beneficially reused as fuel in a power plant.
The Superior Environmental Performance:
The goal of the stakeholders for the project is to
clean up the site in approximately half the time a
normal cleanup would take, which will reduce the
exposure time period and expedite risk reduction
to human health and the environment. In addition,
ExxonMobil is focusing on the future use of the
site and will incorporate the redevelopment strat-
egy into site cleanup. Economic redevelopment is
critical to the surrounding community, and the site
has great potential as it is located on flat land, in
proximity to a major interstate highway and the
Monongahela River. ExxonMobil is interested in
meeting the community need of selling the prop-
erty to a commercial business that could create jobs
in the area. ExxonMobil will continue to work
actively to ensure and maintain involvement of key
stakeholders and the general public during the site
cleanup.
-------
Progress in Meeting Commitments
(As of September 2001)
ExxonMobil has demolished most of the buildings
and structures on-site (see Figures 16, 17, and 18).
• Completed in spring of 2000, ExxonMobil
conducted an EE/C A of proposed removal ac-
tions at the waste management areas located
on the western portion of the site known as
the Waste Management Area (WMA).
• In June 2000, EPA outlined the non-time-criti-
cal removal workplan in an Action Memoran-
dum. The Action Memorandum calls for the
consolidation of the landfill materials in the
WMA.
- The waste will be segregated into coal
waste to be recycled as fuel and other non-
hazardous debris. Since this workplan was
approved ExxonMobil has agreed to re-
cycle a much greater percentage of the
waste as fuel and subsequently reduce the
volume of waste that will be landfilled on-
site. ExxonMobil has identified a com-
pany that uses an innovative technology
to render the coal waste non-hazardous so
that it can be burned as fuel in a power
plant.
- During 2000, ExxonMobil removed the
oxidation impoundment located to the rear
of the site. The impoundment contained
approximately 600,000 gallons of acidic
water. The water in the oxidation im-
poundment was slowly trickling into a
tributary located in the western part of the
site. After the water was neutralized and
drained, the oxidation impoundment was
closed, graded, and seeded for erosion
control. ExxonMobil built a channel con-
structed of limestone rock to treat the wa-
ter as it drained out of the landfills. This
will provide temporary treatment until the
acidic coal material in the landfill is re-
moved and recycled during the removal
action.
,U.
—iv"- "
. ' tit
- ' ' s;
Figure 16
In January 1999, a backhoe demolishes some of the
structures at Fairmont Coke Works in order to prepare the
site for redevelopment.
Figure 17
In April 1999, the demolition at the Fairmont Coke Works is
near completion, with many of the structures completely
leveled.
Figure 18
By winter of2000 all demolition work is complete at the
Fairmont Coke Works. This image shows the snow-covered
site, leveled for future redevelopment.
-------
- During 2001, ExxonMobil completed
cleanup of a breeze storage area and sludge
impoundment, then closed and regraded
the area.
• ExxonMobil has begun an EE/CA has begun
to investigate risk in the process area in the
eastern portion of the site.
• Wetlands in the area have been surveyed and
evaluated. EPA has determined that the wet-
lands are part of existing drainage systems;
therefore, mitigation will not be required.
However, during remediation, these areas may
need to be graded to improve drainage.
• In order to facilitate redevelopment, a market
valuation of the property has been completed.
In addition, ExxonMobil has selected a
brownfields expert as a real estate broker to
facilitate the process of finding an investor
interested in redeveloping the site.
• The focus over the next six months will be to
complete the non-time-critical removal action
in the landfills in the western portion of the
site and to complete the second EE/CA to as-
sess the risks in the eastern process area. In
addition, the stakeholders will continue to hold
meetings approximately every month.
Benefits for the Environment
• Due to the streamlined XL experiment, the
risks to human health and the environment at
this Superfund site will be addressed in half
the time.
• In addition, deed restrictions have been placed
on the property to ensure that future activities
do not result in exposure to unacceptable lev-
els of risk.
• An innovative process of waste segregation
will render much of the coal waste on-site non-
hazardous, allowing for a greater percentage
of the material to be used as a fuel substitute
in a nearby power plant. In addition, this pro-
cess will segregate the construction and demo-
lition waste for landfilling on-site. Using this
process, ExxonMobil expects to recycle 80
percent of the material in the WMA, using it
as fuel in a nearby power plant. This waste
will not have to be shipped to a hazardous
waste landfill, thus conserving off-site land-
fill space and reducing the volume of material
requiring landfilling on-site.
Benefits for Stakeholders
• Stakeholders have the opportunity to influence
the implementation of the project by partici-
pation in a 25-person FCLP advisory panel that
meets monthly to discuss the project. The
regular meetings of the FCLP with
ExxonMobil, EPA, and WVDEP help invoke
a sense of trust and respect among stakehold-
ers.
• This XL project provides benefits to the com-
munity that are not typically provided for at
Superfund sites, such as demolishing on-site
structures to facilitate redevelopment. The
stakeholders hope that such aesthetic improve-
ments will spur investor interest in the site.
• Citizens can also discuss concerns directly with
ExxonMobil by using ExxonMobil's toll-free
project hotline set up explicitly for the com-
munity.
• Citizens were given a unique opportunity early
on in the project to provide input into matters
such as the future use of the property, on-site
demolition of buildings, and the site cleanup
process.
Benefits for the Project Sponsor
• Reporting requirements have been reduced,
and stakeholders have relied on electronic
communication, which expedites review of de-
cision documents.
• The streamlined process will result in a shorter
cleanup time and will possibly result in long-
term cost savings. In addition, the sooner the
cleanup is completed, the sooner investors may
purchase and redevelop the property.
-------
Information Sources: The information in this
summary comes from the following sources: (1)
the FPA for the ExxonMobil XL project, May 25,
1999; (2) Project XL Stakeholder Involvement
Evaluation—Final Draft Report, May 2000; (3)
focus group discussions in December 1999 with
representatives of ExxonMobil Corporation, fed-
eral and state regulatory agencies, and representa-
tives of the local community; (4) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000; and (5) Meeting Minutes of the FCLP.
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Georgia-Pacific
(So r po rati o
Final Project Agreement Signed May 31, 2000
Background
The Project Sponsor: Georgia-Pacific is a lead-
ing manufacturer and distributor of paper and
building products. Georgia-Pacific Corporation
owns and operates a non-sulfur, non-bleaching pulp
and paper mill at Big Island, Virginia. The facility
sits on 900 acres of land and employs approxi-
mately 380 people. Despite the fact that Big Is-
land was the first facility to develop and use this
non-sulfur chemical pulping process, eliminating
the rotten egg odor associated with pulp mills, it
currently uses old technology with smelters dat-
ing back to the 1940s. The facility produces cor-
rugating medium, which is used by box plants to
make the fluted inner layer of corrugated boxes,
and linerboard, which is used for the inside and
outside layers of boxes. The mill is located in
Bedford County, adjacent to the James River. The
George Washington National Forest is located to
the north and east of the James River, and to the
west is the Jefferson National Forest. The James
River Face National Wilderness Area is about three
miles to the northwest of the mill.
The wood pulping operation at Big Island involves
chipping wood and adding it to a digester that con-
tains a chemical solution called "white liquor" (pri-
marily consisting of sodium carbonate at the Big
Island facility). The white liquor is heated in a
digester, which cooks the chips and forms pulp by
breaking down the lignin, or glue, that holds the
wood together. The wood pulp is then recovered
from the digester, leaving unusable wood wastes,
including fines and knots, in the pulping chemical
solution, which is considered "black liquor." Cur-
rent practice at the mill to recover the useful chemi-
cals in the black liquor is to reduce the volume
and concentrate the liquid through evaporation.
The liquid is then burned in two smelters, called
"recovery furnaces." The smelters recover the
sodium carbonate in a molten form, which is dis-
solved again to produce new white liquor.
The Experiment: While the combustion smelt-
ing technique is the current industry standard,
Georgia-Pacific is investigating using "black liquor
gasification," which is a new and innovative way
to recover chemicals used to make wood pulp. The
PulseEnhanced™ Steam Reforming black liquor
gasification system, believed to be a better, cleaner
approach, is intended to eventually replace the
existing smelter type of recovery furnaces. The
new gasification process uses heat and steam to
convert organic compounds (including lignin and
wood fibers) in the black liquor into a gas consist-
ing primarily of hydrogen and recovers the pulping
chemicals for reuse. The hydrogen gas would then
be used as a fuel source to run the gasification pro-
cess and to produce steam. The pulping chemi-
cals are recovered as pellets of sodium carbonate
that will be used to make new solutions of white
liquor. The Georgia-Pacific XL project tests
whether the installation and operation of this in-
novative gasification system at its Big Island pulp
and paper mill will lower emissions in a defined
amount of time, thereby surpassing federal regu-
latory requirements for pulp and paper mills, and
allow for decommissioning of the existing com-
bustion smelters.
The Flexibility: Under the Clean Air Act, the mill
at Big Island must comply with the Pulp and Pa-
per Mill Cluster Rule, which is a hazardous air
pollution standard that requires installation of
maximum achievable control technology (MACT),
to limit the amount of air pollutants that can be
emitted from regulated areas in the plant. A sec-
ond MACT standard (MACT II), that would ap-
ply to the existing smelters, was proposed in 1998
to control and reduce emissions from combustion
sources associated with recovery of chemicals used
to make wood pulp. Due to the age and the physi-
cal condition of the plant, Georgia-Pacific would
have to substantially upgrade or rebuild the smelt-
ers and add additional emissions controls to meet
the MACT II standards or they would need to re-
place the smelters with new recovery boilers us-
ing conventional technology. Georgia-Pacific
expects that its gasifier technology could be op-
erational in time to meet the MACT II standards
when they become effective. However, Georgia-
Pacific is using Project XL to get flexibility in the
following ways:
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• To be able to operate the existing smelters past
the MACT II compliance date, if necessary
while the gasifier technology is brought online;
• To ensure that if the gasifier technology fails,
Georgia-Pacific would be allowed to operate
its existing smelters, as necessary, past the
MACT II compliance date while it constructs
a conventional recovery furnace to replace the
existing smelters; and
• To allow the existing smelters to operate for a
set period of time after the MACT II compli-
ance date while Georgia-Pacific runs trials of
the gasifier on black liquor imported from a
Kraft pulp mill (these tests are crucial to dem-
onstrating that this new gasification technol-
ogy can be used in other plants in the pulp and
paper industry, which are dominated by Kraft
type mills). In addition, Georgia-Pacific has
committed to running these trials as a condi-
tion for receiving partial project funding from
the Department of Energy (DOE). This fund-
ing will allow Georgia-Pacific to be reimbursed
for certain expenses such as construction costs.
EPA promulgated the MACT II requirements on
January 12, 2001, which enacted the law and initi-
ated the compliance schedule. Paper and pulp mills
must be compliant by January 12,2004, and Geor-
gia-Pacific will install, test, and implement the new
system within that timeframe. However, if they
are not able to meet the schedule due to system
failure, EPA has granted contingent regulatory flex-
ibility. EPA amended its regulations in March 2001
(40 CFR Sections 63.861, 63.863, and 63.867) to
allow implementation of the gasification system
project and to allow contingencies regarding the
project's success or failure. This is a preventive,
stopgap measure that will be triggered only if the
gasification system does not work or more time is
needed to test additional aspects of the system. If
either of these situations occurs past the compli-
ance date in 2004, Georgia-Pacific will need to
operate its two existing smelters, which do not meet
the MACT II requirements and invoke this federal
regulatory flexibility.
Other Innovations: (1) Reducing Emissions
through Innovative Technological Approaches.
Georgia-Pacific is employing a cutting-edge recov-
ery technology that the scientific community and
its suppliers have brought to the point where it is
ready for a full-scale implementation. Complying
with MACT II requirements will significantly re-
duce emissions from mills and force companies to
rebuild or replace existing infrastructure, thereby
effecting an environmental quality change. (2)
Transferable Technologies. This technology is also
transferable and therefore highly useable by other
paper and pulp mills. The Big Island facility will
test the effectiveness of the PulseEnhanced™
Steam Reforming gasification technology and
other pulping facilities facing comparable circum-
stances could benefit from the technology.
The Superior Environmental Performance:
Overall, the gasification system is expected to re-
duce the mill's consumption of fossil fuel, increase
efficiency in energy conversion and chemical re-
covery, eliminate the smelt-water explosion haz-
ard, reduce maintenance costs, and significantly
lower environmental emissions of criteria pollut-
ants, greenhouse gases, and hazardous air pollut-
ants. Other benefits of the system include
emissions levels that will be far lower than in con-
ventional smelter and recovery boiler processes and
the recycling and reuse of steam generated by the
technology.
Without the XL project and the implementation of
the gasification technology, newer but conventional
recovery boilers will be installed that will meet
MACT II requirements, but will not significantly
reduce emission levels. The current standard emis-
sions are 2.97 pounds of total gaseous organic haz-
ardous air pollutants per ton of black liquor solids,
and with the successful implementation of the gas-
ification system, Georgia-Pacific expects emission
levels of 0.02 pounds of total gaseous organic haz-
ardous air pollutants per ton of black liquor solids.
Georgia-Pacific will further extend its superior
environmental performance by recovering and re-
using the steam generated by the gasification sys-
tem. In addition to producing steam, this
gasification technology will be used to generate
its own on-site electricity. The reduction in fossil
fuel use from combusting the gas produced by the
project is expected to result in a decrease produc-
tion of greenhouse gases.
-------
Progress in Meeting Commitments
(As of August 2001)
Georgia-Pacific is continuing to work toward meet-
ing all commitments that were set out in the FPA.
• On February 15, Georgia-Pacific received
funding from DOE. On March 20, 2001, a
signing ceremony was held to commemorate
the agreement between DOE and Georgia-Pa-
cific.
• Also in March 2001, EPA published a proposed
site-specific rule for the XL Project in the Fed-
eral Register. EPA did not receive any com-
ments on the rule and it went final on June 25,
2001. The rule provides Georgia-Pacific with
the flexibility they needed to undertake the
project.
• On August 1, 2001, Georgia-Pacific hosted a
stakeholder meeting at the Big Island Mill to
update the stakeholders on the status of the
project.
• The construction and commissioning are ex-
pected to happen over the next three years and
start-up of the gasification system is projected
on or before February 15, 2004.
• Decommissioning of the existing smelters will
occur when the new gasification system is
online and the trials with black liquor from
kraft mills are completed.
• Compliance with MACT II requirements will
occur when the gasification system is online.
Benefits for the Environment
• The new gasification system ensures that en-
vironmental protection will be increased by the
reduction in the consumption of fossil fuel; in-
creased efficiency in energy conversion and
chemical recovery; elimination of the smelt-
water explosion hazard inherent in the opera-
tion of conventional recovery boilers; and
lower emissions of criteria pollutants (i.e.,
particulate matter, sulfur dioxide, nitrogen
oxides, volatile organic compounds, and green-
house gases). If implementation is successful
and other pulp and paper mills adopt the gas-
ification technology, it will have a far-reach-
ing effect in meeting current and future air
quality standards while reducing energy de-
mand for this industry.
Benefits for Stakeholders
• Stakeholders, which include local residents,
government officials, other municipalities, and
community and nonprofit organizations are
learning more through this XL project regard-
ing day-to-day facility operations and ways in
which this project can reduce the facility's en-
vironmental impacts.
Benefits for Project Sponsors
• The new gasification system may reduce main-
tenance costs at the Big Island facility. To date,
the new gasification system has only been pi-
lot tested; therefore, successful implementa-
tion at Big Island facility will provide
innovative, environmental, and economic ben-
efits to Georgia-Pacific, as well as the indus-
try and EPA. This first full-scale installation
of a gasification system through the XL pro-
gram is important for the industry as a whole.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Georgia-Pacific Corporation
Project, May 31, 2000; and (2) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000.
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HAVCO
Corporation
Final Project Agreement Signed October 2, 1997
Project Close Out Expected by December 2001
Background
The Project Sponsor: The HADCO Corporation,
now a wholly owned subsidiary of Sanmina Cor-
poration, is a leading manufacturer of printed wir-
ing boards (PWB) and electronic interconnection
products. Founded in 1966 as a three-person op-
eration in Cambridge, Massachusetts, HADCO has
grown to employ more than 8,000 employees in
the United States and Malaysia. Three HADCO
facilities are involved in the XL project: Owego,
New York; Derry, New Hampshire; and Hudson,
New Hampshire. This project is expected to close
out from the XL program by December 2001.
The Experiment: The HADCO project was ex-
amining whether valuable copper metals could be
recovered more safely and cost-effectively through
direct reuse by a primary metals smelter rather than
through following the current requirement to first
ship copper sludge wastes long distances to inter-
mediate processors. Based on HADCO's experi-
ences with this project through close out, EPA can
develop a framework to address the potential is-
sues that this type of project may encounter and
that can hinder a company's ability to achieve su-
perior environmental performance.
The Flexibility: To improve recycling and reduce
risks to the surrounding communities, EPA, the
State of New York, and the State of New Hamp-
shire offered flexibility in solid waste disposal to
three HADCO facilities. Testing of the facilities'
sludge from wastes from electroplating processes
indicated that these sludges had a high concentra-
tion of several valuable metals, especially copper,
and relatively low toxicity in comparison to typi-
cal electroplating sludges. New Hampshire deter-
mined that the sludge was eligible for a solid waste
variance or a conditional delisting. New York de-
termined that the sludge was eligible for a solid
waste variance. Although the project is in the pro-
cess of being closed out, the company intends to
proceed with the delisting in Region 1 and the pro-
cessing of a solid waste variance in Region 2.
The Superior Environmental Performance:
Under the original project, HADCO committed to
using all savings realized from this project to ex-
pand its pollution prevention and recycling pro-
grams. HADCO also committed to recycling
copper dust, which is another byproduct of its op-
erations, and to examining the potential of install-
ing additional sludge dryers to reduce the volume
of sludge wastes as HADCO currently employs
some sludge drying in each of the three facilities.
Progress in Meeting Commitments
(Last reported results as of July 2000)
HADCO and EPA began discussions of closing out
the project early in 2001. As of July 2000, the
following commitments were met by HADCO:
• HADCO met its commitments to submit
samples of its sludge waste for analysis.
• HADCO filed a petition seeking a conditional
delisting in the State of New Hampshire.
• The New York Owego facility filed for a solid
waste variance in the State of New York on
September 28,1999. Updated revisions to the
variance application are required to be submit-
ted by HADCO as a result of the closeout of
this project from the XL program. Once ap-
proved and issued by New York State Depart-
ment of Environmental Conservation
(NYSDEC), HADCO may continue to recycle
its F006 sludge at primary metals smelters or
other metal reclamation facilities.
• HADCO provided baseline data regarding its
voluntary effort to reduce air emissions asso-
ciated with both direct recycling of F006
sludge and the reduction in the numbers of
sludge shipments to processing facilities in its
annual report submitted to EPA on January 7,
2000. The report contained data concerning
the number of sludge shipments from both the
New York and New Hampshire facilities. The
Owego, New York, facility had a sludge dryer
in operation since mid 1995. A decrease in
-------
sludge shipments from the Owego facility was
not apparent because of a substantial increase
in production as well as relocation/construc-
tion activities at the plant that put the dryer
out of service from September 1998 through
June 1999.
• HADCO submitted to EPA and the states let-
ters of interest to secure contracts with smelt-
ers that can accept the sludge for recycling.
• Once HADCO had the conditional delisting,
the solid waste variance, and the appropriate
contracts in place, the company would have
followed through on the following environ-
mental commitments: direct savings resulting
from reduced transportation or recycling un-
der the project to increase copper reclamation
activities at the HADCO facilities; voluntar-
ily examine ways its New Hampshire facili-
ties could use additional sludge dryers in order
to reduce the quantity of sludge transported;
and minimize and reclaim copper drilling, saw-
ing, and edging.
Project Assessment Rationale for
Project Closeout
• Given the additional burden of reporting, sam-
pling, and potential capital expenditures that
this XL project imposed on Sanmina facilities,
the company indicated that a withdrawal would
best serve their current needs, especially as
both the delisting in Region 1 and the process-
ing of a solid waste variance in Region 2 can
continue regardless of the company's XL sta-
tus.
• HADCO had difficulty identifying smelters
that would directly accept its Resource Con-
servation and Recovery Act-exempt wastewa-
ter treatment sludge. F006 sludge is generally
a good candidate for raw material substitution
at smelters; however, these smelters do not
have the administrative support structure to
receive relatively small amounts of waste slud-
ges from numerous generators. Although
HADCO is a larger generator, some of its sites
had difficulty securing contracts with smelt-
ers. The metal recovery market has created
intermediary companies that aggregate these
sludges and are then able to ship quantities of
waste sludges that are significant to smelters
(e.g., greater than 40,000 pounds/shipment).
The Owego facility, which uses conventional
precipitation, flocculation treatment has suc-
cessfully shipped F006 sludges directly to
smelters for over four years. The Owego
sludge, which has 18 to 22 percent copper by
dry weight, is a valued commodity to smelt-
ers. Individual companies smaller than
HADCO Owego, may not able to ship sludges
at such volumes and copper concentrations.
Currently, market forces do not strongly sup-
port a generator's direct recycling of these slud-
ges without the use of the aforementioned
intermediary metals aggregators.
• Over the course of the HADCO XL project
term, the delisting process was delegated by
EPA Headquarters to the regions and was re-
designed to offer decision making within an
average of 180 days, versus a delisting pro-
cess that traditionally took as long as four to
six years. These timesaving measures have
been achieved through a streamlined applica-
tion process, more uniform sampling require-
ments and an updated, user-friendly
fate-transport model. Thus, HADCO no longer
needs to rely on the XL process to expedite
the delisting request.
Obtaining a solid waste variance from the
NYSDEC does not require federal regulatory
flexibility, thus eliminating the main incentive
for HADCO to retain its XL status.
Benefits for the Environment
• HADCO improved its pollution prevention
efforts by voluntarily installing a sludge dryer
in its Derry, New Hampshire, facility, which
reduced the quantity of electroplating sludge
shipped off-site by 16,000 pounds. Owego
invested cost savings achieved from direct
shipment to the smelter in more extensive re-
source recovery (e.g., recycling drill dust that
formerly was landfilled).
-------
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CJmatiorv C-o^po^atiokA
Final Project Agreement Signed December 20, 1999
Background
The Project Sponsor: Imation Corporation is a
global technology company and the world's larg-
est manufacturer of magnetic data storage tape, a
product used to backup electronic data. To keep
in step with the ever-changing computer industry
and technologies, magnetic tape manufacturing
requires frequent and timely changes to plant op-
erations.
Imation's magnetic tape manufacturing process in-
volves spraying a solvent-based magnetic coating
onto the tape, a process which releases volatile
organic compounds (VOCs) into the air, including
some VOCs classified by EPA as hazardous air
pollutants (HAPs). Imation's Camarillo plant is
located in Ventura County, California, which is in
violation of federal air quality standards for ozone
(classified as severe nonattainment for ozone), as
well as California state standards for ozone and
particulate matter (PM). VOCs are precursors to
the formation of ozone, so their release in Ventura
County is of particular concern. The federal Clean
Air Act (CAA), major nonattainment New Source
Review (NSR) regulations, and the county's mi-
nor NSR regulations require most changes to
Imation's manufacturing processes to be reviewed
and approved in advance. Under these rules,
Imation must apply for a preconstruction permit
for each change and the county must issue the per-
mit before the change can be made.
The Experiment: The Imation XL project builds
upon the 1996 covenant between Imation and the
State of California and is testing whether innova-
tive permitting and NSR strategies can be used to
enable the company to make facility changes with-
out delay (i.e., avoiding case-by-case approvals)
while producing superior environmental perfor-
mance. To avoid potential delays and streamline
approval, this experiment is employing two prin-
cipal mechanisms. First, the company has accepted
a plant-wide cap on VOC emissions, and second,
the company's Title V permit (required by the
CAA) was designed to characterize Imation's an-
ticipated changes as alternative operating sce-
narios.
Imation Camarillo will be subject to a voluntary
VOC emissions cap (called a plant-wide applica-
bility limit, or PAL) for VOC emissions of 150
tons per year (tpy). The PAL will ensure that the
emissions from the plant do not overly contribute
to regional air pollution, do not interfere with rea-
sonable further progress toward attainment of the
ozone National Ambient Air Quality Standards
(NAAQS), and do not trigger the major NSR pro-
cess. In addition to the 150 tpy cap on VOC emis-
sions, Imation must meet a minimum control
efficiency of 95 percent and a 100 percent capture
efficiency for all organic compounds (VOCs and
FIAPs) emitted from coating manufacturing opera-
tions at the facility, regardless of whether the
amount emitted is below 150 tpy. This will ensure
that Imation meets any emission standards that will
apply to any of the changes contemplated by the
company. To meet the capture efficiency standard,
the coating and drying system is totally enclosed
so that no VOCs escape to the atmosphere.
As long as Imation's actual VOC emissions do not
exceed the PAL, modifications can be made at the
facility without triggering major or minor NSR
approval processes. In addition, Imation has agreed
to facility-wide emission caps for other CAA cri-
teria pollutants: 30 tpy of carbon monoxide (CO);
8.34 tpy of nitrous oxides (NOx); less than 15 tpy
each of PM and sulfur oxides (SOJ, but will not
be receiving NSR flexibility in these cases.
The Flexibility: Under the CAA, relief from the
Ventura County Air Pollution Control District's
(VCAPCD's) NSR program can be granted by re-
vising the Ventura County portion of the Califor-
nia State Implementation Plan (SIP), which details
how NSR is implemented in California. EPA has
approved a site-specific revision to the California
SIP, which in effect, establishes an alternative ap-
proach to the VCAPCD's NSR program for new
and modified sources at Imation's Camarillo fa-
cility. In addition, EPA has worked with Ventura
County to characterize anticipated changes as al-
ternative operating scenarios in Imation's operat-
ing permit. These scenarios can be put into effect
without further approval from Ventura County or
EPA. All of the federal and state standards ad-
dressed by Imation's preapprovals regulate coat-
ing operations that emit VOCs and HAPs, and the
-------
preapproved operations will be identical or very
similar to the existing coating operations at the
facility.
Other Innovations: (1) Limited Preapprovals for
Air Permits. By focusing on the total emissions of
a facility, Project XL is testing and confirming flex-
ible emission reduction strategies that may be both
duplicated at similar facilities across the country
and integrated into EPA's existing regulatory re-
gime. Imation Camarillo intends to share pollu-
tion prevention successes it discovers with others
in the industrial community. (2) Increased Flex-
ibility in Facility Operations. In addition, these
projects are testing alternative major NSR appli-
cability systems that allow PALs instead of tradi-
tional NSRs 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 lim-
its on their total emissions in exchange for in-
creased flexibility to add and subtract production
units without having to go through NSR and the
associated permitting. This would provide com-
munities with certainty that emissions will not in-
crease above permitted levels. EPA is also
developing guidance on flexible permitting ap-
proaches that will allow a facility to permit alter-
native operating scenarios, establish limits on
emissions, and use other techniques to provide
them with operational flexibility for the life of the
permit.
The Superior Environmental Performance:
Imation Camarillo voluntarily reduced facility-
wide VOC emissions by 43 percent by operating
under the PAL (which calls for a voluntary reduc-
tion of VOC emissions from 263 tpy to 150 tpy),
ensuring that the emissions from the plant do not
overly contribute to regional air pollution and do
not interfere with reasonable further progress to-
ward ozone NAAQS attainment. In addition to
the reductions in VOC emissions, Imation
Camarillo will cap CAA criteria air pollutants, in-
cluding CO, NOx, and SO, which can contribute
to acid rain, damage plant life, and cause adverse
health effects such as respiratory problems.
Progress in Meeting Commitments
(As of September 2001)
• Imation agreed to comply with federally en-
forceable caps on emissions under the CAA.
Emission levels have met all federal caps since
the implementation of the project.
- Criteria Air Pollutants: Under the FPA,
the following limits for criteria air pollut-
ants were established: 8.34 tpy for NOx,
15 tpy for PM, 15 tpy for SO^ and 30 tpy
for CO. For 2000, Imation's emissions for
criteria air pollutants were much lower
than the limits set. Imation reported emis-
sion rates of 4.683 tons of NOx, 0.0267
tons of SO , 0.143 tons of PM, and 1.636
x' '
tons of CO. For January through Septem-
ber 2001, emissions for NOx (3.503 tons),
SOx (0.019 tons), PM (0.106 tons), and CO
(1.227 tons) continued to be far below the
permitted level and are below 2000 lev-
els. The permit limits and emissions are
presented in Figure 19.
- VOCs: Total VOC emissions for 2000
measured only 24.38 tons, 83.75 percent
below the limit set by VCAPCD (150
tons). Actual emissions for January
through May 2001 are well below the per-
mit limit (see Figure 20).
- HAPs: Since the FPA was signed, Imation
has come into full compliance with the
maximum achievable control technology
(MACT) standard requirements under the
CAA for HAPs produced during magnetic
tape manufacturing, even though some
facility operations are not subject to the
standard. While Imation would otherwise
be subject to the federal New Source Per-
formance Standards for magnetic tape,
they agreed to comply with the more strin-
gent MACT standards resulting in lower
total emissions (see Figure 21).
• Imation agreed to meet a minimum control
efficiency of 95 percent and a 100 percent cap-
ture efficiency for all organic compounds emit-
ted.
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Imation - Facility-Wide Permit and
Emissions Levels for Criteria Air Pollutants
Jan-Sept 2001 Actual
1.227
q 2000 Actual
1.636
^ 1999 Actual
| 1.85
Permit Limit
30
Jan-9ept 2001 Actual
0.106
^ 2000 Actual
0.143
1999 Actual
0.16
Permit Limit
ZH15
Jan-Sept 2001 Actual
0.019
X 2000 Actual
0.0267
o
O) 1999 Actual
0.0317
Permit Limit
| 15
Jan-Sept 2001 Actual
~] 3.503
X 2000 Actual
Zj 4.683
o
2 1999 Actual
] 5.29
Permit Umit
^2 8 34
¦ ¦it j—i—i
0 5 10 15 20 25 30 35
Emissions (Tons per Year)
Figure 19
Imation's permit limits and emission levels for criteria air
pollutants.
Imation
- Facility-Wide Permit Limit
and VOC Emissions
Jan-Sept 2001 Actual
|24.21
2000 Actual
24.38
1999 Actual
| 22.905
1150
50 100 150 200
Emissions (Tons per Year)
l^iguee 20
Imation's permit limits and emissions for volatile organic
compounds.
Imation - Facility-Wide Permit Limit
and HAPs Emissions
Jan-Sept 2001 Actual
13.4
13.737
1999 Actual
^]0.B8
Permit Limit
, , i
Emissions (Tons per Year)
Figure 21
Imation's permit limits and emissions for hazardous air
pollutants.
- The facility has met these requirements ev-
ery month between February 2000, when
reporting began, and January 2001. Most
months, control efficiency exceeded 99
percent for each of the adsorbers.
• A state-of-the-art monitoring system will be
used by Imation to quantify and differentiate
VOC and HAP emissions.
- A continuous emissions monitoring sys-
tem measures the efficiency at four loca-
tions along the manufacturing process.
• Monthly reports will be provided to EPA and
VCAPCD by Imation documenting facility
emissions.
- Monthly reports have been submitted for
February 2000 through January 2001.
• Stakeholder involvement will be increased by
establishing a Project Stakeholders Group and
providing monthly reports.
- The Imation Community Stakeholders
Group was established in October 2000
and has been meeting semiannually.
• Imation agreed to design and implement an
ISO-14001-style environmental management
system (EMS).
- The Imation EMS is frequently updated
to improve environmental performance at
the Camarillo facility.
• VCAPCD agreed to adopt a site-specific rule
that will revise the Ventura County's portion
of the California SIP.
- Rule 37 was adopted September 14, 1999
by VCAPCD, authorizing a PAL, and re-
quiring best available control technology
and/or best available control technology
for toxics analyses and tiered health risk
assessments for any change in operations.
• EPA committed to acting on Ventura County's
proposed SIP revision.
- Final approval of revision to the Califor-
nia SIP was published in the Federal
-------
Register December 13,1999, acknowledg-
ing the compliance of VCAPCD's Rule 37
with the requirements of the CAA.
Benefits for the Environment
• Between 1996 and 1999, Imation Camarillo
voluntarily reduced its annual emission of
VOCs from 263 tpy to 150 tpy, a 43 percent
reduction. As a result, VCAPCD granted
Imation an emission reduction credit (ERC)
certificate for 113 tpy of VOC. Such ERCs
can usually be sold to other emitters within
the VCAPCD. In this case, Imation agreed to
donate the credits back to VCAPCD to sell or
retire. VCAPCD is planning to use the pro-
ceeds of selling the ERCs to finance environ-
mental projects.
• The ISO 14001-style EMS for the Camarillo
facility, which includes an integrated set of
environmental goals, procedures, and assess-
ments, is frequently updated to improve envi-
ronmental performance.
Benefits for Stakeholders
• Community members are involved in the
implementation of this project through the
Imation Community Stakeholders Group. Fol-
lowing the signing of the FPA, Imation formed
the Imation Community Stakeholders Group
to evaluate implementation of the project dur-
ing the initial five-year term of the XL project.
The group is charged with evaluating the on-
going activities under the project and provid-
ing a link between the community, the
regulatory agencies, and Imation Camarillo fa-
cility. The group will advise Imation on local
community concerns and maintain an open
dialogue with Imation to ensure transparency
of facility operations related to the project.
• Imation makes its monthly reports available
on the Internet and sends a copy of them to the
local public library. Imation also sends a copy
of their monthly report directly to persons or
groups who identify themselves as interested
parties to the project.
• The PAL provides communities with certainty
that emissions will not increase above permit-
ted levels.
Benefits for the Project Sponsor
• Since changes have been anticipated and pro-
vided for in the Title V permit, Imation may
make changes without further Title V permit
revision.
• As long as Imation's actual VOC emissions
do not exceed the PAL, modifications can be
made at the facility without triggering major
or minor NSR approval processes.
• 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 flexibil-
ity to add and subtract production units with-
out having to go through NSR and the
associated permitting.
Information Resources: The information sources
used to develop this progress report include: (1)
the FPA for the Imation Camarillo XL Project (De-
cember 20, 1999); (2) stakeholder review materi-
als; (3) Imation's monthly and annual reports on
the XL Project (several are available online through
Imation's Web site at http://www.imation.com/
en_US/main.jhtml?Id=10_07_04_02_01); and (4)
the 2000 Project XL Comprehensive Report, Vol-
ume 2: Directory of Project Experiments and Re-
sults, November 2000.
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Jn+eJ (Sorpora+iorv
Final Project Agreement Signed November 19, 1996
Background
The Project Sponsor: Intel Corporation, the
world's largest semiconductor manufacturer, has
operated the 720-acre Ocotillo site in Chandler,
Arizona, since 1996. The Ocotillo site has two
chip fabrication facilities. Fab 12 was Intel's first
facility operating on the Ocotillo site. Intel is cur-
rently building a second chip fabrication facility
(Fab 22) capable of manufacturing 300-millime-
ter chips. Intel's Project XL agreement applies to
the entire Ocotillo site, including any new semi-
conductor-related facilities that may be built at the
site. In the highly competitive semiconductor in-
dustry, success is directly related to a
manufacturer's ability to bring new technologies
to the marketplace quickly.
The Experiment: The Intel project's goal is to
implement an Environmental Management Mas-
ter Plan that includes a facility-wide cap on air
emissions to replace individual permit limits for
different air emission sources. The Intel project
provides a test case for two innovations for im-
proving air permitting: the elimination of case-by-
case review of specific manufacturing process
changes, if emissions remain under a capped
amount; and pre-approval of a major plant expan-
sion, if emissions remain below a capped amount
for the entire site.
The Flexibility: The Intel XL project establishes
a long-term plan to minimize the Ocotillo facility's
environmental impact on local air, land, and water
quality; to minimize both its use of fresh water and
its generation of waste; and to undertake a number
of other actions to enhance the overall environ-
mental quality of the community. As an incentive
to achieve environmental performance at the Oco-
tillo facility, EPA, the Arizona Department of En-
vironmental Quality (ADEQ), the Maricopa
County Bureau of Air Pollution Control, and the
City of Chandler will provide a more flexible and
cost-effective process for regulatory management.
The FPA provides regulatory flexibility in the ar-
eas of air quality permitting, environmental per-
formance reporting, and innovative technology.
The FPA and the revised air quality permit pro-
vide 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 plant site emission limits are not ex-
ceeded and all other FPA and permit limits are met.
To provide an additional safety factor, Arizona
Ambient Air Quality Guideline limits for hazard-
ous air pollutants (HAPs) will not be exceeded at
the Intel facility property line or elsewhere on the
site. This flexibility in air quality regulation al-
lows Intel to eliminate potentially 30 to 50 permit
reviews a year and bring new products to market
faster. This is exemplified by Intel's plan to build
a new production manufacturing facility. Early in
2000, Intel announced it would build its first high-
volume production manufacturing facility capable
of producing 300-millimeter chips at the Ocotillo
site in Chandler, Arizona. The company said it
would invest $2 billion to build and equip the wa-
fer fabrication facility. It is expected that Intel will
seek this expansion under the Ocotillo facility's
existing air emissions cap, which was established
by the original Project XL permit in 1996. Intel
has noted that the new facility will allow the com-
pany to maintain its leadership in the extremely
competitive world of semiconductors.
Other Innovations: (1) Consolidated Reporting.
The project allows Intel to consolidate reporting
for federal, state, county, and city permitting and
regulatory programs into one annual and four quar-
terly reports. This project will serve as a test for
sector-wide collection of higher-quality informa-
tion from regulated industries and directly influ-
ence the development of the comprehensive
information management plan to be developed by
EPA's Office of Environmental Information. (2)
Internet Reporting and Stakeholder Input. The
new data and reporting formats were designed in
conjunction with the EPA, the ADEQ, the
Maricopa County Bureau of Air Pollution Control,
the City of Chandler, the Gila River Indian Com-
munity Department of Environmental Quality, and
area residents who are part of the stakeholder team.
Based on input from the team, Intel agreed to put
routine environmental reports 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/). Now citizens, as well as regulatory
officials, can routinely monitor the facility's
progress toward its environmental commitments.
(3) Computer-based Emergency Planning and Pre-
paredness. The emergency requirements will be
incorporated within the Chandler Fire Department
Hazardous Materials Management Plan (HMMP)
for Intel. The information in the HMMP will be
integrated into the computer-based emergency in-
formation system maintained by Intel and the Chan-
dler Fire Department. The benefits associated with
this innovative approach are enhanced prepared-
ness and prevention activities by Intel and the
Chandler Fire Department due to increased clarity
of requirements, and enhanced emergency response
by the City of Chandler Fire Department due to an
on-board HMMP emergency information system
computer on emergency response vehicles. (4) Air
Permits. The Intel XL project is testing
preapproval and elimination of review of specific
manufacturing process changes to see if emissions
remain under a capped amount for the entire site,
even with the possibility of plant expansion. These
emission caps are set at levels low enough for the
entire site to remain a minor source of criteria and
HAPs under the Clean Air Act. These tests will
directly influence EPA's sector-based action plan
and the Agency's permit reform efforts.
The Superior Environmental Performance:
As long as Intel remains within the air emissions
caps, the site will remain a minor stationary source
of criteria air pollutants. Intel has also committed
to meet other environmental goals that are designed
to improve the area's water quality, conserve wa-
ter, reduce the generation of hazardous and non-
hazardous waste, and improve the general
environmental performance of the facility.
Progress in Meeting Commitments
(As of August 2001)
Intel has been very successful in meeting its envi-
ronmental commitments under the project.
• Intel committed to capping the air emissions
for the entire facility as follows: volatile or-
ganic compounds (VOCs) at 40 tons per year
(tpy) (see Figure 22), nitrogen oxides and car-
bon monoxide (CO) at 49 tpy; sulfur dioxide
and particulate matter at 5 tpy; phosphine at 4
tpy, sulfuric acid at 9 tpy; and organic HAPs
and inorganic HAPs capped at 10 tpy. For all
of these commitments, Intel's facility has re-
mained well under the limit for 1997, 1998,
1999, and 2000.
- Intel has fulfilled its commitment to cap
CO emissions at less than 49 tpy for the
entire site, by achieving a total of 4.3 tpy
in 1997, 6.1 tpy in 1998, 6.2 tpy in 1999,
and 5.2 tpy in 2000 (see Figure 23).
- Intel has far exceeded its commitment to
cap aggregate combined organic HAPs at
10 tpy by achieving a total of 0.5 tpy in
1997,1.3 tpy in 1998,0.7 tpy in 1999, and
1.5 tpy in 2000 (see Figure 24).
- Intel has far exceeded its commitment to
cap aggregate combined inorganic HAPs
at 10 tpy by achieving a total of 0.7 tpy in
1997,1.7 tpy in 1998,2.1 tpy in 1999, and
2.3 tpy in 2000 (see Figure 25).
• Intel has achieved its water quality and water
use commitments, with one minor exception.
Intel originally committed to use 100 percent
treated effluent water for its semiconductor
cooling-manufacturing towers and for land-
scaping. Although the facility achieved only
80 percent of wastewater reuse in 1997, Intel
achieved 97 percent of wastewater reuse in
1998. The company informed stakeholders
that it would not likely be able to achieve more
than 95 percent due to the intermittent need to
use small quantities of fresh city water when
treated effluent cannot be made available due
to unforeseen treatment plant interruptions.
Stakeholders agreed to change the goal from
-------
Intel - Volatile Organic Compounds Emissions
2000 Actual
1999 Actual
1998 Actual
1997 Actual
Performance Goal
Baseline
17.3
16.3
less than
50
10
20 30
Tons per Year
50
T"ignee 22
Intel's emisions of VOCs from 1997 to 2000.
Intel - Carbon Monoxide Emissions
2000 Actual
1999 Actual
1998 Actual
1997 Actual
Performance Goal
Baseline
]
3
>
>
5.2
6.2
1
less than
100
20
40 60
Tons per Year
100
Fi giAfe 23
Intel's emissions of CO from 1997 to 2000.
Intel - Aggregate Combined Organic
Hazardous Air Pollutants Emissions
2000 Actual
1999 Actual
1998 Actual
1997 Actual
Performance Goal
Baseline
0.7
],3
0.5
less
than 25
10 15 20
Tons per Year
25
T~igut»e 24
Intel's emissions of aggregate combined organic HAPs from
1997 to 2000.
100 percent to 95 percent. Intel was able to
reach a level of 99 percent in 1999 and 96 per-
cent in 2000.
Intel achieved its solid waste recycling goals.
Intel's goals are to increase recycling to 40
percent in 1997, 55 percent in 1999, and 60
percent in 2001. In 1997, the facility exceeded
its recycling goal, and by the end of 1998, Intel
had already exceeded its commitment for 2001.
In 1999, Intel continued its progress toward
increased recycling by achieving a level of 67
percent. In 2000, Intel recycled 17,788 pounds
of solid waste for a level of 84 percent of waste
recycled (see Figure 26). At the beginning of
the project, the company struggled to meet
these goals, which led to creative, effective
solutions. For example, to meet the solid waste
recycling commitments, Intel found a box
manufacturer that transforms packaging wood
into landscaping tree boxes.
Intel's goals are to recycle 60 percent of haz-
ardous wastes generated at the facility in 1997,
50 percent in 1999, and 40 percent in 2001.
The specified percentages in the recycling
goals decrease because Intel anticipates reduc-
ing the hazardous waste generated at the facil-
ity through pollution prevention measures.
The facility achieved beyond the 60 percent
recycling goal for 1997. In 1998, the com-
pany started a new manufacturing process
module that produced a non-recyclable waste
stream. Intel executed several projects to re-
duce these wastes, and as a result almost
achieved the 1999 goal by the end of 1998 (it
achieved a 53 percent recycling rate). In 1999,
Intel continued its aggressive hazardous waste
recycling efforts and exceeded its recycling
goal by achieving a level of 65 percent. Intel
again exceeded expectations in 2000 by recy-
cling 55 percent of hazardous waste (see Fig-
ure 27).
Intel's goals are to recycle 25 percent of non-
hazardous chemical waste in 1997,50 percent
in 1999, and 70 percent in 2001. The facility
exceeded its 1997 and 1999 goals and is on
track to exceed 2001 goals. Intel achieved a
rate of 58 percent in 1997, and 78 percent in
1999.
-------
• In addition to the site-wide cap on air emis-
sions, Intel voluntarily established a produc-
tion-based performance standard called the
production unit factor (PUF). The purpose of
the PUF is to ensure that air emissions per unit
of production will not increase. The PUF is
expressed annually as tons of emissions (VOCs
or HAPs) per year per unit of annual produc-
tion. Each year, Intel reports the annual PUF
for the reporting year relative to the base year,
which is 1997. The VOC and HAP PUFs for
1998 relative to the base year index of 1.0 were
0.3 and 0.7, respectively; the value for VOCs
for 1999 relative to the base year was 0.26;
the HAP PUF for 1999 relative to the base year
was 0.84; and the 2000 VOC and HAP PUFs
relative to the base year were 0.27 and 0.64,
respectively. This means that VOC and HAP
emissions per unit of production were less than
the baseline year in all subsequent years.
• The FPA for the Intel XL project will expire
at the end of 2001. After five years of suc-
cessful operation under the existing FPA, Intel,
EPA, the State of Arizona, Maricopa County,
and the other involved stakeholders are inter-
ested in renewing the agreement for five addi-
tional years. To that end, in June of 2001 Intel
convened the first of a series of stakeholder
discussions. The goal is to have the renewal
agreement signed before the existing agree-
ment expires on December 31. Intel is pro-
posing to leave much of the existing agreement
intact, making relatively minor adjustments
based on operating experience to date and to
accommodate plans for the Ocotillo facility for
the next five years.
Benefits for the Environment
• Air emissions for criteria and HAPs are being
maintained at levels that ensure that the cur-
rent site remains a minor air emissions source,
as defined by the Clean Air Act.
• Intel's recycling activities for hazardous waste,
solid waste, and water are successful. In par-
ticular, water conservation is a priority envi-
ronmental goal in this arid Arizona region, and
Intel's activities in this area are well regarded
Intel - Aggregate Combined Inorganic
Hazardous Air Pollutants Emissions
2000 Actual
1999 Actual
1998 Actual
1997 Actual
Performance Goal
Baseline
>
>
]0-7
10 15
Tons per Year
IFtCjUfe. 25
Intel's emissions of aggregate combined inorganic HAPs
from1997 to 2000.
Intel - Solid Waste Recycling
2001 Goal
2000 Actual
1999 Actual
1999 Goal
1998 Actual
1997 Actual
20 40 60 80 100
Percent Solid Waste Recycled
Pi0wre 2.6
Intel's solid waste recycling percentages from 1997 to 2000.
