OPERA TIONAL APPROACH FOR DEVELOPING
A POLLUTION PREVENTION
BY
DESIGN PROJECT
A Mode! developed from Denver International Airport's
Pollution Prevention Project
U.S. Environmental Protection Agency
Region VIII
January 26, 1993

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TABLE OF CONTENTS
Page
I.	OBJECTIVES	l
II.	BENEFITS	l
III.	STEPS TO MAKE IT HAPPEN
1.	Identify Your Project	2
2.	Lay the Groundwork	3
3.	Form A Partnership with the Selected Facility	4
4.	Formulate a Multi-Media P2 Team	5
5.	Select and Implement Activities	6
6.	Measure Success	7
7.	Avoid Pitfalls	8
IV.	TRANSFERABILITY TO OTHER PROJECTS	9
V.	CURRENT DIA ACTIVITIES	10
U S EPA Region 8 Library
80C-L
999 18th SI , Suite 500
Denver, CO 80202-2466

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OPERATIONAL APPROACH
FOR
POLLUTION PREVENTION BY DESIGN
OBJECTIVES
The -objactive of the partnership with the City and County
of Denver's New Airport staff is to encourage the development
of pollution prevention concepts in the planning, design,
construction, operation and maintenance of Denver International
Airport (DZA) that will protect air, water and land resources
and result in long-term benefits to the community.
BENEFITS
The Pollution Prevention Partnership by Design concept is
a win/win situation for all participants --City and County of
Denver and the DIA staff. EPA as a Region, the EPA multi-media
P2 team, and the on-site coordinator.
The benefits reaped by EPA through this type of partnership
include:
o The opportunity to establish long-term constructive
partnerships;
o A higher profile for EPA's non-regulatory role, as
advocated by Administrator William Reilly;
o The opportunity to build multi-media pollution
prevention into design, construction, operation and
maintenance of a large operating facility;
o Identification of opportunities for involvement and
Innovation through greater awareness of current
planning and accomplishments;
o The opportunity for EPA and its partner(s) to gain
pollution prevention technical expertise;
o An effective and efficieint means to attain federal and
state environmental goals without lengthy and costly
enforcement actions;
o Conservation of natural resources; and
o Providing economic growth while minimizing.
environmental damage, thereby effecting a more
competitive nation on an international scene.
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STEPS TO MAKE IT HAPPEN
Step 1: IDENTIFY YOUR PROJECT
General Ting
It is important to carefully evaluate potential projects.
Consider aucix factors as project schedule, type of operations,
opportunities and feasibility for change, and political
acceptance of- EPA's roie. EPA will have greater opportunity to
encourage pollution prevention activities if the project is in
the planning stage, if operations involve management of EPA
regulated.waste screams, and if you have management support
from the facility. Avoid projects involving litigation or cost
recovery actions with EPA."
EPA Region VIII selected the DIA pollution prevention
project due to the potential for significant environmental and
public health impact to the Denver Metropolitan Area from
airport operations. These issues were identified during the
National Environmental Policy Act (NEPA) process and
incorporated as suggestions in the final Environmental Impact
Statement.
Many of the environmental issues encountered in designing
and constructing DIA are not addressed under current
environmental requirements. By woricing proactively with DIA's
planners and engineers outside of a traditional enforcement
role. EPA Region VTII was able to influence design,
construction, and operation and maintenance activities to
ensure that airport operations will be compatible with the
surrounding environment.
In general, consider projects which:
o Are consistent with EPA Regional and national
priorities, i.e. high risk and geographic targeting;
o Have the potential for multi-media application;
o Are at the planning stage (prior to final design and
construction or initial retrofitting);
o Offer application of P2 through the NEPA process (can
be used as a catalyst), if applicable; and
o Present an opportunity for acceptance and mutual
cooperation.
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Step 2: LAY THE GROUNDWORK
General Ties
Identifying key decision makers within your Region from
the various Regional program offices is crucial to ensuring
that the selected project has Region-wide support. By gaining
consensus among all key decision makers, '-he project will have
a greater chance -of succeeding-since-these-key-players control
resource allocation for the project.