Intel - Hazardous Waste Recycling
2001 Goal
2000 Actual
1999 Actual
1999 Goal
1998 Actual
1997 Actual
1997 Goal
20 40 60 80
Percent Hazardous Waste Recycled
Figure 27
Intel's hazardous waste recycling percentages from 1997 to
2000.
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by the City of Chandler. Intel has expanded
its commitment to increase water conservation
for the community with its newest high-vol-
ume production manufacturing facility (Fab
22) by introducing a new Innovative Water
Conservation Treatment System. This treat-
ment system will continue to take advantage
of the external recycling benefits introduced
with its first manufacturing facility (Fab 12)
while adding the ability to capture internal re-
cycling and reuse further avoiding fresh water
use. A new water conservation indicator is
being developed to demonstrate the positive
environmental impact, which will be reported
in quarterly reports.
Benefits for Stakeholders
• Stakeholders are able to be involved in the
project through a stakeholder team, which en-
sures that national, regional, and local regula-
tory authorities and private citizens can
participate as full partners in the project's
implementation. This team meets once a quar-
ter to review the project's progress reports.
• Local stakeholders and the surrounding com-
munity will continue to enjoy increased eco-
nomic benefits by Intel's decision to build
another semiconductor manufacturing facility
at the Ocotillo site. This decision was due in
part to the success of the innovative Intel XL
project facility emissions cap.
• The community has better access to informa-
tion through Internet reporting and a stake-
holder-developed, easy-to-understand format
for the consolidated reports.
Benefits for the Project Sponsor
• Intel is building its first 300-millimeter chip,
high-volume production manufacturing fabri-
cation facility at the Ocotillo site under its ex-
isting air emissions cap, which was established
under the 1996 XL permit.
• Intel has found the innovations being tested at
the Arizona facility to be so beneficial that the
company is implementing performance-based
concepts for air emissions at two other com-
pany facilities.
• Intel is renewing its FPA with national, re-
gional, and local stakeholders so it may con-
tinue to receive the flexibility benefits provided
in Project XL. Negotiations of this process
are expected to be complete in December 2001.
Spin-off Benefits
• The City of Chandler has received a grant to
study the industrial reuse of wastewater. The
XL project was used to advance the study.
• The project prompted the City of Chandler's
fire department to establish a new overall ap-
proach to hazardous waste handling.
Information Resources: The information in this
summary comes from the following sources: (1)
the December 1999 XL Project Progress Report—
Intel Corporation (EPA-100-R-00-005); (2) focus
group discussions in December 1998 and Decem-
ber 1999 with representatives of the federal, state,
and local regulatory agencies, Intel Corporation,
and stakeholders involved in the project; (3) data
from Intel Quarterly Reports, and the 1997, 1998,
1999, and 2000 Annual Reports; and (4) Project
XL Stakeholder Involvement Evaluation—Final
Draft Report, May 2000.
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United States range from 360,000 to 500,000 tons
per year on a dry weight basis. Should the experi-
ment be assessed as widely transferable, EPA could
eliminate existing disincentives to recycling types
of F006 waste that can be safe, effective substi-
tutes for other feedstock material. This action
could translate to a significant reuse of F006 sludge
and thereby increase national landfill capacity.
The Superior Environmental Performance:
By using the F006 sludge in the manufacture of
cement, several superior environmental benefits are
expected. Using the sludge as an ingredient in the
manufacture of a commercially available product
can offer an environmentally beneficial alternative
to the disposal of the sludge in a permitted hazard-
ous waste landfill. This would also conserve ex-
pensive and valuable landfill capacity for the
environmentally protective disposal of hazardous
wastes that cannot otherwise be recycled at the
present time. An additional environmental ben-
efit of this project would be the reuse of waste
material in lieu of continued consumption of a non-
renewable resource, which would conserve re-
sources and help decrease invasive mining and
quarrying operations.
To further ensure superior environmental perfor-
mance, IBM has agreed to continue to meet the
RCRA management standards and conduct RCRA-
type inspections. In addition to the ongoing moni-
toring of sludge quality, IBM has committed to
continue providing proper storage of sludge mate-
rial at the East Fishkill facility as if it were still
regulated as a RCRA waste.
IBM will also ensure the proper transport of sludge
from the East Fishkill facility to the cement kiln
and will provide its sludge only to cement kilns
that agree to provide the proper storage, handling,
and utilization of the sludge. Further, IBM will
prepare and submit to EPA and NYSDEC an an-
nual report providing a summary of transportation
and reuse activities associated with this XL project.
Progress in Meeting Commitments
(As of September 2001)
• IBM committed to an ongoing monitoring of
sludge quality by collecting sludge samples for
analysis of specific constituents identified by
EPA. IBM will collect and analyze a sludge
sample quarterly until 12 samples have been
collected, after which the frequency of sam-
pling events will change to every six months.
- In September 2000, IBM submitted the
analytical results of three sludge samples
to EPA and NYSDEC. IBM also agreed
to conduct an analysis of fluoride concen-
trations on the remaining nine sludge
samples.
- As of September 2001, IBM has provided
analytical results of 13 additional samples
to EPA Region 2. Fluoride concentrations
in five of the sludge samples were ana-
lyzed, but have not yet been submitted.
Since November 2000, all sample analy-
ses have included fluoride concentrations.
• IBM agreed to provide its sludge only to ce-
ment kilns that agree to provide the proper stor-
age, handling, and utilization of the sludge.
- IBM is currently in the process of identi-
fying and selecting cement kilns and
sludge transporters.
• EPA published a proposed rule in the Federal
Register on June 6, 2001. The proposed rule,
once finalized, would provide the IBM East
Fishkill facility with site-specific regulatory
flexibility under RCRA required to implement
this XL project.
• A supplemental proposal is being developed
by EPA and is expected to be promulgated by
December 31, 2001. This supplemental pro-
posal is needed to amend a specific threshold
level that was originally proposed as a condi-
tion of the site-specific exclusion from the
regulatory definition of hazardous waste. This
supplemental proposal is needed to reflect
more current data received on the sludge.
-------
• IBM has submitted a request for a Beneficial
Use Determination for this project to NYSDEC
in July 2001. Processing of the request is pend-
ing finalization of the EPA proposed rule.
Benefits for the Environment
• Recycling the F006 sludge into cement
achieves a higher position on EPA's hierarchy
of waste management options, from ultimate
disposal to a recycling scenario. This waste-
minimization practice will result in an increase
in landfill capacity for other hazardous wastes
that cannot be recycled at the present time.
Benefits for Stakeholders
• Through meetings with IBM, local environ-
mental groups, Dutchess County Environmen-
tal Management Council, and the Town of East
Fishkill Conservation Advisory Council have
had the opportunity to have a deeper involve-
ment in understanding the environmental man-
agement of the facility, ask questions, and
participate in the implementation of this XL
project.
Benefits for the Project Sponsor
• The sludge recycling process will result in
some cost savings to IBM. The transport and
disposal of the F006 sludge to a landfill in
Canada is costly. Depending on the location
of the cement kiln facility, significant cost re-
ductions from transportation may result. Also,
the elimination of the need for export notifi-
cation, hazardous waste manifests both in the
United States and Canada, and an annual gen-
erator report will result in an overall reduc-
tion in paperwork.
Information Resources: The information in this
summary comes from the following sources: (1)
the September 2000 FPA for the IBM East Fishkill
Facility F006 Sludge Recycling Project; and (2)
the 2000 Project XL Comprehensive Report, Vol-
ume 2: Directory of Project Experiments and Re-
sults, November 2000.
-------
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Final Project Agreement Signed July 31, 2000
Background
Project Sponsor: International Business Ma-
chines (IBM) Essex Junction, Vermont, is a semi-
conductor facility located in Chittenden County
near Burlington, Vermont. The facility property
encompasses approximately 735 acres, which are
divided by the Winooski River. The manufactur-
ing facility lies on 243 acres west of the Winooksi
River in Essex Junction, and the remaining prop-
erty contains non-manufacturing buildings. The
Essex Junction facility manufactures and tests
semiconductor logic devices through a complex,
multistep manufacturing process. In addition to
the 7,500 IBM employees working at the site, there
are approximately 1,500 contractors working on-
site on any given day.
The Experiment: IBM has recently developed an
innovative copper metallization process to create
electrical interconnections between device levels
for new semiconductor technologies. This process
replaced the aluminum chemical vapor deposition
process, a dry process used in previous generation
semiconductor device technologies. This innova-
tive metallization process is environmentally su-
perior to the old process. This new process greatly
reduces the use and emission of perfluorinated
compounds (PFCs), a cleaning agent for the alu-
minum deposition process, which are significant
global warming gases. In addition, the process is
also 30 to 40 percent more energy efficient and
produces chips that are approximately 25 percent
more energy efficient.
In designing the process, IBM worked with the
manufacturers of the plating solutions and the
manufacturer of the plating tool to minimize waste
and increase efficiency. The copper metallization
process uses this specialized tool to bring the mi-
crochips into contact with the copper plating solu-
tion and apply an electrical current to plate the
copper onto the chip surface. During the process,
the semiconductor chips are rinsed with sulfuric
acid and deionized water. The rinse water result-
ing from the copper metallization process, approxi-
mately 3,000 gallons per day, is combined with
the other wastewater generated at the facility, ap-
proximately 4 million gallons per day. These
wastewaters are sent to the facility's wastewater
treatment plan, which produces sludge as a
byproduct of wastewater treatment. EPA currently
considers IBM's process a traditional electroplat-
ing process for purposes of the Resource Conser-
vation and Recovery Act (RCRA). Under RCRA
regulations, sludge or solids created from the treat-
ment of wastewaters that include rinse waters gen-
erated from an electroplating process are listed as
F006 wastes and are therefore considered hazard-
ous wastes (40 CFR 261.31).
IBM believes that the classification system used
by RCRA artificially inflates the company's haz-
ardous waste generation numbers, fails to provide
additional environmental protection, and increases
the paperwork and reporting burden. EPA and IBM
believe an evaluation of the "production side" of
the sequence of operations that results in the waste-
water treatment sludge would be more useful. The
wastewater treatment sludge is considered hazard-
ous due to an "upstream" production unit that meets
the definition of a RCRA electroplating operation.
With this project, EPA will evaluate the upstream
production unit to determine whether the engineer-
ing and chemistry associated with the process in
question contains any constituents or conditions
capable of producing a hazardous waste. EPA will
focus on the key parameters on the production side
to make a determination of the regulatory status of
the waste materials generated.
The Flexibility: In September 2000, EPA ex-
empted the copper metallization manufacturing
process at the Essex Junction facility in a site-spe-
cific rule, rather than delisting the wastewater treat-
ment sludge, which would normally occur through
EPA's delisting process under 40 CFR 260.22. The
exemption was based on the fact that the new pro-
cess is significantly different from the industrial
-------
processes evaluated to establish the regulation on
wastewaters and sludge resulting from plating pro-
cesses. Additionally, the chemicals used in IBM's
process do not contain any of the contaminants
listed in Appendix VII of 40 CFR 261, which are
the focus of the original F006 definition. This
exemption does not apply to the spent plating bath,
which will continue to be drummed and disposed
of as required by RCRA regulations.
The Vermont Department of Environmental Con-
servation (VTDEC) has also adopted a site-spe-
cific rule for the state that will exempt the
wastewater sludge from IBM's copper metalliza-
tion process through a site-specific exemption,
contingent on any federal standards that are
adopted (under Section 7-203 of the Vermont Haz-
ardous Waste Management Regulations). In addi-
tion, the State of Vermont had previously waived
its hazardous waste tax, saving IBM approximately
$225,000 per year.
Other Innovations: (1) Testing Regulatory Ap-
proaches. This XL project offers EPA the oppor-
tunity to test a different approach to reevaluating
whether a specific wastestream is appropriately
subject to regulatory controls as a listed waste.
This process exemption approach is innovative in
that EPA is evaluating an upstream manufacturing
process to see whether it is capable of producing a
hazardous waste, rather than delisting the waste-
water treatment sludge, which would normally
occur through EPA's delisting process under CFR
260.22. (2) Testing New Technology. This XL
project may help semiconductor chipmakers ac-
celerate their transition to the higher-speed, lower-
cost, copper-based devices that are manufactured
through an innovative process that is environmen-
tally superior to the old process, aluminum chemi-
cal vapor deposition. In addition, an industry-wide
switch to the copper metallization process would
significantly reduce greenhouse gas emissions be-
cause the copper metallization process requires
fewer cleaning steps that use certain greenhouse
gases.
The Superior Environmental Performance:
The implementation of the copper metallization
process results in reduced greenhouse gas emis-
sions at the IBM Burlington plant, especially PFCs.
In addition, this process is 30 to 40 percent more
energy efficient than the traditional process and
produces microchips that are approximately 25 per-
cent more efficient. This XL project may help
semiconductor chipmakers accelerate their transi-
tion to the higher-speed, lower-cost, copper-based
devices that are manufactured through the innova-
tive copper metallization process that is environ-
mentally superior to the old process, aluminum
chemical vapor deposition. An industry-wide
switch to the copper metallization process would
significantly reduce the emissions of PFCs because
the copper metallization process requires fewer
cleaning steps that use those greenhouse gases.
The exemption of the copper metallization process
results in treatment sludges that are not regulated
under RCRA and have the potential to be reused.
The reuse of this sludge would result in conserva-
tion of landfill space and the conservation of raw
materials that would be used in place of the sludge.
IBM has also decided to redirect the cost savings
for this exemption, along with an additional $2.0
million, into an effort, which will result in a 40
percent (normalized to production) reduction in
greenhouse gas by 2002, using 1995 as a base year.
Progress in Meeting Commitments
(As of July 2001)
• EPA finalized a site-specific rule on Septem-
ber 12,2000, via the Federal Register, that will
provide a site-specific exemption of the waste-
water treatment sludge produced from IBM's
copper metallization process from 40 CFR
261.31.
• The VTDEC issued a site-specific rule for the
IBM facility on March 15, 2001.
• IBM has already implemented the copper met-
allization process on some lines and is expand-
ing it to others. The sludge from the copper
plating process became exempt from the
RCRA F006 classification on March 15,2001.
- IBM submitted its first report regarding
the monitoring of copper metallization
plating bath, rinse waters, and PFC emis-
sions on July 12, 2001.
-------
• IBM is discussing use of the sludge as an in-
gredient in the manufacture of cement with a
cement kiln.
• IBM will channel its cost savings from not
having to handle the sludge as hazardous waste
to supplement an additional voluntary effort
to reduce greenhouse gas emissions from its
chamber cleaning processes.
- IBM is investing an additional $2 million
at its Vermont facility to significantly re-
duce the facility's overall greenhouse gas
emissions and expects that these efforts
will help reduce the overall greenhouse gas
emissions at the facility by approximately
40 percent in the year 2002 when measured
against 1995 emissions of 93,000 metric
tons of carbon equivalent.
Benefits for the Environment
• The exemption of the copper plating process
at this IBM facility reduces the amount of de-
fined hazardous waste generated by the facil-
ity. This, in turn, results in a reduction of the
amount of waste to be transported and placed
in RCRA-regulated hazardous waste landfills.
• Implementation of the copper metallization
process results in reduced greenhouse gas
emissions. The use of PFCs, which are green-
house gases, as chamber cleaning agents in the
manufacturing process is minimized in the
copper metallization process.
• The new copper metallization process is 30 to
40 percent more energy efficient than alumi-
num vapor chemical deposition. The new tech-
nique produces semiconductor chips that are
25 percent more energy efficient.
• IBM is voluntarily channeling its cost savings
from the reclassification of the sludge as non-
hazardous to supplement an additional volun-
tary effort to reduce greenhouse gas emissions
from its other chamber cleaning operations.
Benefits for Stakeholders
• IBM continues to keep an open dialogue with
interested stakeholders about the development
of the project. This process gives stakehold-
ers the opportunity to gain more knowledge
about the semiconductor manufacturing facil-
ity.
Benefits for the Project Sponsor
• IBM will realize a decrease in the administra-
tive requirements and taxes associated with the
generation of hazardous waste.
Information Resources: The information sources
used to develop this progress report include (1)
the FPA for the IBM XL Project: Copper Metalli-
zation, dated July 31,2000; (2) the Project XL Site-
Specific Rulemaking for the IBM Semiconductor
Manufacturing Facility in Essex Junction, Ver-
mont, dated September 12, 2000; and (3) the 2000
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
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C^v+emcrHorval Papei^
(z^f-fluervt
Jmp Govern ervfs
Final Project Agreement Signed June 29, 2000
Background
The Project Sponsor: International Paper's (IP)
Androscoggin Mill is a large integrated Kraft pulp
and paper mill and a major manufacturer of coated
paper and specialty paper. The facility includes a
wood yard, two wood rooms, utilities, two con-
tinuous pulp digesters, two bleach plants, and five
paper machines. The plant is located in Jay, Maine,
adjacent to the Androscoggin River and has been
in operation since 1965. It produces approximately
1,860 tons of paper per day and has 1,200 employ-
ees. The facility was in EPA New England's (Re-
gion 1) 1996 Environmental Leadership Program,
was a participant in the StarTrack Program, and
has won numerous Governor's Awards for Envi-
ronmental Excellence. The facility is currently a
charter member of EPA's national Performance
Track program.
The Experiment: IP seeks a regulatory exemp-
tion from the best management practices (BMPs)
required under the water portion of EPA's Pulp and
Paper Cluster Rules (40 CFR 430.03) in order to
reinvest resources to implement effluent improve-
ment projects. These effluent improvement
projects will be designed specifically to reduce fi-
nal effluent discharge of chemical oxygen demand
(COD) and color through process modification to
the black liquor cycle—a chemical cycle that is
used to break down wood fibers to create pulp and
paper. The exact mix of projects will be identified
through a collaborative process with IP, EPA,
Maine Department of Environmental Protection
(ME DEP), the Town of Jay, and active stakehold-
ers. EPA and IP anticipate that implementation of
these effluent improvement projects will yield
greater COD and color reduction than compliance
with the Cluster Rule's BMPs. The facility will
design and implement the effluent improvement
projects with the assistance of the Technical As-
sessment Group and Collaborative Process Team,
and the facility's effluent discharge permit will later
be modified to reflect the resulting performance
gains.
The Flexibility: Through this experiment, IP will
receive a regulatory exemption from applicable
BMP requirements, which will be replaced with
targeted, facility-specific effluent improvement
projects and with quantitative, enforceable permit
limits. This exemption would be in effect as long
as IP continues to implement the XL project as
outlined in the FPA. In exchange for this exemp-
tion, IP is taking a number of steps designed spe-
cifically to improve the mill's effluent quality for
COD and color beyond levels to be attained
through implementation of BMP requirements.
Other Innovations: (1) Use of Collaborative
Process and Technical Teams for Continuous Im-
provement. Environmental decision making and
planning is often an insulated process, which of-
ten only involves facility personnel. This project
provides an innovative feature that guarantees in-
put from stakeholders, regulators, and facility rep-
resentatives throughout the life of the project. Most
importantly, they are allowed to play a distinctive
role in environmental decision making and plan-
ning for the facility—an approach never tested
before to this extent in Project XL. (2) New Tech-
nologies to Improve Effluent Limits. This project
provides a concrete opportunity to evaluate appli-
cable new effluent technologies that are tailored
to a mill's specific operations and to determine the
extent of environmental improvement beyond what
would be attained by more rigid adherence to ex-
isting regulations. Beyond the impact on the IP
Androscoggin Mill, the results of this project may
help clarify the parameters for applying new ef-
fluent technologies at other similar pulp and paper
mills through technology transfers (such as pre-
sentations at conferences). In addition, this project
may serve to inform EPA's future rule making re-
garding regulations for COD and color relevant to
pulp and paper mills.
The Superior Environmental Performance:
The superior environmental performance in this
project will be derived from the following efforts:
(1) Use of the collaborative partnership between
-------
regulators, industry, and environmental groups to
work together to identify the most important pol-
lution projects; (2) the effluent improvement
projects described in the FPA (that IP plans to
implement at the facility); (3) the Phase 1 COD
and color limits that IP will accept into their dis-
charge permit representing the baseline from which
superior environmental performance will be mea-
sured; (4) the performance goals (in place of the
more flexible BMPs otherwise required by EPA's
applicable regulations); and (5) the more stringent
Phase 2 COD and color limits IP will accept once
the effluent improvement projects have been imple-
mented and monitored.
In proposing its XL project, IP considered its cur-
rent activities and practices taking place at the
Androscoggin Mill advanced enough to be func-
tionally equivalent to performance expected to re-
sult from compliance with the BMPs required
under the Pulp and Paper Cluster Rules.
Progress in Meeting Commitments
(As of August 2001)
Overall, IP has been able to meet all of its envi-
ronmental commitments to date for the project.
• IP accepted Phase 1 permit limits for COD and
color into its National Pollution Discharge
Elimination System (NPDES) permit when it
was reissued.
• IP will work in good faith towards identifica-
tion, implementation, and completion of the
effluent improvement projects within three
years of signing the FPA.
- IP is fully participating in all aspects of
project identification and implementation.
• IP will provide biannual reports to the Col-
laborative Process Team on progress made to-
ward implementing the effluent improvement
projects and achieving the associated mile-
stones and performance goals.
- Progress reports on the IP project are be-
ing prepared quarterly by the University
of Maine.
• EPA will reissue IP's NPDES permit (if ME
DEP does not receive authority to implement
the water permitting program).
- EPA gave ME DEP NPDES permit del-
egation authority in late 2000.
• EPA will promulgate a site-specific rule when
the FPA is signed that exempts IP's
Androscoggin's Mill from the BMP require-
ments for 40 CFR 403.03 (subject to consid-
eration of public comment).
- EPA signed the site-specific rule on July
27, 2000.
• EPA will participate in good faith on the Tech-
nical Assessment and Collaborative Process
Teams and make decisions expeditiously.
- EPA representatives participate in monthly
meetings of both the Collaborative and
Technical teams.
• ME DEP will amend IP's state discharge li-
cense.
- ME DEP is currently working on the dis-
charge license.
• ME DEP promulgated a site-specific rule pur-
suant to this XL project after the FPA was
signed, which exempted IP's Androscoggin
mill from the BMP requirements of 40 CRF
403.03 (subject to consideration of public com-
ment).
• ME DEP will participate in good faith on the
Technical Assessment and Collaborative Pro-
cess Teams and make decisions expeditiously.
- ME DEP participates in monthly meetings
of the Collaborative and Technical project
teams.
In addition to meeting the commitments in the FPA,
IP has accomplished the following:
• Effluent Improvement Project Identification.
The mill has been active in identifying and
reducing waste streams that contribute to black
liquor COD and Color. IP has spent
-------
approximately $350,000 of the $780,000 it al-
located for capital and this XL project to date.
• Implementation of Effluent Improvement
Projects. Overall, the effluent improvement
projects implemented under the XL project
have resulted in a reduction in COD discharge
of about 36 percent relative to the situation
that existed in 1999. These projects have re-
duced the COD discharge of the pulp mill from
about 57 to 36 kilograms COD/metric ton
pulp. The projects implemented to date have
resulted from closing up the screen rooms in
the A and B pulp mills. Implementation of the
two remaining approved projects will reduce
COD discharge further.
Benefits for the Environment
• Replacing generic BMPs with targeted, facil-
ity-specific effluent improvement projects
based on COD and color limits and perfor-
mance measures represents major progress in
reducing toxic effluent levels from pulp and
paper mills. These effluent improvement
projects ultimately will contribute to improved
ambient water quality downstream in the
Androscoggin River.
• The methodology developed to identify COD
and color point sources is transferable and can
be used by other paper mills seeking to im-
prove effluent.
• The facility-wide study has led IP to investi-
gate other methods to reduce pollutant dis-
charges from the paper mill portion of the
facility independent of the XL project.
Benefits for Stakeholders
• The Collaborative Process Team represents an
innovative feature that guarantees input from
stakeholders, regulators, and facility represen-
tatives throughout the life of the project. Most
importantly, they are allowed to play a distinc-
tive role in environmental decision making and
planning for the facility—an approach never
tested before to this extent in Project XL.
Benefits for the Project Sponsor
• Implementing the effluent improvement
projects has resulted in significant costs sav-
ings for IP from recovery and recycling chemi-
cals used in pulp and paper mill. Furthermore,
IP is demonstrating its continued commitment
to environmental innovation and leadership in
the pulp and paper mill industry.
Information Resources: The information in this
progress report comes from the following sources:
(1) Final Project Agreement; (2) 2000 Project XL
Comprehensive Report, Volume 2: Directory of
Project Experiments and Results, November 2000;
and (3) three quarterly reports (August 9, October
18, December 28, 2000) on the project prepared
by Professor Joseph M. Genco and Adriaan van
Heinigen, Department of Chemical Engineering,
University of Maine, Orono, Maine.
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Jinternational Paper
Predictive Emissions
AAoiaitoriK\0
Final Project Agreement Signed April 20, 2000
Background
The Project Sponsor: International Paper's (IP)
Androscoggin Mill is a large integrated Kraft pulp
and paper mill and a major manufacturer of coated
paper and specialty paper. The facility includes a
wood yard, two wood rooms, utilities, two con-
tinuous pulp digesters, two bleach plants, and five
paper machines. The plant is located in Jay, Maine,
adjacent to the Androscoggin River and has been
in operation since 1965. It produces approximately
1,860 tons of paper per day and has 1,200 employ-
ees. The facility was in EPA New England's (Re-
gion 1) 1996 Environmental Leadership Program,
is a participant in the Star Track Program, and has
won numerous Governor's Awards for Environ-
mental Excellence. The facility is currently a char-
ter member of EPA's national Performance Track
program.
The Experiment: IP's Androscoggin Mill will
develop, test, and validate a state-of-the art inno-
vative computer model that can accurately predict
pollutant [particulate matter (PM), sulfur dioxide
(SOJ, and nitrogen oxides (NOx)| emissions on a
continuous basis. The computer model is called a
predictive emissions monitoring system (PEMS).
The PEMS will be installed on the waste fuel in-
cinerator (WFI)—a type of boiler that burns paper
mill paper, sludge, bark, and fuel oil to produce
steam—and is monitored for emissions annually
at the stack. The PEMS would develop a relation-
ship between the WFI operating conditions (i.e.,
burn rates and fuel type), steam production, and
emission rates to continuously predict pollutant
emissions. The PEMS technology may also be able
to optimize the relationship between emission rates
and steam production rates identifying the opera-
tional setting so the WFI can be operated at mini-
mum emissions and with maximum steam
production. IP will also test PEMS to see that it is
providing instant compliance information, allow-
ing mill operators to prevent potential noncompli-
ance situations and stay within permitted limits.
PEMS have been developed and used for simple
stacks such as gas-fired boilers, but until recently
have had only limited application for complex
stacks such as the WFI. The PEMS will be devel-
oped and tested on the WFI for 30 months. Three
formal validation tests, developed by EPA's Of-
fice of Air Quality Planning and Standards, will
be performed on the PEMS model. The formal
validation tests will test emissions in order to col-
lect data to develop and evaluate the accuracy and
precision of the PEMS. At the completion of the
annual model specifications test—which comes
after the third validation test—the project will have
tested the PEMS in the following ways:
• To determine if the PEMS technology can pro-
vide accurate, continuous information for PM
emissions from a complex boiler (WFI);
• To determine if PEMS can assist in reducing
emissions while maintaining a high rate of
steam production;
• To determine key operating parameters that
affect emissions and potential exceedences;
and
• To determine if PEMS technology is transfer-
able to other complex emission sources includ-
ing those with high moisture content.
The Flexibility: This project seeks regulatory
flexibility under Title V, section 502 of the Clean
Air Act, as necessary, through a Testing Agree-
ment. The agreement allows IP to briefly exceed
its air pollution license limits under controlled and
limited circumstances on the WFI during the test-
ing of the PEMS computer model. As specified in
the FPA, IP will offset any emissions exceedences
by emission reductions at the mill's other stacks.
The ability to exceed license limits during model
development, testing, and modification of PEMS
is the only way that IP can ensure that the PEMS
model will accurately predict actual exceedances
if they occur once the PEMS is operating. The
FPA provides the terms and limitations of any po-
tential exceedances during the testing of PEMS.
IP will also be allowed to replace their continuous
-------
emission monitors with PEMS if it is shown that
PEMS does accurately provide continuous emis-
sions data.
Other Innovations: Pollution Prevention. PEMS
identifies operating parameters and uses them to
predict emissions and link them to statistically sig-
nificant parameter settings, which represents a
change from traditional "end-of-pipe" monitoring
techniques. This project promotes pollution pre-
vention by identifying opportunities for source re-
duction and allowing IP to set voluntary goals to
reduce emissions through preventative measures.
The Superior Environmental Performance:
The primary environmental benefit of this project
is the increased information on environmental
emissions, especially on particulate matter, and the
enhanced ability to adjust emissions before any
exceedances actually occur. IP also voluntarily
agrees to commit to maintain operations at a level
equal or less than 90 percent of its maximum per-
mitted emission limits. In addition, IP will seek to
optimize production so that emissions decrease
while production remains the same or increase.
Progress In Meeting Commitments
(As of August 2001)
Overall, IP is meeting its project commitments to
date.
• IP committed to develop, implement, and
evaluate the PEMS in accordance with the
terms of the FPA, the Testing Agreement, and
the Test Plan.
- These processes are ongoing and are un-
derway at the Androscoggin Mill.
IP committed to supplying monitoring and
summary reports on project progress.
- The summary reports will be included in
an IP Progress Report, which is in devel-
opment and will be completed when test
data are final. This is expected to occur
within 25 months of the testing, or sum-
mer 2002.
• IP voluntarily committed to keep emissions
from the WFI at equal to or less than 90 per-
cent of permitted limits for the duration of the
project term and to invoke the necessary pro-
cess adjustments when predicted emissions
approach 90 percent of permitted limits on the
WFI.
- Unofficial data were collected during For-
mal Data Validation Test #1 for two
months in the fall of 2000, including over
370 15-minute separate tests and 93 sepa-
rate conditions. These data indicate that
emissions are far below the 90 percent of
permitted limits; WFI emissions during
testing indicate that emissions will be half
of the permitted limits. Unofficial data
also indicate that the WFI can operate at
maximum production in terms of steam
and not exceed emissions limitations. In
December 2000, data from sampling were
calculated and tabulated for use in devel-
oping the PEMS model. Currently, the data
are being statistically compared to deter-
mine how well the model can predict emis-
sion rates. During testing, there were the
expected exceedences of emissions license
limits; however, these did not last longer
than 15 minutes and they did not impact
National Ambient Air Quality Standards.
Benefits for the Environment
• The PEMS model, once fully developed, will
be able to forecast and prevent air emission
exceedances before they occur at the
Androscoggin Mill plant.
• The ability to predict emissions from a com-
plex, saturated stack on a continuous basis is
significant to IP and other facilities. There has
been very limited application of PEMS for
complex stacks with high moisture content.
This project will help demonstrate if this tech-
nology can be transferred to complex boilers,
kilns, and incinerators. The goal is to have
PEMS-generated information used by opera-
tors to decrease emissions while maximizing
production.
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Benefits for Stakeholders
• IP has been active in engaging stakeholders
from the local community and non-governmen-
tal organizations. Most noteworthy is IP's in-
volvement with the Town of Jay High School,
which is encouraging students to be interested
in science and environmental technologies
with this project. The IP project manager has
given presentations to the Jay High School
Science Club regarding the project, and in turn
a student presented information on the project
to the Androscoggin Watershed Council. The
students have also had the opportunity to ob-
serve work conducted during the testing at the
mill.
Benefits for the Project Sponsor
• Currently under the Clean Air Act, IP is re-
quired to conduct continuous emissions moni-
toring (CEM) for applicable pollutants. This
project will provide IP with flexibility to re-
move the CEM requirement for S02and NOx.
If the PEMS implementation is successful, it
will provide continuous monitoring for all of
the WFI pollutants, thereby eliminating the
need for CEM.
• If PEMS proves to be successful, IP can imple-
ment PEMS to monitor SO,, NOx, and PM and
replace the requirement to stack test for PM
emissions every two years. The testing re-
quired by IP would then be an annual test of
the PEMS.
Information Resources: The information in this
summary was obtained from the following sources:
(1) the FPA for the International Paper PEMS
Project, April 20, 2000; and (2) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000.
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cfcuzk J\A. Berry
Co r po rati o rv
Final Project Agreement Signed August 8, 1996
Project Closed Out June 2, 1999
Background
The Project Sponsor: Jack M. Berry is a mid-
size citrus juice-processing company. The
company's facility in LaBelle, Florida, is the site
of the Project XL pilot. It is located 30 miles east
of Fort Myers at the site of Berry's largest grove,
consisting of about 10,000 acres of orange and
grapefruit trees.
The Experiment: The Berry project's goal was
to establish a process by which Berry would pre-
pare a Comprehensive Operating Permit (COP) in
partnership with the Florida Department of Envi-
ronmental Protection, South Florida Water Man-
agement District, and EPA. The COP would have
been a multimedia permit that was part of a stream-
lined permitting approach that was expected to
better integrate plant operation and compliance
procedures, as well as eliminate unnecessary ad-
ministrative requirements.
The Flexibility: Under the COP, the State of
Florida and EPA would have relieved Berry of
administrative and procedural rules that require the
preparation and certification of multiple permit
renewal applications every few years. Flexibility
in Florida regulations governing the permit appli-
cation process would have allowed Berry to accel-
erate its permit application process. The
streamlined permitting approach was anticipated
to result in cost savings that Berry would have re-
invested in new environmentally beneficial oper-
ating procedures. The burden on EPA and the State
of Florida to review and issue permits would have
been reduced as well.
Other Innovations: (1) Reduction in Reporting
Burden. The State of Florida would have allowed
Berry to use nonstandard forms for reporting en-
vironmental performance, which would be simpli-
fied and part of the approved COP. The State of
Florida might not have required Berry to have its
environmental reports certified by a professional
engineer, because the COP would have been more
comprehensive than a certified professional
engineer's application. (2) Environmental Man-
agement System (EMS). Berry had committed to
instituting the International Organization for Stan-
dardization (ISO) 14000 EMS program as a means
to systematically manage continuous environmen-
tal performance, including pollution prevention and
source reduction strategies. (3) Standard Operat-
ing Procedures. Berry had intended to complete
detailed, yet easy-to-follow, work instructions for
implementing the COP that ultimately would have
been linked to the EMS, to raise the level of em-
ployee environmental awareness and contributions
to permit compliance.
The Superior Environmental Performance:
Berry would have reduced air emissions of vola-
tile organic compounds (VOCs), sulfur dioxide
(SO,), and nitrogen oxides (NOx) through volun-
tary installation of updated equipment and imple-
mentation of updated citrus-processing procedures.
Berry would have also reduced the amount of haz-
ardous and solid waste generated by the facility
through pollution prevention, reduction, and recy-
cling.
Progress in Meeting Commitments
(As of closeout on June 2, 1999)
The Berry project was unique in that it experienced
a change in management. Through a lease agree-
ment signed in 1997, Cargill, Inc.,8 became the new
operator of Berry's LaBelle, Florida, facility. As
a result, for the Berry XL pilot project to continue,
Cargill would have had to become a party to the
FPA. Work on development of the COP was put
on hold in late 1997 pending a decision by Berry
and Cargill regarding continuing the project. Get-
ting to a final decision on the project's future, how-
ever, proved elusive. Since further progress
appeared unlikely, three years after the project
agreement was signed, EPA and the State of Florida
chose to terminate the agreement in June 1999.
"Cargill is an international marketer, processor and distribu-
tor of agricultural, food, financial and industrial products with
some 80,600 employees in more than 1,000 locations in 65
countries and with business activities in 130 more.
-------
Therefore, the LaBelle facility remains part of the
traditional regulatory system under federal, state,
and local regulations.
• The Berry facility met some of its project com-
mitments even though work on the COP was
not completed. In 1997, Berry reported that
the facility had:
- Developed some standard operating pro-
cedures and detailed work instructions;
- Eliminated an 88-acre spray field in 1997
that had been used for wastewater disposal
since 1974;
- Reused treated industrial wastewater pro-
duced by the facility for irrigating a 1,400-
acre section of citrus groves;
- Installed a more efficient peel dryer to re-
duce citrus processing VOC emissions;
- Begun work on meeting commitments to
reduce disposal of solid waste and increase
scrap metal recycling; and
- Begun work to reduce the number and
types of solvents and lubricants used on-
site.
• Because the COP had not been completed,
there was no progress by Berry on:
- Preparing an emissions reduction strategy
for S02, NOx, and VOCs and reporting on
its results;
- Providing information on the amount of
solid waste and scrap metal recycled by
December 1998. (In February 1997, the
company reported that solid waste recy-
cling was initiated and scrap metal recy-
cling was increased.);
- Providing information on the quantities of
hazardous materials eliminated through a
self-audit program, on the preparation of
an inventory of spray-can solvents and lu-
bricants used on-site, and on the replace-
ment of some hazardous materials with
environmentally friendly alternatives;
- Establishing a target date for completing
the documentation of implementing the
new ISO 14000 EMS;
- Involving stakeholders in the development
and implementation of the final COP; and
- Voluntarily meeting drinking water stan-
dards equal to half of the maximum con-
taminant levels (MCLs) allowed under the
Safe Drinking Water Act (SDWA) and the
Florida Administrative Code. Test data
indicated that, except for radionuclides,
Berry either met a voluntary drinking wa-
ter standard equal to half of the MCLs al-
lowed under the SDWA or was not able to
detect the contaminant. However, there
was information on progress toward reduc-
ing radionuclide levels.
Benefits for the Environment
• In 1997, the company reported that the effort
to develop easier-to-follow work instructions
had led to continuous improvement in envi-
ronmental performance by reducing incidences
of minor environmental violations.
• The elimination of the 88-acre spray field re-
moved an odor problem.
• Treated industrial wastewater produced by the
facility was reused to irrigate a 1,400-acre sec-
tion of citrus groves.
Benefits for Stakeholders
• The stakeholder participation for this project
was not evaluated because it would have been
linked to the COP development, which never
occurred.
Benefits for the Project Sponsor
• In 1997, Berry reported that the preparation of
standardized work procedures increased the
Berry facility staff's awareness of the environ-
mental aspects of their jobs. The improved
work procedures also standardized environ-
mental testing at the facility and raised its level
-------
of compliance by reducing its incidences of
minor violations of environmental regulations.
Information Resources: The information in this
summary comes from the following sources: (1)
the March 1998 XL Project Progress Report—Jack
M. Berry, Inc., (EPA-100-F-99-003); (2) focus
group discussions in December 1999 with repre-
sentatives of the federal and state regulatory agen-
cies, Jack M. Berry, Inc., and Cargill, Inc.; and (3)
the Project XL Preliminary Status Report (EPA-
100-R-98-008).
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Final Project Agreement Signed September 7, 2000
Background
The Project Sponsor: Growing out of efforts to
improve the environmental performance of their
own laboratories, EPA and the U.S. Department
of Energy (DOE) developed Laboratories for the
21st Century (Labs21), a voluntary program de-
signed to improve the environmental performance
of our nation's laboratories. The primary guiding
principle of the Labs21 program is that improving
the energy efficiency and environmental perfor-
mance of a laboratory requires examining the en-
tire facility from a "whole building" perspective.
Adopting this perspective allows laboratory own-
ers to improve the efficiency of the entire facility,
rather than focusing on specific laboratory com-
ponents. Labs21 is dedicated to the pursuit of sus-
tainable, high-performance, and low-energy
laboratories that will (1) minimize overall envi-
ronmental impacts, (2) protect occupant safety, (3)
optimize whole building efficiency on a life-cycle
basis, and (4) establish goals, track performance,
and share results for continuous improvement.
The Experiment: EPA's Office of Administration
and Resources Management (OARM) and the Of-
fice of Environmental Policy Innovation (OEPI)
in the Office of Policy, Economics and Innovation
have set in place a customized and expedited re-
view process to provide regulatory or administra-
tive flexibility under Project XL to enable
laboratories to maximize environmental perfor-
mance under Labs21. Although flexible incentives
are available to laboratories through the existing
XL program, laboratories under the Lab21 program
will enjoy a streamlined application and selection
process. In the first phase of this project EPA is
working internally and with laboratories to syn-
chronize the Labs21 and Project XL applications
and review processes. The second phase of the
Labs21 XL project will be to develop and issue
case-specific agreements for testing innovative
ways to maximize environmental performance at
laboratories.
The Flexibility: The project signatories to the
Labs21 FPA are EPA's OEPI and OARM. The FPA
functions as an "umbrella FPA" and does not de-
scribe any specific federal regulatory flexibility.
Rather, Labs21 seeks to create environmental
showcase laboratories by encouraging laboratory
owners, operators, and designers to partner with
EPA and DOE and to adopt the Labs21 approach.
Specific regulatory flexibility will be negotiated
in the second stage of the project, including spe-
cific details on regulations, policies, or programs
under which the flexibility is to be granted, since
the wide range of research activities conducted by
laboratories are subject to a variety of EPA regu-
lations; for example, Resource Conservation and
Recovery Act, Emergency Planning and Commu-
nity Right to Know Act, Clean Air Act, Clean
Water Act, and Toxic Substance Control Act. Be-
cause the agreements may be with single or mul-
tiple Labs21 partners, flexibility may be granted
on a facility, group, or media level.
Other Innovations: Promoting Energy Efficiency
Lessons in Other Agency Innovation Programs.
While the Labs21 program is innovative in its fo-
cus on laboratories in the United States, its em-
phasis is on improving the energy efficiency of the
whole building rather than the components of the
lab individually. Examining energy and water re-
quirements from the comprehensive building per-
spective promoted by Labs21 can identify
significant opportunities to improve efficiencies
across all types of commercial structures. EPA
intends to take what it learns from the Labs21 XL
project and transfer lessons learned to other inno-
vative Agency programs designed to help reduce
pollution by promoting energy and water efficiency
such as EPA's Energy Star and Water Alliances
for Voluntary Efficiency (WAVE) programs.
The Superior Environmental Performance: The
Labs21 program is establishing partnership agree-
ments with over a dozen public and private sector
pilot partners. EPA and DOE are working with
each partner to define a specific project, set vol-
untary energy reduction and environmental perfor-
mance goals, and measure and report the success
of their efforts. The lessons learned from the pilot
phase will be applied once the Labs21 program is
fully implemented. The following is a sample of
-------
the types of projects these partners have commit-
ted to:
• Bristol-Myers Squibb is planning an 80,000
square-foot addition to its existing facility in
Wallingford, Connecticut. Of that, 56,000
square feet will be new laboratory space.
Bristol-Myers Squibb has made a commitment
to design, install, and operate equipment to
reduce both energy and water consumption at
this site.
• Wyeth-Ayerst (Wyeth) Pharmaceuticals has
two projects in the Labs21 program. The first
is a renovation of its 1.2 million square-foot
Collegeville, Pennsylvania, headquarters and
research and development campus. Wyeth in-
tends to make the campus a benchmark for re-
source efficiency and sustainability among
similar facilities worldwide.
• The second project is Wyeth's new Vaccine
Discovery Research Facility in Pearl River,
New York. This laboratory will be designed,
built, and commissioned to achieve a LEED™
gold rating or better. LEED™ is a rating sys-
tem created by the U.S. Green Building Coun-
cil to evaluate the sustainable design and
performance of a given facility.
• The National Oceanic and Atmospheric
Administration's (NOAA's) National Marine
Fisheries Service is in the process of renew-
ing its 50-year old laboratory in Honolulu,
Hawaii. NOAA is planning to construct a
state-of-the-art fisheries research laboratory
that fully embraces sustainable design and en-
ergy conservation measures. In addition to
taking the whole building philosophy to de-
sign, NOAA is maximizing energy-efficient
equipment and "green" building products.
• The National Renewable Energy Laboratory's
Science and Technology Facility, located in
Golden, Colorado, will take a whole building
approach to design; incorporate daylighting in
most areas, including most labs; develop and
implement an aggressive energy budget; and
allow for easy future additions of building in-
tegrated photovoltaics as an electricity source.
Progress in Meeting Commitments
(As of November 2001)
The Labs21 program is still in its initial stages.
To date, no Labs21 partners have expressed an in-
terest in pursuing regulatory flexibility through the
XL program. OARM will continue to promote the
XL component of the Labs21 program to partici-
pating partners. Once a partner expresses interest,
OARM will coordinate with OEPI to take advan-
tage of the Labs21 XL framework and ensure the
partner has access to the resources of the XL pro-
gram. If project partners use regulatory flexibility
potentially available to them under XL, the fol-
lowing commitments would be applicable:
OARM
• Cooperating with EPA's OEPI to ensure that
information requested under Labs21, includ-
ing enforcement and environmental informa-
tion, is sufficient to support the analytic needs
of the XL review.
• Outlining environmental commitments for
Labs21 partners.
• Forwarding requests from Labs21 partners for
flexibility to OEPI, including proposed com-
mitments for achieving superior environmen-
tal performance.
• Reviewing Labs21 partners' progress in
achieving environmental commitments under
Labs21.
• Notifying OEPI if a lab fails to achieve the
stated goals.
• Participating in discussions with OEPI regard-
ing any possible need to revoke flexibilities
granted to Labs21 partners.
• Adhering to additional commitments as out-
lined in any subsequent addenda.
• Coordinating implementation of a nationwide
support system to build regional capacity for
Labs21 and a referral process to coordinate the
Project XL implementation.
-------
OEPI
Cooperating with OARM to ensure informa-
tion requested, including enforcement and en-
vironmental information, is sufficient to
support the analytic needs of the XL review.
• Reviewing requests from Labs21 partners for
flexibility and completing any rule makings
necessary.
Upholding the XL process, including commit-
ments to involve stakeholders and ensure spon-
sors have satisfactory compliance records.
• Revoking any previously granted flexibility if
such an action should be necessary as a result
of a joint determination by OARM and OEPI.
• Adhering to additional commitments as out-
lined in any subsequent addenda.
Labs21 Partners
• Submitting information necessary to complete
the Labs21/XL review.
Striving to achieve the environmental goals
outlined in any case-specific agreements.
• Undertaking specific actions such as capital
improvements or operational changes that were
agreed to as part of demonstrating pursuit of
improved environmental performance.
• Reporting on progress towards enforceable
commitments and compliance with any en-
forceable requirements.
• Notifying OEPI if the laboratory is likely to
fail or is failing to achieve the stated goals.
• Adhering to additional commitments as out-
lined in the FPA addendum.
Benefits for the Environment
• It is estimated that the typical laboratory cur-
rently uses five times as much energy and wa-
ter per square foot as the typical office
building. EPA and DOE estimate that labora-
tories using the Labs21 approach can decrease
energy consumption by 60 to 75 percent.
• Assuming that 50 percent of U.S. laboratories
achieve a 30 percent reduction in energy con-
sumption, the U.S. could reduce its annual en-
ergy consumption by 84 trillion British thermal
units (Btus), equal to the energy consumed by
2.2 million households.
• Conserving 84 trillion Btus of energy would
decrease carbon dioxide emissions by 16.7
million tons, equivalent to removing 3 million
automobiles from highways or preserving 56
million trees from harvest. Reducing carbon
dioxide emissions can help alleviate potential
human-influenced, adverse effects on the glo-
bal climate. An efficiency improvement of this
magnitude would save $1.2 billion annually.
Benefits for Stakeholders
• In addition to protecting the environment and
saving money, more funds would be made avail-
able for scientific research, and the potentially
large pool of participants would drive the de-
mand for energy-efficient and renewable energy
building technologies and building concepts.
Benefits for the Project Sponsor
• Laboratories making modifications to their
facilities to improve environmental perfor-
mance and increase energy efficiency have
access to flexible incentives through the XL
program. OARM and OEPI have a custom-
ized and expedited review process to provide
regulatory or administrative flexibility under
Project XL to enable laboratories to maximize
environmental performance under Labs21.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for Labs21 Project, signed September 7,
2000; and (2) the 2000 Project XL Comprehensive
Report, Volume 2: Directory of Project Experi-
ments and Results, November 2000. Additional
information on the Labs21 program can be found
at http://www.epa.gov/labs21 century.
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L_ead Saje, Bostoh
Final Project Agreement Signed August 29, 2000
Background
The Project Sponsor: Lead Safe Boston (LSB)
is a federally funded de-leading assistance program
that operates under the City of Boston's Depart-
ment of Neighborhood Development. The program
collaborates with state agencies and private orga-
nizations, including the Massachusetts Housing
Finance Agency's "Get the Lead Out" Program,
the Lead Action Collaborative, Ecumenical Social
Action Committee, and Massachusetts Affordable
Housing Alliance, to prevent lead poisoning of
young children by working to control lead hazards
in the highest-risk areas of the city. Boston has an
estimated 153,064 housing units containing lead-
based paint (LBP), occupied by approximately
69,500 families with children.
Over the past five years, the LSB program has used
a combination of federal, state, and local resources
to abate LBP hazards in 707 privately owned hous-
ing units, while undertaking an aggressive com-
munity outreach and education campaign to make
residents aware of the severe risks of lead in the
living environment. During the next 36-month
phase of its program, LSB is targeting the neigh-
borhoods of Roxbury and Dorchester. These neigh-
borhoods have a concentration of older housing,
the vast majority of which is likely to have lead
contamination. LSB will complete lead hazard
control or abatement activities in a minimum of
180 housing units in one- to four-unit buildings,
occupied by low- or moderate-income families with
children aged six years and younger. Funding will
be provided by the U.S. Department of Housing
and Urban Development (HUD).
The Experiment: In this XL project, LSB seeks
to increase the number of housing units that have
LBP hazards abated by utilizing provisions in the
Resource Conservation and Recovery Act's
(RCRA) Household Waste Exclusion (HWE) rule
[40 CFR 261.5 (b)(1)] that allow LBP debris from
residential housing units to be disposed of as
"household waste" instead of hazardous waste.
Disposing of LBP debris as a household waste,
subject to state regulation, will reduce the cost of
lead abatements in residential housing. As part of
this project, LSB has pledged to use the cost sav-
ings made available through implementation of this
XL project to perform approximately 12 additional
residential lead abatements that will reduce lead
exposure risks for roughly 30 children in Boston's
Dorchester and Roxbury neighborhoods.
The Flexibility: Through RCRA, EPA regulates
the disposal of solid and hazardous wastes. Since
1980, EPA has excluded household waste from the
universe of RCRA hazardous wastes under 40 CFR
261.4(b)(1). In 1998, EPA clarified that the house-
hold waste exclusion applies to "all LBP waste
generated as a result of actions by residents of
households to renovate, remodel, or abate their
homes on their own" [63 FR 70233, 70241 (Dec.
18, 1998)]. In a July 31, 2000, policy memoran-
dum, EPA's Office of Solid Waste and Emergency
Response further clarified that lead-based paint de-
bris generated by contractors in households is con-
sidered household waste and therefore excluded
from the RCRA hazardous waste regulations. On
May 4, 2001, Massachusetts Department of Envi-
ronmental Protection (MA DEP) issued a policy
memorandum that endorsed the provisions of EPA's
July 2001 memorandum.
LSB will utilize provisions in this July 31, 2000,
policy memorandum developed by EPA to extend
the use of the RCRA HWE rule to contractors and
individuals performing lead abatements in residen-
tial housing units. The provisions will enable LSB
to treat the architectural lead debris from these
projects as household waste in lieu of hazardous
waste and, thereby, forego costly toxicity charac-
teristic leaching procedure (TCLP) testing and
enable disposal of LBP debris in municipal solid
waste landfills. Moreover, to further accelerate
the pace of LBP removal from residences, EPA
issued on October 22, 2001, a direct final rule en-
abling residential LBP waste to be sent to construc-
tion and demolition landfills as well.
This practice will simplify many lead abatement
activities and significantly reduce their costs. By
allowing the debris from residential housing units
to be disposed of as household waste, EPA's new
policy memorandum reduces the disposal cost for
LSB by an average of $286 per project, which is
-------
270 percent lower than its average cost ($768) of
hazardous disposal. This represents significant
cost savings to the LSB program, as LSB prepares
to complete lead hazard control activities in a mini-
mum of 180 housing units. LSB estimates that it
will save approximately $100,260 in disposal costs
and TCLP testing fees.
Other Innovations: (I) Establishment of a Trans-
ferable Model for Other States and Localities. This
project will establish a highly transferable model
in two unique and important ways. First, EPA's
policy memorandum is nationally applicable as it
encourages states to take steps necessary to offer
more flexibility at the state level. States retain the
discretion to implement this federal policy in a
more stringent manner or to be broader in scope
than the federal program as they see fit. Second,
LSB's program will serve as a model project by
encouraging the use of best management practices
for handling LBP debris from residential housing
as set out by HUD. (2) Cleanup of Additional Hous-
ing Units. The decreased costs of disposing of LBP
as household wastes will allow lead abatement
dollars to stretch further, thereby potentially en-
abling the cleanup of thousands of additional hous-
ing units nationally if the flexibility is broadened
beyond LSB.
The Superior Environmental Performance:
By extending the RCRA HWE rule to allow con-
tractors and individuals to perform lead abatements
in residential housing units, EPA will enable LSB
to forgo costly testing and disposal of lead debris
in solid waste landfills, allowing more lead abate-
ment projects to take place with the funds saved in
disposal costs, thus preventing more children from
being exposed to lead hazards. In addition to en-
couraging use of the HWE rule to facilitate resi-
dential LBP abatement activities, EPA also strongly
encourages individuals and contractors to use best
management practices, as set out by HUD when
evaluating and controlling LBP hazards in hous-
ing units. By ensuring that appropriate safety mea-
sures are taken at the time of the removal, worker
health will also be protected. LSB's procedures
and contract requirements ensure that all contrac-
tors undertaking LBP remediation under LSB's
auspices must follow all federal, state, and local
health and safety precautions that apply to this type
of activity.
Progress in Meeting Commitments
(As of November 2001)
* EPA committed to issue a policy memorandum
clarifying the regulatory status of wastes gen-
erated as a result of LBP activities in homes
and other residences as non-hazardous waste
under the RCRA HWE Rule at 40 CFR
261.4(b) 1. To increase awareness about the
policy memorandum, EPA committed to cir-
culate the document to all EPA regions, states,
tribes, and trade associations, as well as to post
it on the EPA Web site.
- EPA issued the policy memorandum on
July 31, 2000.
- EPA has mailed the policy memorandum
to all EPA regions, states, tribes, and trade
associations and posted the memorandum
on the following EPA Web sites: http://
www.epa.gov/projectxl and http://
www.epa.gov/lead/fslbp. htm.
- On October 23, 2001, EPA published in
the Federal Register (Vol. 66, No. 205, pp.
53535-53542) a direct final rule to help
accelerate the pace of LBP removal from
residences, and thereby reduce exposure
to children and adults from the risks asso-
ciated with lead by revising the definition
of "municipal solid waste landfill unit" and
by the addition of two new definitions:
"construction and demolition (C&D) land-
fill" and "residential LBP waste." This
rule will expressly allow residential LBP
waste to be disposed of in C&D landfills
and continue to allow the disposal of resi-
dential LBP waste in municipal solid waste
landfills. This rule will become effective
on January 22, 2002, unless EPA receives
adverse comment by November 23,2001.
• MA DEP committed to develop state solid and
hazardous waste management strategies con-
sistent with the federal policy memorandum
to address the disposal of LBP debris from resi-
dential housing.
-------
- MA DEP issued its own solid and hazard-
ous waste management strategies consis-
tent with the federal policy memorandum
to address the disposal of LBP debris from
residential housing on May 4, 2001.
• In addition to the planned abatement projects
at 180 housing units, LSB committed to per-
form an additional 12 lead abatement projects
using the cost savings realized from following
EPA's and MA DEP's new policy memoran-
dum.
Benefits for the Environment
• This project will reduce the environmental
impact of LBP hazards by encouraging the use
of best management practices for handling
LBP debris from residential housing units as
set out by HUD. Given that the EPA policy
memorandum is applicable nationally, the LSB
program will serve as a model for other LBP
removal and disposal programs across the
country.
Benefits for Stakeholders
• The project will provide additional resources
for lead abatement to benefit the families and
affected children who live in the housing units
that are cleaned up under this program. Ulti-
mately, this will result in more low-income
families having LBP hazards removed from
their homes.
Benefits for the Project Sponsor
• The regulatory flexibility provided by this XL
project will allow LSB to perform additional
abatements with the same amount of funding
as a result of reduced LBP testing and disposal
costs.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Lead Safe Boston Project, August
29, 2000; (2) the 2000 Project XL Comprehensive
Report, Volume 2: Directory of Project Experi-
ments and Results, November 2000; and (3) final
rule published in Federal Register, Volume 66, No.
205.
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Louisville cxnd
jjeff^son (Zounty
y\/\efi^opolWc\v\ Sewer
District
Final Project Agreement Signed September 28, 2000
Background
The Project Sponsor: Louisville and Jefferson
County Metropolitan Sewer District (MSD) is a
nonprofit regional utility service. The Louisville
and Jefferson County MSD is responsible for
wastewater collection and treatment, a comprehen-
sive public storm water drainage system for Louis-
ville and Jefferson County, flood management and
control, stream monitoring, hazardous materials
control, and several other programs. In Septem-
ber 1998, Louisville and Jefferson County MSD
was awarded a grant for the development of pre-
treatment performance measures, designed to quan-
tify the environmental impact of the pretreatment
program in the Jefferson County sewer-shed.
The Experiment: Louisville and Jefferson
County MSD plans to experiment with a new ap-
proach to its pretreatment program at the Jefferson
Wastewater Treatment Plant by establishing links
between wastewater programs (such as collection
systems, stormwater, sludge) and moving toward
a more holistic watershed protection strategy.
Through information gathering and sharing be-
tween wastewater programs, Louisville and
Jefferson County MSD will test shifting resources
from the pretreatment program and applying re-
sources toward other environmental programs in
order to achieve greater environmental gain in the
watershed with fewer resources expended. The
project is proceeding in three phases: (1) data col-
lection and development of pretreatment perfor-
mance measures; (2) program redevelopment; and
(3) program implementation.
The Flexibility: Louisville and Jefferson County
MSD is regulated under the National Pollution
Discharge Elimination System. EPA promulgated
a rule amending the National Pretreatment Program
regulations on October 3, 2001. This rule allows
publicly owned treatment works (POTWs) that
have completed the Project XL selection process,
including FPA, to modify their approved local pre-
treatment programs. Potential regulatory flexibil-
ity expected will allow Louisville and Jefferson
County MSD to (1) change the permitting require-
ments, (2) use an alternative definition for signifi-
cant industrial user and significant noncompliance,
and (3) allow participating industrial users to not
sample for pollutants that are not expected to be
present.
Other Innovations: (1) Innovation/Multimedia
Pollution Prevention. The integration of the pre-
treatment program with other environmental moni-
toring and management programs will allow more
efficient use of resources. Louisville and Jefferson
County MSD will test several of the 18 recom-
mended results-oriented measures for assessing
performance of pretreatment programs developed
by a special committee from the Association of
Metropolitan Sewerage Agencies in 1994, under a
cooperative agreement grant with EPA. When
appropriate, Louisville and Jefferson County MSD
will reinvest cost-savings into pollution preven-
tion activities, including outreach, education, and
technical assistance, first within the pretreatment
program, then in other watershed-based programs.
Louisville and Jefferson County MSD is working
with the Kentucky Pollution Prevention Center for
input in this area. (2) Transferability to Other
Municipalities. Other municipalities will be able
to draw valuable lessons from Louisville/ Jefferson
County MSD's experience, as it relates to imple-
menting a performance-based program in indi-
vidual facilities and ultimately across a multi-plant,
multi-watershed sewer district. Louisville and
Jefferson County MSD's XL project confronts the
operational, data collection and analysis, and en-
vironmental challenges posed by a regulatory struc-
ture that compartmentalizes programs that in
practice would benefit from a more holistic ap-
proach and will attempt to build links between the
pretreatment program and the rest of the system.
(3) Focusing Regulatory Flexibility for Maximum
Environmental Benefit. With information gained
from the performance measures, and with the regu-
latory flexibility provided by the pilot project, re-
sources can ultimately be shifted to address the
greatest environmental concerns in the watershed.
-------
Louisville and Jefferson County MSD's strategy
is to take better information and reallocate re-
sources with this XL program to create environ-
mental benefits according to a specific
prioritization strategy.
The Superior Environmental Performance:
Louisville and Jefferson County MSD proposes to
better manage its pretreatment program through a
holistic watershed approach, leading to improved
pollutant loading trends in the watershed. Louis-
ville and Jefferson County MSD aims to develop
a specific strategy to monitor and identify pollut-
ant sources, conduct pollution prevention outreach,
provide education and technical assistance, and
reinvest cost savings in watershed-based improve-
ments.
Progress in Meeting Commitments
(As of October 2001)
Louisville and Jefferson County MSD is in the ini-
tial stage of project implementation. They have
met the following commitments:
• Louisville and Jefferson County MSD has col-
lected data to establish a baseline for existing
pollutant loadings.
• Louisville and Jefferson County MSD and
stakeholders developed the criteria for pollut-
ants of concern, pretreatment program modi-
fications, superior environmental performance,
and project accountability programs to be
implemented.
• On October 3, 2001, EPA promulgated a rule
amending the National Pretreatment Program
regulations to allow POTWs that have com-
pleted the Project XL selection process, includ-
ing FPA development, to modify their
approved local pretreatment programs. These
POTWs will be allowed to modify their pro-
grams, and implement the new local programs
as described in their FPAs.
Commitments for the future of the project include
the following:
• Louisville and Jefferson County MSD will
continue to collect and analyze data in the wa-
tershed and develop performance measures in
order to move toward a more holistic water-
shed protection strategy.
• In Phase 2, EPA intends to propose and issue
(subject to applicable procedures and review
of public comments) a site-specific rule should
one prove necessary, amending 40 CFR 403,
that applies specifically to MSD's Jefferson
wastewater treatment plant. Then EPA intends
to work with the Commonwealth of Kentucky
to issue a permit or a permit modification un-
der 40 CFR Part 1222, Clean Water Act Sec-
tion 402 and Title 401 of the Kentucky
Administrative Regulations.
• Louisville and Jefferson MSD will prepare and
submit progress reports to EPA and the Ken-
tucky Department of Environmental Protection
every six months and submit a performance
assessment report every year.
Benefits for the Environment
• The implementation of a sewer-shed model
incorporates loadings from direct and indirect
discharges to allow Louisville and Jefferson
County MSD to determine the most environ-
mentally effective management responses.
• Environmental targeting of resources allows
Louisville and Jefferson County MSD to tar-
get the most significant threats to water qual-
ity and allocate resources accordingly.
• Louisville and Jefferson County MSD will
look within, as well as beyond, their pretreat-
ment program to reduce pollutants of concern
toward target thresholds.
-------
Benefits for Stakeholders
• Regulated stakeholders that can demonstrate
minimal or non-existent impacts will have the
opportunity to reduce required sampling, lead-
ing to cost savings.
• Stakeholders will have the opportunity to ap-
prove programs to be funded by the reinvest-
ment of saved compliance and monitoring
expenses.
Benefits for the Project Sponsor
• Through this XL project, Louisville and
Jefferson County MSD will receive flexibility
in determination of significant industrial us-
ers, significant non-compliance, and sampling
requirements.
• This flexibility will free up Louisville and
Jefferson County MSD resources, which will
then be targeted towards addressing sources
of the highest-priority pollutants rather than
sources proven to be insignificant.
Information Resources: The information sources
used to develop this progress report include: (1)
the FPA for the Louisville and Jefferson County
Metropolitan Sewer District XL Project, dated
September 28, 2000; (2) information from the Lou-
isville and Jefferson County MSD home page,
http://www.msdlouky.org; (3) information from the
EPA Office of Wastewater Management Web site,
http://www.epa.gov/owm; and (4) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000.
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Lucervf Xeck^vologies
Final Project Agreement Signed August 19, 1998
Background
The Project Sponsor: The Microelectronics
Group of Lucent Technologies, Inc., (Lucent) de-
signs and manufactures integrated circuits and
other electronic components for the computer and
communications industries.
The Experiment: The Lucent project goal is to
operate an International Organization for
Standardization's (ISO) 14001 environmental man-
agement system (EMS) that will manage multime-
dia environmental impacts for all of the company's
facilities (see Figure 28). Through the implemen-
tation of its EMS, Lucent seeks to achieve envi-
ronmental performance superior to that required
by its current permits. Specifically, this project
will test whether the use of a high-quality EMS
creates a system that is more efficient, more trans-
parent, more understandable, and more flexible.
The project uses a unique strategy of integrating
regulators into the EMS process to set environ-
mental goals and to track performance. Also, as
part of its EMS approach, Lucent has committed
to obtaining input from a facility-based Local En-
vironmental Advisory Group (LEAG) composed
of local stakeholders, including environmental or-
ganizations, community groups, employees, and
other interested citizens. Ultimately, over the five-
year period the Lucent project will identify whether
a high-quality EMS can serve as the basis for an
integrated environmental management approach,
using a single document to govern environmental
management in at all of Lucent's Microelectron-
ics facilities.
The project consists of two implementation mecha-
nisms: (1) umbrella FPA and (2) site-specific ad-
denda. The umbrella FPA, which applies to all
U.S.-based Lucent microelectronics facilities, pro-
vides overarching goals for the project, identifies
concepts to be potentially tested over the term of
the FPA, and provides broad tools for project imple-
mentation. The site-specific addenda would gov-
ern implementation of a XL project at an individual
Lucent facility. To date, Lucent and EPA have yet
to develop a site-specific project.
The Flexibility: Under the umbrella FPA, Lucent
anticipates using the EMS to provide a vehicle for
consolidation of all federal and state permits into
a single Microelectronics-wide, multimedia per-
mit, based on annual targets set jointly by the com-
pany and regulators. This would result in an annual
review of one permit rather than the current sys-
tem of multiyear renewals of individual permits.
In addition, the EMS could provide Lucent with a
Identify
Environmental
Aspects
(e.g., VOC
emissions)
Flow Diagram:
Lucent EMS Process Overview
Identity
Environmental
Objectives
(e.g., reduce
VOC emissions)
Stakeholder Input
Identify
Targets
i.g., reduce to
< 25 tpy)
=>
Monitor
and Measure
Performance
Implement
EMS Targets
at Each
Facility
=>
Report
Results
(Matrix)
Evaluate
Superior
Environmental
Performance
Pigui*e 28
Lucent EMS process overview.
-------
streamlined process for incorporating new regula-
tory flexibility approaches and consolidating re-
porting requirements.
The Superior Environmental Performance: The
umbrella FPA is a multi-regional attempt to incor-
porate high-quality environmental management
practices on a corporate-wide level. Lucent's EMS
fosters superior environmental performance by
identifying opportunities to reduce environmental
impacts in a variety of areas, both regulated and
non-regulated. Any future site-specific projects
negotiated under the umbrella agreement will serve
as vehicles for achieving superior environmental
performance and considering regulatory flexibil-
ity at the individual facilities.
Information Resources: The information in this
summary comes from the following sources: (1)
the December 1999 XL Project Progress Report—
Lucent Technologies (EPA- 100-R-00-012) and (2)
the FPA for Lucent Technologies XL Project.
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yVtassackusei+s
Department o|
(Srv v i ro rv me nta I
Protection
(Savirorvmervtal
Results Program
Final Project Agreement Signed October 6, 1998
Background
The Project Sponsor: In 1996, the Massachusetts
Department of Environmental Protection (MA
DEP) initiated a new program known as the Envi-
ronmental Results Program (ERP). The ERP in-
stitutes a cost-effective approach that improves
environmental performance and environmental
protection while increasing flexibility for compa-
nies in the Commonwealth of Massachusetts. The
ERP is one of 15 finalists chosen for the Innova-
tions in American Government awards, a program
of the Institute for Government Innovation at
Harvard University's John F. Kennedy School of
Government, administered in partnership with the
Council for Excellence in Government.
The Experiment: This project is testing an ini-
tiative to improve environmental performance in
specific industry sectors by streamlining permit-
ting and reporting and to improve and better mea-
sure environmental performance across the state.
MA DEP developed the ERP, a multimedia, whole
sector-based regulatory system that replaces case-
by-case state permits with industry-wide environ-
mental performance standards and an annual
certification of compliance. It is a mandatory pro-
gram in Massachusetts for three small-business
sectors—printers, photo processors, and dry clean-
ers. Facilities in these sectors receive compliance
assistance material to help conduct their own en-
vironmental self-audit. Based on the results, the
facility either certifies compliance, or if problems
are found, develops a Return-to-Compliance plan.
Senior-level company officials are required to an-
nually self-certify that the participating companies
are, and have systems in place to ensure that they
will continue to be, in compliance with all appli-
cable air, water, and hazardous waste management
performance standards throughout the facility.
Industry representatives have cooperated with MA
DEP in establishing criteria for reporting compli-
ance with state standards without developing per-
mits for each facility. The project reduces the
reporting burden for affected facilities and MA
DEP while fostering superior environmental per-
formance by identifying and encouraging oppor-
tunities for pollution prevention. One of the goals
of the ERP is to reduce the number of state per-
mits applied for, renewed, and issued, and to make
more informed decisions about how to focus state
resources on high-priority environmental problems.
Additional goals of the ERP are to increase the
number of facilities in compliance and to expand
the universe of companies identified in the regula-
tory system. The ERP applies three innovative
tools to enhance and measure environmental per-
formance. These tools supplement MA DEP's tra-
ditional compliance inspection and enforcement
efforts:
1. Compliance assistance from the agency
through outreach and innovative workbooks
to clearly explain facilities' environmental ob-
ligations;
2. An annual self-certification of compliance by
companies to increase self-evaluation and ac-
countability, which requires a senior company
official's certification; and
3. A new performance measurement methodol-
ogy to track results, determine priorities and
strategically target inspections and compliance
assistance efforts. The methodology includes
a tool known as Environmental Business Prac-
tice Indicators (EBPIs) as a key way to con-
firm facility performance in the three industry
sectors currently in the ERP. EBPIs are indus-
try-specific measures that provide a snapshot
of a facility's environmental performance.
They are unique in that they include measure-
ment of adherence to traditional regulatory
standards (e.g., level of compliance with la-
beling, record keeping, and monitoring, such
as putting labels on barrels of hazardous waste)
and "beyond compliance" measures such as
-------
voluntary pollution prevention (P2) activities
(e.g., recommending that facilities have signs
above sinks warning employees about the
dangers of pouring toxic chemicals down
sinks). The goal in using EBPIs is to "bench-
mark" and evaluate facility/sector performance
and use that information to determine indus-
try-wide compliance rates and actual environ-
mental performance, focus compliance
assurance and enforcement resources, and
evaluate the ERP's programmatic effective-
ness.
The Flexibility: MA DEP and EPA signed an
umbrella FPA to establish an expedited EPA re-
view process for any changes to federal regula-
tions or policies that MA DEP may propose to
ensure effective ERP implementation. The um-
brella FPA will be expanded through addenda that
will provide the necessary regulatory flexibility and
specify requirements for superior environmental
performance for each sector. Currently, EPA and
MA DEP are working on providing flexibility to
the dry cleaning sector under the maximum achiev-
able control technology rule applicable to dry
cleaners under the Clean Air Act by delegating to
the state authority to reduce record retention time.
Other Innovations: EPA and State Joint Partner-
ship for ERP Expansion: EPA and MA DEP also
are working together to expand the ERP to other
interested states through the ERP Partnership
Project. EPA's Office of Enforcement and Com-
pliance Assurance, Office of Policy, Economics,
and Innovation, and Region 1, have joined with
MA DEP to investigate whether the ERP approach
and its tools can be transferred to other states and
other environmental management issues. This
partnership is interested in creating opportunities
for other states to learn about the ERP approach
and its tools, facilitating information sharing
among states, and supporting use of the ERP to
solve environmental problems. For more infor-
mation on this partnership please visit: http://
www.epa.gov/permits/masserp.htm.
The Superior Environmental Performance:
The ERP intends to achieve superior environmen-
tal performance by:
• Promoting P2 through outreach and assistance;
• Giving MA DEP a better understanding of
regulated industries; and
• Increasing the number of facilities operating
within MA DEP's regulatory programs.
Progress in Meeting Commitments
(As of November 2001)
Overall, MA DEP has successfully met their com-
mitments through the implementation of ERP com-
ponents to achieve superior environmental
performance. The ERP provided extensive out-
reach and technical assistance to participating sec-
tors to promote pollution prevention, and
successfully eliminated a significant number of
permits in the printing sector. A summary of the
ERP commitments in the initial FPA is provided
below. The preliminary graphical information and
supporting data that are presented below on the
status of the ERP are taken from a draft user's guide
for the ERP (November 2001), which is under de-
velopment by the EPA and MA DEP.
• MA DEP committed to provide clear perfor-
mance standards and compliance assistance to
companies in the participating sectors through
outreach and technical assistance.
- In order to set up a performance measure-
ment system for the ERP, MA DEP iden-
tifies the universe of facilities and conducts
pre-certification inspections to establish a
baseline against which progress under the
ERP could be compared. By employing a
statistical approach to performance mea-
surement, MA DEP can base its perfor-
mance measurement on a statistically valid
sample of facilities in each sector that re-
liably indicate the performance of the
whole group rather than needing to obtain
data from all facilities in a group.
- The ERP measurement system evaluates
the environmental performance of ERP
sectors using MA DEP inspection check-
lists and facility self-certification forms.
MA DEP inspectors complete a statisti-
cally valid number of on-site inspections
-------
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and complete detailed inspection check-
lists during both random and targeted
on-site inspections before implementation
of the ERP and after facilities complete
self-certification forms. The MA DEP in-
spection checklist and self-certification
form questions are designed to assess com-
pliance with regulatory requirements and
include questions for each sector that re-
late to beyond compliance and P2 activi-
ties. The subset of regulated and
non-regulated practices contained in the
checklists, the EBPIs, are also included in
the inspector's checklists and are used to
(1) calculate facility and sector compliance
"scores" before and after ERP outreach
and certification, (2) determine the statis-
tical significance of changes in specific en-
vironmental indicators or of whole groups,
and (3) evaluate the accuracy of self-cer-
tification forms submitted by ERP facili-
ties. The number of EBPIs developed for
each sector is different. Printers have 18
EBPI measures, dry cleaners have 16, and
photo processors have 8. The number of
indicators is based on the complexity of
the industry and the number of multime-
dia discharges.
- MA DEP has promulgated regulations
with additional performance standards
with extensive review by the public and
industry sectors. During the first year of
implementation in each sector in 1997 and
1998, respectively, MA DEP conducted .
workshops to provide guidance and assis-
tance to industry representatives in under-
standing and complying with the
standards.
- The ERP provides the compliance assis-
tance tools that enable businesses in the
participating sectors to determine what
rules are applicable to them and what is
required to comply. MA DEP designed
and implemented its compliance efforts in
close collaboration with organizations and
associations representing and interested in
the covered sectors. Compliance assis-
tance efforts include workbooks and work-
shops for each sector that clearly explain
all of a facility's applicable environmen-
tal obligations. ERP sector workbooks
include regulatory compliance require-
ments, environmental practices that are
beyond compliance, and information about
environmental, worker, and public health
impacts of facility operations. Compliance
assistance workbooks are designed as a
basis for self-certification and are written
from a facility-operator's point of view in
an easy-to-read format. The workbooks
are meant to be stand-alone documents,
which present all covered compliance stan-
dards for all media. Background informa-
tion on the ERP process is underway for
the dry cleaners, photo processors, and
printers sectors and can be found at the
MA DEP Web site (http://www. state,
ma.us/dep/erp). Compliance assistance
workshops are also conducted by MA
DEP, which works closely with trade as-
sociations to determine how many and in
what locations the workshops should be
held to reach the greatest number of fa-
cilities. MA DEP holds initial workshops
after the ERP kickoff for each ERP sector
and then holds additional workshops, as
needed, based on problem areas identified
by MA DEP from inspections, certifica-
tion reviews, and data analyses to update
the regulated community on any changes
in requirements.
MA DEP committed to promote corporate ac-
countability and self-evaluation of environ-
mental performance by requiring annual
compliance self-certification.
- Under the ERP, MA DEP established a
self-certification process for each of the
three sectors. Because firms must certify
annually, the ERP requires companies to
conduct an environmental review annually.
The ERP includes similar components to
an environmental management system
where compliance obligations are speci-
fied/detailed and audited on a regular ba-
sis. Because the certification forms require
the signature of a high-level owner or
-------
1997 Air Regulatory Database
90°o Not on File
1998 ERP Database
13% Not on File
87% On File
2000 ERP Database
2% Not on File
\
1~igure 29
Percentage of dry cleaners in MA DEP databases from 1997 to 2000.
manager, the process has improved senior
management's attention to environmental
management.
- Each ERP Certification Plan contains in-
structions, a Non-Applicability Statement,
a Compliance Certification Form, a Return
to Compliance Form, and a Spill or Re-
lease Summary Form. As an additional
tool for printers, MA DEP provides a free
interactive training CD-ROM. The CD-
ROM is a companion to the Printers Envi-
ronmental Certification Workbook and
provides multimedia instructions to print
shop employees about what they can do
to comply with ERP requirements, evalu-
ate P2 alternatives, and keep the environ-
ment safe.
• MA DEP committed to encourage the adop-
tion of P2 techniques via sector-specific guid-
ance and implementation manuals and
inclusion in performance standards.
- MA DEP developed workbooks that pro-
vide step-by-step guides to compliance and
P2 techniques. These outreach efforts were
developed through extensive interaction
with related industry experts. For example,
40 percent of dry cleaners in Massachu-
setts are Korean, so MA DEP worked with
the Korean Dry Cleaners Association to
translate the workbook to overcome any
possible language barriers.
- Nine specific P2 measures have been in-
corporated into EBPIs for the printer sec-
tor.
• MA DEP committed to improve compliance
assurance and enforcement by better identify-
ing the universe of firms in each sector, con-
ducting random inspections, and targeting
non-reporters and deficient certifiers.
- As a result of MA DEP's efforts, using this
ERP approach, small business coverage
within this regulatory system has expanded
by 340 percent (2007 Draft User's Guide).
MA DEP applied the ERP to three small
business sectors for which it had little in-
formation, yet working with trade associa-
tions and other sector stakeholders, MA
DEP identified a more complete universe
of firms. It is estimated that the ERP al-
lows MA DEP to track environmental per-
formance for 80 to 90 percent of the firms
in a sector compared to the 33 percent prior
to ERP. To date, based on data collected
by MA DEP, the ERP program has over
2,200 participating companies—approxi-
mately: 1,100 printers, 600 dry cleaners,
and 500 photo processors. The number of
companies exceeds those that were tradi-
tionally accounted for by MA DEP prior
to the implementation of the ERP (see Fig-
ure 29). The inclusion of a more complete
universe of firms in the ERP leads to
greater sector-wide compliance. The most
notable increase in coverage for a single
sector has been in the dry cleaning sector.
-------
Due to the large number of small busi-
nesses and the rapid turnover of business
ownership in this industry, it has been his-
torically difficult to track them under
conventional permitting and enforcement
programs. Between 1997 and 2000 the
percentage of dry cleaners on file at MA
DEP increased from 10 percent to 98 per-
cent of the estimated total number of dry
cleaning facilities.
- Under the ERP, MA DEP's strategy to en-
sure compliance includes continued field
presence by way of targeted and random
inspections, review, analysis of certifica-
tion data (including Return-to-Compliance
forms), and use of the agency's enforce-
ment protocols as appropriate. Based on
EBPI data, MA DEP targets a variety of
business activities. These activities in-
clude those that have not filed certifica-
tions, firms whose certifications are
incomplete or technically deficient, and
companies that have been the subjects of
complaints.
MA DEP committed to conduct an evaluation
of the program to measure and evaluate com-
pliance and environmental results.
- EBPIs are used to measure, track, and as-
sess compliance through evaluation of pro-
gram results and sector performance.
Specifically, they compare baseline inspec-
tion data (which include EBPIs) collected
during random inspections before imple-
mentation of the ERP to data collected
during random inspections after outreach
and certification under the ERP. Environ-
mental results analyses are based on the
data from MA DEP inspection checklists
and the facility self-certification forms.
The facility and sector agreement scores
are based on the percentage of indicators
for which an "in agreement" answer was
noted on the checklist, normalized to a 1
to 10 scale. For example, a facility with
an overall environmental performance
score of 7.8 adhered with 78 percent of
the EBPIs. As a result of the ERP's per-
formance measurement tools, MA DEP is
able to reliably report on environmental
results and progress in the ERP's sectors
in a unique way, based on statistically
sound data, and because it includes in-
sights into compliance status as well as en-
vironmental performance. MA DEP is
able to use performance metrics to exam-
ine ERP outcomes by individual facility,
environmental medium, overall perfor-
mance for a sector, and performance on
key environmental practices. The results
presented below are based on three years
of data for the dry cleaning and photo-pro-
cessing sectors (baseline measurement in
1997; post self-certification measurements
in 1998 and 2000), and over two years for
the printing sector (baseline in 1998; post
self-certification in 1999).
Dry Cleaning Sector
- The dry cleaning sector's overall environ-
mental performance was measured by the
16 EBPIs from inspection checklists ap-
plicable to each facility. For example "in
agreement" was marked on the checklist
for EBPI number 10a, "Is there no odor of
perchloroethylene readily detectable in the
facility?" if the inspector's checklist
matches the facility self-certification form
and as stating that no odor of perchloroet-
hylene is readily noted. The number of
"in agreement checks" are totaled for all
of the EBPIs per facility and then aggre-
gated for the whole sector. This aggre-
gate score is a reflection of how well the
sector is performing using EBPIs as
"Cable iO: Dry Cleaning ^Aggi'ega+e Sector Performance
Year 1-1997 Year 2-1998 Year 3-2000
(prior to self-certification) (one year after initial self-certification) (two years after self-certification)
8.3
8.6
9.0
-------
indicators. The aggregate sector perfor-
mance for the dry cleaning sector increased
from 83 percent to 90 percent from the
baseline assessment in 1997 (Year 1) to a
second comparison in 2000 (Year 3), indi-
cating a 7 percent increase in environmen-
tal performance (see Table 10).
- Figure 30 illustrates the change in perfor-
mance from dry cleaners for all indicators
over time from the baseline in 1997 to the
second comparison in 2000. The chart de-
picts four outcomes: (1) the percentage of
facilities that had an increase in perfor-
mance from 1997 to 2000; (2) the percent-
age of facilities that had a decrease in
performance from 1997 to 2000; (3) the
percentage of facilities that had no statis-
tically significant change in performance
and previously had a high level of perfor-
mance, thus, maintaining their high level
of performance; (4) and the percentage of
facilities that had no statistically signifi-
cant change in performance and previously
had a low level of performance, thus, main-
taining their low level of performance.
While these data do not explain why fa-
cility behavior is positive or negative, they
do indicate trends that inform MA DEP
that 86 percent of facility responses show
good performance, while 14 percent need
further attention.
Printing Sector
- Data for the printing industry are available
for two years, as the printers' ERP started
one year later than the other two sectors.
From Year 1 to 2, the printing sector's
overall performance for the 18 EBPIs ap-
plicable to each facility in this sector in-
creased from 74 percent to 87 percent from
the baseline in 1998 to the first compari-
son in 1999 (see Table 11).
25% (15)
No Change in
Performance
(high initial)
MA DEP-Dry Cleaning Trends
2% (1)
No Change in
Performance (low initial)
61% (36)
Increase in
Performance
12% (7)
Decrease in
Performance
()=number of indicators
Pigure. 30
Aggregate indicator trends comparing the 1997 baseline to
2000 comparison evaluation data for the dry cleaning sector.
MA DEP-Printing Sector Trends
18% (11)
No Change in
Performance
(high initial) ^
60% (36)/^
Increase in
Performance
22% (13)
Decrease in
Performance
()=number of indicators
T~'\C)ure. 31
Aggregate indicator trends comparing the 1998 baseline to
1999 comparison evaluation data for the printing sector.
MA DEP-Photo Processing Sector Trends
3% (1>
Decrease in
Performance \*
87% (26) ^
Increase in
Performance
10% (3)
* No Change in
Performance
(high initial)
()=number of indicators
^igu^e 32
Aggregate indicator trends comparing the 1997 baseline to
2000 comparison evaluation data for the photo processing
sector.
Table 11! Printing .Aggregate Sector "Performance.
Year 1-1998
(prior to self-certification)
Year 2-1999
(After Initial self-certification)
7.4
¦MMHi
8.7
¦
-------
- Figure 31 illustrates the change in perfor-
mance from printers for all indicators over
time from the baseline in 1998 to the first
comparison in 1999. The chart depicts
three outcomes: (1) the percentage of fa-
cilities that had an increase in performance
from 1998 to 1999, (2) the percentage of
facilities that had a decrease in perfor-
mance from 1998 to 1999, and (3) the per-
centage of facilities that had no statistically
significant change in performance and pre-
viously had a high level of performance,
thus, maintaining their high level of per-
formance. While the data do not explain
why facility behavior is positive or nega-
tive, they do indicate trends that inform
MA DEP that 78 percent of facility re-
sponses show good performance while 22
percent need further attention.
Photo Processing Sector
- The aggregate photo processing results
show the largest increase in EBPI perfor-
mance across the three sectors, increasing
overall by 34 percent (from 53 percent in
Year 1 to 92 percent in Year 3) (see Table
12). MA DEP speculates that this increase
in performance between the baseline •
(1997) and the second comparison in 2000
may be a result of a meeting held in early
2000 with the Photo Processing Associa-
tions to identify low performance results
for the sector and communication of those
results to facility operators.
- Figure 32 illustrates the change in perfor-
mance from photo processors for all indi- .
cators over time from the baseline in 1997
to the second comparison in 2000. The
figure depicts three outcomes: (1) the per-
centage of facilities that had an increase
in performance from 1997 to 2000, (2) the
percentage of facilities that had a decrease
in performance from 1997 to 2000, and (3)
the percentage of facilities that had no sta-
tistically significant change in perfor-
mance and previously had a high level of
performance, thus, maintaining their high
level of performance. While the data do
not explain why facility behavior is posi-
tive or negative, they do indicate trends
that inform MA DEP that 97 percent of
facility responses show good performance
while 3 percent need further follow-up.
In addition to calculating facility and industry
wide scores, MA DEP also conducts an accu-
racy analysis. During random inspections, MA
DEP compares results of data collected from
those facilities before the ERP was launched
to the answers on the certification forms from
facilities after the ERP to determine the over-
all level of accuracy of the certification data.
MA DEP also conducts targeted inspections
based on its review of facilities' self-certifica-
tion forms. The purpose of these inspections
is to determine whether a facility and MA DEP
agree about a facility's compliance status.
The current ERP information technology sys-
tem is not automated. Business certifications
are submitted manually, and MA DEP reviews
the data manually. EPA has provided the ERP
with automation system support. It is expected
that this support will allow MA DEP to auto-
mate portions of its ERP system within the next
year.
Information on the progress of the ERP is
posted on the MA DEP Web site: http://
www.state.ma.us/dep/erp. The site includes
publications, ERP sector regulations, and cer-
tification packets, press releases, and other
~Vable 12: Photo Processing Aggregate Sector 1Pe.rformav\ce.
Year 1-1997 Year 2-1998 Year 3-1999
(prior to self-certification) (After Initial self-certification) (Two Years After self-certifica-
5.3
6.0
9.2
-------
background material. It does not include spe-
cific information on facilities participating in
the program or any data from the certifications.
However, these data are available in the state's
public reading room.
• MA DEP is currently expanding the ERP and
developing program tools and regulations for
two more sectors—firms that discharge indus-
trial wastewaters (IWW sector) to sewers and
firms installing or modifying boilers (combus-
tion sector). In September 2001, MA DEP
launched the industrial boiler ERP initiative.
The IWW ERP initiative is expected to be
launched in mid-2002.
Benefits for the Environment
• The ERP is mandatory for targeted business
sectors. Participating Massachusetts firms
must evaluate their environmental compliance
annually and certify adherence to ERP perfor-
mance standards. MA DEP believes that the
ERP's requirements will have several facility-
specific impacts. Some examples of these are
changes in practices regarding waste handling,
equipment maintenance and operation, and
leak checking to reduce emissions and mini-
mize the likelihood and impact of spills and
workplace exposure.
• The ERP requires printers to use low-volatile
organic compound (VOC) press cleaning so-
lutions that reduce VOC emissions. MA DEP
estimates that this approach in the printing in-
dustry will reduce statewide VOCs by 10 per-
cent.
• The ERP requires dry cleaners to use leak test
equipment to conduct leak checks weekly, a
stricter requirement than the pre-ERP monthly
sniff test requirement. It is estimated that us-
ing this leak detection technique and conduct-
ing repairs as needed could reduce statewide
perchloroethylene emissions.
• The ERP's improved waste-handling practices,
especially in the dry cleaning sector, should
improve hazardous waste management, yield-
ing benefits such as reduced perchloroethyl-
ene-laden waste disposal that has contributed
to the creation of numerous hazardous waste
sites and water supply closings in the state.
• For the photo-processing sector, the ERP in-
cludes standards to reduce silver discharges to
publicly owned treatment works, as well as re-
duce illegal discharges to septic systems, the
ground, or surface water. Silver recovery
equipment is estimated to reduce silver dis-
charges by 99 percent. Photo processors have
reduced silver discharge through more frequent
replacement of silver recovery canisters. Ap-
proximately 15 percent of photo processors had
no silver recovery equipment prior to the ERP.
Benefits for Stakeholders
• ERP eliminated all permits for small source
facilities in the printer sector. Printers that are
classified as large air emissions sources still
must receive a permit. For small sources, the
ERP gives printers the flexibility to add or
modify certain equipment without waiting for
MA DEP approval.
• Building on the success of the Massachusetts
Printing Partnership, MA DEP's effort to in-
clude a more complete universe of firms in
each sector has leveled the playing field be-
tween firms complying with regulations and
those that have gained a competitive advan-
tage by ignoring their regulatory responsibil-
ity. Firms in all three current ERP sectors are
no longer required to obtain permits for indus-
trial wastewater discharges. Prior to the ERP,
many of the firms in these sectors were re-
quired to have IWW permits, yet very few did
or even knew of these requirements. Under
the ERP, these firms are regulated more equally
through the flexibility of the self-certification
process.
• The ERP is similar to an environmental man-
agement system (EMS). The ERP's anijual
certification requirement and well-designed
workbooks help firms establish procedures,
accountability, and records similar to compo-
nents of a small-scale EMS. As firms conduct
the frequent compliance reviews documented
-------
in ERP workbooks, they help ensure that their
business is in compliance with all applicable
multimedia regulations.
• Business environmental costs are reduced.
Participating firms that were already in the MA
DEP system have recognized net savings
through the ERP For example, prior to the
ERP, a midsize printer paid a $300 small-quan-
tity generator-fee, $150 to $450 for air per-
mits, and $1,300 for an IWW permit. Under
ERP, those fees were replaced with an annual
fee of $200 (printers have gradation in fees
depending on the size).
• MA DEP and business collaboration is en-
hanced. Massachusetts firms in participating
ERP sectors have the opportunity to assist in
the development of performance standards,
workbooks, and workshops, as well as com-
ment and review regulations proposed for their
sector.
Information Resources: The information sources
used to develop this project summary include (1)
the FPA for the MA DEP XL project; (2) a draft of
a user's guide for government agencies entitled,
The Massachusetts Environmental Results Pro-
gram (November 2001); (4) Learning from Inno-
vations in Environmental Protection, Research
Paper Number 1, Evaluation of the Massachusetts
Environmental Results Program (June 2000) by
Susan April and Tim Greiner of Kerr, Greiner,
Anderson & April, Inc., prepared for the National
Academy of Public Administration; (5) the Janu-
ary 2000 Project XL Progress Report MA Depart-
ment of Environmental Protection (EPA
1OO-R-OO-013); and (6) The Project XL 2000 Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
• ERP applicability has expanded. The ERP has
brought the federal-state partnership and its op-
portunities, to a wider, national audience. It
brings to all states the possibility for great en-
vironmental gains through an adoption of an
ERP-type program.
Benefits for the Project Sponsor
• Through the ERP MA DEP created a more
complete database of the universe of firms
identified in each sector.
• MA DEP now has the capability to track the
environmental performance for 80 to 90 per-
cent of the firms in the dry cleaning, photo-
processing, and printing sectors. This is a
significant increase in the universe of firms
identified prior to the ERP (which is estimated
to be less than one-third).
• MA DEP will be able to focus their enforce-
ment resources on non-responding entities and
problematic certifications, thus targeting enti-
ties that are more likely to be in non-compli-
ance with environmental standards.
-------
yVlerck & (Comparvy,
Jkvc.
Final Project Agreement Signed December 15, 1997
Background
The Project Sponsor: Merck & Company, Inc.,
is a worldwide, research-intensive, health products
company that discovers, develops, manufactures,
and markets human and animal health products.
Merck's Stonewall plant near Elkton, Virginia, was
established in 1941. The plant employs more than
900 people in a range of pharmaceutical manufac-
turing activities such as fermentation, solvent ex-
traction, organic chemical synthesis, and finishing
and packaging operations. The Stonewall plant is
located 1.5 miles from the Shenandoah National
Park, which has experienced substantial air qual-
ity degradation and related resource impacts over
the past several decades.