DIA Model
Unanimous support from EPA Region VTII Senior Management
was acquired prior to the initiation of the DIA project. A
Regional "Project Champion" was identified with the task of
soliciting this support, resolving outstanding issues related
to the project, and coordinating activities among the various
EPA programs. Direct communication occurred between the
Regional Administrator and the Mayor of Denver.
To initiate the partnership project, we recommend the
following:
o Obtain the support of Senior Management of EPA, the
selected facility, and local government;
o Identify a Regional "Project Champion" to provide
enthusiasm, perseverance, and basic organizational
functions; and
o Obtain a commitment for the appropriate financial and
human resources.
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Step 3: FORM A PARTNERSHIP WITH THE SELECTED FACILITY
General Tina
A partnership with a selected facility can only succeed
under a foundation of mutual trust, respect and cooperation.
Building a bridge with your partner is a tasfc which requires a
sensitivity and understanding towards the partners' over-
arching objectives. In some respects, your partner should be
viewed as the customer and EPA as the provider of technical and
regulatory information.
DIA Model
For the DIA project, che EPA Region VIII Administrator met
personally with the DIA Construction Project Manager and later
with che Mayor of Denver co discuss objectives and offer
assistance. As the project progressed, EPA's Senior Management
offered to invest greater resources in a full-time, on-site
EPA coordinator. A Memorandum of Understanding formalized this
commitment and set forth oo^ectives, responsibilities and other
details of the partnership.
To form a partnership with a select facility, we recommend
using the following mechanisms:
o A Memorandum of Understanding documenting each party's
responsibilities and expectations; and
o An Intergovernmental Personnel Act (IPA) assignment
committing human resources to Federal, state, tribal,
or local projects.
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Step 4: FORMULATE A MULTI-MEDIA P2 TEAM
General Tics
Having completed the agreement with the facility, you will
need a structure within your Region to help provide technical
and regulatory expertise. Establishment of a cross-media team
representing all Divisions will facilitate this communication
and assistance. Real success ultimately lies in the enthusiasm
and commitment from individuals on the P2 team. Working with
TQM principles, these members value pollution prevention. They
are proven "doers" who have integrated P2 into their respective
Division's activities. These members have the responsibility
to research state-of-the-art issues, secure additional
resources, and transfer information to and from their
Divisions.
DIA Model
EPA's DIA Team memcers invest approximately 20 hours per
month, providing advice and recommendations to the on-site
coordinator. The Policy Office has the lead role in
facilitating internal communications and coordination,
contributing approximately 20-40 hours per week. The on-site
coordinator provides monthly progress reports to the team and
reports directly to the DIA Environmental Manager. This
structure creates a cooperative, open atmosphere.
When compiling a project team, consider the following:
o Select a team leader or chairperson to facilitate
internal communications and coordination;
o Identify members from all relevant Regional Divisions
to ensure multi-media participation and obtain support
from their management; and
o Consider the need for an EPA pollution prevention
coordinator on-site at the new airport office;
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Step 5: SELECT AND IMPLEMENT ACTIVITIES
General Tins
For che EPA project ceam co function effectively, it is
important to set specific ground rules pertaining to internal
communication and coordination at the onset of the project. In
particular, it is important to reach an understanding within
the team regarding project goals, EPA program expectations,
individual roles and responsibilities, and internal
communication procedures. Communication of project activities
is crucial for the team co be aware of P2 opportunities.
DIA Model
DIA projects can be recommended by DIA staff, che on-site
coordinator or the EPA csam, but all parties have to approve
activities. Projects should be consistent with EPA program
goals, as specified at che onset of the project. The multi-
media impact of all proposed recommendations are considered
jointly by the team. Monthly progress reports and meetings
ensure timely communication. At a crucial stage of EPA's
involvement, DIA's construction project manager briefed EPA's
Senior Management of DIA plans and activities. To maintain a
level of interest and increased understanding by EPA's Senior
Management, DIA staff provided a guided bus tour of the DIA
construction site.
The following procedures can be helpful in effective
implementation of activities:
o Team members prepare a ranked list of their respective
Division's goals for the project;
o Projects are jointly agreed upon by the P2 team, the
on-site coordinator and DIA;
o The team, with leadership from the on-site coordinator,
coordinates procedures for implementation of the
project, including consultation and information
exchange;
o On a level of expertise outside regulatory issues, EPA
must be willing to research and identify cost effective
P2 alternatives;
o To monitor che progress of activities and keep abreast
of issues, che ceam and on-site coordinator meet
monthly; and
o The on-site coordinator briefs EPA Senior Management
and provides recommendations regarding the level of EPA
investment in the project, with advice from the team.
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Step 6: MEASURE SUCCESS
General Tips
Although success is more easily calculated by EPA's
involvement in specific projects, a follow-up stage is
important to quantify results. These measurements and results
should be compared to the major risk areas identified by the
Region, and the Region's priorities, as well as the Agency's
Ten Themes and priorities.
DIA Model
A final stage ci project will allow Region VIII to
monitor, document and evaluate the results. Potential follow-
up activities will verify implementation of recommendations and
expectations. Workshops will provide training on
interpretation and implementation of recommendations, i.e.
tenant lease agreement terms, audit findings. We plan to work
with DIA staff to also concentrate on outreach and public
education of the environmental efforts undertaken at DIA.

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Step 7: AVOID PITFALLS
General Tin*
Building a bridge of crust cakes more Chan funding or an
offer of assistance. It takes a lot of time and persistence.
Since the P2 team is participating in an advisory capacity, che
team must be sensitive to issues and concerns it does not deal
with in its traditional enforcement role. EPA is only one
player that the facility operators have to deal with, and
environmental considerations are not always first priority.
The "financial reality" of the private sector affects decision
making.
DIA Model
The DIA project has teen an on-going learning process for
EPA, and it was intended co be. Some of che situations cannot
be foreseen. For instance. DIA's recommended centralized
handling of glycol affects airline employees' work assignments
and consequently involves airlines' contractual terms with the
unions. We need to be sensitive and keep a wide perspective
outlook.
Being aware of certain issues cam increase the chances of
success of your project, including the following:
o Working under contract deadlines, time is always a
consideration-- additional environmental planning might
result in additional time constraints;
o The bottom line is economics when most budgets are
limited;
o Private sector motivation can affect decisions;
o Know your "stakeholders" -- internal politics within
the state or governmental entities as well as the
private sector can add "hidden agendas" that are not
easily foreseen;
o Share success with the facility -- it can be easy for
EPA to take credit for environmentally sound results
when the facility makes the decisions and implements
projects; and
o Lack of EPA technical capabilities for state-of-che art
P2 issues can hinder achievement of project goals.
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TRANSFERABILITY TO OTHER PROJECTS
The concept of EPA entering into a partnership agreement
with, tiie regulated sector has broad applicability in promotion of
pollution prevention. The EPA "Green Lights" energy conservation
program is based on this prenu.se.
Other potential partnership possibilities include:
o Public worfcs projects, (i.e. highways, airports, '96
Olympic facilities)
o Federal facility operations (new or retrofitting),
including r.aticr.ai paries; and
o Major private sector initiatives.

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CURRENT DIA ACTIVITIES
.Project activities fall into the priorities identified by
the EPA Airport P2 Team and approved by DIA--water conservation/
non-potable reuse, stormwater/deicing fluids/pretreatment and
groundwater protection, indoor air quality, use of alternative
fuels, travel reduction measures, hazardous and solid waste
management, and public education. The City and County of
Denver's new airport environmental manager, planners and
engineers and EPA's P2 Team, led by the on-site coordinator,
cooperatively worked on numerous projects with significant
results. These results opened the door for assigning an EPA
liaison to work on outdoor air quality with an emphasis on a rail
link to DIA.
Anticipated FY92 EPA Resources: $192K, 1.9 FTE
-- A pilot test conducted at Stapleton could encourage use
of wall hung ultra-low volume toilets which would save
enough water during the first year of airport
operations to serve 1,575 families.
-- Evaluation of cathodic protection requirements could
reduce corrosion of underground pipes and tanks, which
was the major cause of leaks at Stapleton operations.
-- Evaluation of electrical reliability requirements for
wastewater pump stations will help ensure continual
operation of wastewater systems.
-- DIA's proposed management of glycol helps define best
management practice (BMP) standards for glycol ethylene
management in the country, i.e. containment and
reclamation for offsite processing into a marketable
product.
-- Revising implementation of the storm water permitting
process ensures full accountability of operators
managing hazardous waste.