The Experiment: Because of its proximity to
Shenandoah National Park, Merck has volunteered
to convert its coal-burning powerhouse to natural
gas, a much cleaner-burning fuel, at the Merck
Stonewall plant. The company's conversion to
natural gas has significantly reduced emission lev-
els for sulfur dioxide (S02) and nitrogen oxides
(NOx), pollutants associated with visibility impair-
ment and acid deposition, which have been ob-
served in nearby Shenandoah National Park. In
this XL project, the Virginia Department of Envi-
ronmental Quality (VADEQ) has issued a site-spe-
cific permit for Merck's Stonewall plant. Merck's
air quality permit includes a site-wide cap on the
facility's total emissions of criteria air pollutants
[volatile organic compounds (VOCs) as a surro-
gate for ozone, particulate matter-10 (PM-10), car-
bon monoxide, SO,, and NOJ. The permit also
contains individual pollutant emission caps on SO,,
NOx, and PM-10. As long as emissions remain
below the caps, Merck will no longer need to ob-
tain prior approval from EPA or VADEQ for
changes at the facility that cause changes in emis-
sions.
The Flexibility: Under the Project XL initiative,
EPA and the Commonwealth of Virginia collabo-
rated on implementing flexibilities, including a
site-specific rule, variance, and permit under the
Clean Air Act's Prevention of Significant Dete-
rioration (PSD) program to authorize site-wide
caps and an innovative best achievable control
technology approach. Existing New Source Re-
view (NSR) and air permitting regulations required
that most changes to the manufacturing process at
the Merck Stonewall plant be reviewed and ap-
proved by the VADEQ prior to being implemented.
This requires a considerable effort by the facility
as well as the regulators to frequently prepare and
review permit applications for many process modi-
fications. In addition to the permit flexibility, EPA
also provided flexibility in complying with Re-
source Conservation and Recovery Act air emis-
sion requirements that apply to certain existing
hazardous waste management units.
Other Innovations: (1) Limited Preapprovalsfor
Air Permits. Pharmaceutical industries change
their product lines frequently. Usually, such
changes require a time-consuming preconstruction
permit exercise potentially resulting in delays in
getting new products to market. By focusing on
the total emissions of a facility, XL is testing and
confirming flexible emission reduction strategies
that may be both duplicated at similar facilities
across the country and integrated into EPA's exist-
ing regulatory regime. (2) Tiered Reporting—
Building Incentives into Data Collection
Requirements. A key innovative feature of Merck's
XL project is that the monitoring, record keeping,
and reporting requirements for the PSD permit in-
crease in stringency as the site's actual total crite-
ria pollutant emissions come closer to the total
emissions cap. Annual reporting is required when
facility-wide emissions are less than 75 percent of
the cap. Semiannual reporting is required when
facility-wide emissions are between 75 percent and
90 percent of the cap. Monthly reporting is re-
quired when emissions are equal to or greater than
90 percent of the total emissions cap. Since data
collection and reporting are expensive, this pro-
vides an additional incentive for the facility to
minimize its emissions.
The Superior Environmental Performance:
Merck will improve air quality in the Shenandoah
National Park and surrounding community by op-
erating under the site-wide emissions caps and
-------
permanently reducing total criteria air pollutant
emissions by approximately 300 tons per year, a
20 percent reduction versus recent actual emis-
sions, as required by the facility-wide cap. Crite-
ria pollutants such as SO, and NOx emissions can
damage plant life, reduce visibility, contribute to
acid rain, and cause adverse health effects. In ad-
dition, NOx reacts with VOCs to create ground-
level ozone, which can damage vegetation and
structures and also have harmful effects on the res-
piratory system of people. The emission subcaps
guarantee at least a 25 percent reduction of SO,
and 10 percent reduction of NOx versus recent ac-
tual emission levels.
Progress in Meeting Commitments
(As of September 2001)
• EPA has met its commitment to propose a site-
specific PSD and NSR rule, which provides
an alternative means of compliance with state
and federal air standards for the Merck Stone-
wall plant. EPA promulgated the final rule on
October 8, 1997. In addition, EPA delegated
full authority to Virginia for implementing and
enforcing the PSD rule on November 24, 1997.
• The State Air Pollution Control Board of Vir-
ginia issued a variance on September 10, 1997,
consistent with EPA's rule; VADEQ granted
the PSD permit to the Merck Stonewall plant
on January 7, 1998, with an effective date of
February 10, 1998.
• The Title V permit for the facility was issued
on September 7, 2001, with an effective date
of October 1, 2001.
• The Merck Stonewall plant has met its com-
mitment to replace its coal-fired boilers with
natural gas boilers. The conversion was com-
pleted in July 2000.
• The facility's actual emissions averaged over
1992 and 1993 were used to establish a
baseline level of 1,503 tons per year for total
criteria pollutants. Under the new facility-wide
cap, total criteria pollutant emissions will be
maintained at levels below 1,202 tons per year.
Merck - Total Criteria Pollutant Emissions
July 2000-Juna 2001
February 2000-
January 2001
Emissions Cap
199.02
, 499.54
0 200 400 600 800 1000 1200 1400 1600
Tons per Year
Figure 33
Merck Stonewall facility total criteria air pollutants
emissions data, baseline, and emissions cap data for 2000-
2001.
Merck - Sulfur Dioxide Emissions
July 2000-June 2001
February 2000-
January 2001
Emissions Cap
J 18.7E
0 100 200 300 400 500 600 700 800
Tons per Year
T-'igiAfe. 34
Merck Stonewall facility sulfur dioxide emissions for 2000-2001.
-------
- The 12-month total for facility-wide cri-
teria pollutant emissions from July 2000
to June 2001 was 199.02 tons, nearly an
87 percent reduction from the baseline
emissions. (See Figure 33.)
In addition to the facility-wide cap on total cri-
teria pollutants, subcaps were placed on
Merck's emissions of SO,, NOx, and PM-10.
Baseline levels for these criteria pollutants are
the average actual emissions during 1992 and
1993. The new subcaps will limit S02emis-
sions to 539 tons per year (a 25 percent reduc-
tion) and NOx emissions to 262 tons per year
(a 10 percent reduction). The PM subcap, ad-
justed based on the stack test of the new boil-
ers in accordance with the PSD permit, stands
at a level of 46 tons per year. Facility-wide
total and individual criteria pollutant air emis-
sions will be determined monthly.
- In its semiannual report, Merck reported a
12-month total of SO, emissions from July
2000 through June 2001 of only 18.79 tons,
a 97 percent reduction from baseline emis-
sions. (See Figure 34.)
- The 12-month total of NOx emissions from
July 2000 through June 2001 was 39.63
tons, an 86 percent reduction from baseline
emissions. (See Figure 35.)
- Merck reported a 12-month total of PM-
10 emissions from July 2000 through June
2001 of 6.25 tons, an 85 percent reduction
from baseline emissions. This reduction
in PM-10 emissions exceeded the expec-
tations outlined in the FPA. (See Figure
36.)
Merck - Nitrogen Oxides Emissions
July 2000-Juna 2001
February 2000-
January 2001
Emissions Cap
100 150 200 250 300
Tons per Year
Figure 35
Merck Stonewall facility nitrogen oxides emissions data for
2000-2001.
July 2000-June 2001
February 2000-
January 2001
Emissions Cap
Merck - Particulate Matter -10 Emissions
6.25
21.15
0 5 10 15 20 25 30 35 40 45
Tons per Year
"igure 36
Merck Stonewall facility PM-10 emissions data for 2000-2001.
The new PSD permit and associated caps be-
came effective on November 9, 2000, when
Merck reported that its facility-wide emis-
sions were below the caps described in the
PSD permit.
- Since November 2000, Merck has been al-
lowed to make changes to their processes
that could result in air emissions increases
without prior approval, as long as the emis-
sions remain below the caps. Additionally,
-------
the Stonewall plant is required, under the
FPA, to operate under the caps and increase
the frequency of their monitoring, record
keeping, and reporting if criteria pollutant
emissions trigger more frequent data-col-
lection requirements. Part of the project is
a comprehensive monitoring, record keep-
ing, and reporting system that increases in
stringency as actual emissions approach the
cap.
• Because of concerns expressed by stakehold-
ers about VOC emissions and the potential re-
duced visibility and increased vegetation
impacts caused by greater ozone formation,
Merck will assess air quality impacts on nearby
Shenandoah National Park if VOC emissions
reach certain specified levels. Because VOC
levels have remained well below baseline lev-
els, additional assessments have not been nec-
essary.
• Merck will continue to monitor facility-wide
air emissions. Merck submitted an annual
progress report on March 1, 2001, and a semi-
annual emissions report on August 31, 2001.
Benefits for the Environment
• The conversion to natural gas has reduced to-
tal criteria air pollutant emissions for the pow-
erhouse by approximately 1,300 tons per year.
The conversion has also virtually eliminated
lead emissions and reduced the emissions of
the hazardous air pollutants, hydrogen chlo-
ride, and hydrogen fluoride.
• The facility-wide cap will limit total emissions
of criteria air pollutants to levels 20 percent
below baseline levels, S02 emissions to levels
25 percent below baseline levels, NOx emis-
sions to levels 10 percent below baseline lev-
els, and particulate matter to levels
approximately equal to baseline levels. These
caps became effective on November 9, 2000,
when Merck notified VADEQ that its emis-
sions had been reduced below the caps. The
first 12 months of operation after the conver-
sion to natural gas resulted in an 87 percent
reduction of total criteria emissions.
• A comprehensive monitoring, record keeping,
and reporting program will increase in strin-
gency as actual criteria pollutant emissions ap-
proach the cap. This provides an incentive for
Merck to minimize air emissions.
• This XL project has the potential to improve
air quality and visibility in the Shenandoah
National Park and vegetation damage in the
park should be lessened by reducing SO, and
NO air emissions.
x
• Merck will assess the air quality impacts in
Shenandoah National Park if VOC emissions
reach specified levels.
Benefits for Stakeholders
• Stakeholders will have better access to envi-
ronmental information through Merck's com-
prehensive monitoring, record keeping, and
reporting program.
• Stakeholders will receive information on an
ongoing basis that enables them to evaluate
Merck's performance under the facility-wide
emission caps and the impact of incentives to
minimize facility air emissions.
• The Merck stakeholder group can participate
in periodic reviews of performance in meet-
ing limits set under Merck's PSD permit. The
stakeholder group will meet every five years
to evaluate the project's implementation and
to mutually agree on whether project changes
are needed.
Benefits for the Project Sponsor
• Merck expects to avoid millions of dollars
worth of potential production delays in the
competitive first-to-market pharmaceutical in-
dustry by eliminating repetitive permit re-
views.
• Merck is provided flexibility to make produc-
tion changes without first obtaining permitting
approval, as long as emissions remain below
capped levels.
-------
• The permit streamlined content requirements
of the application for Merck's Title V operat-
ing permit and compliance certification.
Information Resources: The information in this
summary comes from several sources, including
(1) the FPA for the Merck & Company, Inc., Stone-
wall Plant XL Project, December 15,1997; (2) the
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000; (3) Merck's Project XL Annual
Progress Report, March 1, 2001; (4) Merck's
Project XL: Semiannual Report, August 31,2001;
and (5) focus group discussions in December 1999
with representatives of EPA and the Merck Stone-
wall plant.
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J\A^-\^opo\ ifarv Wafef4
Reclamation District
o| G^eafe/ C-kicago
Final Project Agreement Signed August 30, 2000
Background
The Project Sponsor: The Metropolitan Water
Reclamation District (District) of Greater Chicago
is a publicly owned treatment works (POTW) that
treats wastewaters from domestic, commercial, and
industrial sources in Chicago and 126 surround-
ing communities. Located in Cook County, Illi-
nois, the District has maintained an industrial waste
pretreatment program for more than 30 years.
Through its industrial pretreatment program, the
District regulates process wastewater discharges
from approximately 535 significant industrial us-
ers (SIUs), including approximately 362 categori-
cal industrial users (CIUs) as of June 1, 2000. In
1996, EPA awarded the District the National Ex-
cellence Award for Pretreatment Programs in the
Large Category (greater than 100 SIUs).
The Experiment: During implementation of the
project, the District plans to redirect resources
currently allocated for certain regulatory obliga-
tions that add limited environmental value to other
programs that it believes potentially provide greater
environmental benefit within the District's pretreat-
ment program. The District primarily seeks to free
up additional resources by reducing the self-moni-
toring frequency and reporting for, and inspection
and monitoring of, small CIUs with good compli-
ance records. In addition, during project imple-
mentation, the District has a goal to limit the
detailed oversight information regarding SIUs in
their annual pretreatment program report to EPA
to only the population of SIUs that were found in
significant noncompliance (SNC) at any time dur-
ing the report year.
The saved resources from the program flexibility
described above would be reallocated within the
District to advance environmental protection. The
District aims to create strategic performance part-
nerships with industrial sector facilities meeting
the goals of the national strategic goals program
(SGP). The SGP establishes both facility-specific
and sector-wide performance goals that extend
beyond traditional compliance with environmen-
tal regulations. The strategic performance part-
nerships would develop and evaluate alternative
monitoring systems that would hopefully prove
superior to the current traditional monitoring sys-
tems. The District intends to begin addressing lo-
cal pollutants that have not been regulated, through
the development of toxic reduction action plans
(TRAP). The District also intends to revise the
pretreatment program annual report format to in-
clude detailed information regarding environmen-
tal performance not currently required.
The Flexibility: The District is requesting regu-
latory flexibility from EPA and the Illinois Envi-
ronmental Protection Agency (IEPA) from the
oversight requirements (i.e., inspection and sam-
pling) of the Clean Water Act's General Pretreat-
ment Regulations to regulate discharges from small
(de minimus) CIUs that have very low potential to
violate pretreatment standards and requirements or
adversely impact the operations of the district's
waste reclamation plants (WRPs) and the environ-
ment. This project will be implemented following
EPA's promulgation and IEPA's subsequent adop-
tion of a rule amending the National Pretreatment
Program regulations. On October 3, 2001, EPA
promulgated a rule amending the National Pretreat-
ment Program to allow POTWs that have com-
pleted the Project XL selection process, including
FPA development, to modify their approved local
Pretreatment Programs. These POTWs will be
allowed to modify their programs and implement
the new local programs as described in the FPA.
Other Innovations: (1) Alternative Effluent
Monitoring Systems: Strategic Performance Part-
nerships. The creation of strategic performance
partnerships would enable the District to further
work with demonstrated sector leaders to develop,
test, and implement alternative measurement sys-
tems demonstrating environmental performance.
These alternative measurement systems have the
potential to be more accurate and precise, allow-
ing for improved process performance and de-
creased loadings of regulated pollutants. Rather
than the traditional effluent discharge sampling,
the District will use statistical process control data,
-------
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collected by the SIU at critical points along its pro-
cess line, at frequent intervals. These data are used
to regularly track process performance and prod-
uct quality at the SIU and could also serve to as-
sess pretreatment performance and wastewater
quality. (2) Encouraging Pollution Reduction and
Water Conservation. Because of the oversight flex-
ibility of de minimus and non-significant CIUs,
other facilities that currently do not meet the crite-
ria for these classifications may implement pollu-
tion reduction and water conservation measures in
order to obtain de minimus or non-significant CIU
status. This may result in decreased loadings of
regulated pollutants into the WRPs.
The Superior Environmental Performance:
This project has the potential to achieve environ-
mental performance that is superior to the current
system. The reduced oversight of smaller CIUs
may provide incentives for facilities to reduce pol-
lutant loadings and water usage and improve fa-
cility performance; similarly, the opportunity to
participate in the strategic performance partner-
ships may serve as an incentive for sector indus-
tries to participate in the SGP. Regulatory
flexibility would allow the District to reallocate
currently committed resources to other activities
with greater potential for environmental benefit.
The TRAP program will identify and address cur-
rently unregulated pollutants of local concern.
Under TRAP, the District, EPA and IEPA will use
existing environmental data to identify priority
pollutants that are documented to be present in
quantities or concentrations that may be a risk to
the District's facilities or the ambient environment
but not currently subject to regulation. A greater
quality of water effluent will be achieved and the
District will be well prepared should these pollut-
ants become regulated in the future.
As part of this XL project, the District will include
in its newly formatted annual pretreatment program
report additional data about the quality of the
wastewaters being discharged and the quality of
the waters in the receiving surface water bodies.
The additional data and analysis may include up
to 18 performance measures not currently reported.
Progress in Meeting Commitments
(As of October 2001)
EPA has committed to proposing and promul-
gating a site-specific modification to the Clean
Water Act General Pretreatment Regulations
providing oversight and reporting flexibility
to the District.
- The final rule was published October 3,
2001.
• IEPA has committed to adopting the regula-
tory modifications of the federal rule.
Once the appropriate regulatory flexibility is
in place, the District will:
- Report on 18 performance measures not
currently included in the pretreatment pro-
gram annual report, which are listed be-
low.
1. Trends in mass loadings of metals and
other toxic and non-conventional pol-
lutants in POTW effluent; and com-
parisons to allowable levels in
National Pollutant Discharge Elimina-
tion System (NPDES) permits.
2. Trends in emissions of hazardous pol-
lutants to the air, particularly for vola-
tile pollutants from unit processes and
metals from incineration.
3. Trends in mass loadings of metals and
other toxic contaminants to POTW in-
fluent, as a total and, where possible,
divided into domestic, commercial, in-
dustrial, and storm contributions to the
total; and comparison to allowable
loadings as calculated during the
headworks analysis, where such analy-
sis is available.
4. Reductions in annual average metals
levels in biosolids, with an indication
of any trend towards or compliance
with the most stringent nationwide
biosolids standards.
-------
5. Percentage of compliance with
NPDES permit discharge require-
ments.
6. For each POTW, whether the POTW
is failing whole effluent toxicity dis-
charge criteria due to industrial
sources.
7. Percentage of compliance with non-
pathogen biosolids quality limits for
the management method currently
used, with sites divided into catego-
ries based on applicable regulations,
calculated as the number of samples
in compliance out of all samples (i.e.,
the average for that calendar year).
8. Percentage of compliance at each in-
dustrial user (IU) with categorical dis-
charge limits.
9. Percentage of compliance at each IU
with all permit discharge limits.
10. Percentage of IUs in compliance with
reporting requirements.
11. Number and percentage of IUs in SNC
for the current year that were also in
SNC for the previous year.
12. Whether an effective method is being
used to prevent, detect, and remediate
incidents of violations of the specific
prohibitions attributable to industrial
or commercial sources (e.g., fire, ex-
plosion hazards, fume toxicity, etc.).
13. Whether an effective procedure is be-
ing used to identify non-domestic us-
ers and to update the list of regulated
users.
14. Number of sample events conducted
by the Control Authority per SIU per
year, and percentage of all sample
events that were conducted by the
Control Authority.
15. Number of inspections per SIU per
year.
16. Whether the Control Authority has
site-specific, technically based local
limits, based on the most recent regu-
latory changes and latest NPDES per-
mit requirements; or a rationale for the
lack of such limits.
17. Whether the POTW or Control Au-
thority has significant activities or ac-
complishments that demonstrate
performance beyond traditional goals
and standards.
18. Whether or not the POTW has an ef-
fective public involvement program in
place.
- Identify which CIUs are eligible to be clas-
sified as de minimus or non-significant
CIUs; and
- Develop Strategic Performance Partner-
ships with facilities participating in the
SGP.
• In June 2001, after five months of collabora-
tion, the stakeholders selected mercury in ef-
fluent discharges, hexavalent chromium in air
emissions, nitrogen and phosphorus in efflu-
ent discharges, and dioxin, dibenzofurans, and
polychlorinated biphenyls in sludge as the non-
regulated pollutants for the TRAP initiative.
Benefits for the Environment
• The project expects to reduce the amount of
hazardous and toxic waste generated and re-
leased, decrease water and energy consump-
tion, decrease demand for raw materials, and
improve quality of influent, effluent, and
biosolids.
Benefits for Stakeholders
• Workers in industrial facilities may benefit
from decreased exposure to toxic materials if
they are phased out or treated in a more envi-
ronmentally friendly way.
-------
• CIUs that meet compliance and capacity cri-
teria will be subject to reduced self-monitor-
ing, reduced reporting, and fewer inspections.
Qualifying CIUs will also be issued non-ex-
piring Discharge Authorizations.
Benefits for the Sponsor
• With the flexibility, the District will be able to
shift limited resources from certain less pro-
ductive requirements, such as monitoring in-
dustries that have excellent or very good
records of compliance, to more proactive pol-
lutions reduction strategies.
• Reduced overall loading to the District sys-
tem will ease the burden on water treatment
and discharge, resulting in cost savings for the
District.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Metropolitan Water Reclamation
District of Greater Chicago, signed August 30,
2000; and (2) the Project XL Comprehensive Re-
port, Volume 2: Directory of Project Experiments
and Results, November 2000.
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M olex vUkACo^pora+ed
Final Project Agreement Signed August 8, 1998
Project Completed as of August 2000
Background
The Project Sponsor: Molex Incorporated is a
multinational company that operates 47 facilities
worldwide, manufacturing electroplating, metal
stamping, fiber optics, plastic molding, and other
products. The Molex project covers an electro-
plating facility in Lincoln, Nebraska.
The Experiment: Molex electroplates coatings of
nickel, copper, and tin and lead on substrate mate-
rials for a variety of manufacturing purposes. The
process generates large volumes of wastewater
containing metal contaminants, which are subse-
quently captured in wastewater treatment systems
and become a Resource Conservation and Recov-
ery Act (RCRA)-regulated hazardous waste.
Molex previously operated a wastewater treatment
system that combined the wastewater streams from
nickel, copper, and a tin/lead composite plating
processes. These waste streams were treated in a
single wastewater treatment process that generated
a hazardous multiple-metal waste material from
which only one of the metals could be recovered
with the rest disposed. By switching to a process
that segregates the wastewater streams from the
plant's multiple electroplating processes and treats
each one separately, Molex is able to recover metal
contaminants separately, reduce the amount of
metal disposed of, and reduce metal contaminant
levels in the effluents discharged from the facility's
wastewater treatment systems to the city's publicly
owned treatment works (POTW). Molex has re-
quested a variance from hazardous waste regula-
tions in order to reduce the costs of storing and
shipping these wastes and to increase the rate of
metals recovery from the multiple waste streams.
The Flexibility: EPA, pursuant to RCRA Section
3005(b), has authorized the State of Nebraska's
Department of Environmental Quality (NDEQ) to
carry out Nebraska's Hazardous Waste Manage-
ment Program in lieu of the federal program. Un-
der this authority, the NDEQ issued a variance to
Molex granting it a temporary exemption from the
classification as hazardous waste of segregated
sludges generated during wastewater treatment.
Without this variance, the sludge materials would
be subject to the NDEQ's generator requirements
for storage and shipment of hazardous wastes. By
obtaining approval from the NDEQ under RCRA
to classify its segregated process sludge as a "com-
modity-like" material rather than as a hazardous
waste, Molex can ship the sludges using common
carriers rather than hazardous waste haulers, who
are subject to additional RCRA regulations. Ad-
ditionally, Molex is permitted to ship the hazard-
ous materials on an as-needed basis, rather than
every 90 days, as is typically required for hazard-
ous waste.
On July 10, 2000, Molex requested a two-year
extension of the temporary variance, which had
remained in effect for two years and was set to
expire August 7, 2000. In the request for this ex-
tension, Molex noted that it is expanding the pro-
duction area of the plating department at the
Uplands facility. This expansion, Molex stated,
may offer an opportunity to continue to gather data
under a greater process flow. In response, on Au-
gust 2, 2000, EPA and NDEQ issued a six-month
extension of the variance. The additional six
months allowed Molex time to complete the final
report. Molex submitted the final report at the end
of 2000. The FPA for this project terminated in
August 2000; the company submitted a final re-
port in December 2000. In February 2001, NDEQ
granted an additional variance extension, not to
exceed 18 months.
The final data will be examined to determine the
effects that separate treatment of Molex's waste
streams have on metal content in wastewater ef-
fluents. Data gathered will also be examined to
demonstrate whether the segregated system pro-
duces a recyclable sludge with market value. Ul-
timately, data gained through this project will
provide the information necessary to assess
whether modifications to national or state perfor-
mance standards are possible.
The Superior Environmental Performance:
In the Molex project, the treatment of segregated
wastewater streams should result in at least a 50
percent reduction in mass loadings of metal con-
taminants in wastewater effluents, as well as in
-------
lower tin/lead composite sludge disposal costs be-
cause pure metal sludges can be sold directly to
processors. Molex is making a significant up-front
investment for longer-term benefit. The pure tin/
lead composite sludge does not require disposal
and thus, no disposal fee; however, the operational
and compliance costs of a segregated waste treat-
ment system are higher than those associated with
a single wastewater treatment process.
Progress in Meeting Commitments
(As of September 2001)
Overall, Molex has been successful in meeting its
environmental commitments under the project.
• Note about the baseline data: It is important
to note that sludge volumes between the com-
bined treatment process and the baseline seg-
regated treatment process are not strictly
comparable because the combined treatment
sludges were dried but the segregated treat-
ment sludges were not. Data from 1999 were
measured based on four Molex quarterly re-
ports, which covered project performance from
August 7, 1998, to August 7, 1999. Data from
2000 were measured based on four Molex
quarterly reports, which cover project perfor-
mance from August 8,1999, to August 7,2000,
and the final cumulative report from Molex.
- Molex estimated that the segregated treat-
ment system would generate a total of
71,328 pounds of sludge, but 1999 actual
generation rates based on the quarterly
reports indicate that actual sludge genera-
tion rates were 10.3 percent higher (78,709
pounds) than the estimated baseline for the
segregated system. In 2000, the total
amount of metals sludge generated was
112,498, a 58 percent increase over the
estimated baseline. Based on the quarterly
reports, it is estimated that the segregated
treatment system has resulted in an aver-
age 65 percent reduction in the concentra-
tion of copper, tin and lead, and nickel in
the effluent discharged by the POTW in
1999 and an average 76 percent reduction
in 2000.
Molex - Copper Sludge Generation Rates
For the Segregated Treatment System
2000 Actual
1999 Actual
Baseline Estimate
35,200
21,242
13,376
10,000 20,000 30,000 40,000 50,000
Pounds of Copper Sludge
T-igure 37
Copper sludge generation rates for 1999 and 2000.
Molex - Nickel Sludge Generation Rates
For the Segregated Treatment System
2000 Actual
1999 Actual
Baseline Estimate
60,684
48,928
45,089
0 10,000 20,000 30,000 40,000 50,000 60,000 70,000
Pounds of Nickel Sludge
T~igure 38
Nickel sludge generation rates for the segregated treatment
system.
-------
Molex estimated that 13,376 pounds of
copper sludge would be generated with the
segregated treatment system. However,
1999 actual generation rates were 59 per-
cent higher (21,242 pounds) than the esti-
mated baseline. For 2000, Molex has
generated 35,200 pounds of copper sludge,
a 163 percent increase from the baseline
data. Based on the quarterly reports, and
since this sludge is recycled, it is estimated
that the use of the segregated system has
resulted in a 66 percent reduction in cop-
per concentrations in the POTW's efflu-
ent in 1999 and an average 76 percent
reduction in 2000, compared to baseline
(see Figure 37).
Molex estimated that 45,089 pounds of
nickel sludge would be generated with the
segregated treatment system. However,
1999 actual generation rates were 8.5 per-
cent higher (48,928 pounds) than the esti-
mated baseline. In 2000, a total of 60,694
pounds of nickel sludge have been gener-
ated. Based on the quarterly reports, and
since this sludge is recycled, use of the seg-
regated system has resulted in decreased
nickel concentrations in the POTW's ef-
fluent by 67 percent in 1999 and 82 per-
cent in 2000 (see Figure 38).
Molex estimated that 12,863 pounds of tin
and lead sludges would be generated with
the segregated treatment system. Actual
generation rates in 1999 were 34 percent
lower (8,539 pounds) than the estimated
baseline. However, in 2000, Molex has
generated 16,614 pounds of tin and lead
sludges. Based on the quarterly reports,
and since this sludge is recycled, use of
the segregated system in 1999 has resulted
in estimated decreased concentrations of
tin (98 percent) and lead (29 percent) in
the effluent being discharged by the
POTW. In addition, in 2000 the use of the
segregated system has resulted in esti-
mated decreased concentrations of tin (98
percent) and lead (44 percent) in the ef-
fluent (see Figures 39 and 40).
Molex - Tin/Lead Sludge Generation Rates
For the Segregated Treatment System
2000 Actual
1999 Actual
Baseline Estimate
16,614
8,539
12,863
10,000 20,000 30,000 40,000 50,000
Pounds of Tin/Lead Sludge
l-igufe 39
TinAead sludge generation rates for the segregated
treatment system.
Molex - Estimated Reductions in Metal
Concentrations in Effluent
Copper 1999 Actual
Copper 2000 Actual
Nickel 1999 Actual
Nickel 2000 Actual
Tin 1999 Actual
Tin 2000 Actual
Lead 1999 Actual
Lead 2000 Actual
66%
79%
67%
82%
98%
98%
29%
44%
_l_
-J
0 20 40 60 80 100
Percent Reduction of Metals Concentrations
Figure 40
Estimate reductions in metal concentrations in effluent.
-------
- Molex estimated that it would be able to
recycle 71,328 pounds of metals sludges
in a year. However, the quarterly reports
indicate that between August 1998 and Au-
gust 1999, a total of 78,709 pounds of
sludge were sent to the recycler, 10.3 per-
cent more than estimated. In addition, in
2000, a total of 134,988 pounds of sludge
were sent to the recycler, 89 percent more
than expected (see Figure 41).
• In January 2001, Molex requested a second
extension of the temporary variance that had
been granted on August 2,1998, and extended
on August 2, 2000. On February 6, 2001, the
NDEQ extended the variance for a period of Figu>.e 41
time not to exceed 18 months. Volume of metals recovered from sludge shipped to recycler.
Benefits for the Environment
• The amount of metals discharged to Lincoln,
Nebraska's POTW have been reduced.
• A total of 213,697 pounds of sludge have been
sent to the recycler since project inception.
This direct recycling of mono-metal-bearing
sludges by reclamation facilities has decreased
the need for mining of ores and the use of other
virgin materials. In addition, Molex noted that
the variance allows them to make two truck
shipments of sludge per year, rather than 12
partially full truck shipments, reducing fuel
consumption and emissions.
Benefits for Stakeholders
• Stakeholders were involved in the environmen-
tal design and impact assessment of the XL
project and were given opportunity to partici-
pate fully in project development.
• The public has access to periodic reports sub-
mitted by Molex to EPA through the Project
XL Web site.
Benefit for the Project Sponsor
Molex - Volume of Metals Sludge Shipped to Recycler
2000 Actual
1999 Actual
Baseline Estimate
78,709
71,328
134,988
0 25,000 50,000 75,000 100,000 125,000 150,000
Pounds per Year
Molex has been allowed to handle the
nonprecious mono-metals-bearing sludges as
precious metals-bearing sludge and not as a
-------
RCRA hazardous waste. This results in a re-
duced cost of storing and shipping the sludge.
Molex has estimated that this new system has
saved the company approximately $45,320 a
year over the unsegregated treatment technol-
ogy-
Information Resources: The information in this
summary comes from several sources: (1) the De-
cember 2000 Project XL Progress Report—Molex
Incorporated; (2) focus group discussions in De-
cember 1999 with representatives of the Molex
Company, EPA Regional and Headquarters staff,
World Resources (a national environmental group),
Nebraska Department of Environmental Quality,
and the City of Lincoln; (3) Molex Project XL
quarterly reports from August 1998 through Sep-
tember 2000; (4) Final Report for Project XL at
Molex, 2000; and (5) the 2000 Project XL Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
-------
y\)arm0anseft Bay
Commission
Final Project Agreement Signed September 25, 2000
Background
The Project Sponsor: Narragansett Bay Commis-
sion (NBC), a publicly owned treatment works
(POTW), operates the wastewater collection and
treatment system for the greater Providence, Rhode
Island, area, including wastewater discharges from
approximately 360,000 people and 8,000 busi-
nesses. NBC has two treatment plants, the Field's
Point wastewater treatment plant and the Bucklin
Point wastewater treatment plant. Since initiating
its industrial pretreatment program, NBC has re-
duced its metal and cyanide loadings to its Field's
Point treatment plant headworks by more than 94
percent. Through its high level of performance,
NBC has received EPA's Pretreatment Excellence
Award in 1990 and 1998. In 1994, NBC devel-
oped two regulatory/pollution prevention integra-
tion programs, NBC Metal Finishing 2000 and
CLEAN P2 Regulatory Relief. The programs test
new regulatory approaches to improve environ-
mental compliance by the local industrial commu-
nity.
The Experiment: NBC permits and regulates
approximately 100 metal finishing companies.
Through Project XL, NBC would like to improve
environmental performance of a select number of
metal finishing companies by redirecting pretreat-
ment regulatory efforts away from 10 metal fin-
ishing companies that have demonstrated superior
environmental performance records (Tier 1 facili-
ties) and focus regulatory efforts on 10 companies
with lower performance records (Tier 2 facilities).
Under this program, Tier 2 facilities would receive
technical assistance or pollution prevention audits
to help them move toward compliance. The pri-
mary goal of this project is to demonstrate that
through more efficient use of existing resources
and staff time, NBC can achieve measurable im-
provements in environmental performance. The
project's progress and success in meeting its goal
will be measured by reductions in pollution and
increased compliance at Tier 2 facilities.
The Flexibility: NBC requests modification of
the pretreatment regulations for up to 10 metal fin-
ishing companies that have established a history
of exemplary environmental performance and com-
pliance as an incentive to maintain their perfor-
mance. NBC also requests flexibility from the
Rhode Island Department of Environmental Man-
agement (R1 DEM) to reduce inspection frequen-
cies and eliminate some monitoring requirements
for Tier 1 facilities. This will enable NBC to refo-
cus its resources toward increased pollution pre-
vention audits, technical assistance, and
compliance inspections on Tier 2 facilities.
Other Innovations: (1) Providing Incentives for
Exceeding Compliance. The NBC pretreatment
XL project will promote pollution prevention
through several activities including identifying
source reduction opportunities, process optimiza-
tion, and input substitution. By reallocating re-
sources from Tier 1 to Tier 2 facilities, NBC hopes
to re-direct its resources to improve compliance
as well as achieve measurable reductions in pollu-
tion that go beyond what is required by regulation.
(2) Transferability to Other POTWs. This project
contains several elements that will be transferable.
If successful, the pollution prevention approaches
and management practices that occur as a result of
the refocusing of resources may be readily trans-
ferable to POTWs and industries in many other
areas. (3) Model for EPA Regulatory Reform. EPA
is in the process of streamlining the general pre-
treatment regulations (Federal Register Vol. 63, No.
140 July 22, 1999, pages 39564-39605). Informa-
tion gathered as part of this XL project may be
used to inform current streamlining efforts.
The Superior Environmental Performance: The
primary goal of this XL project is to demonstrate
that through more efficient use of existing re-
sources, NBC can achieve measurable improve-
ments in the environmental performance levels of
Tier 2 companies while encouraging and assisting
Tier 1 companies to maintain or possibly improve
their current level of superior environmental per-
formance. By focusing more resources on compa-
nies contributing a greater share of the pollutants,
the NBC Pretreatment XL program seeks to fur-
ther reduce metals loadings to the two NBC treat-
ment facilities.
-------
One of NBC's goals is that this XL project will
result in several areas of pollution reduction. Over
the six years of this project, NBC proposes that
the Tier 2 facilities will reduce their process water
usage by 25 percent, total metals (which include
the regulated metal finishing pollutants along with
arsenic and selenium) loadings in their effluent
discharge by 25 percent, and their generation of
F006, Resource Conservation and Recovery Act-
regulated, waste by 25 percent. Progress towards
these goals will be evaluated against one year of
baseline information collected by NBC for the year
preceding selection as a Tier 2 facility. NBC would
then compile annual information and report
progress toward the 25 percent reduction goals in
each annual report. NBC also expects that Tier 2
facilities will improve their compliance rate by 75
percent.
Progress in Meeting Commitments
(As of October 2001)
• EPA has committed to promulgating a site-spe-
cific rule that would modify 40 CFR Part 403
pretreatment regulations and define the con-
ditions of Tier 1 and Tier 2 involvement in the
NBC XL project.
- EPA promulgated a federal rule on Octo-
ber 3, 2001, amending the National Pre-
treatment Program regulations to allow
POTWs that have completed the Project
XL selection process, including FPA de-
velopment, to modify their approved lo-
cal pretreatment programs (65 FR 59738).
The POTW will be allowed to modify its
programs and implement the new program
described in the FPA.
• RI DEM has committed to developing and pro-
mulgating a state site-specific rule that incor-
porates the terms of the federal rule. In
addition, RI DEM has committed to:
- Reissuing NBC's Rhode Island Pollutant
Discharge Elimination System permit to
incorporate the state rule as discussed
above; and
- Reviewing NBC pretreatment program re-
visions in a timely manner and approve
where appropriate so NBC may undertake
the activities described in this FPA.
• NBC is awaiting RI DEM regulatory approval
to implement the proposed plan. Once given,
NBC intends to:
- Reallocate any resources saved from less
oversight of Tier 1 companies to increas-
ing oversight of the selected Tier 2 com-
panies and focusing attention on other
areas of environmental concern;
- Increase sample screening events for each
Tier 2 company from two per year to four
per year;
- Perform an annual pollution prevention au-
dit at each of the Tier 1 and Tier 2 compa-
nies;
- Work with the Tier 2 companies so they
may achieve a 25 percent reduction in
water usage, F006 waste generation, and
total metal concentrations;
- Work with the Tier 2 companies so they
may achieve a 75 percent increase in com-
pliance;
- Supply summary reports on project
progress;
- Revise NBC's pretreatment program, if
necessary, relative to the Tier 1 facilities;
and
- Assist each Tier 1 company with the de-
velopment and implementation of a mul-
timedia self-audit, environmental
compliance plan and audit procedure.
Benefits for the Environment
• The NBC XL project will result in more com-
panies utilizing pollution prevention in place
of end-of-pipe treatment; production tech-
niques that use less water; lower Toxic Release
Inventory emissions; less hazardous waste gen-
eration by participating companies; fewer over-
all industrial user violations; more companies
-------
participating in NBC's pollution prevention
technical assistance efforts and programs; and
higher-quality wastewater discharges.
Benefits for Stakeholders
• NBC will reduce the self-monitoring require-
ments for Tier 1 companies, which means that
less time and money will be spent on monitor-
ing by these companies.
• Cost savings employed by the elimination or
reduction of the frequency for the need to
monitor for pollutants not present in a waste
stream can be used to increase the frequency
of tests made on problematic constituents,
employee training, and/or pollution prevention
initiatives.
• Comments from all other organizations and
individuals are welcomed throughout the
stakeholder process and active stakeholders
will receive semiannual updates on progress
of the XL project from NBC. Updates will
also be available on EPA's Web site.
Benefits for the Project Sponsor
As part of this project, NBC will reduce its
regulatory oversight (i.e., compliance inspec-
tions) for the up to 10 Tier 1 metal finishing
companies.
• Time and effort saved by NBC regulatory per-
sonnel conducting fewer inspections of com-
panies that meet appropriate Project XL
criteria will allow for more focused attention
on compliance inspections, monitoring and
regulating more problematic (Tier 2) compa-
nies.
Information Resources: The information sources
used to develop this progress report include: (1)
the FPA for Narragansett Bay Commission, signed
September 25, 2000; (2) the EPA Office of Waste-
water Management National Pollutant Discharge
Elimination System Web page (http://
cfpubl.epa.gov/npdes/)-, and (3) the 2000 Project
XL Comprehensive Report, Volume 2: Directory
of Project Experiments and Results, November
2000.
-------
y\)aticmal ^A.ercmautics
c\v\c1 Space
7A.dmims+m+iorv Wkite.
Sahds Test Facility
Final Project Agreement Signed September 22, 2000
Background
The Project Sponsor: The National Aeronautics
and Space Administration (NASA) White Sands
Test Facility (WSTF) is located approximately 18
miles northeast of Las Cruces, New Mexico and
operates as a field test installation for the NASA
Lyndon B. Johnson Space Center in Houston,
Texas. The facility also provides test service and
support for the Department of Defense, Depart-
ment of Energy, private industry, and foreign gov-
ernment agencies. The primary WSTF mission is
to develop, qualify, and test the limits of space-
craft propulsion systems and subsystems. The in-
stallation also operates several laboratory facilities
that conduct compatibility and material test proto-
cols.
The Experiment: NASA WSTF proposes to con-
solidate, streamline, and simplify the collection,
management, reporting, and archival of environ-
mental compliance data required by EPA and sev-
eral different bureaus in New Mexico's
Environment Department (NMED). This project
provides a unique opportunity for EPA and NMED
to construct, implement, test, and operate a bureau-
wide reporting system that will provide regulatory
reports and supplemental information on a Web-
based information management and regulatory re-
porting system. This XL project can be
characterized by six primary elements: regulatory
relief and flexibility; CD-ROM submittal and Web
page construction; e-mail submittal notifications;
public access section; testing, technical training,
and permit modification phase-in; and graphics
interface and archival abilities.
NASA estimates that cost savings will be immedi-
ately achieved after implementation of this system
through reduction of paper, postage, and person-
nel requirements. Cost savings associated with
these benefits will be redirected to site-specific
projects during the implementation of the plume-
front remediation system and its associated exten-
sive well drilling effort. The primary benefit of
redirecting additional funding for the plume-front
capture and source area remediation is additional
resources to ensure timely completion of the
project. Additionally, personnel resources can also
be redirected to active waste minimization pro-
grams that will promote site-wide affirmative pro-
curement, recycling, and proactive environmental
management system implementation. Specific cost
savings are displayed in Table 13.
The Flexibility: The proposed Web-based system
will not eliminate any regulatory reporting require-
ments, but only modify the current format, deliv-
ery method, and archival procedures. In this
project, NASA WSTF requests regulatory flexibil-
ity from applicable existing EPA and NMED re-
porting regulations that specify submission of a
paper report or written signature. Specifically,
NASA is seeking regulatory flexibility in order to
electronically report the following:
• Allow the electronic submission of the annual
Post-Closure Care written reporting require-
ments issued by the NMED Solid Waste Bu-
reau as specified in Permit No. 8800019434-2.
• Allow the electronic submission of permit
modification requests as specified by 40 CFR
§270.42. This regulatory relief will include
the ability to electronically transfer the signa-
tory to permit applications and report require-
ments of §270.11.
• Allow the electronic submission of quarterly
and semiannual reports as specified by NMED
Groundwater Bureau Discharge Plans DP-392,
DP-697, DP-584, and DP-1170.
• Allow the electronic submission of regulatory
reports as specified by all sections of Air Qual-
ity Control Permit No. 329-M-1.
• Allow the electronic transfer of groundwater
monitoring data and status reports from the 700
Area Landfill as required by the Closure and
Post-Closure Care Plan issued by the NMED
Solid Waste Bureau.
-------
Table *13: 1~Vojec+ed Oosts and Be
refits for /\jy\sy\
Mndet* Project .X-L
Item
Quantity
Cost Saving
Tinie
Personnel
4,000 Hours'
$140,000"
Annually
White Paper
N/A
$1,000
Annually
Copy Center
1,000 Hours"'
$35,000
Annually
Postage
N/A
$500
Annually
Request for Supplemental
Information and Notice
of Deficiencies
To Be Determined
Approximately
$10,000
Annually
Total Annual Cost Savings
$186,500
Five-Year Estimated Cost Savings
$932,500
Approximately two full-time employees' labor per year.
Based on loaded average labor cost of approximately $35/hour.
""Approximately one half-time employee per year.
• Allow the electronic transfer of progress re-
ports, data, and supplemental information re-
garding the plume-front remediation system to
the Groundwater Bureau and Hazardous and
Radioactive Materials Bureau.
• Minimize the hard copy archival requirements
of the §3008(h) Consent Order, the Post-Clo-
sure Care Permit, and the Resource Conserva-
tion and Recovery Act Hazardous Waste
Operating Permit by allowing recordable CD-
ROM storage of archive data.
• Allow the electronic submission of the
§3008(h) regulatory requirements for written
monthly status reports currently submitted to
the Secretary in triplicate.
Other Innovations: Implementing a Web-based
Information Management and Regulatory Report-
ing System. This Web-based information manage-
ment and regulatory reporting system will save
resources, including document preparation time,
white paper usage, and triplicate reproduction re-
quirements. A Web-based information manage-
ment system will have several benefits over the
existing reporting system, which is largely paper-
based. Web-based information management will
provide more real-time, user-friendly data. This
will enhance communications with other agencies
by providing immediate access to detailed envi-
ronmental compliance information, including
graphical illustrations of current conditions, access
to the groundwater monitoring database system,
and an electronic archive of historical documenta-
tion. 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.
The Superior Environmental Performance:
To achieve superior environmental performance,
this project seeks to do the following:
• Provide real-time desktop access to environ-
mental compliance report deliverables and as-
sociated data;
• Consolidate multi-bureau reporting require-
ments into one system;
• Provide public access to encourage participa-
tion in federal facility compliance activities;
• Increase intrabureau personnel communication
and encourage comprehensive review of data
by allowing desktop access to data;
-------
• Provide graphical presentations to increase
visualization of WSTF conditions and data
interpretations and enhance environmental
management;
• Archive data that can be easily accessed for
determinations of past results and comparisons
to current conditions;
• Eliminate hard copy reports in triplicate (some
documents require five copies); and
Ensure the project is simple and easily trans-
ferable to other federal facilities and private
sector entities throughout the United States
wishing to pursue a similar type of system.
Progress in Meeting Commitments
(As of August 2001)
• EPA committed to initiate a rule-making ef-
fort to provide appropriate legal mechanisms
to initiate the project and allow NMED and
NASA to implement the project.
- The Final Project Rule (Phase I) is await-
ing EPA Headquarters approval.
- Although the project rule is pending,
NASA WSTF is currently submitting the
monthly groundwater activity report to the
NMED Hazardous Waste Bureau (HWB)
on CD-ROM. The personnel at HWB have
stated that the electronic format of the
monthly report is superior to the previous
hard copy submittals and that it provides
monthly data in an organized, simplified,
and easily reviewed format.
• NASA committed to ensuring that on-site train-
ing regarding electronic deliverables is pro-
vided to NMED personnel by trained
information technology specialist WSTF per-
sonnel.
- NASA has provided NMED HWB staff
with training on CD-ROM reporting for-
mat and usage instructions. Additional
training is pending approval of rule mak-
ing.