-- A Hazardous Waste Audit of the new airport construction
site verified compliance of regulatory requirements and
evaluated construction waste minimization efforts.
-- EPA's on-site coordinator served as the project manager
of a solid waste management study of DIA operations,
provided to the City through a $210,000 grant with the
State Office of Energy Conservation. As a result of
this study, the City will decrease the amount of waste
sent to landfills from DIA by 30%.
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EPA, the Colorado Dept. of Health, and DIA jointly are
conducting waste minimization and multi-media audits of
City and tenant operations at Stapleton, beginning with
the City's vehicle maintenance operations. Results of
these audita will be used to modify both the City's and
tenants' waste management operations at DIA.
Evaluation of the use of recycled fly-ash in concrete
verified compliance with existing guidelines for
federal projects. . Over 180,000 tons-of-recycled fly-
ash concrete is being used to build DIA--equivalent to
more than the solid waste recycled in a year by
metropolitan Denver.
EPA is assisting the City in developing pollution
prevention guidelines to be incorporated into DIA's
tenant lease agreements.
An EPA-funded slide show documents pollution prevention
concepts utilized in the planning, design, construction
and maintenance oŁ DIA is currently being used for
documentation and promotion of pollution prevention.
Reviewed permitting process with City and County.
Provided technical assistance pertaining to ambient air
monitoring activities at DIA.
Data collected from the EPA-funded indoor air filter
pilot test has prompted the City of Denver to
reconsider its original selection for indoor air
filters at DIA and purchase a more effective filter...
both $1 M purchases.
-	Participation in Green Lights, EPA's energy
conservation program, will require detailed evaluation
of all lighting at DIA.
-	As the Transportation Co-coordinator, EPA's on-site
coordinator is promoting travel reduction measures for
Stapleton employees and providing assistance in
developing a travel reduction program for DIA
employees.
-	The EPA team is participating with water conservation
and solid waste management planning and zoning strategy
at Gateway, a proposed planned residential/commercial
development adjacent to DIA, making this a true
geographically targeted P2 effort.
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Evaluation of existing groundwater quality and a survey
of existing monitoring wells will determine baseline
groundwater quality prior to DIA construction
activities.
City construction engineers were trained on EPA's SARA
Title III Community Right To Know, reporting
responsibilities of DIA construction contractors.
Based on the knowledge gained through the DIA project,
EPA was able to provide detailed comments requesting
incorporation of pollution prevention measures through
the NEPA process for expansion of an adjacent cargo
airport.
As a result of reviewing waste minimization and erosion
control plans submitted by DIA contractors, we
encouraged more recycling of construction materials and
provided ccmmencs on contractor erosion (air and water)
and sediment control practices.
EPA evaluated the effects of land application of
reclaimed water to underlying groundwater. The
findings indicated that potential impact to groundwater
from the use of reclaimed water should not be an
impediment to pursuing the installation of a reclaimed
water system.
EPA critiqued contractor specifications and developed
construction P2 bid specifications.
After meeting with water providers, they agreed to
install a non-potable water distribution system at DIA
so that this water will be used initially for landscape
irrigation.
-	We are supporting DlA's Construction Project Manager in
ensuring that xeroscaping techniques are used
throughout the DIA area.
-	We are supporting the goal of reducing vehicle miles
travelled (VWT) as a result of travel to and from the
new airport, including transportation options such as
public transit.
-	Provided technical assistance in preparing the scope of
work and reviewing subsequent contractor work plan for
groundwater baseline monitoring at DIA.
-	Evaluated and recommended an alternative fuel policy
for City and DIA tenants.
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-- Provided regulatory assistance regarding the new Clean
Air Act Amendments and Stormwater regulations.
-- Provided technical assistance regarding the P2 design
and installation of above-ground and under-ground fuel
storage tanks.
-- EPA has also assigned a full-time employee to serve as
a federal transportation liaison to the City and County
of Denver to help improve access to DIA. The liaison
works directly with the transportation planning staff
of the City and County of Denver to secure public and
private funding for a rail link between downtown Denver
and DIA. This person coordinates activities between
numerous national and local public and private entities
to develop a unified approach and support for the rail
project. This partnership has also produced
significant results in a short time.
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