Benefits for the Environment
• Cost savings achieved as a result of this project
will permit funding to be redirected to site-
specific projects, such as the implementation
of the plume-front remediation system.
• With increased visualization of WSTF condi-
tions and data interpretations made possible
from data portrayed graphically, environmen-
tal management of the testing facility and the
plume-front remediation will be enhanced.
Benefits for Stakeholders
• The online reporting system will provide EPA,
NMED, and the public with improved access
to up-to-date regulatory information, scientific
data, and analytical tools.
• Improved access to regulatory information,
scientific data, and analytical tools will allow
for more accurate environmental information
trading between NMED bureaus.
Benefits for the Project Sponsors
• Cost savings through the reduction of person-
nel requirements, white paper usage, copy cen-
ter fees, and postage will be redirected to
support site-specific projects (i.e., plume-front
remediation system).
• By allowing electronic submission, this project
will simplify the transfer of progress reports,
data, and supplemental information regarding
plume-front remediation system.
Information Resources: The information sources
used to develop this progress report include: (1)
the Final Rule adopted by EPA on September 22,
2000, and (2) the Project XL 2000 Comprehensive
Report, Volume 1: Directory of Regulatory, Policy;
and Technology Innovations, and Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
-------
y\!evv England
tArviversi+ies'
La bo rato ri es
Final Project Agreement Signed September 28, 1999
Background
The Project Sponsor: Boston College, the Uni-
versity of Massachusetts-Boston (UMass-Boston),
and the University of Vermont (UVM) make up
the New England Universities' Laboratories XL
consortium. The management and disposal of
chemical waste from laboratories is a significant
issue for the universities; laboratory waste man-
agement accounts for the most substantial expense
for their environmental, health, and safety pro-
grams (see Figures 42 and 43). Boston College,
with more than 13,000 students, has approximately
130 research and teaching laboratories and is clas-
sified as a small quantity generator under the Re-
source Conservation and Recovery Act (RCRA).
UMass-Boston, with over 12,000 students, and
UVM, with 10,000 students, are considered by EPA
to be large quantity generators (LQGs). EPA con-
siders UVM, which manages nearly 600 labs, a
LQG because it generates more than 1,000 kilo-
grams (2,200 pounds) of RCRA hazardous waste
in a single month (UVM also has a permitted stor-
age facility). Under a different part of the regula-
tion, UMass-Boston, with over 100 labs, is
classified as an LQG because it surpasses the 1
kilogram (2.2 pound) per month threshold for gen-
eration of acutely hazardous waste.
The Experiment: The Universities' Laboratories
project intends to test the integration of RCRA
hazardous waste regulations with Occupational
Safety and Health Act (OSHA) regulations by re-
quiring that the universities develop a plan similar
to the OSHA-required Chemical Hygiene Plan
(CHP). As a result of the harmonization of the
OSHA CHP and the RCRA-oriented Laboratory
Environmental Management Plan (EMP), the new
system will include best management practices to
actively encourage chemical reuse and recycling,
enhance conformance with internal policies and
procedures, increase efficiency, and better educate
laboratory professionals and researchers. This
T*iguce 42
Laboratory waste awaiting collection.
T~igu>*e 43
Chemical storage in a university laboratory.
performance-based system is developed around a
Laboratory Environmental Management Standard,
which defines the performance-based criteria for
the effective management of laboratory wastes. To
achieve the objectives outlined in the Laboratory
Environmental Management Standard, the univer-
sities are testing a two-part regulatory model that
includes (1) Minimum Performance Criteria for the
management of laboratory wastes and (2) the de-
velopment of a Laboratory EMP, which is a docu-
ment that describes how each university will
conform to the Environmental Management Stan-
dard and the Minimum Performance Criteria. The
new system is expected to provide a better man-
agement approach for research laboratories and to
result in increased pollution prevention while still
ensuring protection of human health and the envi-
ronment.
The Flexibility: EPA published a new site-spe-
cific rule that creates a pilot performance-based
system for managing laboratory waste at these three
universities. This new Laboratory Environmental
-------
Management Standard defines criteria for the ef-
fective management of laboratory waste and in-
corporates requirements detailing the
organizational responsibilities and the training re-
quirements of each participating university. EPA
and the environmental agencies for Massachusetts
and Vermont are providing the universities with a
temporary conditional deferral from two specific
RCRA regulations dealing with Hazardous Waste
Determinations and Satellite Accumulation Pro-
visions. Under the XL rule, participating univer-
sities formally defer the hazardous waste
determination from the laboratory to a central on-
site location. This should allow the universities'
environmental health and safety professionals to
more effectively manage the laboratory waste at
the institutional level and thus increase reuse and
recycling opportunities. Under the XL rule, the
permissible time for waste pickups when labora-
tory waste held in the laboratories reaches 55 gal-
lons is extended from just 3 to 30 days. This
flexibility allows for a more coordinated and effi-
cient pickup and delivery system, which frees up
staff time and prevents many of the compliance
problems associated with unscheduled, time-criti-
cal pickups.
The Superior Environmental Performance:
The environmental benefits of this XL project are
broadly defined in four categories: (1) risk reduc-
tion through the use of a "hazardous chemicals of
concern" (HCOC) inventory and periodic labora-
tory inspections; (2) pollution prevention, includ-
ing laboratory waste reduction, reuse, and
redistribution; (3) enhanced environmental aware-
ness of laboratory workers as measured by an an-
nual survey; and (4) improved conformance with
university waste management policies and proce-
dures. By offering regulatory flexibility to the
participating universities in conjunction with the
EMPs, EPA, the Massachusetts Department of
Environmental Protection (MADEP), and the Ver-
mont Department of Environmental Conservation
(VTDEC) are evaluating the effectiveness of of-
fering flexibility in waste determination and accu-
mulation time in order to encourage the more
efficient management of hazardous waste at the
university level as well as recycling, reuse, and
pollution prevention efforts at universities. The
information that will be gained on the project's
environmental benefits may be used by EPA to
develop a framework to address the potential trans-
ferability of this type of regulatory flexibility to
university laboratories at large.
Progress in Meeting Commitments
(As of August 2001)
• Each university committed to complete a
baseline report of current laboratory waste col-
lection and disposal practices, the amount of
waste generated and disposed of by each uni-
versity, a HCOC inventory, and a survey of
laboratory workers' environmental knowledge.
- The universities completed the baseline as-
sessment on June 28, 2000.
- UVM completed its HCOC survey on
March 31, 2001. UMass Boston is devel-
oping a tracking system for a campus-wide
inventory/HCOC, to be completed by
January 2002. Boston College has deter-
mined that using the full chemical inven-
tory does not meet the needs for the HCOC
survey and has been in the process of com-
pleting its HCOC list and will incorporate
HCOC surveys into refresher training dur-
ing September and October 2001. The
initial risk evaluation survey of the three
universities was completed spring 2000.
- All three participants have completed two
rounds of surveys of laboratory workers.
• EPA committed to promulgating a site-specific
rule providing the legal mechanism for pilot-
ing the new environmental management sys-
tem in the FPA.
- The final rule was published in the Fed-
eral Register on September 28, 1999. The
rule, which applies only to the three par-
ticipating universities, expires on Septem-
ber 28, 2003.
• The State of Vermont committed to promul-
gating a state-specific rule through revisions
to the Vermont Hazardous Waste Management
Regulations covering the participation of
UVM.
-------
Xable 14:
-------
- Revisions to the Vermont Hazardous
Waste Management Regulation became ef-
fective on March 28, 2000. Until the rule
expires, September 20, 2003, UVM is not
subject to the requirements of Sections 7-
202,7-301,7-303,7-305(b), and 7-310 of
the Regulations.
The State of Massachusetts committed to pro-
mulgating a state-specific rule that incorporates
the terms of the Federal Rule within 18 months
from the date that the Federal Rule is final-
ized.
- MADEP finalized a state-specific rule in
May 2001, allowing the universities to
proceed with the project with the increased
regulatory flexibility under 310 CMR
30.355, 30.501, 30.601, and 30.801.
Each university, working in collaboration with
the agencies, committed to develop a Labora-
tory EMP within six months of the effective
date of the FPA. This plan includes policies,
procedures, and practices consistent with the
Minimum Performance Criteria and the Labo-
ratory Environmental Management System
Regulations at 40 CFR part 262, Subpart J.
EPA committed to review and comment on the
EMPs within 30 days of the receipt and
VTDEC committed to review and approve or
disapprove the EMP for UVM.
- The agencies reviewed and commented on
the draft EMPs in March and April of
2000, and final comments for Boston Col-
lege and UMass-Boston were provided in
New England Universities' Laboratories -
University of Massachusetts-Boston:
Laboratory Waste Generation
2000 Data
Goal
line (1999)
4,928.34
5,027
5,585
4600 4800 5000 5200 5400 5600 5800
Tons per Year
T-igu^e 44
UMass-Boston laboratory waste generation.
New England Universities' Laboratories -
Boston College:
Laboratory Waste Generation
Baseline (1999)
20,000 25,000 30,000 35,000 40,000
Tons per Year
T-igu^e. 45
Boston College laboratory waste generation.
New England Universities' Laboratories -
University of Vermont:
Laboratory Waste Generation
Baseline (1999)
30,000 32,000 34,000 36,000 38,000 40,000
Tons per Year
T-'igwre ^6
University of Vermont laboratory waste generation.
"Table 15: Reduction of /vnnwal Ceneratio^i of .Laboratory Wastes
Boston College
UMass-Boston
UVM
Baseline (1999)
25,269 pounds
5,585 pounds
36,156
pounds
2000 Data
38,754 pounds
4,928.34 pounds
38,269
pounds
(Percent change)
(+57%)
(-11.76%)
(+4%)
Goal
22,742 pounds
5,027 pounds
32,549
pounds
(Percent change)
(-10%)
(-10%)
(-10%)
-------
May. Boston College implemented its
EMP as of September 1, 2000. UMass-
Boston implemented its EMP on October
6, 2000. UVM's EMP was approved by
VTDEC in December 2000 and was imple-
mented as of January 2001.
Each university committed to provide to its
laboratory workers initial training and infor-
mation on the EMP and to continue training
throughout the life of this laboratory XL
project.
- Training at Boston College and UMass-
Boston began in fall 2000. UVM initiated
training in March 2001. Training is an
ongoing process.
Each university will be responsible for collect-
ing data and monitoring its environmental per-
formance using the Environmental
Performance Indicators (EPIs) created for this
XL project, which will be reviewed by EPA
and each university's individual stakeholder
groups (see Table 14). Each university will
also take appropriate steps to evaluate com-
pliance and address any nonconformance
within its Laboratory EMP within 12 months
of the effective date of this FPA,
- Monitoring began in fall 2000. A First
Year Status Update was submitted Decem-
ber 28, 2000. The complete First Year
Progress Report was submitted June 28,
2001. The reports are available at http://
www.c2e2.org.
The Laboratory XL project commits the uni-
versities to achieve better results, with the
goals of 10 percent reduction in waste from
the baseline (see Table 15).
- In 2000, UMass-Boston decreased their
annual generation of waste by nearly 12
percent, surpassing the 10 percent reduc-
tion goal. (See Figure 44).
- Waste generation at Boston College in-
creased by 57 percent in 2000. (See Fig-
ure 45). It is estimated that this increase
is due to an increase in waste generation
by the Chemistry Department. On aver-
age, the Chemistry Department generates
96 percent of all laboratory waste at the
college. There are a few factors that could
account for increases in waste generation
by the Chemistry Department. For ex-
ample, in 2000 several laboratories in the
Chemistry Department were moved
(thereby generating additional waste from
laboratory cleanouts); two laboratories
started doing more wet chemistry; and the
number of laboratory workers (graduate
students, post-doctoral fellows, and under-
graduate students) increased.
- Laboratory waste at UVM increased by 4
percent in 2000, primarily due to labora-
tory cleaning and disposal of old chemi-
cals. (See Figure 46).
- The total quantity of 1 aboratory waste gen-
erated at each university reflects the vary-
ing types of research conducted at the
different institutions, the different types
and sizes of laboratory rooms, and the dif-
ferent approaches to waste management.
- It is important to note that the defined pol-
lution prevention goals in the FPA were
intended to be reasonable targets. Because
of the great variability in research activity
from year to year, and the realities of the
research culture and grant cycles, it is dif-
ficult to commit to aggressive, quantifi-
able reductions in laboratory wastes. The
project seeks to demonstrate superior en-
vironmental performance through a clear
pattern of pollution prevention, compli-
ance and enhanced environmental aware-
ness.
Another goal in this XL project is to achieve
20 percent increase in reuse of redistribution
of chemicals from measured baseline. Cur-
rently, less than 1 percent of all laboratory
waste produced in university labs is estimated
to be reused.
- All three universities have the infrastruc-
ture in place to begin collecting and redis-
tributing laboratory waste for reuse.
-------
Although the three universities have pro-
moted reuse training and started collect-
ing waste for potential reuse, institutional
redistribution has not yet begun.
Benefits for the Environment
• Increased awareness by laboratory staff and
students of the importance of handling haz-
ardous chemicals, reducing chemicals, and
properly disposing of chemicals may result in
more efficient use, and reuse, of laboratory
chemicals. The project seeks to enhance both
the safety and environmental aspects of chemi-
cal management at university laboratories.
Through better chemical management coupled
with pollution prevention, environmental im-
pacts are expected to be reduced.
• Through inventory and self-inspection activi-
ties, laboratories are gaining a better under-
standing of the types of highly hazardous
chemicals that are being used and disposed.
As a result of this increased awareness within
the lab, the institutions can, over time, accom-
plish their goal of reducing HCOC use and in-
creasing chemical reuse with the associated
environmental, safety, and health benefits of
reduced risk of fewer hazardous chemicals and
greater control on those hazardous chemicals
that remain.
• The universities will reduce the overall amount
of hazardous waste generated and increase the
use of laboratory waste over the life of the
project.
Benefits for Stakeholders
• Implementation of the EMPs in each of the
laboratories on campus will increase labora-
tory workers' familiarity with and knowledge
of proper laboratory waste disposal methods
and increase awareness of possibilities for
chemical reuse and recycling. Laboratory
workers in university settings often graduate
to become the laboratory workers in industrial
settings. The benefits of this project include
the additional training and hazard awareness
of the next generation of researchers, chemi-
cal handlers, and problem solvers.
Benefits for the Project Sponsors
• Deferral of hazardous waste determination
from the laboratory to a central on-site loca-
tion will allow for more effective management
of laboratory waste at the institutional level
and thus increase reuse and recycling oppor-
tunities.
• Increase of permissible time for waste pick-
ups from 3 to 30 days will allow for a more
coordinated and efficient pickup and delivery
system, which frees up staff time to concen-
trate on training and pollution prevention op-
portunities.
• The development of infrastructure and train-
ing designed to increase waste minimization
and an organized and coordinated campus-
wide chemical reuse system will result in de-
creased environmental impact of operations.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the New England Universities' Labo-
ratories Project, September 1999; (2) Project XL
Site Specific Rulemaking for University Labora-
tories, Final Rule, published in the Federal Regis-
ter September 28, 1999; (3) Amendments to
Vermont's Hazardous Waste Management Regu-
lations, March 2000; (4) Boston College's Draft
EMP, April 2000; (5) New England Laboratories
Focus Groups conducted in 1999 and presented in
the Project XL Stakeholder Involvement Evalua-
tion (October 2000); (6) New England Laborato-
ries Project XL Baseline Assessment, June 28,
2000; (7) New England University Laboratories
Project XL First Year Progress Report, June 28,
2001; and (8) the 2000 Project XL Comprehensive
Report, Volume 2: Directory of Project Experi-
ments and Results, November 2000.
-------
y\) e vv
Depa rfmenl o|
firv v i »^o rv menfa I
Profection <^\old
Track Proqmm
Final Project Agreement Signed January 19,2001
Background
The Project Sponsor: In November 1996, the
New Jersey Department of Environmental Protec-
tion (NJDEP) embarked on the development of a
two-tiered environmental performance system, the
Silver and Gold Track Program for Environmen-
tal Performance, which rewards participating fa-
cilities for committing to high standards of
environmental achievement. The Silver Track
portion of the program was implemented in Sep-
tember of 1999 and includes baseline incentives
such as expedited permitting, consolidated report-
ing, and facility recognition. As New Jersey con-
tinues to face numerous environmental
management challenges related to its industrial
history, the nature of its economy, high population
density, and intensive land development patterns,
the implementation of the Silver and Gold Track
Program is viewed as an innovative strategy to pro-
mote high standards of environmental protection
throughout the state.
The Experiment: NJDEP is working on a state-
wide XL approach to its experimentation with the
Silver and Gold Track Program for Environmen-
tal Performance. The Silver Track 11 tier provides
moderate levels of operational incentives that do
not require the granting of federal regulatory flex-
ibility. In contrast, the Gold Track tier will seek to
test the concept of providing some federal regula-
tory flexibility based on a higher level of environ-
mental commitment made by the participating
facility. Under this project, NJDEP would be re-
sponsible for oversight of participating facilities
and would be empowered to administer, via the
XL mechanism and to the greatest extent possible,
all of the flexibility described in the Gold Track
FPA and media-specific addenda.
The Flexibility: The Gold Track proposal will use
the XL mechanism to enable NJDEP to negotiate
federal regulatory flexibility as an incentive under
Gold Track. The FPA includes an outline of the
process and criteria for admission into and admin-
istration of Gold Track. Specific regulatory flex-
ibility is presented and described in media-specific
addenda to the FPA, which also describe qualifi-
cations for that flexibility and any rule making nec-
essary to make the project legally enforceable.
There are currently three media-specific addenda
to the FPA, all of which were signed on January
19, 2001: an air-specific addendum, a Resource
Conservation and Recovery Act-specific adden-
dum, and a water-specific addendum. NJDEP is
currently undergoing rule making to codify the
regulatory flexibilities offered under the Gold
Track tier. This tier will be implemented in early
2002 as a pilot limited to no more than nine facili-
ties. EPA is also doing a rule making, not yet pro-
posed, to implement some aspects of the FPA.
The Superior Environmental Performance: The
following represent the range of "beyond compli-
ance" environmental benefits that could be ex-
pected from Gold Track participants:
• Reduced carbon dioxide (CO,,) and other
greenhouse gas (GHG) emissions by 3.5 per-
cent over 1990 levels by 2005;
• Increased use of environmental management
systems;
• Increased levels of recycling and reuse of haz-
ardous waste;
• Reduced emissions of signature pollutants in
addition to CO, (nitrogen oxides and volatile
organic compounds), and certain hazardous air
pollutants such as mercury; and
• Greater use of comprehensive facility moni-
toring and consolidated targeted environmen-
tal tracking and reporting.
Progress in Meeting Commitments
The FPA was signed in early 2001. The commit-
ments outlined in the FPA are summarized below:
-------
-------
y\)evv Vo A< State
Depa^+meKt oj
£rVvvi rorvmervtal
(Conservation
Final Project Agreement Signed July 12, 1999
Background
The Project Sponsor: The New York State De-
partment of Environmental Conservation (DEC)
was created on July 1, 1970, to bring together in a
single agency all state programs directed toward
protecting and enhancing the environment. The
New York State DEC is responsible for adminis-
tration and enforcement of the New York State
Environmental Conservation Law. The New York
State DEC has three main functions: natural re-
source management, environmental quality protec-
tion, and the promotion of human health, safety,
and recreation.
The Experiment: The New York State DEC
project would allow public utilities located in New
York State to consolidate hazardous wastes gener-
ated at remote locations (e.g., manholes). The
project will allow the utilities to consolidate the
waste at a central collection facility for up to 90
days before transport and disposal, rather than hav-
ing to transport by piecemeal such wastes directly
to permitted hazardous waste treatment/disposal
facilities.
The Flexibility: Resource Conservation and Re-
covery Act regulations generally require utility
companies that generate hazardous wastes at re-
mote locations to transport such wastes directly to
treatment, storage, and disposal facilities. Under
this project and its site-specific rule, the partici-
pating utilities will instead be able to transport the
waste to off-site central collection facilities, where
they may consolidate waste within 90 days. In
addition, participating utilities will be allowed to
submit a single biennial report for the central col-
lection facility, rather than for each remote loca-
tion from which hazardous waste is generated.
The Superior Environmental Performance:
The project requires each participating utility to
reinvest one-third of its direct cost savings into one
or more new environmentally beneficial projects;
reduces the risk of hazardous waste releases at re-
mote locations while avoiding traffic disruptions;
allows the consolidation of similar wastes at cen-
tral collection facilities, which will reduce the num-
ber of vehicle trips to often distant treatment,
storage, and disposal facilities; and simplifies ex-
isting paperwork and reporting requirements.
Progress in Meeting Commitments
(As of August 2001)
• EPA published a Final rule that will allow par-
ticipating New York State utilities to con-
solidate hazardous waste generated at remote
locations. The rule became effective January
10, 2000.
• On February 23, 2000, New York State DEC
issued an enforcement directive that allows the
state to proceed with implementing the XL
project until it publishes its own state rule.
On 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 continuing to discuss settle-
ment options with the petitioners.
Benefits for the Environment
• This project will increase public safety by fa-
cilitating and requiring the expeditious removal
of hazardous wastes from remote locations.
Benefits for Stakeholders
• Public utilities should realize considerable di-
rect-cost savings through more efficient trans-
portation use from centrally consolidating
hazardous wastes and thereby reduce the num-
ber of lengthy trips made by waste transport-
ing vehicles.
-------
• The project also will eliminate the need to re-
port remote locations under separate identifi-
cation numbers and will allow the participating
utilities to biennially report waste generated
at separate remote locations.
• Overall, the results of this project will mini-
mize unnecessary paperwork and more effi-
ciently use time and labor resources.
Benefits for the Project Sponsor
This project will bring about a significant re-
duction in paperwork and savings in time and
labor, both for public utilities and environmen-
tal regulatory agencies, which can then redi-
rect such resources to other environmental
needs.
Information Resources: The information sources
used to develop this progress report include: (1)
the December 1999 Project XL Progress Report—
New York State Department of Environmental Con-
servation (EPA-R-00-0017); (2) the Final rule
adopted by EPA on July 12, 1999; and (3) the 2000
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
-------
OH^\o-7Vlc/\)eil
Pka^maceufical
Comparvy
Final Project Agreement Signed September 22, 2000
Background
The Project Sponsor: Ortho-McNeil Pharmaceu-
tical (OMP) and the R.W. Johnson Pharmaceuti-
cal Research Institute (PRI), divisions of Johnson
& Johnson, are jointly sponsoring this XL project.
OMP manufactures and markets pharmaceutical
products in several therapeutic categories, includ-
ing women's health, central nervous system, in-
fectious disease, and wound healing. OMP's
research and development efforts are conducted
by PRI, a sister company. PRI develops and uses
radiolabeled compounds for the research and de-
velopment of pharmaceuticals/drugs. OMP is
headquartered in Raritan, New Jersey, and employs
more than 2,000 people. The company has manu-
facturing operations in Raritan, New Jersey; Spring
House, Pennsylvania; and Manati and Dorado,
Puerto Rico. This project is being conducted at
the Spring House, Pennsylvania, site.
The Experiment: OMP is testing a unique tech-
nology that treats a waste byproduct (consisting
of both organic and radioactive components) of its
pharmaceutical research and development. In or-
der to meet the Food and Drug Administration's
requirements for studying the safety and efficacy
of new pharmaceuticals in the human body, PRI
uses drugs labeled with radioisotopes, which en-
able the drugs' bioabsorption and metabolism in
the body to be tracked with precision. As a result
of these studies, a waste mixture consisting of ra-
dioactive material and an organic compound are
produced. EPA regulates low-level mixed waste
(LLMW) under the Resource Conservation and
Recovery Act (RCRA), and the radioactive com-
ponent is regulated by the Nuclear Regulatory
Commission (NRC) as a low-level waste under the
Atomic Energy Act of 1954.
The high temperature catalytic oxidation (HTCO)
process uses catalytic oxidation to destroy the haz-
ardous component and capture the radioactivity
from the waste mixture. This bench-top oxidation
process will allow OMP to process LLMW in the
same, secure laboratory where it is created, limit-
ing lab worker exposure and reducing the risk from
releases during storage, transportation, and han-
dling. In addition, the process captures the radio-
active components of the waste rather than
releasing it through the incineration process, which
makes these waste products amenable to recycling
and reuse. This XL project would allow OMP to
transition the treatment process from an initial test-
ing phase to a long-term development phase, with
the ultimate goal of providing this technology and
the permitting provision exclusion to similar gen-
erators of small quantities of LLMW.
The Flexibility: Assuming OMP's LLMW is a
RCRA hazardous waste, the HTCO process meets
RCRA's definition of treatment, because the oxi-
dation destroys the organic components of the
samples. With few exceptions, under RCRA, a
process that is considered treatment typically trig-
gers a requirement to obtain a RCRA Treatment,
Storage, and Disposal Facility (TSDF) permit.
With this project, OMP will be able to treat small
volumes of LLMW on-site with its HTCO process
without a RCRA TSDF permit. To encourage use
of the oxidation process, the OMP XL project ex-
cludes the small volumes of LLMW created and
treated using OMP's HTOC process within a NRC-
licensed pharmaceutical research and development
laboratory from RCRA's regulatory definition of
hazardous waste in 40 CFR§ 261.4(b). However,
OMP's LLMW remains a solid waste and subject
to other RCRA authorities, including EPA's author-
ity under RCRA Section 7003, which addresses
situations of "imminent and substantial endanger-
ment to health or the environment." The State of
Pennsylvania Department of Environmental Pro-
tection (PADEP) has been authorized to adminis-
ter and implement most of the hazardous waste
program in lieu of EPA, including the "mixed
waste" portion of the regulatory program.
Other Innovations: (1) Innovative Recovery of
Radioactive Waste. The HTCO process enables
the capture of the radioactive component of OMP's
LLMW as a uniform, consistent waste stream that
is amenable to recovery and reuse. (2) Improved
Waste Handling and Safety. The OMP HTCO
-------
process is designed to handle all LLMW on-site in
the NRC-regulated, controlled laboratory environ-
ment in which it was generated, thereby further
reducing the minimal potential for spills or releases
during the on-site and off-site handling and trans-
portation. (3) Technology Transfer. If this project
is determined to be successful and this regulatory
flexibility is adopted at a national level, the HTCO
technology developed by OMP may be transfer-
able to other organizations that generates or treats
small amounts of mixed wastes, such as pharma-
ceutical companies, research institutions, and col-
leges and universities. While testing its technology,
OMP has decided not to patent the technology and
has made it available to all interested parties. By
enabling OMP and other organizations to utilize
this technology, the technology and its environ-
mental and economical benefits may be made avail-
able to a much larger number of users.
The Superior Environmental Performance:
As a result of the expanded regulatory flexibility
granted through Project XL, OMP will be able to
continue developing and testing the HTCO pro-
cess. By treating LLMW on-site where it is gen-
erated, the HTCO process results in several
environmentally superior and transferable benefits
as compared to presently available commercial
treatment and disposal alternatives involving in-
cineration or land disposal. For example, the ra-
dioactive component of OMP's LLMW is captured
and made available for recovery and reuse, as op-
posed to being lost during incineration. In addi-
tion, OMP will handle all LLMW on-site in the
controlled laboratory environment in which it is
generated, thereby limiting lab worker exposure
and reducing the minimal potential for spills or
releases during on-site and ofif-site handling and
transportation. The use of the technology among
generators of small amounts of mixed wastes may
create a more economically favorable environment
for the commercial development of low-level waste
recycling.
Progress in Meeting Commitments
(As of August 2001)
• EPA committed to propose and issue a site-
specific rule, amending 40 CFR § 261.4, which
applies to the OMP Spring House facility, al-
lowing the facility to run its LLMW catalytic
oxidation process without obtaining a permit
under RCRA.
- EPA published the Notice of Proposed
Rulemaking in the Federal Register on July
24, 2001, allowing for the site-specific
exclusion under RCRA that would enable
OMP to utilize the HTCO process to treat
LLMW on-site without a RCRA permit.
• PADEP committed to propose and issue a per-
mit by rule as necessary under state law, 25
Pennsylvania Code 270a.60, or use other le-
gal mechanisms to allow for the implementa-
tion of this XL project.
- PADEP action by rule is pending publica-
tion of the final rule by EPA.
• OMP committed to monitor and report bian-
nually: (1) destruction removal efficiencies for
all organic components of the LLMW subject
to treatment and (2) capture efficiencies for
the radioactive component of the LLMW sub-
ject to treatment.
- The 2000 Treatability Study Annual Re-
port for OMP's Spring House facility, out-
lining both the destruction removal
efficiencies (DREs) and capture efficien-
cies for the radioactive component of
LLMW subject to treatment, was submit-
ted to both PADEP and EPA on March 12,
2001. A second report is due September
15,2001.
- OMP reported that in 2000 it generated a
total of nine samples of LLMW subject to
two treatability studies in their research fa-
cility. Both studies were conducted using
a HTCO process to destroy the organic
components of the mixed waste in order
to reclassify the waste as low-level radio-
active waste for disposal. The first study
-------
resulted in a DRE of approximately 99.998
percent and a destruction removal recov-
ery rate of 99.3 percent (+/- 3 percent).
The second study resulted in a DRE of
approximately 99.999 percent and a de-
struction removal recovery rate of 96.8
percent (+/- 3 percent).
OMP committed to make available its HTCO
technology to all companies and institutions
that generate research-and-development quan-
tities of LLMW.
- OMP scientists continue working with a
number of outside organizations, which in-
clude several international and domestic
corporations and the Lawrence Berkeley
National Laboratory, to develop the HTCO
technology, provide technical assistance,
and share data.
- OMP presented information on the cata-
lytic oxidation treatment process to inter-
ested parties at a symposium sponsored by
the International Radioisotope Society in
Mason, Ohio, on May 17,2001. The sym-
posium was co-organized and co-chaired
by representatives from OMP. At the sym-
posium, a representative from PR1 re-
viewed current and developing treatment
and disposal techniques, while focusing on
the HTCO process being utilized by PRI.
OMP committed to meet quarterly with the
Lower Gwynedd Township (LGT) Industrial
Compact, an environmental group, to provide
a regular forum for public discussion.
- OMP provides quarterly status reports at
its regular meetings with the LGT Indus-
trial Compact. In addition, the OMP site
manager attends monthly LGT supervisor
meetings and is available to answer any
questions raised by LGT or township citi-
zens during these meetings.
OMP committed to meet quarterly with mem-
bers of the Community Advisory Council
(CAC) sponsored by Rhom & Haas Corpora-
tion to discuss environmental issues.
- At this time, the Council's activities have
been discontinued due to reorganization
and downsizing at the Rhom & Haas Cor-
poration, which heads the CAC.
• OMP will host annual stakeholder meetings.
- OMP meets with the LGT quarterly, and
will hold larger, annual stakeholder meet-
ings as needed.
Benefits for the Environment
• OMP's processing of LLMW in the same labo-
ratory in which it is created limits lab worker
exposure and enables the capture of radioac-
tive components of the waste rather than los-
ing it to the incineration process.
• To date, the OMP process is effectively cap-
turing the radioactive components of the waste
rather than losing it to the incineration pro-
cess, making these waste products amenable
to recycling and reuse.
Benefits for Stakeholders
• OMP is sharing the environmentally benefi-
cial HTCO technology freely with other re-
search institutions and government agencies
that also generate LLMW. Through extensive
outreach to state and federal regulatory agen-
cies; the local community, local, state, and
national environmental groups; and other in-
terested parties, including government labo-
ratories, domestic and international
pharmaceutical research companies, and com-
mercial pharmaceutical manufacturers, OMP
has increased information sharing and learn-
ing about the HTCO process and its potential
environmental benefits. The company is col-
laborating with these outside organizations that
are working to develop the HTCO technology,
providing technical assistance, guidance, and
data sharing.
-------
Benefits for the Project Sponsor
• By enabling OMP to use this technology, the
company not only will be able to treat LLMW
in a much more environmentally beneficial
manner, but will also achieve significant eco-
nomic savings as a result of reduced transpor-
tation and disposal costs. OMP reported that
during FY 2000, it generated a total of nine
samples on three separate occasions. Given
that a minimum charge of $35,000 would have
been incurred for each shipment to dispose of
the waste off-site, the on-site processing of the
waste saved OMP an estimated $105,000 in
2000 (3 x $35,000).
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Ortho-McNeil Pharmaceutical
Project, signed September 22, 2000; and (2) the
2000 Project XL Comprehensive Report, Volume
2: Directory of Project Experiments and Results,
November 2000.
-------
Pennsylvania
Department o|
i ron mental
Protection (Coal
T^eminin0 and
Reclamation Project
Final Project Agreement Signed September 22, 2000
Background
The Project Sponsor: The Pennsylvania Depart-
ment of Environmental Protection's (PADEP's)
mission is to protect Pennsylvania's air, land, and
water from pollution and to provide for the health
and safety of its citizens through a cleaner envi-
ronment. PADEP works as a partner with indi-
viduals, organizations, governments, and
businesses to prevent pollution and restore natural
resources. Six district mining offices within
PADEP oversee Pennsylvania's mining program.
Their duties include licensing, bonding, permitting,
and inspecting all surface and underground anthra-
cite and bituminous coal mines, coal preparation
plants, coal refuse disposal, and industrial mineral
quarries. The offices also concentrate on industry
compliance assistance as well as all aspects of
pollution prevention advocacy.
The Experiment: PADEP proposed this XL
project to explore a new approach to encourage
the remining and reclamation of abandoned coal
mine sites. The approach would be based on the
implementation of best management practices
(BMPs) instead of compliance with in-stream pol-
lutant concentration limits and implementation of
compliance with the National Pollutant Discharge
Elimination System (NPDES) numeric effluent
limitations measured at individual discharge points.
This XL project will test this approach in up to
eight watersheds with significant acid mine drain-
age (AMD) pollution. The project will collect data
to compare overall in-stream pollutant concentra-
tions versus the loading from individual discharge
points and provide for the evaluation of the per-
formance of BMPs and this alternate strategy in
PADEP's efforts to address AMD.
The Flexibility: An existing amendment to the
Clean Water Act (CWA) provides remining opera-
tions an exception to the effluent limitation per-
mitting requirements for iron, manganese, and pH
for preexisting discharges from abandoned mine
lands mined before 1977. Instead, the project per-
mit may set site-specific numeric effluent limita-
tions representing best available technology on a
case-by-case basis for these parameters. These lim-
its are to be set so that the permit may not allow
the levels of acidity, iron, and manganese dis-
charged to exceed preexisting levels from past
mining operations in the area before the remining
activity begins. The remining operation must dem-
onstrate the potential for improved water quality
from the remining.
Under this project, PADEP will continue to apply
current effluent limitations and permitting require-
ments to preexisting discharges that are comingled
with discharges from active remining operations.
PADEP will require in-stream compliance moni-
toring rather than point-of-discharge compliance
monitoring for preexisting, non-encountered dis-
charges and all preexisting discharges after active
remining operations.
Other Innovations: (1) Alternative Approaches
to Reducing AMD through Regulatory Innovation.
The use of BMPs without numeric limits is an in-
novative approach that focuses on preventing pol-
lution at the source(s) in the abandoned mine land
areas of the watershed regardless of whether they
will be disturbed (encountered) during the
remining. NPDES permits for remining currently
establish site-specific numeric effluent limitations
representing best available technology. PADEP is
implementing its alternative permit approach so
that reminers may comply with non-numeric limi-
tations in the form of specific BMPs, as well as in-
stream monitoring requirements to measure the
performance of reclamation activities on water
quality in the watershed. (2) Gaining Experience
with Remining BMPs. This XL project will also
allow PADEP, EPA, and the reminers to gain more
experience in implementing, developing, and
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refining the application of new and existing BMPs.
It will also provide data on the most effective BMPs
and information on possible improvements in their
use.
The Superior Environmental Performance:
This pilot project is expected to provide superior
environmental performance by encouraging coal
operators to undertake remining projects that oth-
erwise would have been too risky or expensive be-
cause of the potential to have to treat preexisting
acidic discharges following the remining. In re-
turn for this lessening of the risk associated with
potential treatment costs, the reminers would
implement more reclamation activities in the wa-
tershed than existing Pennsylvania regulations or
federal law require. With this proposal, the
reminers would still be responsible for an equally
protective standard of maintaining overall water
quality in the stream but would accomplish this
via BMPs. Under this project, treatment of dis-
charges would be undertaken only as a last resort
if the BMPs fail (or were not implemented) and
water quality is degraded. Remining (with recla-
mation to present-day standards) is an effective way
to reclaim abandoned mine lands and improve
water quality, at little or no cost to taxpayers. These
pilots are designed to increase the number of
remining operations providing reclamation and to
enhance the degree of reclamation and AMD-
abatement measures taken on remining operations.
Each of the pilot watersheds has been severely
degraded by AMD from abandoned mine dis-
charges and either is currently listed on
Pennsylvania's CWA list of impaired waters that
do not meet water quality standards or has been
identified as a water body that does not meet wa-
ter quality criteria due to abandoned mine drain-
age. For each watershed, PADEP expects that
remining efforts will be an integral part of a water
quality remediation plan and that water quality
improvements will be achieved by implementing
BMPs.
Progress in Meeting Commitments
(As of February 2001)
The project is in its initial stages and activities are
just getting underway. The following commitments
have been made in the FPA.
• PADEP will collect data to compare in-stream
pollutant concentrations with the loading from
individual discharge points to provide for the
evaluation of the performance of BMPs.
• PADEP will test the BMPs approach in up to
eight watersheds with AMD pollution.
- On February 7, 2001, Sky Haven Corpo-
ration signed the first PADEP Mining Per-
mit and Consent Order and Agreement for
a remining project in the Surveyor Run wa-
tershed in Clearfield County, Pennsylva-
nia. The remining started in late February.
Four other projects are currently in devel-
opment.
- BMPs that will be applied at the Surveyor
Run Watershed project include revegeta-
tion of 50 acres, blending acid forming
strata with alkaline strata, and eliminating
16,300 linear feet of dangerous highwall.
• Reminers will meet or improve water quality
at an in-stream monitoring point (or points)
rather than at each individual discharge to the
stream.
• PADEP will continue to apply current efflu-
ent limitations/permitting requirements to pre-
existing discharges that are physically
encountered and collected with discharges
during active remining operations.
• PADEP and EPA will make all project infor-
mation available to stakeholders in a form that
is accessible and easy to understand.
• PADEP inspection frequencies will be in-
creased appropriately to ensure the BMPs have
been fully implemented.
• PADEP will submit periodic reports and up-
dates regarding the activity on these pilot sites
and water quality monitoring results to EPA.
-------
• Reminers have applied to use the Project XL
permit approach at several other sites. PADEP
is currently working with reminers to develop
these permits.
Benefits for the Environment
• Each remining site selected in this XL project
is an abandoned area that was left unreclaimed
and was not expected to be remined under the
existing permitting program. Under mining
laws, a mine operator engaging in remining
must reclaim the area once remining activities
are complete.
• Reclamation activities, including regrading
and revegetating the sites, are expected to re-
sult in both improved surface water quality and
a reduction in erosion and sedimentation in ad-
jacent streams, while also creating habitat for
flora and fauna, eliminating physical hazards
such as highwalls and pits, and improving aes-
thetics through restoration of a barren land-
scape.
Benefits for Stakeholders
• This project has the potential to benefit all the
stakeholders. The reminer will be able to re-
move and sell the coal with a lessened risk of
long-term liability to treat discharges. Local,
state, and federal stakeholders will benefit
since more land in the watershed will be re-
claimed at no cost to the taxpayer.
Benefits for the Project Sponsor
• PADEP will be able to test an innovative ap-
proach designed to reclaim abandoned mines
in Pennsylvania. If successful, PADEP may
update their remining regulations to provide
for greater use of this pollution prevention/
BMP approach.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Pennsylvania Department of Envi-
ronmental Protection XL project, signed Septem-
ber 22, 2000; and (2) the 2000 Project XL
Comprehensive Report, Volume 2: Directory of
Project Experiments and Results, November 2000.
-------
V^PCa industries,
Dna,
Final Project Agreement Signed September 14, 2000
Background
The Project Sponsor: PPG Industries, Inc., (PPG)
is a leading global supplier of coating, continu-
ous-strand fiberglass, flat and fabricated glass, and
chemicals. As a technological leader for 116 years,
PPG has introduced many new products and pro-
cess innovations, especially in the area of new
chemical development. These new chemical sub-
stances are developed in PPG's research and de-
velopment (R&D) facilities located in Monroeville,
Allison Park, and Harmarville, Pennsylvania, in
the greater Pittsburgh area.
The Experiment: EPA's Pollution Prevention
(P2) Framework is a new screening methodology,
based on a set of computerized risk screening tools,
to assist in characterizing the fate and hazards likely
to arise from the manufacture, use, and disposal of
new chemicals. The P2 Framework, developed by
EPA's Office of Prevention, Pesticides and Toxic
Substances, was created to calculate or estimate
important risk-related properties based on analy-
ses of chemical structures and to design safer
chemicals, reduce waste generation, and identify
other pollution prevention opportunities. In chemi-
cal manufacturing, companies invest substantial
resources into new product development before
seeking EPA approval, which is necessary under
the Toxics Substances Control Act (TSCA) for new
industrial chemicals. As a result, chemical prod-
uct developers would like to minimize costs and
risks associated with worker exposure, reporting,
testing, recalls, and product liability. Recogniz-
ing the potential environmental and economic ben-
efits, EPA is making the P2 Framework
methodologies available to the chemical manufac-
turing industry to help promote the selection and
application of safer chemicals and processes dur-
ing the early stages of decision making regarding
chemical development. Applying the P2 Frame-
work, PPG will incorporate environmental and
health information into the early stages of its
chemical development operations, as well as iden-
tify opportunities for pollution prevention. In ad-
dition, PPG believes that many other companies
can develop environmentally preferable products
by applying the P2 Framework, especially at the
R&D stage of product development.
The Flexibility: TSCA governs the manufacture,
importation, processing, distribution, use, and dis-
posal of industrial chemical substances, including
new chemicals. Annually, EPA evaluates approxi-
mately 1,500 to 2,000 new chemical notices sub-
mitted by industry. Section 5 of TSCA requires
prospective manufacturers (or importers) to wait
90 days after submitting a premanufacture notice
(PMN) before they can begin to manufacture (or
import) a new chemical substance. Within the 90-
day period, EPA must evaluate the report, identify
potential risks of the new chemical substance, and
specifically determine whether the substance may
present an unreasonable risk to human health or
the environment. Unless the requirements for an
exemption are met, a PMN submitter may not
manufacture a new chemical substance until 90
days after it has submitted a PMN to EPA.
Under this project, because PPG is using the P2
Framework, EPA has agreed that PMN substances
submitted by PPG, which EPA determines to
present a low risk, can be manufactured prior to
day 90 of the review period pursuant to a test mar-
keting exemption (TME). Additionally, for chemi-
cal substances for which PPG uses the P2
Framework, PPG may submit combination TME
applications and PMNs for concurrent review by
EPA. Although EPA generally discourages simul-
taneous submittals, for the purposes of Project XL,
EPA will allow such concurrent submissions to be
sustained when the TME is granted and the corre-
sponding PMN is dropped from further review
during the first 30 days of the review period.
Other Innovations: (1) Pollution Prevention. EPA
expects that PPG's use of the P2 Framework to
prescreen its product development options will re-
sult in increased opportunities for pollution preven-
tion by preventing the generation of pollution rather
than controlling pollution once it has been created.
(2) Reducing the Regulatory Burden. The use of
the P2 Framework allows PPG to anticipate and
address EPA's concerns prior to PMN submission,
greatly decreases the probability of adverse
-------
regulatory action later, and improves the efficiency
of EPA's PMN review process. (3) Stakeholder In-
volvement. Directly involving business and techni-
cal stakeholders in the project is key to the goal of
encouraging use of the P2 Framework during de-
velopment of new chemicals submitted as PMNs to
EPA. The sharing of this new technological tool by
EPA and the communication of its benefits by PPG
with other stakeholders represents an unprecedented
cooperative approach to pollution prevention.
The Superior Environmental Performance:
PPG's commitment to use the P2 Framework and
promote its use within the industry reflects a com-
mitment to pollution prevention, as companies are
not required to test new chemical substances un-
der TSCA prior to submission to EPA. New prod-
uct research and development can be a very
expensive process. Therefore, it is cost-effective
to shepherd the "best" chemical candidate through
later phases of the product development process.
By using the P2 Framework, it is expected that PPG
will develop innovative, cleaner, and more envi-
ronmentally benign products and processes be-
cause it will be able to identify early on any
problems with the chemical development and it will
avoid carrying problem chemicals through prod-
uct development cycles which could result in irre-
coverable costs. In addition, it is expected that
PPG's manufacturing processes and waste handling
processes will operate at higher levels of environ-
mental performance due to an increased emphasis
on pollution prevention.
Progress in Meeting Commitments
(As of August 2001)
• Overall, PPG has been able to meet all of its
environmental commitments to date for the
project.
• PPG committed to applying the P2 Framework
in its new product development program and
submitting PMNs to EPA based on P2 Frame-
work analysis data.
- PPG has used the P2 Framework success-
fully on approximately 20 new products
in the coatings division, primarily paints
and resins. All of the products have been
evaluated using the P2 Framework assess-
ment. Of the 20 products, 14 have been
submitted to EPA. Of the 14 submissions,
five have been submitted as simultaneous
TME/PMN notifications. In addition,
three more products will be submitted as
PMNs to EPA in the near future.
- In the chemicals division, PPG has applied
the P2 Framework to five chemicals.
These chemicals will be submitted to EPA
for PMN review.
• PPG committed to conduct a validation study
to compare measured aquatic toxicity data with
structure activity relationships (SARs) predic-
tions from ECOSAR (Ecological SAR), which
is a personal computer software program de-
signed to estimate the toxicity of chemicals
used in industry and discharged into water.
ECOSAR uses SARs to predict the aquatic
toxicity of chemicals based on their structural
similarity to chemicals for which aquatic tox-
icity data are available. SARs express the cor-
relations between a compound's physico-
chemical properties and its aquatic toxicity.
SARs measured for one compound can be used
to predict the toxicity of similar compounds
belonging to the same chemical class.
- PPG committed to work with EPA to vali-
date certain SAR predictions with the
ECOSAR program. PPG submitted to
EPA an SAR validation report in Decem-
ber 2000. SAR predictions were gener-
ated for 38 polymeric chemicals submitted
by PPG to EPA as PMNs. These predic-
tions using SAR data were compared to
actual measured data on the same set of
chemicals.
- The results indicate 87 to 90 percent agree-
ment between the predictions and mea-
sured data. Data were considered to be in
agreement if SAR predictions were within
the same order of magnitude (less than a
tenfold difference) as measured data, or
there were no effects at saturation and the
measured data showed no effects at the
maximum attainable or limit test values.
The actual data are classified as TSCA
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Confidential Business Information and
cannot be released; however, an abstract
of the SAR study was presented as a poster
at the March 2001 annual meeting of the
Society of Toxicology in San Francisco.
- PPG, independent of the FPA, conducted
a second SAR study on chlorinated ben-
zenes. This study was presented at the
October 2000 Allegheny-Erie Society of
Toxicology meeting in Pittsburgh.
PPG committed to communicating with other
industries on the uses and benefits of the P2
Framework and to promote understanding
about the P2 Framework through outreach to
industry and other stakeholders.
- PPG has conducted outreach by giving
several presentations about the beneficial
uses of the P2 Framework at the follow-
ing meetings: (1) Allegheny-Erie Society
of Toxicology, fall meeting in Pittsburgh,
October 13, 2000; (2) Pittsburgh Chapter
of the Society for Risk Analysis, meeting
in Pittsburgh, December 11, 2000; (3) So-
ciety of Toxicology, National Meeting in
San Francisco, March 2001; and (4) Green
Chemistry and Engineering Conference in
Washington, D.C., June 2001.
- PPG also will assist EPA, as necessary,
with its own outreach on the P2 Frame-
work and a similar innovative idea known
as the PBT Profiler, which is a new risk
screening methodology that is designed to
help companies identify chemicals that are
persistent (P), bioconcentrate (B), and
present toxicity (T) issues of concern. PPG
will conduct an evaluation of the PBT
Profiler and make suggestions for im-
provement and comment on its utility in
PPG's product stewardship efforts.
Key focus areas for the PPG project over the
next six months will mostly likely include PPG
submitting five PMNs for new chemicals that
have successfully passed the P2 Framework
and PPG reviewing, commenting on, and mak-
ing suggestions for improving EPA's PBT
Profiler in PPG's product stewardship efforts.
Benefits for the Environment
• As chemical screening is not required under
TSCA, the use of the P2 Framework represents
a huge step in effectively trying to minimize
the environmental impacts of new chemical
and product development. Use of the P2
Framework highlights areas and opportunities
for pollution prevention during the beginning
R&D phases of new chemical development,
which decreases the toxicity and pollution
potential of chemicals.
• PPG's use of the P2 Framework to success-
fully screen chemicals has allowed them to
submit PMNs to EPA with the knowledge that
they have, to the extent possible, been able to
reduce environmental impacts and make their
chemicals and products safer.
• Through extensive outreach, PPG will be able
to share their experiences with the P2 Frame-
work and help more chemical manufacturers
use and understand this tool to produce more
environmentally sound products.
Benefits for Stakeholders
• Through the outreach component of this
project, more informal partnerships between
chemical manufacturers, EPA, state agencies,
and the public have been created to increase
information sharing and learning about new
tools to minimize environmental impacts of
chemicals.
Benefits for the Project Sponsor
• Generally, early screening of new chemicals
presents a definite competitive edge for PPG.
For example, with the P2 Framework in use,
there is more effective decision making on
chemical products and chemical candidates for
use, which helps PPG avoid potential regula-
tory delays. Without regulatory delays, PPG
will see a faster time to market in a highly com-
petitive industry and can experience reduced
manufacturing costs for its products.
-------
Information Resources: The information in this
summary comes from the following sources: (1)
the Project XL FPA for the PPG Industries, Inc.,
Project, September 14, 2000; and (2) the 2000
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
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Progressive 7A.U+0
Jrvsurcmce (Comparvy
Final Project Agreement Signed July 27, 2000
Background
The Project Sponsor: Progressive Auto Insur-
ance is the fourth largest auto insurer in the United
States, insuring more than 5 million people and
operating more than 350 offices nationwide. In
August 1998, Progressive began a limited market-
ing test in Houston, Texas, of a new product,
AutographSM, which bases auto insurance premi-
ums in part on when, where, and how much a ve-
hicle is driven. In August of 1999, the company
expanded the test throughout the State of Texas.
Progressive has piloted this voluntary insurance
policy using AutographSM to determine a
consumer's auto insurance rate. With the use of a
global positioning system installed in the
consumer's vehicle, actual vehicle usage, includ-
ing when and how much the vehicle is driven, can
easily be monitored.
The Experiment: With the AutographSM system,
Progressive seeks to create and test a variable in-
surance cost that will be influenced by the
customer's driving activity and will provide a fi-
nancial incentive for customers to drive less and
choose alternative forms of transportation, such as
public transportation or walking. Auto insurance
rates are traditionally based on variables, includ-
ing vehicle age; vehicle manufacturer and value;
driver's age, sex, marital status, place of residence,
and driving record; types of coverage; and
deductibles selected. However, more specific in-
formation about customer driving patterns, such
as mileage driven and time of day and location of
driving, are generally not taken into account be-
cause of the difficulty involved in monitoring and
tracking the information. Progressive's piloted
insurance program using AutographSM will deter-
mine a consumer's auto insurance rate based on
actual vehicle usage, including when and how
much the vehicle is driven. This system is designed
not only to lower costs for Progressive's custom-
ers, but also to encourage positive driving behav-
iors, leading to a reduction in accidents and thefts.
In addition, by offering this system, Progressive is
helping to reduce the negative environmental im-
pacts that are the result of vehicle miles traveled
(VMT).
In this XL project, EPA is working cooperatively
with the U.S. Department of Transportation on an
analytical study to determine the environmental
impact of Progressive Auto's usage-based auto
insurance product to determine if drivers are mo-
tivated to drive less, and thereby reduce VMT. As
a part of this XL project, Progressive will make
available to EPA aggregated data on participants'
driving mileage gathered throughout the duration
of the study. These data will be used to make cer-
tain correlations between offering customers finan-
cial incentives to drive less and corresponding
environmental impacts of lower VMT associated
with AutographSM customers.
The Flexibility: As this project is an analytical
experiment, no regulatory flexibility is being re-
quested and Progressive does not obtain modifi-
cations of any future laws or regulations. However,
as the project progresses, if it is found that the in-
surance system proves to be environmentally ben-
eficial, it is possible that some alternatives would
be explored for offering incentives to key groups
who enable the expansion of this type of insur-
ance.
The Superior Environmental Performance:
EPA's interest in the Progressive pilot program
derives from the possibility that insurance pricing
plans like AutographSM might alter driving habits,
as well as distinguish existing differences in hab-
its, as drivers learn how their driving habits affect
their costs. With this program, EPA can collect
data on whether people who sign up for a volun-
tary program like AutographSM will reduce their
total driving or their driving during congested pe-
riods, as understanding total VMT is essential to
promoting and crafting EPA's policies dealing with
congestion, smog, vehicle emissions, and "smart
growth" concerns. For more information on the
innovative concept behind the Progressive pilot
program please contact Edmund Coe in EPA's Of-
fice of Air and Radiation, Office of Transporta-
tion and Air Quality, at coe.edmund@epa.gov.
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Information Resources: The information sources
used to develop this summary include: (1) the FPA
for the Progressive Auto Insurance XL Project, July
27, 2000; (2) the Final rule adopted by EPA on
September 22, 2000; (3) the Project XL Compre-
hensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000; and (4)
EPA Progressive Auto Insurance Fact Sheets.
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Steele (Sourvfy Project
XLC9 Final Project Agreement Signed May 31, 2000
Background
The Project Sponsor: A group of nine industrial
facilities in Steele County, Minnesota (Wenger
Corporation, Cybex International, Inc., SPX Cor-
poration-Service Solutions Division, Josten's, Inc.,
Truth Hardware Corporation, Uber Tanning,
Viracon, Inc., Crown Cork & Seal Company, Inc.,
and Atofina), primarily small- to medium-sized
facilities, including some metal finishers, have
agreed to work together to reduce the levels of in-
dustrial pollutants and water flow discharging to
the local wastewater treatment facilities. Eight of
the facilities are located in the Town of Owatonna,
a growing community of 30,000 residents includ-
ing 40 industrial firms. Atofina is located in nearby
Blooming Prairie.
The Experiment: The project has been divided
into two phases. In Phase I, Owatonna participants
will specifically address reducing the discharge of
four priority metals (chromium, nickel, zinc, and
copper) by 20 percent and total water flow by 10
percent within five years. Atofina, the Blooming
Prairie participant, committed to reduce the con-
centration of biological oxygen demand (BOD),
total suspended solids (TSS), and total Kjeldahl
nitrogen (TKN) by 20 percent in the first five years.
The industrial participants also made commitments
to reduce stormwater runoff from their facilities
and assist the Owatonna Wastewater Treatment
Facility (WWTF) in educating the community
about stormwater-related problems such as im-
proper residential sump pump connections.
This project is also testing whether the use of mass-
based limits (e.g., overall amount of pollutant be-
ing discharged by a facility, measured in pounds
per day) rather than the current concentration-based
limits (e.g., concentration of a pollutant, measured
in parts per million) might serve as an incentive
'Project XLC, excellence and Leadership for Communities,
encourages local public sector and community organizations
to come forward with new approaches to demonstrate com-
munity-designed and directed strategies for achieving greater
environmental quality consistent with community economic
goals.
for facilities to conserve water. Concentration-
based limits can be a disincentive for water con-
servation since the greater the volume of water
discharged, the less concentrated the pollutant will
be in the wastewater. The facilities have also com-
mitted to participate in a training to learn how to
develop an ISO 14000-based environmental man-
agement system (EMS) to promote continual im-
provements in environmental performance and
compliance.
In Phase II, which is not covered by the current
FPA, these industrial partners would aim to expand
their efforts to a multimedia approach to environ-
mental permitting, based on overall community
performance, rather than individual facility per-
formance, in the areas of air emissions, solid waste,
hazardous waste, chemical storage, and commu-
nity sustainability. They will test to see if this com-
munity approach to environmental permitting
based on overall performance for the nine compa-
nies (rather than individual facility performance)
will be more effective in reducing environmental
impacts and more economically efficient for the
companies and the local government.
The Flexibility: The FPA outlines five key areas
of regulatory flexibility needed for the Steele
County XLC project to proceed with Phase I. On
October 6, 2000, EPA promulgated a site-specific
rule (65 FR 59738) giving flexibility described in
the FPA to the Owatonna WWTF for six Owatonna
project sponsors (Viracon, Wenger and Atofina do
not discharge to the Owatonna WWTF and there-
fore are not covered by the site-specific rule). The
site-specific rule covers the following four areas:
• Monitoring Frequency Reduction. The site-
specific rule gives the Owatonna WWTF the
discretion to reduce monitoring requirements
to once per year for the six participating fa-
cilities after the first metals reduction goal of
20 percent has been met.
• Mass Based Limits. The site-specific rule pro-
vides discretion to the Owatonna WWTF to
convert concentration-based limits to mass-
based limits for the Owatonna sponsors cur-
rently subject to concentration-based
categorical standards.
-------
• Elimination of Monitoring for Pollutants not
Discharged. The rule gives discretion to the
Owatonna WWTF to not require participants
to monitor for pollutants not expected to be
present at levels greater than influent back-
ground levels following comparison with three
years of effluent data.
• Alternative Significant Noncompliance Ap-
proach. The rule gives discretion to the
Owatonna WWTF to publish notices of sig-
nificant noncompliance events, where the vio-
lations did not cause a pass-through or
interference violation and the sponsors have
acted to promptly to correct them, on the Min-
nesota Pollution Control Agency's (MPCA's)
Web site rather than in the local newspaper.
The FPA provides flexibility to the Blooming Prai-
rie WWTF to use its discretion to evaluate the re-
cent performance of the Atofina facility and may
reduce monitoring requirements to twice per month
on the basis of a satisfactory compliance record.
After the Atofina facility has reached the 20 per-
cent reduction goal for BOD, TSS, and TKN, the
Blooming Prairie WWTF may reduce monitoring
frequency to once per month.
Finally, several participating facilities also plan to
use non-regulatory flexibility available from
MPCA to self-certify that their industrial materi-
als and operations are not exposed to stormwater.
Following this self-certification, sponsors will no
longer be required to obtain stormwater permits.
Qualifying sponsors, however, agree to maintain
their stormwater pollution prevention plan to en-
sure continued non-exposure to stormwater.
Other Innovations: (1) Industry-Organized and
Community-Based Environmental Protection
Model. This collaborative approach may: (a) lead
to greater cooperation and creativity in approach-
ing environmental regulations by regulators and
industrial participants; (b) set an example of envi-
ronmental stewardship for other commercial in-
terests throughout Steele County; and (c) educate
the public in Owatonna and Blooming Prairie about
environmental impacts of their actions. This in-
dustrial partnership model could be exported to
other industrial facilities in Steele County and
throughout the United States. (2) Testing the Use
of Mass-based Limits. The project will test whether
mass-based limits are an effective incentive for
reducing water usage. It will provide valuable in-
formation to EPA, who is considering allowing
publicly owned treatment works (POTWs) to set
equivalent mass-based limits as an alternative to
concentration-based limits to meet concentration-
based categorical pretreatment standards on a na-
tional scale through the proposed rule:
Streamlining the General Pretreatment Regulations
for Existing and New Sources of Pollution (July
22, 1999 64 FR 39564). (3) Reduced or Elimi-
nated Monitoring for Regulated Pollutants Not
Present. By testing the flexibility to waive or re-
duce monitoring for categorical standard pollut-
ants not expected to be present in the waste stream,
the Steele County project approach could be ap-
plied broadly by POTWs. This reduced monitor-
ing approach was proposed as part of the July 22,
1999, proposed rule affecting the National Pretreat-
ment Regulations. (4) Peer Group Approach to
Correcting Noncompliance. This project tests the
value of having a non-biased group of peers assist
a noncompliant facility's return to compliance. The
goal of the peer group is that peers will help a
noncompliant facility better understand the nature
and causes of the violation and assist in identify-
ing actions for quickly returning to compliance and
staying in compliance. Further, the peer group
experiment shows promise in "leading by example"
and can thereby promote and spread environmen-
tal stewardship to the greater Steele County indus-
trial community.
The Superior Environmental Performance:
The 20 percent reduction in the four metals and
other priority pollutants will be made within the
first five years of the project. These reductions
will reduce treatment loads at the local WWTF's.
Row reductions, should result in fewer sewer over-
flow events into the nearby Straight River. When
there is excess water volume beyond capacity due
to a storm event and overflow does occur, pollut-
ants in that effluent reaching the river should be
reduced, causing less environmental harm. In ad-
dition, more environmental benefits should be re-
alized because of participating Owatonna facilities'
commitments to develop environmental manage-
ment systems and pollution prevention audits and
to assist the city in alleviating the problem of storm
sewer overflow.
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Progress in Meeting Commitments
(As of October 2001)
• EPA promulgated a federal site-specific rule
on October 6, 2000, (65 FR 59783) that pro-
vides regulatory flexibility for the participat-
ing industrial facilities (participating industrial
users) in Owatonna and the Owatonna WWTF.
The Owatonna WWTF has submitted a pre-
treatment program modification to the MPCA,
which will be incorporated into the Owatonna
WWTF's National Pollutant Discharge Elimi-
nation System permit.
• The Owatonna WWTF has issued amended
pretreatment permits containing mass limits to
each of the participating facilities in Owatonna.
• MPCA has worked with several of the facili-
ties in Owatonna to utilize existing state flex-
ibility to provide an exemption from
stormwater permitting (following an on-site
inspection) for two facilities in Owatonna.
• MPCA provided training for participating fa-
cilities in development of an Environmental
Management System on October 15, 2001.
• Preliminary data for 2000 and early 2001
(January - First Quarter 2001) show that av-
erage reductions in the discharge for chro-
mium, copper, and zinc exceeded the 20
percent reduction goal compared to the five-
year baseline. Nickel flows were 17 percent
below baseline in calendar year 2000 (see Fig-
ure 47). The Owatonna WWTF will continue
to monitor and evaluate the metal discharge
levels from participating facilities in exercis-
ing its discretion to use the flexibility provided
for in the FPA and in the federal XLC site-
specific rule.
• Preliminary data in Owatonna demonstrate that
total water flow rates decreased 6 percent on
average in calendar year 2000 (see Figure 48)
compared to the five-year baseline and 4 per-
cent in the first quarter of 2001.
Owatonna Effluent Metals Reduction
First Quarter 2001
2000 Average
c
Project Goal
Baseline
! 0.94
^2 0.83
1.01
] 1.26
First Quarter 2001
2000 Average
o
Z Project Goal
Baseline
] 0.70
1.21
ZD i-i7
1.46
First Quarter 2001
qJ 2000 Average
Project Goal
O
Baseline
] 0.04
"] 0.2
| 0.25
] 0.31
First Quarter 2001
2000 Average
O Project Goal
q Baseline
I 0.23
^2 0.49
| 0.68
0.85
0.5 1 1.5 2
Pounds Per Day
T-igwce 47
Owatonna effluent metals reduction.
Owatonna Water Use Reduction
First Quarter 2001
2000 Average
Project Goal
415,000
350,000 365.000 380,000 395,000 410,000 425,000
Gallons Per Day
Pigure 48
Owatonna water use reduction.
-------
Benefits for the Environment
• This collaborative approach may lead to
greater cooperation and creativity in approach-
ing environmental regulations by regulators
and industrial participants and set an example
of environmental stewardship for other com-
mercial interests throughout Steele County.
• Several of the industrial participants have re-
ported that this XLC project has helped raise
environmental awareness in their companies,
especially at the upper management level.
• The facilities will address reducing the total
flow by 10 percent and the discharge of chro-
mium, nickel, zinc, and copper by 20 percent
within five years.
Benefits for Stakeholders
• This collaborative approach may educate the
public in Owatonna and Blooming Prairie
about the environmental impacts of their ac-
tions.
• Water conservation by businesses and indus-
try will benefit the community economically
by increasing the projected life span of the ex-
isting wastewater treatment facility. Both resi-
dential and commercial expansions could
continue at an increased rate if additional
wastewater treatment capabilities existed due
to water reduction efforts.
Benefits for the Project Sponsors
• Reduced or eliminated monitoring for regu-
lated pollutants not present.
• This project tests the value of having a non-
biased group of peers assist a noncompliant
facility return to compliance.
• Savings and efficiencies resulting from the
EMS and pollution prevention efforts as part
of the companies' participation in the XLC
project.
• Increased environmental awareness on behalf
of employees.
Information Resources: The information sources
used to develop this progress report include: (1)
the FPA for the Steele County Community XL
Project, dated 31 May 2000; (2) Project XL 2000
Comprehensive Report, Volume 1: Directory of
Regulatory, Policy, and Technology Innovations;
and Volume 2: Directory of Project Experiments
and Results, November 2000; (3) information from
EPA's Office of Wastewater Management Web
page, http://www.epa.gov/owm/; and (4) Informa-
tion provided at a project participants meeting held
on July 17, 2001, at the Steele County Adminis-
tration Center in Owatonna, Minnesota.
-------
LArvited <£99
Producers
Final Project Agreement Signed October 25, 2000
Background
The Project Sponsor: United Egg Producers
(UEP) is a farmer cooperative representing more
than 300 egg producers in more than 20 states.
Most farms are integrated from the point of pro-
duction through the final marketing of the eggs.
The commercial egg production industry is signifi-
cantly concentrated, and approximately 318 com-
panies now produce 96 percent of the nation's 80
billion eggs annually. Most farms (approximately
80 percent) are solely dry litter operations, in which
chicken litter is collected and stored in watertight
cement pits below the bird cages; dried for several
months; and annually removed to be sold or given
to third parties (65 percent), spread on nearby farm-
land owned or controlled by the egg producer (15
percent), or composted into mulch or pellets for
sale into the nursery or retail garden markets (20
percent). Small egg production operations (EPOs)
are more likely (75 percent) to sell their eggs to
larger operations for washing and processing,
where collection and disposal of egg wash water
is often a permitted activity. Most large EPOs store
egg wash water and spread it on land they own or
control. Although egg wash water lagoons are most
common among those who wash eggs on-site, some
operators collect egg wash water in large tanks and
haul it weekly to water treatment centers. Most
UEP farmers are large enough (having more than
100,000 birds) to be defined as concentrated ani-
mal feeding operations (CAFOs) under the Clean
Water Act (CWA). Under current permitting pro-
cedures and CWA regulations, only 12 percent of
egg production farms operate under the federal
National Pollution Discharge Elimination System
(NPDES) permits (although the majority operate
under state and/or local permits and requirements).
The Experiment: The XL project proposed by
UEP uses a less costly and less complex mecha-
nism—a general permit and an environmental
management system (EMS)-based program—to
secure superior environmental results. This project
is designed in anticipation of EPA's final NPDES
CAFO regulations, which were proposed in Janu-
ary 2001 (public comment period closed July 30,
2001) and are slated for promulgation in 2003. It
is UEP's understanding that the final CAFO regu-
lations may well require most UEP members, due
to their size, to obtain individual NPDES permits.
In lieu of obtaining an individual permit, this
project includes a comprehensive program to help
participating facilities achieve superior environ-
mental performance by implementing an EMS
through a general permit issued by individual states
or EPA. Because the new CAFO rules are not due
to be promulgated until 2003, this project brings
egg-producing facilities under an NPDES general
permit that includes superior environmental per-
formance through the implementation of EMSs
several years earlier than otherwise would have
occurred. This innovative project, which will also
include a third-party auditing component, will uti-
lize those common procedures and on-farm man-
agement practices most likely to result in superior
environmental performance. EPA, working with
UEP, states, and others, developed a model gen-
eral permit that states can choose to adopt where
they are the permitting authority. EPA will use the
general permit and the EMS program requirements
in states where it continues to administer the pro-
gram.
The Flexibility: In exchange for implementation
of an EMS subject to third-party audits on an an-
nual basis, participating egg-producing facilities
will be subject to NPDES general permits rather
than individual permits anticipated under EPA's
new CAFO rules to be promulgated in 2003.
The Superior Environmental Performance:
It is anticipated that the superior environmental per-
formance from this project will result from egg-
producing facilities participating in a more
comprehensive program that is based on (I) com-
pliance with a NPDES general permit, including
appropriate land application of manure; (2) devel-
opment and implementation of a multimedia EMS
that helps reduce environmental impacts from ac-
tivities that are not regulated under conventional
NPDES permits; and (3) ongoing audits of EMSs
by an independent third party, in addition to rou-
tine NPDES compliance inspections.
-------
Progress in Meeting Commitments
(As of October 2001)
• Participants in this project committed to col-
lecting, analyzing, and presenting information
that examines the effectiveness of using best
management practices to help protect water
quality. All parties committed to environmen-
tal performance indicators that will help indi-
cate the degree to which the project is
succeeding in meeting its superior environmen-
tal performance goals. These goals are listed
in the Table 16.
In addition, the UEP, EPA, and the states have made
the following commitments.
UEP
• UEP committed to develop detailed guidance
to assist individual facilities in developing all
of the elements of an acceptable EMS. One
component of the guidance will be a "Model
EMS Template for Egg Producers."
- UEP has completed the guidance for indi-
vidual egg producers entitled: "Design-
ing and Implementing an EMS: A
Step-by-Step Instruction for Egg Produc-
ers Participating in the UEP XL Project to
Develop and Implement an Environmen-
tal Management System."
• UEP committed to developing an EMS Train-
ing and Technical Assistance Action Plan.
- UEP provided training workshops on the
XL project and on developing an EMS at
their October 2001 annual meeting. UEP
will also co-host Regional Workshops on
the XL project, as necessary, across the
country that will provide additional infor-
mation and project support for egg pro-
ducers. The first of these workshops was
held on September 28, 2001, in Dallas,
Texas.
• UEP committed to developing a third-party
EMS auditing program. At a minimum, this
program will include (1) necessary qualifica-
tions of auditors, (2) training to ensure auditor
competency, (3) protocols and other written
tools used to conduct the audits, (4) sample
audit finding reports to be used when sharing
information with regulatory agencies and lo-
cal stakeholders, and (5) the method UEP will
use to oversee the operation of the auditing
program.
- Working with EPA and America's Clean
Water Foundation, UEP has completed a
Third-Party Audit Checklist for the UEP
XL Project and Training Guide for XL
Auditors. Trained auditors employed by
the non-governmental organization,
America's Clean Water Foundation, will
conduct the audits and oversee the audit-
ing program.
• UEP committed to develop an outreach pro-
gram designed to help off-site users of manure
from egg producers manage this manure in an
environmentally responsible manner.
- UEP has drafted Know How Much You
Haul and Use, a worksheet and manure
nutrient credit calculator for determining
off-site manure spreading rates. This tool
will be field-tested and improved as
needed for use in 2002. This tool also will
be demonstrated in the UEP training work-
shops and featured in UEP newsletters.
EPA
• EPA committed to offer NPDES general per-
mits to qualified facilities in states that are not
authorized to administer the NPDES program.
- EPA is developing a general permit for two
states, New Mexico and Oklahoma, that
have not been delegated the NPDES pro-
gram. Additional non-delegated states
may also participate in this manner.
• EPA committed to perform a national compli-
ance screen of all egg-producing facilities to
identify those facilities that would not be eli-
gible to participate in the program.
- The national compliance screen is under-
way for all egg producing facilities.
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"Table i<5: £^m/i^oe\men+al Performance CTndica+ors for +Ke lAcSP ,XJ— T-Vojec+
Indicator Measure Source(s) Frequency Status
1. Extent of
state
participation
Extent of egg
producer
participation
3.
Value of UEP
expanded
industry
education
program
Number of
states issuing XL
general permits
Number of egg
producers granted
XL NPDES
general permits
Association of
States and
Water Interstate
Pollution Control
Administrators,
Regional EPA
Administrators, UEP
America's Clean
Water Foundation
(ACWF)
Annually, on
anniversary of
FPA signing
Annually
UEP
UEP promotion of
an education
program through:
-number of fact sheets
and employee training materials;
-number of seminars, workshops
and XL presentations;
-number of seminars, workshops
and XL presentations;
-number of newsletters
and articles on key XL topics;
-survey indications that third-party
manure users program is perceived
as valuable
Annually
Several states have
committed to moving
forward with the process
to issue a general permit
for egg producers in their
states.
In August 2001, more than
80 egg producers signed
a petition, circulated by
UEP, indicating a
commitment to participate
in the project.
To date, UEP has featured
the XL project at its Area
Meetings (held in August
2001) and discussed the
project at its Annual
Meeting in October 2001.
A training session on the
XL project took place
at the UEP Annual
Meeting in October 2001.
Value of
on-farm
assessments
First-time audit
success rate for
producers who
underwent pre-audit
assessments vs.
those who did not
ACWF, UEP
Annually
Data are pending.
5. Environmental
improvements
Evidence that EMS
systems and practices
have reduced negative
impacts on the
environment and
enjoyment of property
by surrounding locale
of farms
States, UEP, ACWF Annually
Data are pending.
6. Continued MS
implementation
among XL
participants
7. More rapid
adoption of
Comprehensive
Nutrient
Management
Plans (CNMPs)
by participating
facilities vs. others
Absence of:
follow-up audit,
failures, state actions,
loss of general permits
Number and
percentage of
UEP manure/
egg wash user
facilities with CNMPs
States, UEP, ACWF Annually
UEP, ACWF
Annually
8. Regulatory
compliance by
XL participants
Compliance rates
of XL participants
States, EPA
Annually
Data are pending.
Data are pending.
Data are pending.
-------
• EPA committed to provide advice to UEP to
assist in achieving the objectives of the FPA.
- EPA has agreed to co-host a series of re-
gional workshops to educate producers
about the UEP XL project and solidify
their participation. The first of these work-
shops took place on September 28, 2001,
in Dallas, Texas. Additional workshops
will take place, as necessary, in late 2001
and early 2002.
The States
• The participating states in this program com-
mitted to issuing NPDES general permits un-
der their applicable state statutes and
regulations that are consistent with the model
NPDES general permit and will use the EMS
guidance developed under this project to
supplement their NPDES general permits.
- Several states have begun the process for
developing a general permit for egg pro-
ducers in their state. These states include
Illinois, Minnesota, Colorado, Florida, and
Utah.
Benefits for the Environment
• EMS requirements for this project will help
egg-producing facilities to remain in compli-
ance and improve areas of their production that
need attention. It will also help ensure that
well-functioning facilities continue to perform
at high levels and continue to address envi-
ronmental issues of concern, and not just those
issues related to water quality.
• By utilizing trained independent auditors, more
oversight of egg-producing facilities can take
place than would be possible with just federal
and state resources. The results of audits, in-
cluding areas where improvements are needed,
will be shared by UEP with other smaller fa-
cilities that may fall below the regulatory
threshold but nonetheless could use the infor-
mation to reduce their environmental impacts.
• UEP urges all egg producers to undergo a vol-
untary, comprehensive on-farm assessment by
America's Clean Water Foundation prior to
commencement of EMS development under
the XL project. Thirty percent of UEP mem-
bers have already undergone these comprehen-
sive assessments and are using the information
to reduce their environmental impacts.
The inspection and oversight of environmen-
tal management will be expanded to a new and
previously unregulated set of EPOs. Currently,
only a portion of EPOs are fully inspected by
regulatory agencies. Facilities participating in
this program will be subject to EMS audits on
a regular basis.
Benefits for Stakeholders
• This project brings together a number of di-
verse groups—EPA, states, UEP, and a vari-
ety of non-governmental organizations—to
help plan the appropriate tools and guidance
necessary for egg producers to promote and
achieve superior environmental performance
at their facilities. UEP continues to work with
key egg production states to educate them on
the program and encourage them to participate
by issuing general NPDES permits for egg pro-
ducers.
• This project provides for greater local input
than is available under EPA's existing NPDES
general permitting regulations. A requirement
of participation in the XL program is to main-
tain ongoing communications with neighbors
and the public. Local communities surround-
ing egg-producing facilities will be able to
access environmental performance information
about the egg producing facilities in their com-
munity on an ongoing basis from their respec-
tive states through EMS audit results.
Benefits for the Project Sponsor
• The XL program, complete with an EMS,
third-party auditing, and a general NPDES per-
mit, will ultimately be a less complex mecha-
nism and less costly system than obtaining
individual NPDES permits for each facility.
Initially some facilities may incur additional
costs in making improvements to their facili-
ties in order to qualify for participation.
-------
• The continuous improvement aspect of the XL
program is tailored to meet the long-term needs
of the egg-producing industry and provides in-
centives for the industry's large egg producers
to maintain superior facilities and practices.
Information Resources: The information in this
summary is taken from the following sources: (1)
The United Egg Producers FPA, signed October
25, 2000; (2) The Project XL Comprehensive Re-
port, Volume 2: Directory of Project Experiments
and Results, November 2000; and (3) the United
Egg Producers Project XL Proposal.
-------
U.S. Poslal Service.
Denver
Final Project Agreement Signed May 22, 2000
Background
The Project Sponsor: With more than 200,000
vehicles nationwide driving more than 1.1 billion
miles annually, the U.S. Postal Service (USPS) has
the nation's largest civilian fleet of vehicles. USPS
has been working for many years to test and pilot
alternative fuels and technologies across the coun-
try, including electric vehicles, vehicles that run
on compressed natural gas (CNG), and flexible fuel
vehicles (FFVs) that can run on either gasoline or
ethanol. Nationwide, the USPS currently has more
than 7,500 vehicles that use CNG, and they have
purchased more than 21,000 FFVs. By 2002, the
USPS expects its fleet of alternative fuel vehicles
to exceed 30,000. The USPS is undertaking ef-
forts to maximize the amount of clean fuels they
use in order to reduce their contribution to air pol-
lution, particularly in urban areas. They are in a
position to establish greater visibility and infra-
structure growth for clean fuels because of the size
of their fleets.
Denver, Colorado, including parts of six adjacent
counties (Adams, Arapahoe, Boulder, Denver,
Douglas and Jefferson) is currently classified as a
nonattainment area for carbon monoxide (CO)
under the Clean Air Act (CAA), but the region is
in the process of petitioning for attainment status.
In accordance with CAA regulations, states with
ozone and CO nonattainment areas are required to
implement a Clean Fuel Fleet Program (CFFP).
CFFPs aim to improve air quality by encouraging
institutions with fleets of vehicles, such as the
USPS, to use cleaner-burning and less-polluting
vehicles.
The Experiment: This project is examining an
innovative approach to managing a new fleet of
FFVs for the USPS. The Colorado CFFP requires
that new vehicle fleet purchases consist of at least
50 percent low-emitting vehicles (LEVs). The
USPS was unable to find a supplier when it re-
quested bids for the required number of LEVs.
Because LEVs are not available to meet the USPS's
special needs, the Postal Service has proposed they
replace current fleet vehicles with FFVs that can
run on either gasoline or E-85, a mixture of 85
percent ethanol and 15 percent gasoline, or any
combination of the two. Compared with gasoline-
fueled vehicles, most E-85-fueled vehicles produce
lower CO and carbon dioxide (C02) emissions (as
much as 39 to 46 percent lower CO,). Emissions
of hydrocarbons and nitrous oxides are generally
the same as, or even lower than, gasoline-powered
vehicles. While these FFVs do not meet federal
standards as LEVs, they are certified as Transi-
tional Low-Emitting Vehicles (TLEVs) that have
lower emissions than standard vehicles, but not as
low as the LEVs.
The USPS will test whether FFVs can effectively
meet the goals of the CFFP The USPS expects to
demonstrate lower overall emissions, because 100
percent of vehicles replaced will be TLEVs, in-
stead of only 50 percent of the replacements being
LEVs. The USPS plans to concentrate 810 FFVs
in the City of Denver. For each E-85 vehicle that
the USPS deploys in Denver, it has agreed to re-
move either a pre-1984 vehicle or a 1987-1991
vehicle from service in the Denver area. The USPS
projects that, as a result of this project, 512 pre-
1984 delivery vehicles will be destroyed.
The Flexibility: The FFVs being acquired by the
USPS do not meet current Colorado CFFP require-
ments as LEVs. Therefore, the USPS has requested
flexibility in meeting the standards and acquiring
pollution credits from the Colorado Department
of Public Health and Environment's (CDPHE's)
Air Pollution Control Division (APCD). Under
current pollution credit requirements, USPS would
not be eligible to receive credits for the purchase
of non-LEV vehicles even though substantial pol-
lution will be prevented with the FFVs (TLEVs)
and retirement of older vehicles. With this XL
project, the APCD will offer the USPS credits for
the purchase of TLEVs accompanied by the re-
moval of existing vehicles. No federal flexibility
is required for the implementation of this project.
Other Innovations: (1) Demonstration of Etha-
nol Tank Conversion. The USPS has developed
-------
technical specifications for modifying an existing
underground storage tank to properly house E-85
fuel and converted one of its fuel underground stor-
age tanks to hold E-85 fuel in January 2001. This
modified underground storage tank can provide
fuel for approximately 70 vehicles and will serve
as a demonstration project for public evaluation
of alternative fuel storage. (2) Encouraging De-
velopment of an Ethanol Infrastructure. The USPS
is committed to helping stimulate the development
of a Denver-area E-85 infrastructure to support its
vehicles. This infrastructure will also be avail-
able to the public. The addition of over 800 ve-
hicles in the Denver region that use E-85 fuels will
provide a significant market incentive for indi-
vidual fuel stations to provide E-85 fuels. The
USPS will work with the National Ethanol Vehicle
Coalition to identify and encourage fueling stations
to install E-85 fueling tanks. (3) Public Education
and Awareness. The use of over 800 FFVs in a
relatively small area will provide an active and
visible demonstration of this emerging technology.
USPS delivery vehicles will be present in hundreds
of neighborhoods on a daily basis. FFV technol-
ogy will generate media attention that can be used
to inform the public about the availability of this
new technology and its flexibility of operation us-
ing different fuels. (4) Transferability. The USPS
project could serve as a model for vehicle fleets
across the country in replacing older vehicles with
alternative fuel vehicles and developing an E-85
infrastructure. As the project proceeds, there will
also be an opportunity to examine and evaluate the
opportunities and barriers in developing and main-
taining an E-85 fueling infrastructure.
The Superior Environmental Performance:
The following are the projected environmental ben-
efits that are expected from this project:
• A significant decrease in USPS's contribution
to vehicle emissions within the Denver metro-
politan area. The model year 2000 vehicle
engines are cleaner burning and more fuel-ef-
ficient than the older model year vehicle en-
gines they are replacing. For example, each
of the vehicles to be replaced emits 250 pounds
per year more CO than each of the replace-
ment FFVs. The net emissions reduction over
a 20-year life cycle is estimated to be 432 tons
of CO, 24 tons of hydrocarbons, and 10 tons
of nitrogen oxides.
• Reduction in evaporative emissions of hazard-
ous chemical constituents (e.g., benzene) as-
sociated with unleaded fuel dispensing.
• Increased market demand for E-85 fuel, both
through the USPS's addition of the approxi-
mately 800 vehicles and the publicity that the
project will provide regarding alternative fuel
vehicles. These two factors will provide eco-
nomic incentives for retail fuel providers to
convert existing gasoline storage tanks to E-
85 storage tanks. The USPS's involvement in
Project XL and the Colorado Environmental
Leadership Program (CELP) are expected to
increase the visibility and promote the uses of
E-85 and alternative fuel vehicles. Addition-
ally, as the commercial availability of E-85
increases, the purchase of dedicated alterna-
tive fuel vehicles, including FFVs and those
that meet LEV or cleaner emissions standards,
by vehicle fleets and private individuals will
increase, thereby reducing mobile source emis-
sions further.
• Creation of a USPS alternative fuel vehicle
model for metropolitan areas that could be ex-
panded and applied to other areas.
Progress in Meeting Commitments
(As of August 2001)
• The USPS committed to joining CELP.
- USPS joined the CELP in May 2000.
• The USPS committed to taking delivery of at
least 794 USPS FFVs certified as TLEVs ca-
pable of operating on either unleaded gasoline
or E-85. For each E-85 vehicle deployed in
the Denver area, the USPS will remove or
transfer an older, more polluting vehicle within
120 days. Furthermore, 512 pre-1984 vehicles
will be scrapped, and 282 1987-1991 vehicles
will be relocated outside the Denver
nonattainment area.
- Delivery of vehicles began in November
2000; 500 new FFV vehicles have been
delivered to date.
-------
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- To date, 278 vehicles have been destroyed
and 208 vehicles have been relocated.
• The USPS committed to helping stimulate the
development of a Denver area E-85 infrastruc-
ture to support its vehicles, which would also
be available to the public.
- Conversion of a USPS underground stor-
age tank to accommodate E-85 was com-
pleted in January 2001. The USPS intends
to use the tank to operate at least 71 postal
vehicles on E-85.
• Whenever purchased, replacement vehicles
will meet or exceed California TLEV certifi-
cation standards. If the fleet size is expanded,
new vehicles will meet or exceed federal Tier
1 certification standards.
- 500 replacement vehicles have been de-
livered. No fleet expanding vehicles have
been purchased at this time.
• Six months after delivery of the first E-85 ve-
hicles, the USPS committed to submitting a
semiannual report to CDPHE and the EPA.
Thereafter, the USPS will submit an annual
report.
- The USPS submitted a semiannual report
in May 2001.
CDPHE committed to proposing an amend-
ment to the Air Quality Control Commission
Regulation Number 17 that will clarify the
provision of emission credits as an incentive
for the CELP.
- The amendment was adopted March 16,
2000, and went into effect May 30, 2000.
• EPA will consider the submission of certain
parts of this project by the CDPHE as a sub-
stitute for the Clean Fuel Vehicle Program pre-
scribed under part C of subchapter II of the
CAA as a revision of the Colorado State Imple-
mentation Plan (SIP) after the USPS has re-
ceived at least 794 FFV vehicles.
- EPA published a proposed rule in the Fed-
eral Register on August 22,2001. The rule
proposed the acceptance of the SIP revi-
sion and the substitution of the USPS
project for Colorado's CFFP
Benefits for the Environment
• The USPS conversion to E-85 vehicles will
result in significantly lower emissions. Net
emissions reduction over a 20-year life cycle
is estimated to be 432 tons of CO, 24 tons of
hydrocarbons, and 10 tons of nitrogen oxides.
• The increased visibility of E-85 vehicles con-
centrated in the Denver region may increase
market demand for alternatively fueled ve-
hicles.
Benefits for Stakeholders
• Denver area residents wil 1 benefit from cleaner
air and fewer emissions from USPS delivery
vehicles.
• Residents with FFVs may benefit from ex-
panded E-85 infrastructure in the region.
Benefits for the Project Sponsor
• With the flexibility offered by this project,
USPS can purchase new fuel-efficient vehicles
(TLEVs) instead of continuing to operate its
existing older, more polluting, vehicles.
• If purchased FFV vehicles run on ethanol
rather than gasoline, USPS may accumulate
emissions credits that can be applied toward
fleet expansion.
Information Resources: The information in this
summary was obtained from the following sources:
(1) the FPA for the USPS Denver XL Project,
signed May 22, 2000; (2) supplementary proposal
materials; (3) Regulation Number 17: Clean Fuel
Fleet Program, Colorado Air Quality Control Com-
mission (last adopted 1/11/01 and effective 3/2/
01); (4) U.S. Department of Energy Alternative
Fuel News stories; (5) USPS press releases and
Web site; and (6) the 2000 Project XL Compre-
hensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
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V)
-t-
-------
Once finalized, the State of Minnesota will
issue permits under the Minnesota's XL stat-
ute to electroplating manufacturers and trans-
porters that have signed the FPA and agreed to
the conditions of the regulations.
• Electroplating waste generators and transport-
ers will commit to conditions spelled out in
the site-specific rule.
• USFilter has committed to the following as the
project is implemented:
- USFilter will submit an annual report on
October 1 on all USFilter XL wastes. It
will provide information separately for
each USFilter XL waste generator.
- USFilter will submit a quarterly report to
EPA, Minnesota Pollution Control
Agency, and the county agencies on Octo-
ber 1, January 1, April 1, and July 1. It
will include information regarding supe-
rior environmental performance of the
project, financial information, an updated
list of all USFilter XL Waste Approved
Customers and Generators, and a list of
all USFilter XL Waste Approved Trans-
porters. USFilter will also report on the
extent to which communication with pub-
lic stakeholders has been maintained
throughout the project.
- USFilter will collect baseline performance
information from each customer's facility
participating in the project.
- USFilter will use a Transportation Track-
ing Document for tracking of waste ship-
ments from customer facilities to
USFilter's facility.
Benefits for the Environment
• I mplementation of the ion exchange system can
result in an increase in the recovery and recy-
cling of metals from electroplating operations,
a reduction in the amount of hazardous chemi-
cals that are discharged to the local POTWs,
and a reduction in the amount of water used in
the electroplating manufacturing process.
Benefits for Stakeholders
• For communities with industrial participants
in this project, off-site discharge and disposal
of wastewater and sludge containing heavy
metals would be reduced.
Benefits for the Project Sponsor
• Through this XL project, USFilter will be able
to offer its customers a means of reducing their
water consumption and increasing the recov-
ery of metals from their industrial processes,
while removing the trigger of increased regu-
latory burden.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the USFilter XL Project, signed Sep-
tember 21,2000; and (2) the 2000 Project XL Com-
prehensive Report, Volume 2: Directory of Project
Experiments and Results, November 2000.
-------
Waste ./Ws^ogemervt,
Dnc.., Vi i^ginia
Landfills Bio^e.a
-------
settlement and other environmental parameters.
This project will also provide EPA with the op-
portunity to obtain data on the differing impacts
that geography, climate, construction, design, main-
tenance, and waste streams may have on the per-
formance of a bioreactor system.
The Superior Environmental Performance:
WMI's commitment to develop and test bioreactor
technologies at its Maplewood and King George
facilities strives to demonstrate improved pollu-
tion prevention methodologies in comparison to
current RCRA-permitted municipal solid waste
disposal methods currently in use. The following
superior environmental benefits are expected with
this project:
• Landfill Life Extension: The life of a landfill,
when operated as a bioreactor, should be ex-
tended due to the biodegradation of the waste.
This more rapid biodegradation increases the
apparent density and decreases the volume of
the in-place waste remaining in the landfill.
Reducing the volume of the waste translates
into either longer landfill life in place and/or
less of a need for additional landfill space.
• Minimizing Long-Term Leachate, Groundwa-
ter, and Surface Water Concerns: Research
has shown that bioreactor processes tend to
reduce the concentration of many pollutants
in leachate, including organic acids and other
soluble organic pollutants. Since a bioreactor
operation brings pH to near-neutral conditions,
metals of concern are largely precipitated and
immobilized in the waste.
• Increasing Landfill Gas Control: While add-
ing liquids to the landfills will increase the rate
of the gas generation, the period of landfill gas
generation will be compressed. WMI plans to
take advantage of this by exploring use of the
landfill gas as a fuel for producing electrical
power. This is expected to further minimize
fugitive methane and volatile organic com-
pound emissions from the landfills.
PRECIPITATION,
LIQUID
TRANSMISSION LINE
INFILTRATION
PROCESS FLOW DIAGRAM - BIOREACTOR
KING GEORGE COUNTY LANDFILL AND RECYCLING CENTER - KING GEORGE COUNTY, VIRGINIA
AND
MAPLEWOOD RECYCUNG AND WASTE DISPOSAL FACILITY - AMELIA COUNTY, VIRGINIA
LEACHATE
REMOVAL LINE
*e 49
Bioreactor process flow diagram for King George and Maplewood.
-------
Progress in Meeting Commitments
(As of August 2001)
WMI, EPA, and the Virginia Department of Envi-
ronmental Quality (VADEQ) are in the prelimi-
nary stages of complying with the environmental
commitments for this project. They have agreed
to the following commitments in the FPA:
• EPA committed to propose and issue a site-
specific rule amending 40 CFR Part 258.28 for
Amelia and King George counties to allow re-
circulation of leachate over cells constructed
with an alternative liner.
• VADEQ committed to hold public hearings in
respective localities as part of the amendment
process for the current solid waste permits.
• VADEQ committed to provide for landfill gas
monitoring, record keeping, and reporting re-
quirements, for the bioreactor testing under
their Title V air permitting program. The Title
V Permit for the King George landfill was
signed on July 31, 2001. The Title V Permit
for the Maplewood landfill is under develop-
ment.
• WMI committed to install trench systems and
gas management structures at the Maplewood
and King George landfills. This will be done
during implementation of the bioreactor test-
ing.
• WMI committed to provide semiannual and
annual groundwater, surface water, and gas
monitoring reports to VADEQ for review.
WMI committed to meet periodically with rep-
resentatives from each stakeholder group to
discuss issues of concern and to disseminate
information.
Benefits for the Environment
• By utilizing the bioreactor technology, WMI
will be able to accelerate the biodegradation
of organic constituents in wastes at its facili-
ties, thereby reducing source contamination in
the landfills and minimizing the threat to
groundwater sources and surface water.
• The bioreactor technology will result in an in-
creased rate of waste stabilization, resulting
in increased waste disposal capacity and the
delay or avoidance of siting a new waste dis-
posal facility.
Benefits for Stakeholders
• Throughout the evolution of the project, stake-
holders have been involved in and informed
about this project and have been encouraged
to share their ideas and concerns through writ-
ten comments and meetings open to the gen-
eral public, providing residents access to
information and decisions regarding the
project.
• The information obtained from this project will
provide EPA and the waste disposal industry
with more data on bioreactors and their use as
a potentially integral part of long-term opera-
tions at these and other municipal solid waste
landfill sites.
Benefits for the Project Sponsor
• Implementing bioreactor operations at the
Maplewood and King George facilities will
result in several direct economic benefits to
WMI through: (1) decreased leachate manage-
ment costs resulting from an increase in the
amount of leachate being consumed in
bioreactor landfill, and (2) increased disposal
capacity due to an increased and more rapid
stabilization of waste in a bioreactor system.
Informational Resources: The information in
this summary comes from the following sources:
(1) the FPA for the Waste Management, Inc., Vir-
ginia Landfills Bioreactors Project, signed Septem-
ber 29, 2000; and (2) the 2000 Project XL
Comprehensive Report, Volume 2: Directory of
Project Experiments and Results, November 2000.
-------
We yerkaewser
Company^ Pi inf River
Ope rati on
Final Project Agreement Signed January 17, 1997
Background
The Project Sponsor: The Weyerhaeuser Com-
pany is one of the largest private owners of forest,
with 5.4 million acres in the United States. Among
its products are timber, paper, and pulp.
Weyerhaeuser's Flint River pulp manufacturing
facility in Oglethorpe, Georgia, manufactures
320,000 tons per year of absorbent fluff pulp used
in diapers. The facility was opened in 1981 and is
located 100 miles southwest of Atlanta, Georgia.
The Experiment: Weyerhaeuser is striving to
minimize the environmental impact of its manu-
facturing processes on the Flint River and the sur-
rounding environment by pursuing a long-term
vision of a minimum impact mill. "Minimum im-
pact manufacturing" (MIM) contains the elements
of a comprehensive pollution prevention program
designed to minimize the use of raw materials and
to stop waste generation rather than to rely on "end-
of-pipe" remedies. MIM involves multi-
disciplinary teams employing a systems engineer-
ing approach, waste reduction, and a commitment
to continuous improvement rather than the more
traditional "project" focus. Specifically, the
Weyerhaeuser project tests a facility-wide permit-
ting approach addressing water effluent discharges,
air emissions, and solid waste generation that is
designed to promote the MIM concept.
The Flexibility: EPA Region 4 and the State of
Georgia have revised Weyerhaeuser's National
Pollution Discharge Elimination System (NPDES)
permit both to include more stringent effluent lim-
its on biological oxygen demand (BOD), total sus-
pended solids (TSS), and absorbable organic
halides (AOX), and to streamline the permit re-
newal process. EPA Region 4 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 dis-
solving tank, calciner (a type of industrial kiln),
and combination boiler (the facility's four major
sources of emissions) to be operated to their de-
sign capacity without triggering permit review and
(2) a cap covering all facility sources except those
four major sources. The dual emission caps con-
tain separate limits for particulate matter (PM),
sulfur dioxide (S02), nitrogen oxides (NOx), car-
bon monoxide (CO), volatile organic compounds
(VOCs), and total reduced sulfur (an odor-caus-
ing pollutant). The modified air quality permit also
streamlines the permit renewal process, includes
alternate excess emission reporting protocols, and
includes a protocol for conducting manufacturing
process experiments without triggering a permit
review. EPA Region 4 and the State of Georgia
have agreed to provide Weyerhaeuser the flexibil-
ity to demonstrate hazardous air pollutant (HAP)
emission reductions that would use innovative
pollution prevention approaches rather than end-
of-pipe HAP controls. Weyerhaeuser prepared an
alternative compliance plan that presented the HAP
emission reductions to be achieved by the facility
following the April 15, 1998, promulgation of the
maximum achievable control technology (MACT)
cluster rule for the pulp and paper industry. EPA
used a site-specific rule making to authorize alter-
native MACT compliance. EPA Region 4 and the
State of Georgia will modify Weyerhaeuser's solid
waste permit to allow nonhazardous industrial
wastes containing free liquids to be disposed of in
a permitted, onsite landfill.
Other Innovations: (1) Reporting Burden Reduc-
tion. The Weyerhaeuser project allows the facil-
ity to consolidate reporting for some of the
applicable federal, state, and local permitting and
regulatory programs into two comprehensive re-
ports each year. Also, the facility is allowed to
eliminate fish tissue sampling requirements due to
improvements in process technologies that have
eliminated detectable dioxin levels in effluents,
remove a requirement for additional assimilative
capacity studies, and perform annual compliance
certification in lieu of periodic discharge monitor-
ing reporting due to the company's 16-year his-
tory of meeting all required discharge levels. (2)
Environmental Management System (EMS).
Weyerhaeuser will voluntarily institute an ISO
14001 EMS at the Flint River facility. The facility
-------
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is developing a comprehensive procedures manual
that conforms to the ISO 14001 standard, which
will, in turn, provide data for EPA's evaluation of
options for an Agency policy on EMSs. (3) Best
Management Practices. Weyerhaeuser will also
reduce solid and hazardous waste generation and
improve forest management practices in more than
300,000 acres of timberland. EPA will participate
in review and evaluation of feasibility studies with
potential applicability of results across the pulp
and paper industry.
The Superior Environmental Performance:
Weyerhaeuser will (1) reduce allowable air emis-
sions by 60 percent under the dual emissions caps,
(2) work toward a goal of cutting bleach plant ef-
fluent by 50 percent over a 10-year period, (3) re-
duce water usage by 1 million gallons a day
(MGD), (4) cut solid waste generation by 50 per-
cent over a 10-year period, and (5) prepare and
implement a facility-wide plan to reduce energy
use.
Progress in Meeting Commitments
(As of September 2001)
• Overall, Weyerhaeuser has been very success-
ful in meeting its environmental commitments
under the project.
- Weyerhaeuser's site-wide air quality per-
mit for the Flint River facility in
Olgethorpe, Georgia, includes dual emis-
sion caps for air pollutants. The follow-
ing caps are based on a 60 percent
reduction from the levels a standard per-
mit would allow—PM at 589 tons per year,
total reduced sulfur at 62 tons per year,
SO, at 879 tons per year, NOx at 1,300 tons
per year, CO at 2,516 tons per year, and
VOCs at 778 tons per year. In 1998, the
Flint River facility's actual emissions were
the following: PM at 390 tons, total re-
duced sulfur at 33 tons, SO, at 582 tons,
NOx at 795 tons, CO at 1,573 tons, and
VOCs at 652 tons. In 1999, the Flint River
facility's actual emissions were the follow-
ing: PM at 390 tons, total reduced sulfur
at 33 tons, SO, at 582 tons, NO at 795
'2 ' x
tons, CO at 1,573 tons, and VOCs at 632
Weyerhaeuser - Particulate Matter
2000 Actual
J433
1999 Actual
' 395
1998 Actual
|390
1997 Actual
1385
1996 Actual
1423
1995 Actual
[ 457
Emissions Cap
J 589
Effective 12/97
Standard Permit
. .
0 300 600 900 1,200 1,500
Tons per Year
Piguce 50
PM emissions data.
-------
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tons. In 2000, the Flint River facility's
actual emissions were the following: PM
at 443 tons, total reduced sulfur at 35 tons,
SO, at 405 tons, NOx at 826 tons, CO at
1612 tons, and VOCs at 646 tons (See fig-
ure 50). Weyerhaeuser will report the 2001
actual emission values at the end of 2001.
Weyerhaeuser will (1) reduce the allow-
able air emissions by 60 percent under the
dual emission caps and (2) continue to look
for new developments that may help reach
the goal of reducing bleach plant effluent
by 50 percent over a 10-year period.
Weyerhaeuser has committed to research-
ing the feasibility of implementing future
technological developments in the indus-
try that may allow the facility to reduce
its bleach plant effluent flow by 50 per-
cent to 10 cubic meters per air dried met-
ric ton (ADMT) of finished product (fluff
pulp used to make diapers) by the year
2006 (see Figure 51). The environmental
benefits projected include a reduction in
water usage (the bleach plant accounts for
approximately half of the plant's water
usage) and reductions in effluent limits on
BOD, TSS, and AOX. To reach its goal,
Weyerhaeuser has conducted feasibility
studies on reducing its water use. Al-
though attainment of this goal is not cur-
rently feasible, technological innovations
continue to be assessed. An ultrafiltration
pilot test has been completed at another
Weyerhaeuser facility. The results of the
pilot study are being evaluated for possible
further feasibility in reducing bleach plant
effluent flow at the Flint River facility.
Weyerhaeuser already has modernized
several components of the pulping process,
reducing the amount of BOD and TSS in
bleach plant wastewater. The facility's
January 1998 NPDES permit allows the
discharge of 3.8 pounds of BOD per
ADMT of finished product and 4.09
pounds of TSS per ADMT of finished
product. In 1998, the facility reduced BOD
in its effluent to 2.13 pounds per ADMT
and TSS in its effluent to 2.80 pounds per
ADMT. In 1999, the BOD in effluent
Weyerhaeuser - Bleach Plant Flow
2001 YTD
(1/01-6/01)
FPA Goal
by 2006
Baseline (1993-95
monthly averages)
9 10 11 12 13 14 15 16 17 18 19 20 21
Cubic Meters per Air-Dried Metric Ton of Finished Product
"igwre 51
Bleach plant flow data.
Weyerhaeuser - Biological Oxygen Demand
2001 YTO
(1/01 -«/01)
2000 Actual
1999 Actual
1998 Actual
1997 Actual
'Permit Level
Effective 1-1-98
Baseline (1993-95
monthly averages)
Allowable under
Guideline Requirements
4.83
-J
0 1 2 3 4 5
Pounds per Air-Dried Metric Tons of Finished Product
'Units used in the NPDES permit are pounds per day.
This data is collected as required by the permit and is available.
The permit level has not been exceeded.
Pigivre. 52
BOD in effluent discharge.
-------
slightly increased to 2.83 pounds per
ADMT and TSS in effluent increased to
3.87 pounds per ADMT. In 2000, the BOD
increased to 3.49 pounds per ADMT and
TSS increased to 3.92 pounds per ADMT.
For the first half of 2001, Weyerhaeuser
reported discharging 3.97 pounds per
ADMT of BOD and 5.21 pounds per
ADMT of TSS (see Figures 52 and 53).
Both BOD and TSS were higher than the
Phase IV goals during these six months as
they usually are for the first half of the year.
During the late summer and fall of the year,
the holding pond is steadily filled to re-
main within the NPDES permit for efflu-
ent color while the river flow is extremely
low. In January the holding pond begins
to be emptied over several months when
river volume returns. This causes the ef-
fluent volume to increase, which causes
an increase in the BOD and TSS. Even
though the results for these parameters are
higher than the Phase IV goal on a pounds
per ADMT basis, the NPDES permit lim-
its have not been exceeded (which are in
pounds per day units).
AOX results continued at a low rate (see
Figure 54). The permit also allows the dis-
charge of 0.15 kilograms of AOX per
ADMT. In the first half of 1998, absorb-
able organic halide levels peaked at 0.13
pounds per ADMT due to an increase in
customer demand for high-brightness pulp.
As a result, the facility has altered its use
of brightening chemicals in the bleach
plant area and was able to regain the
project average of 0.10 kilograms of AOX
per ADMT for 1998 overall. In 1999,
AOX remained at 0.10 kilogram per
ADMT. In 2000, Weyerhaeuser has de-
creased AOX to 0.09 kilogram per ADMT.
For the first half of 2001, AOX values have
remained at 0.09 kilogram per ADMT.
2001 YTD
(1/01-6/01)
2000 Actual
1999 Actual
1998 Actual
"Permit Level
Effective 1-1-98
Baseline (1993-95
monthly averages)
Allowable under
Guideline Requirements
Weyerhaeuser-Total Suspended Solids
5.21
3.92
3.87
0 2 4 6 8 10
Pounds per Air-Dried Metric Ton of Finished Product
'Units used in the NPDES permit are pounds per day.
This data is collected as required by the permit and is available.
The permit level has not been exceeded.
Pigu^e 53
Total suspended solids in Flint River effluent.
Weyerhaeuser - Adsorbable Organic Halides
2001 YTD
(1/01-6/01)
1999 Actual
1998 Actual
1997 Actual
1996 Actual
'Permit Level
Effective 1-1-98
Baseline (1993-95
monthly averages)
Allowable under
Guideline Requirements
0.09
0.09
0.10
0.10
0.10
0.10
0.00 0.04 0.06 0.12 0.16
Kilograms per Air-Dried Metric Ton of Finished Product
"Units used in the NPDES permit are pounds per day.
This data is collected as required by the permit and is available.
The permit limit has not been exceeded.
Figure 54
Adsorbable organic halides in effluent discharge.
Weyerhaeuser also committed to reduce
the facility's use of water from the Flint
River to an 11.5-MGD monthly average,
which, in turn, will reduce the quantity of
treated wastewater discharged back into
the river. Weyerhaeuser's long-term goal
-------
is to further reduce total water withdrawal
voluntarily (see Figure 55). Baseline wa-
ter withdrawal at the facility was a 11.18
MGD monthly average based on average
monthly values for 1993 through 1995.
Water use reductions anticipated from
modernization projects were not sufficient
to offset increased water usage from other
facility process areas, which resulted in
1997 raw water use of a 11.74 MGD
monthly average. In 1998, the total usage
returned to a 11.49 MGD monthly aver-
age through the daily water conservation
focus of the production operators. In 1999,
the water use increased to a 11.92 MGD
monthly average. The primary cause for
this increase was a customer demand for a
higher-brightness pulp. In January 2000,
the Flint River facility initiated several
water usage reforms that have reduced av-
erage daily water usage. In 2000, the total
water usage was 11.11 MGD. In August
2000, the plant submitted an application
to the Georgia Environmental Protection
Division to lower the Surface Water With-
drawal Permit limit by 1.0 MGD. This
application was approved. Water usage
was 11.28 MGD for the first half of 2001.
In the second half of 2001, Weyerhaeuser
will be evaluating a project that may lower
water usage by another 0.75 MGD.
Weyerhaeuser's goal is to reduce its 1995
level of solid waste generation by 50 per-
cent by the year of 2006 (see Figure 56).
This goal will be accomplished through
source elimination and byproduct recy-
cling and reuse. Weyerhaeuser has mod-
ernized several components of its pulping
process, which has generally reduced the
amount of solid waste generated by the
plant. The facility has begun recovering
and reusing lime mud used in its manu-
facturing processes. In 1999, waste gen-
eration was 498 pounds per ADMT, a
decrease from the baseline of 690 pounds
per ADMT. The solid waste generation
for 2000 was 489 pounds per ADMT of
production. For the first half of 2001, most
waste streams were at historically low
Weyerhaeuser - Raw Water Usage
Monthly Average
2001 YTD
(1/01-6/01)
2000 Actual
1999 Actual
1998 Actual
1997 Actual
1996 Actual
Voluntary Goal
Baseline (1993-95
monthly averages
Permit Goal
Enforceable Permit
11.28
11.11
11.92
I11'49
11.74
11.91
110.18
j 11.18
11.50
12.50
5 10
Millions of Gallons per Day
Figure 55
Raw water usage data based on monthly averages.
Weyerhaeuser - Solid Waste Generation
564
2001 YTD
(1/01-6/01)
2000 Actual
1999 Actual
1998 Actual
FPA Goal
by 2006
Baseline
(1995 level)
300 400 500 600 700
Pounds per Air-Dried Metric Ton of Finished Product
Fig wee 56
Solid waste generation from Flint River facility.
-------
levels. However, solid waste generation
for the first half of 2001 increased to 564
pounds per ADMT. Part of this increase
is due to continued problems with the
calciner. The calciner continues to run
unreliably and the frequency of descaling
operations, which produce lime mud, have
been increased, resulting in the increase
in lime mud waste product. Replacing the
calciner with a different piece of equip-
ment would greatly reduce lime mud solid
waste and overall solid waste amounts.
Weyerhaeuser is considering replacing the
calciner in long-term capital planning. The
Weyerhaeuser study of application of com-
post and some process wastes on small test
plots as forest amendments continue.
• On June 27, 2001, EPA published a final rule
(66 FR 34119)10, approving revisions to the
National Emission Standards for Hazardous
Air Pollutants, which concerns the control of
HAP emissions from the pulp and paper in-
dustry. These revisions are one of EPA's steps
to implement the FPA for Weyerhaeuser's XL
project. Operation of the plant continues un-
der this rule, which ensures that fewer HAPs
are released than if the plant operated under
the standard MACT rule. This completes the
administrative procedures for implementing
this project in the FPA.
Weyerhaeuser has feasibility studies in
progress on composting facility byproducts and
applying the composted material on timber-
lands. This trial is continuing into the third
growing season. In addition, composting of
solid waste materials has been evaluated and
successfully tested in recent years. Early in
2001, a new company policy on land-applica-
tion of residuals and solid wastes with the po-
tential to contain detectable concentrations of
dioxins and furans was implemented. The
policy discourages new endeavors in land ap-
'"Inadvertently when EPA published the final rule an June
27, 2001, the date April 16, 2001 was used in two sections of
the rule instead of the date April 16, 2002 which had been
used in the proposed rule. EPA published a technical correc-
tion on October 16, 2001 (66 FR 52537) to correct these two
typographical errors.
plication of process residuals where the com-
pany does not retain control of the use of the
residuals or the land where the residuals are
applied. The company will continue to explore
beneficial uses of the solid waste materials in
controlled settings. Further investigations of
the viability and economics of composting mill
wastes is planned to start in the second half of
2001.
• Weyerhaeuser has completed a facility-wide
energy conservation study as well as three
small-scale energy conservation studies. As
an outcome of the Energy Conservation Study,
an energy goal of 20,000 pounds of steam/
ADMT has been set. For the first half of 2001,
the recovery boiler has been running with a
new soot blower strategy. Weyerhaeuser de-
creased steam usage in the first half of 2001 to
20,140 pounds of steam/ADMT. In 2002,
Weyerhaeuser plans to replace the steam driven
chiller in the pulping unit with a more effi-
cient unit.
• Weyerhaeuser has met its commitments to up-
grade equipment, study process changes, re-
duce effluent discharges, reduce air emissions,
reduce hazardous substance use, recycle solid
wastes, implement timberland management
practices, conduct stakeholder meetings, and
prepare progress reports.
• Weyerhaeuser reorganized and documented the
Flint River EMS to conform to the ISO 14001
standard. In November 2000, an audit of the
EMS was conducted. The Lands & Timber
organization received confirmation in early
2001 that their registration audit was success-
ful and that organization is now certified to
ISO 14001. This resulted from an indepen-
dent audit by the Quality Management Insti-
tute, which is a division of the Canadian
Standards Association. This achievement is
an enhancement to the completed Phase V
project titled "Timberlands Resource Strate-
gies." In addition to certification under the
ISO 14001 EMS standard, Georgia
Weyerhaeuser forest practices have been cer-
tified to the American Forest and Paper
Association's Sustainable Forestry Initiative
standard.
-------
• In the next six months, Weyerhaeuser plans to
identify and implement water conservation
measures to drive towards the goal of 10.18
MGD total water usage. In addition,
Weyerhaeuser will continue efforts in energy
conservation to make progress toward the goal
of 20,000 pounds of steam/ADMT for total
steam usage and continue to operate the EMS
and schedule a certification audit.
Benefits for the Environment
• As of June 2001, the amount of solid waste
generated has been reduced by 30 percent.
• Over the course of the project, actual air emis-
sions of PM, total reduced sulfur, NO , and
' ' x'
CO, have been reduced with decreases rang-
ing from 17.7 percent for total reduced sulfur
to 8.3 percent for NOx.
• After initiating several energy conservation
measures by June 2001, the total plant steam
usage has decreased by 3.4 percent and the
power boiler steaming rate has decreased by
20.3 percent.
Benefits for Stakeholders
• Stakeholders have a better understanding of
facility operations.
• Stakeholders continue to have better access to
project information directly from the facility
in a simplified, consolidated report.
• Stakeholders also continue to have the oppor-
tunity to learn more about the project and its
progress in meeting project goals status by at-
tending Weyerhaeuser Company's annual
stakeholder meeting.
• The cooperative relationship between regula-
tors and the company has had benefits beyond
the company because of the company's efforts
to educate other pulp and paper facilities and
timber suppliers. Specifically, Weyerhaeuser
is working with other timber suppliers and the
Georgia Forestry Commission to promote best
management practices on timberland and plan-
tations.
• The Weyerhaeuser approach to solid and haz-
ardous waste reduction (e.g., recovering lime
mud) is providing a case study that the State
of Georgia will use with other pulp and paper
mills.
• By working directly with a state-of-the-art fa-
cility, EPA is gaining real-world information
and experience about pulp and paper facilities.
Benefits for the Project Sponsor
• Weyerhaeuser achieved an estimated savings
of $176,000 in reporting burden costs during
the first year of operation as a result of the
successful revision and reissue of the facility's
air quality and wastewater discharge permits.
• Weyerhaeuser foresees avoiding $10 million
in capital spending on air pollution control
equipment throughout the term of the agree-
ment, although the actual savings is not quan-
tifiable.
• The "bubble" concept for air emission regula-
tions (i.e., the dual emissions cap) allows the
company to avoid costly unnecessary permit
reviews.
• The MACT applicability assessment and site-
specific rule will allow the company to meet
or exceed the environmental benefits that
would have resulted from new regulations in
a manner that is less costly for the facility.
• EMS implementation has begun to increase
staff education and awareness of the environ-
mental aspects of their jobs.
Information Resources: The information in this
summary comes from the following sources: (1)
the December 2000 XL Project Progress Report—
Weyerhaeuser Flint River Operations (EPA 100-
R-00-006); (2) focus group discussions on
December 1998 with representatives of the fed-
eral and state regulatory agencies, Weyerhaeuser
Flint River Operations, and a local stakeholder in-
volved in the project; (3) annual and midyear re-
ports prepared by Weyerhaeuser Corporation
available through June 2001; (4) focus group dis-
cussions in January 2000 with representatives of
-------
the federal and local regulatory agencies,
Weyerhaeuser, and a local stakeholder; (5) the 2000
Project XL Comprehensive Report, Volume 2:
Directory of Project Experiments and Results,
November 2000; and (6) a press release from Janu-
ary 29, 2001.
-------
Io (Zouvx\y
Bio reactor
Final Project Agreement Signed September 14, 2000
Background
The Project Sponsor: The Yolo County Central
Landfill (YCCL) is a 722-acre landfill operated
by Yolo County Planning and Public Works De-
partment. It is located two miles northeast of the
City of Davis in northern California. Adjacent to
the site are the City of Davis' Wastewater Treat-
ment Plant lagoons, a highway bypass, and agri-
cultural crops. There are also approximately 28
residences within a two-mile radius of the land-
fill, the closest one being 1,600 feet to the south.
The YCCL originally opened in 1975 for the dis-
posal of construction debris and non-hazardous liq-
uid and solid waste. Current onsite operations
include an 11-year-old landfill methane gas recov-
ery and energy generation facility, a drop-off area
for recyclables, a metal recovery facility, a wood
and yard waste recovery and processing area, and
a concrete recycling area. Under the Resource
Conservation and Recovery Act (RCRA), the site
is characterized as a Class III non-hazardous mu-
nicipal landfill (i.e., it accepts most types of solid
and liquid waste, most of which comes from house-
holds).
The Experiment: Yolo County is proposing a 20-
acre module of the YCCL for use as a controlled
bioreactor landfill. A bioreactor landfill converts
and stabilizes decomposable waste in an acceler-
ated manner. The process requires a liquid addi-
tion to the waste, which can include recycled
leachate (i.e., water that collects contaminants as
it trickles through wastes) from the landfill itself.
A bioreactor landfill uses controlled quantities of
liquid to accelerate the otherwise slow decompo-
sition of the waste. This acceleration increases
the biodegradation of the solid waste and can de-
crease the composting time from over 30 years
down to 5 to 10 years. In this type of landfill sys-
tem, liquids are added and circulated through the
waste, as appropriate, to accelerate the natural bio-
degradation rate of waste and therefore decrease
the waste stabilization and decomposition time
relative to what would occur in a conventional land-
fill. Conventional landfills do not use liquid addi-
tions, and landfill operators must receive regula-
tory flexibility from EPA in order to operate a
bioreactor. This acceleration in the decomposi-
tion process is beneficial because it can increase
landfill capacity and subsequent landfill life, im-
prove opportunities for treating the leachate liq-
uid draining from the landfill, reduce landfill
post-closure management activities, and produce
a methane gas byproduct that can be captured and
used as a renewable energy resource.
In the first phase of this 20-acre project, Module
D has been constructed. This 12-acre module con-
tains one 9.5-acre cell, which will be operated
anaerobically, and a 2.5-acre cell to be operated
aerobically. The county will construct the second
phase of Module D in two years and, depending
on the results of the first phase of Module D, the
county may operate the second phase either anaero-
bically or aerobically. The monitoring and report-
ing of the second phase of Module D are not
discussed in this proposal as the county intends to
revise the FPA in two years when more data be-
come available from phase one of the project. The
county decided to construct this 20-acre cell in two
phases to reduce the construction cost of the project
and to apply what is learned from the first phase to
the second phase.
This project is testing whether the following envi-
ronmental and waste management benefits can be
accrued with a bioreactor landfill:
• Maximization of landfill gas control and cap-
ture of methane and volatile organic com-
pounds emissions;
• Landfill life extension and/or reduced landfill
use;
• Greater capture of leachate and a decrease in
the pollutant loads of leachate;
• More rapid waste stabilization; and
• Decreased long-term risks associated with the
landfill.
-------
The Flexibility: Yolo County requested and has
been granted regulatory flexibility for liquid addi-
tions, which is the addition of liquid waste to a
landfill and is generally a prohibited activity un-
der federal waste laws and waste laws for the State
of California. EPA issued a site-specific rule to
amend 40 CFR §258.28 for Liquid Restrictions on
August 13,2001. The county plans to supplement
the liquid additions at the bioreactor with ground-
water and also wants the flexibility to utilize gray
water, which is typically domestic wastewater or
water from the wastewater treatment plant, and
food-processing wastes that are currently land ap-
plied. Due to the existing high water table, Yolo
County regularly extracts groundwater, which may
be used in the bioreactor. While these types of
liquid wastes are not normally beneficial, the
county believes that they may be useful in accel-
erating the biodegradation process of solid waste
in the bioreactor.
The county also requested flexibility on liquid ad-
ditions under several sections of California laws
governing waste management under the Califor-
nia Code of Regulations, Title 27, Environmental
Protection, which addresses the recirculation of
liquids in lined municipal landfills.
Other Innovations: (1) Evaluating Innovative
Approaches to Solid Waste Management. This
project assists in understanding how the perfor-
mance of bioreactor landfills and liquid additions
affect operations under anaerobic and aerobic de-
composition conditions. (2) Exploring RCRA Flex-
ibility for Landfills. Under RCRA, liquid additions
are prohibited at landfills, but the bioreactor sys-
tem requires the use of liquids to properly func-
tion. EPA has been requesting information on the
liquid additions and is currently considering re-
vising 40 CFR Part 258 to allow for leachate recir-
culation in bioreactor landfills with the proper liner.
Through this XL project, EPA can further evalu-
ate whether allowing leachate recirculation in land-
fills can prove beneficial.
The Superior Environmental Performance:
The full-scale Yolo County Bioreactor Project will
combine the acceleration of waste decomposition
and the efficient capture of methane gas. The ac-
celeration of the waste decomposition will be
Figure 57
Control Cell—Note how pile is still raised in the center.
Figm*e 58
Test Cell - Note how pile is sagging in the center. This is
due to the accelerated decomposition.
accomplished through the addition of liquids to the
waste pile, which speed up the composting, stabi-
lization, and generation of methane (see Figures
57 and 58). The methane will be captured at a
slight vacuum from a freely gas-permeable shred-
ded tire collection layer beneath the low-perme-
ability cover. Near complete extraction using this
approach has already been demonstrated at a test
cell where YCCL has been operating a smaller
bioreactor demonstration project for over three
years.
The demonstration test cell project is a an anaero-
bic controlled bioreactor landfill, which consisted
of two demonstration landfill cells, each filled with
approximately 9,000 tons of curbside garbage. The
"test" cell, or enhanced cell, received controlled
liquid additions and recirculated leachate, while
the "control" cell served as a control or baseline to
represent a conventional landfill. The demonstra-
tion project showed close to a 10-fold increase in
methane recovery rate and an 18 percent decrease
in the volume of solid waste compared to conven-
tional landfills. The full-scale bioreactor project
proposed in the Project XL program is a larger-
scale replication of this demonstration project.
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Progress in Meeting Commitments
(As of October 2001)
• Many of Yolo County's commitments will be
met after testing is completed. The testing was
scheduled to begin in summer 2001. The con-
struction of the aerobic liner was completed
in August 2001, and waste is currently being
placed into the cell. Waste was placed in the
cell until October 2001. Yolo County worked
toward meeting all of its commitments as test-
ing progresses throughout the fall of 2001.
• EPA committed to propose and issue a site-
specific rule, amending 40 CFR Part 258.28,
that applies specifically to this landfill.
- The rule was proposed on May 9, 2001.
The final rule was published in the Fed-
eral Register on August 13, 2001.
• In October 2000, Yolo County submitted an
application to Yolo-Solano Air Quality Man-
agement District (YSAQMD) requesting a fed-
erally enforceable state operating permit
(FESOP) regarding gas monitoring require-
ments. In addition, YSAQMD has been noti-
fied by Yolo County regarding the progress that
is being made at the landfill. The gas collec-
tion and control system is scheduled for
completion by the end of November 2001 and
water additions are scheduled to begin in De-
cember. YSAQMD stated that they would
have the draft revised FESOP permit com-
pleted by mid November 2001.
• Alternatives in energy generation systems to
minimize nitrogen oxides are being explored
as the testing occurs.
Accurate data for the bioreactor landfill is be-
ing generated and a record-keeping system is
being established as the testing occurs.
Benefits for the Environment
• Accelerating the decomposition process is ben-
eficial because it can increase landfill capac-
ity and subsequent landfill life, improve
opportunities for treating the leachate liquid
draining from the landfill, reduce landfill post-
closure management activities, and produce a
methane gas byproduct that can be captured,
which decreases emissions and can be used as
a renewable resource. The bioreactor will be
able to accept more waste over its lifetime
making its environmental performance supe-
rior to that of a conventional landfill.
Benefits for Stakeholders
• Present landfill capacity at YCCL is sufficient
until the year 2040, but with successful imple-
mentation of the bioreactor, the county and its
residents could see that lifespan extend,
thereby reducing the need for additional land-
fills in the county.
Benefits for the Project Sponsor
• Along with stakeholders, project sponsors will
benefit from the extended life of the landfill
and the decreased long-term risks associated
with the landfill. Additionally, the effective
and efficient capture of methane gas and its
subsequent conversion to electricity could be
sold to the local grid, farmers, or the City of
Davis.
Information Resources: The information in this
summary comes from the following sources: (1)
the FPA for the Yolo County Bioreactor Landfill
Project, signed September 14, 2000; and (2) the
Project XL Comprehensive Report, Volume 2: Di-
rectory of Project Experiments and Results, No-
vember 2000.
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Appendices
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T^ppendix y\:
Jrvformatiorv Sourae.s and ]\\e3\\odo\oc^y
This report relies on the cumulative information
from a number of sources. The sections below
describe these sources with brief descriptions of
the methodologies involved in developing them.
Sponsors Reports
Project sponsors prepare quarterly, midyear, or
annual reports as required by the individual project
final project agreements (FPAs). For more infor-
mation on these reports, please visit EPA's Project
XL Web site at http://www.epa.gov/projectxl.
<£P.A Progress
Reports
EPA Progress reports provide an overview of the
status of projects implementing FPAs for one year
or more. EPA develops these reports with the as-
sistance of the project sponsors and co-regulators;
and the stakeholders who are direct participants in
the projects have the opportunity to review them.
The progress reports include (1) a background sec-
tion briefly describing the facility's project and an-
ticipated 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/projectxl.
Stakeholder
CJrvvolvemervt Reports
In September 1998, Resolve, Inc., prepared a re-
port entitled Evaluation of Project XL Stakeholder
Processes (EPA-100-R-98-009). This report pro-
vided a review of the design and conduct of the
stakeholder processes at four of the initial projects
(Intel, Weyerhaeuser, HADCO, Merck). The re-
port described the involvement of stakeholders in
FPA negotiation and implementation, with infor-
mation on national and local stakeholder perspec-
tives about their role. It also outlined the various
models developed by company sponsors and re-
ported 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 Ne-
gotiation Network. Project XL Stakeholder
Involvement Evaluation (October 2000) covers
eight projects in various stages of negotiation or
implementation (Andersen, Atlantic Steel, Witco,
ExxonMobil, HADCO, Intel, New England Uni-
versities Laboratories, and Department of Defense
Vandenberg Air Force Base). It considers the early
dynamics of stakeholder processes in projects de-
veloping their FPA, stakeholder satisfaction and
effectiveness of involvement 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.
Otker Reports
The Project XL Preliminary Status Report (Sep-
tember 1998) examined three projects in imple-
mentation for at least one year as of January 1998:
Berry, Intel, and Weyerhaeuser. The report covers
the projects' initial results on innovation and sys-
tem change, as well as progress in meeting FPA
commitments, stakeholder participation outcomes,
environmental performance, and lessons learned.
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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
functions. Information compiled in progress re-
ports, focus groups, stakeholder reports, and other
documentation and information gained through the
experience of EPA staff is synthesized and de-
scribed. The report follows up the work started in
the Preliminary Status Report.
The Project XL 2000 Comprehensive Report (No-
vember 2000) was divided into two volumes. Vol-
ume 1—Directory of Regulatory, Policy, and
Technology Innovations presents the innovations
and lessons learned organized by how they relate
to the seven core functions that EPA typically per-
forms to carry out its mission to protect human
health and the environment. Volume 2—Directory
of Project Experiments and Results provides a sta-
tus report of the more than 50 projects and pro-
posals Project XL has supported to date.
Project Hocus Ci^oups
EPA conducted focus groups in December 1998,
January 1999, and January 2000 for various
projects. Focus group participants included com-
pany employees, co-regulator representatives (typi-
cally state and local government), citizen and
non-government organization stakeholders, and
EPA Headquarters and regional staff. Project-spe-
cific 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 implementa-
tion process; (2) the value of the project to their
organization; and (3) the opportunities to apply in-
formation 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 implementing a project. A list of the focus
groups and their participants as well as focus group
highlights is presented in Appendix B.
Otkcr Reports
In 2000, the National Academy of Public Admin-
istration (NAPA) commissioned independent re-
search studies that assessed innovation efforts by
EPA, states, communities and businesses, and oth-
ers to improve the effectiveness and efficiency of
environmental management programs.
Environment.gov: Transforming Environmental
Protection for the 21st Century, released in No-
vember 2000, is a report that summarizes results
of 17 research studies, which examined efforts by
the EPA, states, communities, businesses, and oth-
ers to improve the effectiveness and efficiency of
environmental protection. The report makes rec-
ommendations based on the studies and on other
information and recommends to EPA and Congress
how to continue the process of innovation, learn-
ing, and revitalization of the nation's commitment
to environmental protection. One of the reports
focused on the Massachusetts Department of En-
vironmental Protection's Environmental Results
Program. Presented in Appendix B, Focus Group
Highlights, are some adaptations of NAPA's find-
ings with respect to the Environmental Results Pro-
gram.
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^Appendix B:
Focus C\foup -Higkligk+s
Andersen Corporation
Focus Group Conducted in August 1999
Organization
Minnesota Pollution
Control Agency
Andersen Corporation
Andersen Corporation
Bloomberg & Podpeskar
(Andersen Counsel)
Chair, Andersen Stakeholder
Committee
Minnesota Center for
Environmental Advocacy
EPA Region 5
EPA Region 5
EPA Office of General Counsel
EPA Office of Enforcement
and Compliance Assurance
EPA Office of Reinvention
Name
Andrew Ronchak
Kirk Hogberg
Libby Johnston
Jon Bloomberg
Jim Kellison
Carol Wiessner
Brian Barwick
Rachel Rineheart
Mark Kataoka
Carol Holmes
Nancy Birnbaum
Issues Needing Resolution
• Certain stakeholders were concerned that
Andersen was not accountable to the Commu-
nity Advisory Committee (CAC) and that the
CAC needed greater opportunity to develop
overall goals of the stakeholder process.
• Certain stakeholders wished that their concerns
not directly related to the XL project would
have been more thoroughly addressed during
the XL discussions.
• Furnishing participants with an outline and the
goals of the project, a detailed time line, and a
description of what to expect from the stake-
holder involvement process at the beginning
of the project would have been valuable.
Lessons Learned
• EPA noted that Andersen's ability to listen and
react to community concerns helped make the
stakeholder involvement effort a success.
• It is important for stakeholders to understand
their roles in the stakeholder process.
• One stakeholder emphasized that the CAC's
complete access to information was very im-
portant and led to a greater trust in the stake-
holder process.
• EPA should have spent more time explaining
to stakeholders the reasons its review process
continually delayed project development.
• EPA decision-makers must be well informed
and prepared to participate in key decisions in
order for projects to develop in an effective
and timely manner.
• Face-to-face meetings appear to have been
more effective than electronic and telephone
communications.
• It has been difficult to adequately explain tech-
nical aspects of the project to CAC members.
• One stakeholder emphasized that the gener-
ally positive reception to the project by the
CAC was due mainly to the fact that the CAC
membership was weighted in favor of
Andersen supporters.
• MPCA prefers a more extensive role in devel-
oping and implementing XL projects.
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VI
IE
1
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U-
Atlantic Steel Site, Jacoby
Development Corporation
Focus Group Conducted in 1999
Name
Mike Brandon
Dan Cohen
Connie Cooper
Michelle Glen
Brian Hagar
Brian Leary
Shannon Powell
Randy Roark
Mike Replogle
Bernadette Smith
Tim State
Tim Torma
Organization
Chairman, Home Park
Community Improvement
Association
City of Atlanta, Principal
Planner, Current Planning
EPA, Region 4
EPA, Region 4
Sierra Club
Project Lead, CRB Realty
(Jacoby)
Midtown Alliance
Urban designer and manager
of the Home Park Charette
(Georgia Institute of
Technology)
Federal Transportation
Director, Environmental
Defense
Home Park Community
Improvement Association
Home Park Community
Improvement Association
EPA Headquarters
• A number of stakeholders were not satisfied
with the stakeholder involvement process.
They felt the process was unclear from the be-
ginning, did not provide a sufficient forum for
input, and was managed as a formality. To
avoid this problem in the future, Jacoby will
sponsor additional public meetings and encour-
age more direct stakeholder involvement.
Crompton Corporation
(formerly Witco Corporation)
Focus Group Conducted in December 1998
Issues Needing Resolution
• Major project milestones are slightly behind
schedule. Due to minor setbacks, the construc-
tion of the 17th Street Bridge/Extension has
been delayed for a year. Jacoby expects to
remain on-track in meeting its scheduled com-
mitments however, and bridge construction is
expected to begin in December 2001.
Lessons Learned
• Since the Atlantic Steel redevelopment project
is still in its early stages, the principal lesson
to be learned is whether smart growth strate-
gies can be applied to brownfields and trans-
portation projects, such that air quality and
other environmental performance can be im-
proved, as part of an overall community revi-
talization plan.
Name
Okey Tucker
Tony Vandenberg
Brenda Gotanda
Lucy Pontiveros
Jon McClung
Tad Radzinski
Beth Termini
Nancy Birnbaum
Sherri Walker
Jim McKnight *
Michele Aston *
Organization
OSi Specialties
OSi Specialties
Manko, Gold & Katcher
West Virginia Department
of Environmental Protection
West Virginia Department of
Environmental Protection
EPA Region 3
EPA Region 3
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
Citizen Stakeholder
EPA Office of Air Quality
Planning and Standards
• These persons were unable to attend the scheduled focus
group and so were either interviewed separately or asked to
submit written comments.
Issues Needing Resolution
• Crompton incorporated a section into the waste
minimization/pollution prevention (WM/PP)
study that described regulatory barriers to
implementing some of the study's findings,
which will need to be addressed.
• Crompton needs to evaluate additional WM/
PP opportunities identified in the study rela-
tive to other facility projects competing for
capital funds.
• Federal and state agency stakeholders ex-
pressed interest in seeing greater participation
in the XL project from the six surrounding
communities. Currently only one community
representative is involved in the project, but
-------
EPA and the West Virginia Department of En-
vironmental Protection would like to see a
minimum of one representative from each com-
munity.
Lessons Learned
• During the development of the FPA, project
participants should:
- Simplify the process;
- Show more trust for each other;
- Involve program offices early and through-
out;
- Meet face-to-face on a frequent basis;
- Draft the legal implementation document
and the FPA at the same time;
- Keep the FPA simple; put the details in
the legal implementation document;
- Speed EPA Headquarters review times;
and
- Work from drafted language (it is easier
than discussing general concepts).
• EPA should encourage other project sponsors
to include WM/PP studies in XL projects.
• One stakeholder noted that the key to commu-
nity participation results from understanding
local culture.
• Two community stakeholders noted that it
would have been positive if EPA had interacted
more with local officials earlier in the project.
• A company stakeholder emphasized that the
Crompton XL project provided a means for
EPA and Crompton to learn how to work to-
gether more effectively.
• For a variety of possible reasons, sometimes
community residents simply will not partici-
pate in an XL project despite noteworthy ef-
forts made by the project sponsor to encourage
it.
Department of Defense Vandenberg
Air Force Base (AFB)
Focus Group Conducted in January 2000
Name
Organization
Monte McVay
John Gunderson
Lt. Col. Scott
Westfall
Nancy Wilhausen
Peter Cantle
Jerry Schiebe
Dave Romano
Ron Tan
Maureen Sullivan
Col. John Coho
Joe Wilson
Sara Segal
John Walser
Will Garvey
Walter Walsh
Vandenberg AFB
Vandenberg AFB
Vandenberg AFB
Tetra Tech (Vandenberg AFB
contractor)
Santa Barbara County Air
Pollution Control (APCD)
Santa Barbara County APCD
Santa Barbara County APCD
Santa Barbara County APCD
Department of Defense
(DoD), Pentagon
DoD, Pentagon
DoD, Pentagon
EPA Region 9
EPA Region 9, Air Office
EPA Federal Facilities
Restoration and Reuse Office
EPA Office of
Environmental Policy
Innovation
Issues Needing Resolution
• As of January 1999, the identification of 10
tons of emission reductions was behind sched-
ule. After further evaluation and research for
emission reduction opportunities from station-
ary sources, Vandenberg AFB calculated that
this goal would not be achieved with the re-
maining budget and milestone schedule.
Therefore, on August 25, 1999, Vandenberg
AFB presented an alternative proposal to meet
this goal, which includes the purchase of 12
tons of emission reduction credits (ERCs) from
another source with the balance of Environ-
mental Investment (ENVVEST) program
funds to be applied to Vandenberg AFB's
Mobile Source Reduction Program.
• Vandenberg AFB is updating the original emis-
sions reduction plan submitted to the District
pursuant to the first FPA milestone require-
ment. The original plan was partially approved
by the District on February 28, 1998. This
-------
plan is being updated to reflect inclusion of •
the alternative implementation strategy and
will be submitted to the District in the fall of
2001. The purchased ERCs will be applied to
the fifth program milestone. Upon receipt of
the updated emission reduction plan, the Dis-
trict shall be asked to review, approve, and for- *
ward the plan to EPA Region 9 for inclusion
in the State Implementation Plan (SIP) for the
purpose of fulfilling ENVVEST program
goals. In January 2002, EPA Region 9 will be
forwarded the final emission reduction plan
for review. The review and SIP approval pro-
cess could take several months.
• Overall EPA, participating Vandenberg AFB
personnel and board members of both the Citi-
zens Advisory Board (CAB) and Community
Advisory Council (CAC) were satisfied with
the process leading up to the signing of the
FPA. However, CAB and CAC board mem-
bers expressed interest in seeing greater op-
portunities for citizen involvement.
• During FPA development, EPA was concerned
about the heavy reliance upon preexisting
Vandenberg community boards, which possi-
•
bly precluded participation of citizens not as-
sociated with the base or county agencies.
• One stakeholder expressed a desire to see an
increased level of communications between
stakeholders as well as more lead time for
stakeholders to consider ideas and proposals
affecting the project.
• Due to staff shortages in EPA Region 9, there
has been a decreased amount of stakeholder
communication and facilitation activities un-
dertaken by the region for this project.
Lessons Learned
• From the DoD perspective, the cost of devel-
oping the project was very high and may ulti-
mately outweigh the benefits. This happened, #
in part, because this was the first XL/
ENVVEST project.
Since Vandenberg AFB's pollution prevention
manager had to spend most of his time on XL/
ENVVEST during the first 18 months of the
project, there were other pollution prevention
opportunities the base could not pursue.
Even though the project is designed to signifi-
cantly reduce, if not eliminate, the possibility
of citizen lawsuits, the potential for them cre-
ated anxiety among those in DoD wanting to
try innovative approaches.
The FPA negotiation process needs to be
streamlined. The involvement of too many
people slowed negotiations, and the DoD chain
of command is long. Support from EPA and
DoD headquarters offices is important during
initial negotiations.
Participants need to know early in the nego-
tiation process their roles and responsibilities
and understand which regulations cannot be
changed.
Active support from EPA Headquarters is
needed throughout implementation.
The project probably could not have happened
without the EPA/DoD Memorandum of Agree-
ment.
The FPA allows for continued flexibility dur-
ing project implementation, which will help
in overcoming obstacles.
True research and development is costly and
time consuming.
There is a perception by many other DoD in-
stallations that the ENVVEST program is a
tool for avoiding Title V requirements, though
this is not the case.
EPA and DoD have different approaches to,
and definitions of, stakeholder involvement.
The concept of federal facilities broadening
community involvement beyond cleanup and
restoration is worthwhile.
-------
• The different public stakeholder advisory
board members felt the stakeholder involve-
ment process was a success. Overall, they felt
that the issues were reasonably straightforward
and that the project as a whole did not require
their intense review.
• Early on, one environmental group expressed
concerns about the proposed elimination of the
facility's Title V major source status. The
group was soon after satisfied with Vandenberg
AFB's response to the questions and concerns
raised and decided not to participate further in
the project.
• Vandenberg's positive reputation in the com-
munity may have reduced nearby community
members' interest in the project.
ExxonMobil Corporation
Focus Group Conducted December 1999
Name
Art Chin
John Hannig
Tom Bass
Melissa Pennington
Michael Cummings
Nick Fantasia
David Nicholas
Katherine Dawes
Greg Ondich
Ian Penn
Organization
ExxonMobil USA
ExxonMobil USA
West Virginia DEP
EPA Region 3
Fairmont Community
Liaison Panel
Fairmont Community
Liaison Panel
EPA Headquarters
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
Issues Needing Resolution
• One stakeholder noted that the required envi-
ronmental reports do not keep up with the ac-
tual work taking place and therefore cannot
serve as EPA enforcement records.
• Inability to determine whether a nearby artifi-
cial wetland can legally be removed has caused
delays.
• One stakeholder emphasized the need to en-
sure that the stakeholder group more accurately
reflects a cross-section of the community.
Lessons Learned
• EPA had difficulty obtaining agreement from
its internal enforcement offices during the de-
velopment of the FPA. Internally, EPA must
be able to balance the priorities of the XL pro-
gram offices with the priorities of the enforce-
ment office.
• Some of the environmental reporting require-
ments are seen as excessively burdensome and
could be streamlined. EPA has since sus-
pended the quarterly status reports because the
minutes from the monthly stakeholder meet-
ings provide sufficient information.
• Hosting more than one public meeting to iden-
tify stakeholders and technical experts would
have been useful.
• The community gained confidence in
ExxonMobil through its willingness to inter-
act with the community. The quick, candid
dialogue with the stakeholder panel facilitated
this trust.
• Certain stakeholders felt that more time should
have been spent at the beginning of the project
to clarify the roles of the stakeholders partici-
pating in the process.
• It can be difficult to identify all parties and the
decision maker for each party wishing to par-
ticipate.
• One stakeholder noted that if agreement is
reached regarding what the contaminated site
will be used for before or during the site in-
vestigation and removal stages, the amount of
time needed for the removal and remediation
process can be reduced.
• Projects can run more smoothly and efficiently
with organized stakeholder involvement.
-------
• One stakeholder emphasized the need to have
buy-in from all major parties before moving
further into the stakeholder process.
• Electronic reporting provides real-time com-
munication and expedites review.
• Another stakeholder emphasized the value of
having experts from different agencies in-
volved to enable the community to better un-
derstand the different issues.
HADCO Corporation
Focus Group Conducted December 1998
Name
Lee Wilmot
George Frantz*
Ken Rota*
Aleksandra
Dobkowski
James Sullivan
Ken Marschner
Larry Nadler
Sam Sage
Suganthi Simon
Organization
HADCO Corporation
EPA Region 1
EPA Region 1
EPA Region 2
EPA Region 2
New Hampshire
Department of Environmental
Services
New York State Department
of Environmental
Conservation
New York Local Stakeholder
EPA Office of Reinvention
• These persons were unable to attend the scheduled focus
group and so were either interviewed separately or asked to
submit written comments.
Issues Needing Resolution
• HADCO must improve communications with
its stakeholder by providing them with infor-
mation on the sludge tests and analysts.
• Although the delisting process has been del-
egated to the regions, regional staff will con-
tinue to need the expertise of Headquarters
delisting staff during the implementation of the
HADCO project.
• Putting contracts in place between HADCO
and appropriate metal smelters is taking longer
and is more complex than anticipated. Waste
processors and metal smelters seem to be part
of a horizontally integrated market, leading to
delays in HADCO obtaining the new contracts
necessary to implement the project.
Lessons Learned
(From focus group discussions in January 1999)
• Waste processors and metal smelters seem to
be part of a horizontally integrated market,
leading to delays in HADCO obtaining the new
contracts necessary to implement the project.
Attempts to put contracts in place between
HADCO and appropriate metal smelters were
more complex than anticipated.
• Due to a delegation of the delisting process
from EPA Headquarters to EPA regions, the
delisting process was greatly streamlined from
an average of four to six years to an average
of 180 days. Therefore, HADCO no longer
needed to rely on the XL process to expedite
the delisting request.
• This experiment would have greatly benefited
from an up-front analysis of the economic and
administrative structures of the copper recy-
cling and reclamation market.
Lessons Learned
(From focus group discussions in December 1998)
• Data collection has taken more time than an-
ticipated.
• Clear project goals outlined in a pre-proposal
phase will provide for a smoother negotiation
process and shorten the time spent on devel-
oping the FPA.
• Clear lines of communication and a decision-
making process should be established early on
in the negotiations and should be understood
and accepted by all project participants.
• Stakeholder outreach and education should be
as extensive as possible to attract stakehold-
ers and ensure their continued participation.
-------
• The project structure should have been planned
in more detail to ensure that complete interac-
tion was achieved between all parties. Since
the project involves multiple jurisdictions—
two states, two EPA regions, and EPA Head-
quarters—some participants felt as though
their necessary involvement was not always
appropriate.
• Stakeholders want more resources (e.g., paid
travel) in order to be better involved and more
knowledgeable about the different facilities in-
volved.
• The use of communications technology, such
as teleconferencing, is a valuable asset for a
project that may involve multiple facilities in
different locations and may serve to increase
involvement of private citizens.
• EPA Headquarters' knowledge of Resource
Conservation and Recovery Act (RCRA) waste
regulations was important to project negotia-
tions and will continue to be important during
project implementation.
• Involvement of EPA's upper management can
help move negotiations along and can improve
the decision-making processes.
• Building a consensus among the involved EPA
offices at critical junctures of a project must
be effectively facilitated by EPA Headquarters
to sustain project momentum.
Intel Corporation
Focus Group Conducted in December 1998
Focus Group Conducted in December 1999
Name
Jim Larsen
Gregg Workman
Jo Crumbaker
Pat Sampson
Barbara Knox
Jim Lemmon
David Matusow*
Colleen McKaughan
Organization
Intel Corporation
Arizona Department of
Environmental Quality
Maricopa County, Arizona
City of Chandler, Arizona
Community Advisory Panel
Community Advisory Panel
Community Advisory Panel
EPA Region 9
Name
Jim Larsen
Steve Brittle
Jim Lemmon
Greg Workman
Jo Crumbaker
Pat Sampson
Colleen McKaughan
Katherine Dawes
Organization
Intel Corporation
Local Citizen
Local Citizen
Arizona Department of
Environmental Quality
Maricopa County, Arizona
City of Chandler, Arizona
EPA Region 9
EPA Office of Environmental
Policy Innovation
* These persons were unable to attend the scheduled focus
group and so were either interviewed separately or asked to
submit written comments.
Issues Needing Resolution
(From focus group discussions in December 1998 and
December 1999)
Certain stakeholders feel that Intel has limited
their influence over the project. For example,
Intel's decision to change from using arsenic
to arsine gas in one of its processes was made
without consulting the stakeholder team. Sev-
eral stakeholders noted that more consultation
would have been appropriate.
• Certain local industries have noted that not
being granted the same regulatory flexibility
as Intel is unfair. Some wish to be granted the
same level of regulatory flexibility, without
necessarily going through the same process.
However, several stakeholders strongly object
to such action.
• Some stakeholders would prefer that a greater
emphasis be placed on water consumption and
waste minimization instead of water recycling
and waste reduction.
Most stakeholders believe that greater public
participation would improve the project. How-
ever, several barriers have prevented this, in-
cluding lack of time, appropriate level of
technical understanding, and resources (includ-
ing funds for citizen reimbursement and tech-
nical support).
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• One stakeholder had major concerns about the
public availability of timely and detailed in-
formation on process changes initiated by Intel.
While the specific concern was addressed by
Intel through sharing more detailed informa-
tion about the process change, the stakeholder
is still uncomfortable with the long-term im-
plications of this form of public participation.
The stakeholder wants more technical details
to be available to the public, as well as the tech-
nical assistance to interpret it, so that the com-
munity can evaluate the potential impacts on
health and the environment and influence the
company's decision-making process for choos-
ing among different available technologies or
chemicals.
• Except for the small stakeholder team, the pub-
lic has not shown interest nor attended public
meetings. While there is speculation as to why
this is the case (the project is too technical in
nature for sustained interest; the sponsor al-
ready has the broad trust of the community
regarding the project; the public does not have
enough access to information in order to be
active), the reasons for this trend are not yet
well understood.
• Stakeholders stated that project reports could
be improved by more narrative descriptions of
the company's Design for the Environment
commitment, the basis of the air quality stan-
dards, and the water and hazardous waste por-
tions of the project.
• There are continuing stakeholder concerns
about the state standards, (i.e., the Arizona Am-
bient Air Quality Guidelines), as applied to the
fence line standards used for the project.
Lessons Learned
(From focus group discussions in December 1998 and
December 1999)
• Stakeholder concerns can be addressed by pro-
viding sufficient information. For example,
even though stakeholders were notably con-
cerned about Intel's decision to switch to
arsine gas, stakeholder concerns were relieved
after Intel made considerable efforts to address
them.
• It is important to set ground rules and dead-
lines at the beginning of the stakeholder pro-
cess and to make efforts to ensure that all
stakeholders fully understand them.
• FPA development could have been expedited
if earlier in the process public stakeholders had
received education and training on environ-
mental terminology and issues and on the tech-
nical and business characteristics of the
semiconductor industry.
• Public stakeholders report high costs in terms
of their personal time, since they are volun-
teers.
• Without ongoing technical assistance, the gen-
eral public's ability to understand the impacts
of the project's changes on human health and
the environment is limited.
• Through the process of developing the agree-
ment, Intel and the regulatory agencies have
developed a better understanding of stake-
holder concerns and resource needs to partici-
pate in environmental projects.
• The air permit approach is probably applicable
to other semiconductor manufacturing facili-
ties, but might not be practicable for facilities
that experience frequent changes in air emis-
sion levels.
• In reference to the introduction of SDS arsine
technology, citizens noted that the FPA pro-
cess worked the way it was intended.
• Report centralization is a good practice.
-------
Jack M. Berry, Inc.
Focus Group Conducted in December 1998
Name
Organization
Charlie Fast Cargill, Inc.
Ernie Caldwell Jack M. Berry, Inc.
Jacki McGorty* Florida Department of
Environmental Protection
Chad Carbone* EPA Office of Environmental
Policy Innovation
Michelle Glenn EPA Region 4
Zylpha Pryor EPA Region 4
• These persons were unable to attend the scheduled focus
group and so were either interviewed separately or asked to
submit written comments.
Lessons Learned
• Ultimately, for the Berry project to have got-
ten back on track, each organization involved
would have had to made a new or renewed
commitments, with well-defined roles and re-
sponsibilities of each partner and a new clear
time line for accomplishing the various tasks
involved.
• While the organizations involved had differ-
ent perspectives about the project's implemen-
tation, all of them agreed on the following:
testing the Comprehensive Operating Permit
(COP) concept is still a good idea; FPAs for
XL projects need to describe the steps that
should be taken by the signatories should a
change in a facility's owner or operator occur;
and EPA needs to clarify XL's incentives to
attract and maintain the interest of a small busi-
ness like Berry.
• For all XL projects, the commitment of all par-
ties, the division of responsibility, and
timelines must be very clear from the begin-
ning. Also, the EPA and state regulators must
make an accurate assessment of the resources
available and the internal capabilities of com-
pany to implement the project.
• If a facility management and changeover oc-
curs during a project, the EPA and state regu-
lators must start working with the new
company as soon as possible to ease the
project's transition.
• XL FPAs must include language that spells out
the time frame for making a decision about pro-
ceeding with the project when the management
of the facility changes.
Massachusetts Department of
Environmental Protection (MA DEP)
Environmental Results Program
(Adapted from Research Paper for the National Acad-
emy of Public Administration in June 2000)
Issues Needing Resolution
• EPA has been working with MA DEP on its
application for delegation of Environmental
Results Program (ERP) dry cleaning programs
pursuant to §112(1) of the Clean Air Act
(C A A). The Massachusetts ERP for dry clean-
ers differs from the federal program in that dry
cleaners are required to retain records for three
years versus the five years required under the
federal program. In its application for delega-
tion, MA DEP will be asking the region to
make a determination that ERP for dry clean-
ers is at least equivalent to the federal program
on the grounds that the dry cleaning ERP cov-
ers a broader universe than the federal pro-
gram; imposes the use of leak detection devices
in addition to the perception method required
by federal law; and goes beyond the federal
program in requiring dry cleaners to submit
annual certifications of compliance under
CAA, RCRA, and the Clean Water Act.
Lessons Learned
• MA DEP found it difficult to develop "pure"
performance standards. Many of the regula-
tory standards resemble general permits or
those with source-specific standards. These
standards are based on technology or perfor-
mance, or some of both.
• Building on the success of the Massachusetts
Printing Partnership, MA DEP's effort to in-
clude a more complete universe of firms in each
sector has leveled the playing field between
firms complying with regulations and those that
have gained a competitive advantage by ignor-
ing their regulatory responsibility.
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• Stakeholder relationships are important. MA
DEP's involvement of stakeholders was key
to getting the ERP program off the ground. The
initial design group consisted of members of
EPA, environmental advocacy groups, busi-
ness and industry, consulting firms, and the le-
gal community. However, after the first 18
months the group has not met on a regular ba-
sis. In order to sustain ERP, MA DEP has rec-
ognized the need for continued stakeholder
involvement and support. As a result, MA
DEP has assigned sector managers to develop
communications plans to improve communi-
cation with and among stakeholders after sec-
tor implementation.
Merck & Company, Inc.
Focus Group Conducted in December 1998
Name
Ted Jett
Stephen Klevickis
Stephen Tarnowski
Larry Simmons
Mike Kiss
Christi Gordon
Betty Sellers
Cecil Rodrigues
Robin Moran
Nancy Birnbaum
Organization
Merck & Co., Inc.
Merck & Co., Inc.
Merck & Co., Inc.
Virginia Department of
Environmental Quality
Virginia Department of
Environmental Quality
National Park Service,
Shenandoah National Park
Elkton Community
EPA Region 3
EPA Region 3
EPA Office of Environmental
Policy Innovation
Focus Group Conducted in January 2000
Name
Ted Jett
Greg Ondich
Eric Marsh
Organization
Merck & Co., Inc.
EPA Office of
Environmental Policy
Innovation
EPA Office of Environmental
Policy Innovation
Issues Needing Resolution
• It is unclear how this project will address the
recently issued pharmaceutical Maximum
Available Control Technology (MACT) re-
quirements. Merck, EPA, and the State of Vir-
ginia are working to ensure that XL project
flexibility gains can continue under these re-
cently issued regulations.
• Because the facility-wide caps do not place an
individual subcap on volatile organic com-
pounds (VOCs), the community and National
Park Service are concerned about the poten-
tial impacts of increased VOC emissions.
Actual VOC emissions will be tracked closely,
and VOC impact analyses will be updated as
needed.
• Stakeholders believed that it was premature to
try to identify barriers to project implementa-
tion in 1998, since Merck's Prevention of Sig-
nificant Deterioration (PSD) permit has just
been issued by the Commonwealth of Virginia.
Lessons Learned
• Technical support for community stakehold-
ers is needed early in the process.
• EPA needs to communicate clear goals at the
beginning of project development negotiations.
• Third-party facilitation would have helped the
negotiation process.
• Transaction costs for community stakeholders
were particularly high.
• An incentive-based permit provided Merck
with the motivation to purchase the lowest
emission technology available.
• Community stakeholders felt that they were
not included in some crucial negotiations.
• For this XL project, stakeholders did not an-
ticipate the delay in securing a natural gas sup-
ply. Nonetheless, the conversion was
completed before the August 2000 deadline.
-------
Stakeholders caution others to anticipate
worst-case scenarios and build in time for po-
tential delays.
• The stakeholders did not anticipate the length
of time needed to secure a natural gas supply
connection to the boilers. The delay led to
more limited interaction between Merck and
some of the stakeholder groups, including the
National Park Service and local community
members, presumably due to a lack of infor-
mation to report.
Molex Corporation
Focus Group Conducted in December 1999
Organization
Molex Corporation
Nebraska Department of
Environmental Quality
(NDEQ)
City of Lincoln, Nebraska
World Resources Corporation
(Stakeholder)
World Resources Corporation
(Stakeholder)
EPA Region 7
EPA Region 7
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
EPA Headquarters
EPA Headquarters
EPA Headquarters
Issues Needing Resolution
• The two-year temporary variance was set to
expire on August 7, 2000. EPA and NDEQ
have granted an additional six-month variance.
Molex has formally requested a two-year ex-
tension to continue the XL project under in-
creased production. A decision by NDEQ and
EPA on extending the variance an additional
two years is expected after Molex has com-
pleted the final report.
Name
Paul Eckerson
Bill Gilley
Gerardo Talero
Miles Takaki
Allen Moser
David Doyle
Bob Richards
Katherine Dawes
Ian Penn
Mitch Kidwell
Greg Ondich
Jim Lounesbury
Marilyn Jude
Christine Mason
Lessons Learned
• One stakeholder suggested that it would have
been more helpful to give EPA Region 7, as
opposed to EPA Headquarters, greater respon-
sibility over the project.
• All parties involved in FPA development
should know their roles and responsibilities at
the beginning of FPA development.
• Late involvement of national groups delayed
implementation of the project. However, this
may have been avoided if EPA had encour-
aged national stakeholders to hold discussions
with local stakeholders from the beginning of
the project.
• One stakeholder noted that the project may
have advanced more smoothly if more time
was spent up front talking through the issues.
New England Universities'
Laboratories
Focus Group Conducted in 1999
Name
Tom Balf
Dan Brannegan
Kathleen Butler
Karen Deady
John DelaHunt
George Frantz
George Hawkins
Suzanne Howard
Anne Kelly
Jim Miller
Ed Schoener
Ralph Stuart
Vermont
Wayne Thomann
Fay Thompson
Sherri Walker
Zehra Schneider
Graham
Organization
Nexus Environmental
Partners (formerly ML
Strategies)
Pfizer, Inc.
Community resident,
University of Vermont
Director, Environment, Health
and Safety, University of
Massachusetts, Boston
The Colorado College
EPA Region 1
EPA Region 1
Project Lead, Boston College
EPA Region 1
Massachusetts Department of
Environmental Protection
Ecologia
Project Lead, University of
Duke University
University of Minnesota
EPA Headquarters
University Project Lead,
University of Massachusetts,
Boston
-------
Issues Needing Resolution
• Some lab-based stakeholders believe that EPA
has placed too many restrictions that are simi-
lar to existing regulations. They would like
EPA staff to be more proactive at reducing the
constraints that limit creative and innovative
solutions for the projects.
• Stakeholders from the national meetings feel
that EPA's position on the types of allowable
treatment within labs and storage areas, the
definition of what constituted a "lab unit," and
issues associated with on-site storage and the
"arbitrary" 90-day limit for accumulating
waste have yet to be successfully addressed.
• There is a lack of participation among exter-
nal stakeholders, likely due to a lack of stake-
holder focus on hazardous waste compared to
other issues that involve the campuses and the
community members. Efforts continue to be
made to involve external stakeholders.
Lessons Learned
The national meetings were viewed as construc-
tive, meaningful, and important experiences. Most
stakeholders involved felt that they were able to
contribute effectively.
• The e-mail listserv works to provide internal
and external stakeholders with updates and an
opportunity to comment both on the XL project
and on other health, safety, and environmental
topics of interest.
• For discussing particulars of the project and
focusing on a dialogue on the project, stake-
holders participate more when using a profes-
sional conference type format.
• Most environmental groups lack the funds and
time to participate extensive stakeholder pro-
cesses. A stakeholder commented that the in-
volvement by nonprofit organizations was
insufficient and suggested that they should be
funded in order to more fully participate.
• Some national stakeholders suggested routine
updates on project developments or a stake-
holder follow-up meeting to keep them updated
and more involved.
• Local stakeholders were able to achieve their
goal of increasing awareness among labora-
tory personnel through internal processes.
• Several stakeholders noted that the numerous
rewrites of the project agreement were ineffi-
cient.
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Weyerhaeuser Company Flint River
Operation
Focus Group Conducted in December 1998
Name
Frank Wohrley
Terrell Aldridge
Willard Parker
Mark Johnson
Harland Cofer
David Word
Bob Donaghue
Lee Page
Michelle Glenn
Karrie Jo Shell
Nancy Birnbaum
Organization
Weyerhaeuser Flint River
Operation
Weyerhaeuser Flint River
Operation
Weyerhaeuser Flint River
Operation
Weyerhaeuser, Atlanta,
Georgia
Georgia Southwestern
University (Local Stakeholder)
Georgia Environmental
Protection Division
Georgia Pollution Prevention
Assistance Division
EPA Region 4
EPA Region 4
EPA Region 4
EPA Office of Environmental
Policy Innovation
Focus Group Conducted in December 1999
Gary Strandburg
Frank Worhrley
Mark Johnson
Gary Risner
Harland Cofer
Lee Page
Steve Shedd
Katherine Dawes
Greg Ondich
lan Penn
Organization
Weyerhaeuser Flint River
Operation
Weyerhaeuser Flint River
Operation
Weyerhaeuser Flint River
Operation
Weyerhaeuser Flint River
Operation
Georgia Southwestern
University (Local Stakeholder)
EPA Region 4
EPA Region 4
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
EPA Office of Environmental
Policy Innovation
Issues Needing Resolution
(From focus group discussions in December 1998)
must prioritize staff time. Also, it takes time
to get the permits needed to initiate and con-
duct the studies.
• Three energy conservation projects—the re-
covery boiler sootblower system, power boiler
advanced controls, and the turbo generator ex-
haust pressure control—are currently in
progress to improve the efficient use of steam
in the plant. Weyerhaeuser decreased steam
usage in the first half of 2001 and plans to re-
place the steam-driven chiller in the pulping
unit with a more efficient unit.
• At this time, it is not known how much cost
savings Weyerhaeuser will gain through imple-
menting the dual emissions cap as a result of
facility expansion, because no expansion is
planned at this time.
Lessons Learned
(From focus group discussions in December 1998)
• Site visits early in FPA negotiations helped to
build trust and educate regulators about facil-
ity operations.
• Stakeholders want more education (i.e., tech-
nical assistance) early in the FPA negotiation
process.
• Including permit language in FPA appendices
was very important for smooth implementa-
tion of the project commitments by
Weyerhaeuser, EPA, and the state.
• Conducting studies on changes to manufactur-
ing processes takes more time that the project
participants expected.
• The facility has a set budget, and therefore staff
time has to be prioritized for implementing dif-
ferent parts of the FPA, particularly the volun-
tary and feasibility study commitments.
• The delays in conducting feasibility studies for
the air emissions and part of the solid waste
portions of the project have occurred in part
because Weyerhaeuser has a set budget and
-------
^Appe-^dix glossary
300-millimeter Wafers: 300-millimeter wafers
manufactured at a high-volume production manu-
facturing facility represent a technological advance
in semiconductor chips over the standard 200-mil-
limeter (8-inch) wafers that are used in many semi-
conductor manufacturing plants today.
300-millimeter chips offer over twice as much sur-
face area over the conventional chips and will re-
duce manufacturing costs per wafer by more than
30 percent.
Adsorbable Organic Halogens (AOX): AOX is
a measurement of the amount of organic halogens
present in water. In paper manufacturing, organic
halogens are commonly byproducts of chlorine
bleaching processes. The AOX value is expressed
in equivalent chlorine.
Aerobic: Life or processes that require, or are not
destroyed by, the presence of oxygen. (See:
Anaerobic.)
Aluminum Chemical Vapor Deposition
Process: A dry process used by previous genera-
tion semiconductor device technologies. Vapor
deposition technologies include processes that put
materials into a vapor state via condensation,
chemical reaction, or conversion and then coat a
product with that material.
Anaerobic: Life or processes that occur in, or are
not destroyed by, the absence of oxygen.
Area of Contamination (AOC): A non-discrete
land area on which there is generally dispersed
contamination.
Asbestos-Containing Waste Materials
(ACWM): Mill tailings or any waste that contains
commercial asbestos and is generated by a source
covered by the Clean Air Act Asbestos National
Emissions Standards for Hazardous Air Pollutants
(NESHAPS).
Attainment Area: A designated geographic area
considered to have air quality as good as or better
than the National Ambient Air Quality Standards
(NAAQS) 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 fu-
ture environmental performance can be compared.
Best Management Practice (BMP): Methods
that have been determined to be the most effec-
tive, practical means of accomplishing a given goal.
Biochemical Oxygen Demand (BOD): A mea-
sure of the amount of oxygen consumed in the bio-
logical processes that break down organic matter
in water. The greater the BOD, the greater the de-
gree of pollution.
Biodegradable: Capable of decomposing under
natural conditions.
Black Liquor: A byproduct of the paper pulping
process; spent cooking liquor that has been sepa-
rated from the pulp produced by the Kraft, soda,
or semi-chemical pulping process.
British Thermal Unit (Btu): Unit of heat energy
equal to the amount of heat required to raise the
temperature of one pound of water by one degree
Fahrenheit at sea level.
Brownfield: Abandoned, idled, or underused in-
dustrial and commercial facilities/sites where ex-
pansion or redevelopment is complicated by real
or perceived environmental contamination. They
can be in urban, suburban, or rural areas.
Carbon Monoxide (CO): A colorless, odorless,
poisonous gas produced by incomplete fossil fuel
combustion.
Catalytic Oxidation: Catalytic oxidation is an
alternative technology used in selective applica-
tions to greatly reduce emissions due to volatile
organic compounds (VOCs), hydrocarbons, odors,
and opacity in process exhaust. VOCs are thermally
destroyed at high temperatures by using a solid
catalyst. Catalyst systems used to oxidize VOCs
typically use metal oxide.
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Categorical Industrial User: An industrial user
that is subject to national categorical pretreatment
standards promulgated by EPA.
Categorical Pretreatment Standard:
Limitations on pollutant discharges to publicly
owned treatment works (POTWs) promulgated by
EPA in accordance with Section 307 of the Clean
Water Act, that apply to specific process waste-
water discharges of particular industrial categories
[40 CFR § 403.6 and 40 CFR Parts 405-471].
Chemical Oxygen Demand (COD): A measure
of the oxygen required to oxidize all compounds,
both organic and inorganic, in water.
Clean Air Act (CAA): The CAA is the compre-
hensive federal law that regulates air emissions
from area, stationary, and mobile sources. This law
authorizes EPA to establish National Ambient Air
Quality Standards (NAAQS) to protect public
health and the environment.
Clean Water Act (CWA): The CWA sets the ba-
sic structure for regulating discharges of pollut-
ants to waters of the United States. The law gives
EPA the authority to set technology-based efflu-
ent standards on an industry basis and continues
the requirements 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 wa-
ters unless a National Pollutant Discharge Elimi-
nation System (NPDES) permit is obtained under
the Act.
Comprehensive Environmental Response, Com-
pensation, and Liability Act (CERCLA):
CERCLA is the legislative authority for the
Superfund program funds and carries out EPA solid
waste emergency and long-term removal and re-
medial activities. These activities include estab-
lishing the National Priorities List (NPL),
investigating sites for inclusion on the list, deter-
mining their priority, and conducting and/or su-
pervising cleanup and other remedial actions.
Conditional Delisting: Use of the petition pro-
cess to have a facility's toxic designation rescinded.
Conformity: A Clean Air Act (CAA) requirement
intended to ensure that new transportation invest-
ments do not jeopardize air quality in
nonattainment and maintenance areas. According
to the CAA, no transportation 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.
Continuous Emission Monitoring (CEM):
Continuous measurement of pollutants emitted into
the atmosphere in exhaust gases from combustion
or industrial processes.
Criteria Air Pollutants: The Clean Air Act
(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
describe the characteristics and potential health and
welfare effects of these pollutants.
Dioxin: Any one of a family of compounds known
chemically as dibenzo-p-dioxins. Concern about
dioxin arises from their potential toxicity as a con-
taminant in commercial products. Tests on labora-
tory animals indicate that dioxin is one of the more
toxic synthetic compounds.
Discharge Monitoring Report (DMR): Facilities
that discharge wastewater directly from point
sources to surface waters must submit DMRs un-
der National Pollution Discharge Elimination Sys-
tem (NPDES) wastewater permitting.
Dredge/Dredging: Removal of mud from the
bottom of water bodies. This can disturb the eco-
system and causes silting that kills aquatic life.
Dredging of contaminated muds can expose biota
to heavy metals and other toxics. Dredging activi-
ties may be subject to regulation under Section 404
of the Clean Water Act (CWA).
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Ecological Risk Assessment: The application of
a formal framework, analytical process, or model
to estimate the effects of human action(s) on a natu-
ral resource and to interpret the significance of
those effects in light of the uncertainties identi-
fied in each component of the assessment process.
Such analysis includes initial hazard identification,
exposure and dose response assessments, and risk
characterization.
Effluent: Wastewater, treated or untreated, that
flows out of a treatment plant, sewer, or industrial
outfall. Generally refers to wastes discharged into
surface waters.
Electroplating Operations: Involves plating vari-
ous metals onto printed wiring boards and com-
puter components that provide electronic
interconnection.
Emergency Planning and Community Right to
Know (EPCRA): Also known as Title III of the
Superfund Amendments and Reauthorization Act
of 1986 (SARA), EPCRA was enacted by Con-
gress as the national legislation on community
safety. This law was designated to help local com-
munities protect public health, safety, and the en-
vironment from chemical hazards.
Emissions Cap: A limit designed to prevent pro-
jected growth in emissions from both existing and
future stationary sources from exceeding any man-
dated levels. Generally, such provisions require that
any emission increase from equipment at a facility
be offset by emission reductions from other equip-
ment under the same cap.
End-of-Pipe: Generally refers to technologies,
such as scrubbers on smokestacks and catalytic
convenors on automobile tailpipes, which reduce
the emission or discharge of pollutants to the en-
vironment after they have formed. May also refer
to monitoring or sampling activities that occur af-
ter pollutants have been 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 iden-
tify the selection of a response alternative and re-
lies on existing documentation whenever possible.
F006 Listing: Wastewater treatment sludge pro-
duced from nonspecific electroplating processes
and operations designated as hazardous waste un-
der the Resource Conservation and Recovery Act
(RCRA).
Feasibility Study (FS): Analysis of the practica-
bility of a proposal; e.g., a description and analy-
sis of potential cleanup alternatives for a site such
as one on the National Priorities List (NPL). 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."
Flexible Fuel Vehicle (FFV): A vehicle specially
designed to use multiple fuels, such as methanol,
ethanol, and regular unleaded gasoline in any com-
bination from a single tank. The vehicles have a
special sensor on the fuel line that detect the ratio
of fuels in the tank. The vehicle's fuel injection
and ignition timing are adjusted by an on-board
computer to compensate for the different fuel mix-
tures.
Fly Ash: Noncombustible residual particles ex-
pelled by flue gas.
Fugitive Emissions: Emissions not caught by a
capture system.
Gasification: Conversion of solid material such
as coal into a gas for use as a fuel.
Global Positioning System (GPS): A precise
surveying system based on a set of satellites that
orbit about 12,000 miles above the earth. On earth,
a hand-held specialized computer, a portable GPS
receiver, can receive a signal from a GPS satellite
above the horizon. The receiver then calculates
absolute position, with accuracy that is usually
within a few feet, or better.
Greenfield: Greenfields are generally parkland,
previously undeveloped open space, or agricultural
lands, located near the outskirts of towns, cities
and larger metropolitan areas. (See: Brownfield.)
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Hazardous Air Pollutants (HAPs): Air pollut-
ants that are not covered by the National Ambient
Air Quality Standards (NAAQS) but that may have
an adverse effect on human health or the environ-
ment. Such pollutants include asbestos, beryllium,
mercury, benzene, coke-oven emissions, radionu-
clides, and vinyl chloride.
Hazardous Waste: Byproducts of society that can
pose a substantial or potential hazard to human
health or the environment when improperly man-
aged. Hazardous waste possesses at least one of
four characteristics (ignitability, corrosivity, reac-
tivity, or toxicity) or appears on special EPA lists.
Hydrogen Chloride: Hydrogen chloride is a non-
combustible compound that is highly soluble in
water. In aqueous solution, it forms hydrochloric
acid. Hydrochloric 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, to neutralize basic sys-
tems, to treat oil and gas wells, to conduct analyti-
cal chemistry, and to remove scale from boilers
and heat-exchange equipment.
Hydrogen Fluoride: Hydrogen fluoride, or hy-
drofluoric acid, is a colorless gas or fuming liquid.
It is a chemical intermediary for fluorocarbons,
aluminum fluoride, cryolite, uranium hexafluoride,
and fluoride salts. It is used in fluorination pro-
cesses, as a catalyst, and as a fluorinating agent in
organic and inorganic reactions. It is used to clean
cast iron, copper, and brass; remove efflorescence
from brick and stone; or sand particles from me-
tallic castings.
Indirect Discharge: Introduction of pollutants
from a non-domestic source into a publicly owned
waste-treatment system. Indirect dischargers can
be commercial or industrial facilities whose wastes
enter local sewers.
Industrial User: Any non-domestic source that
introduces pollutants into a municipal wastewater
collection system [40 CFR 403.3(h)].
Influent: Water, wastewater, or other liquid flow-
ing into a reservoir, basin, or treatment plant.
Interference: A discharge which, alone or in con-
junction with a discharge from other sources, both
(1) inhibits or disrupts a publicly owned treatment
works (POTW) and (2) therefore is a cause for vio-
lation of any requirement of the POTW's National
Pollutant Discharge Elimination System (NPDES)
permit (including an increase in the magnitude or
duration of a violation).
International Organization for Standardization
(ISO) 14000: ISO 14000 is primarily concerned
with environmental 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 an
alkaline sulfide solution containing sodium hydrox-
ide for a cooking liquor and sodium sulfide in its
pulping process.
Land Disposal Restrictions (LDR): Rules that
require hazardous wastes to be treated before dis-
posal on land to destroy or immobilize hazardous
constituents that might migrate into soil and
groundwater.
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 considerable strength to the wall and also
protects it against degradation by microorganisms.
Low-emitting Vehicles (LEVs): A vehicle that
emits 0.075 g, or less, of hydrocarbons per mile.
Maximum Available Control Technology
(MACT): The emission standard for air pollution
sources requiring the maximum reduction of haz-
ardous emissions, taking cost and feasibility into
account. Under the Clean Air Act (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.
Metallization: The fabrication step in which
proper interconnection of circuit elements is made.
The act or process of imparting metallic proper-
ties to something.
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Methanol: An alcohol that can be used as an al-
ternative 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 refrigerant, and as a food additive. Mildly toxic
if inhaled.
Mobile Source: Any non-stationary source of air
pollution such as cars, trucks, motorcycles, buses,
airplanes, and locomotives.
"The MON": The National Emission Standard
for Hazardous Air Pollutants (NESHAP) for the
source category "Miscellaneous Organic Chemi-
cal Production and Processes." Some examples of
these processes are the production of explosives,
photographic chemicals, polyester resins, 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 (CAA) applicable to outdoor air
throughout the country.
National Emissions Standards for Hazardous
Air Pollutants (NESHAPs): Emissions standards
set by EPA for air pollutants not covered by Na-
tional Ambient Air Quality Standards (NAAQS)
that may cause an increase in fatalities or in seri-
ous, irreversible, or incapacitating illness. Primary
standards are designed to protect human health,
and secondary standards are designed to protect
public welfare (e.g., building facades, visibility,
crops, and domestic animals).
National Pollutant Discharge Elimination Sys-
tem (NPDES): A provision of the Clean Water
Act (CWA) that prohibits the discharge of pollut-
ants into waters of the United States unless a spe-
cial permit is issued by EPA, a state, or, where
delegated, by a tribal government on an Indian res-
ervation.
National Priorities List (NPL): EPA's list of the
most serious uncontrolled or abandoned hazard-
ous waste sites identified for possible long-term
remedial action under the Superfund program. 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 ef-
fluent standards that limit the amount of pollution
allowed from new sources or from modified exist-
ing sources.
New Source Review (NSR): A Clean Air Act
requirement that State Implementation Plans must
include a permit review that applies to the con-
struction and operation of new and modified sta-
tionary sources in nonattainment areas to ensure
attainment of national ambient air quality stan-
dards.
Nitrogen Oxides (NOx): Air pollutants that are
the result of photochemical reactions of nitric ox-
ide in ambient air. Typically, they are the product
of combustion from transportation and stationary
sources. They are a major contributor to the for-
mation of tropospheric ozone, photochemical
smog, and acid deposition.
Nonattainment Area: A designated geographic
area that does not meet one or more of the Na-
tional Ambient Air Quality Standards (NAAQS)
for the criteria pollutants designated in the Clean
Air Act (CAA). (See: Attainment.)
Non-time-critical Removal (NTC): Those re-
movals where, based on the site evaluation, the lead
agency determines that a removal action is appro-
priate and that there is a planning period of more
than six months available before on-site activities
begin.
Organic Compounds: Naturally occurring (ani-
mal or plant-produced) or synthetic substances
containing mainly carbon, hydrogen, nitrogen, and
oxygen.
Particulate Matter (PM): Fine liquid or solid
particles, such as dust, smoke, mist, fumes, or
smog, found in air or emissions.
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Pass-through: A discharge that exits a publicly
owned treatment works (POTW) into waters of the
United States in quantities or concentrations which,
alone or in conjunction with other discharge
sources, is a cause of a violation of any require-
ment of the POTW's National Pollutant Discharge
Elimination System (NPDES) permit (including an
increase in the magnitude or duration of a viola-
tion).
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 life-
times.
Phosphine: A colorless, flammable gas that is
slightly soluble in water. It is used as an interme-
diate in the synthesis of flame retardants for cot-
ton fabrics, as a doping agent for n-type
semiconductors, a polymerization initiator, and a
condensation catalyst.
Plant Site Emission Limits (PSELs): Facility-
based emission caps that allow production changes
and facility expansion without recurring air qual-
ity permit reviews.
Point Source: A stationary location or fixed fa-
cility 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, pro-
cesses, and activities that create excessive waste
products or pollutants in order to reduce or pre-
vent them through alteration or eliminating a pro-
cess. Such activities, consistent with the Pollution
Prevention Act of 1990, are conducted across all
EPA programs and can involve cooperative efforts
with such agencies as the Departments of Agricul-
ture and Energy. 2. EPA has initiated a number of
voluntary programs in which industrial or commer-
cial "partners" join with EPA in promoting activi-
ties that conserve energy, conserve and protect
water supply, reduce emissions or find ways of
utilizing them as energy resources, and reduce the
waste stream.
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 con-
taminants into the environment, requiring a reme-
dial action response under the Comprehensive
Environmental Response, Compensation, and Li-
ability Act (CERCLA) and the Superfund Amend-
ments and Reauthorization Act of 1986 (SARA).
The PRP is potentially liable for the cleanup costs
in order to compensate the government for its
remediation expenditures.
Premanufacture Notice: Section 5 of the Toxic
Substance Control Act (TSCA) regulates anyone
who plans to manufacture or import a "new" chemi-
cal substance for commercial purposes. Under sec-
tion 5, EPA requires notice before manufacture or
importation of non-exempt substances so that EPA
can evaluate whether the chemical substance poses
a threat to human health or the environment. This
notice is called a premanufacture notice (PMN).
Pretreatment: Processes used to reduce, elimi-
nate, or alter the nature of wastewater pollutants
from non-domestic sources before they are dis-
charged into publicly owned treatment works
(POTWs).
Prevention of Significant Deterioration (PSD):
Standards aimed at keeping areas that are in com-
pliance with National Ambient Air Quality Stan-
dards (NAAQS) from backsliding.
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.
Radiolabel: To tag (a hormone, an enzyme, or
other substance) with a radioactive tracer.
Record of Decision (ROD): A ROD documents
the remedy decision for a site or operable unit. The
ROD certifies that the remedy selection process
has followed the requirements of CERCLA and
the National Contingency Plan (NCP) and dis-
cusses the technical components of the remedy. The
ROD also provides the public with a consolidated
source of information about the site.
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Regulated Asbestos-containing Material
(RACM): Under the Asbestos National Emissions
Standards for Hazardous Air Pollutants
(NESHAP), RACM is defined as (1) friable as-
bestos material, (2) Category I non-friable Asbes-
tos 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 mate-
rial in the course of demolition or renovation op-
erations.
Remedial Action: Remedial actions are actions
documented in the Record of Decision (ROD) that
are taken at National Priorities List (NPL) sites to
eliminate or reduce the pollution to levels which
prevent or minimize the release of hazardous sub-
stances so that they do not migrate or cause sub-
stantial danger to public health or welfare, or the
environment. An example is to remove hazardous
constituents from groundwater using pump and
treat technologies.
Remedial Investigation (RI): An in-depth study
designed to gather data needed to determine the
nature and extent of contamination at a Superfund
site, establish site cleanup criteria, identify pre-
liminary alternatives for remedial action, and sup-
port technical and cost analyses of alternatives. The
remedial investigation is usually done with the fea-
sibility 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
multi-detector 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, conduc-
tance, and temperature.
Removal Action: A short-term federal response
to prevent, minimize, or mitigate damage to the
public or the environment at sites where hazard-
ous substances have been released. Examples of
removal actions are excavating contaminated soil,
erecting a security fence, or stabilizing a berm,
dike, or impoundment. 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.
Resource Conservation and Recovery Act
(RCRA): Passed in 1976, RCRA gives EPA the
authority to control hazardous waste from "cradle-
to-grave." This includes the generation, transpor-
tation, treatment, storage, and disposal of
hazardous waste. RCRA also set forth a framework
for the management of nonhazardous wastes.
RCRA enables EPA to address environmental prob-
lems that could result from underground tanks stor-
ing petroleum and other hazardous substances.
RCRA focuses only on active and future facilities
and does not address abandoned sites.
Safe Drinking Water Act (SDWA): A law es-
tablished to protect the quality of drinking water.
This law focuses on all waters actually or poten-
tially designated for drinking use, whether from
aboveground or underground sources. The Act
authorizes EPA to establish safe standards of pu-
rity and requires all owners or operators of public
water systems to comply with primary (health-re-
lated) standards. State governments, which assume
this power from EPA, also encourage attainment
of secondary standards (e.g., water clarity).
Semi-chemical Mill: A mill that produces pulp
using a combination of both chemical and mechani-
cal pulping processes, with or without bleaching.
Sludge: A semisolid residue from any of a num-
ber of air or water treatment processes; this can be
a hazardous or non-hazardous waste.
Sludge Dryers: A piece of equipment that reduces
the volume and weight of the semisolid 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 sepa-
rate its metal content. Its emissions generally cause
pollution. "Smelting" is the process involved.
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State Implementation Plan (SIP): EPA-ap-
proved state plans for the establishment, regula-
tion, and enforcement of air pollution standards.
Stationary Source: A fixed-site producer of pol-
lution, mainly power plants and other facilities
using industrial combustion processes. (See: Point
Source.)
Sulfur Dioxide (S02): SO, gases are formed when
fuel containing sulfur (mainly coal and oil) is
burned and can be formed during metal smelting
and other industrial processes. S02 is associated
with acidification of lakes and streams, acceler-
ated corrosion of buildings and monuments, re-
duced visibility, and such adverse health effects as
inhibition of breathing, respiratory illness, and
aggravation of existing cardiovascular 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 fertilizer 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 pu-
rification of petroleum, the pickling of metal, elec-
troplating baths, nonferrous metallurgy, and
production of rayon and film; and as a laboratory
reagent.
Superfund: The program operated under the leg-
islative authority of the Comprehensive Environ-
mental Response, Compensation, and Liability Act
(CERCLA) and the Superfund Amendments and
Reauthorization Act of 1986 (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 (NPL), investigating sites for inclu-
sion on the list, determining their priority, and con-
ducting and/or supervising cleanup and other
remedial actions.
Sustainable Forestry Initiative™ (SFI): The SFI
is a comprehensive program of forestry and con-
servation practices designed to ensure the continu-
ing 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
percent of the lumber produced in America today.
Compliance with the SFI guidelines is mandatory
for AF&PA companies to retain AF&PA member-
ship.
Title V of the Clean Air Act: Establishes a fed-
eral operating permit program that applies to any
major stationary facility or source of air pollution.
The purpose of the operating permits program is
to ensure compliance with all applicable require-
ments of the Clean Air Act (CAA). Under the pro-
gram, permits are issued by states or, when a state
fails to carry out the CAA satisfactorily, by EPA.
The permit includes information on which pollut-
ants are being released, how much may be released,
and what kinds of steps the source's owner or op-
erator is taking to reduce pollution, including plans
to monitor the pollution.
Total Kjeldahl Nitrogen (TKN): TKN is defined
functionally 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 nu-
merous synthetic organic compounds.
Total Suspended Solids (TSS): A measure of the
suspended solids in wastewater, effluent, or water
bodies, determined by tests for "total suspended
nonfilterable solids."
Toxic Release Inventory (TRI): Database of
toxic releases in the United States compiled from
"Section 313 reports" required by the Superfund
Amendments and Reauthorization Act of 1986
(SARA) Title III.
Toxic Substances Control Act (TSCA): A law
enacted by Congress in 1976 to give EPA the abil-
ity to track the 75,000 industrial chemicals cur-
rently 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 human-health hazard. EPA can
ban the manufacture and import of those chemi-
cals that pose an unreasonable risk.
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Transitional Low-Emitting Vehicle (TLEV):
A vehicle that emits 0.125 g, or less, of hydrocar-
bons per mile.
Transportation Control Measure (TCM):
TCMs include a variety of measures used to re-
duce motor vehicle emissions, primarily reducing
the amount of vehicle miles traveled (VMTs).
These can include carpool and vanpool programs,
parking management, traffic flow improvements,
high occupancy vehicle lanes, and park-and-ride
lots.
Variance: Government permission for a delay or
exception in the application of a given law, ordi-
nance, or regulation.
Vehicle Miles Traveled (VMT): A measure of
the total amount of miles traveled by vehicle within
a region.
Volatile Organic Compounds (VOCs): Any or-
ganic compound that easily evaporates and par-
ticipates in atmospheric photochemical reactions,
except those designated by EPA as having negli-
gible photochemical reactivity.
Wastewater: Spent or used water from a home,
community, farm, or industry that contains dis-
solved or suspended matter.
Wastewater Treatment Sludge: The sludge that
is produced from the treatment and removal of
pollutants of wastewater.
Watershed: The land area that drains into a
stream; the watershed for a major river may en-
compass a number of smaller watersheds that ulti-
mately combine at a common point.
"Wet" Demolition Method: A demolition tech-
nique specified in the Asbestos National Emissions
Standards for Hazardous Air Pollutants
(NESHAPs) requirements to limit the release the
asbestos particulates.
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