United States
                        Environmental Protection
                        Agency
                               Office of the
                               Administrator
                               [Mail Code 1802]
EPA-100-F-00-039
September 2000
(http://www.epa.gov)
 &EPA
 WHAT IS
 PROJECT  XL?
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  SUMMARY  OF
  THE  IBM
  FISHKILL
  PROJECT
SUPERIOR
ENVIRONMENTAL
PERFORMANCE
Project XL:
Fishkill
IBM
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Project XL, which stands for "excellence and Leadership," is a national
initiative that tests innovative ways of achieving better and more cost-effective
public health and environmental protection. The information  and lessons
learned from Project XL are being used to assist the U.S. Environmental
Protection Agency (EPA) in redesigning its current regulatory and policy-
setting approaches.  Project XL encourages testing of cleaner, cheaper, and
smarter ways to attain environmental results superior to those achieved under
current regulations and policies, in conjunction with greater accountability to
stakeholders. It is vital that each project tests new ideas with the potential for
wide application and broad environmental benefits. As of September 2000,
over thirty pilot experiments are being implemented  and several additional
projects are in various stages of development.

The  International Business Machines (IBM) East Fishkill facility in Hopewell
Junction,  New York, manufactures semiconductor and electronic computing
equipment. IBM East Fishkill's manufacturing operations  produce a
wastewater treatment sludge that is designated as FO06 hazardous waste
under Resource Conservation and Recovery Act (RCRA) regulations. The
sludge currently is disposed of in a permitted landfill approximately 350 miles
away. Through Project XL, IBM East Fishkill will test an innovative method  for
recycling  this waste stream as an ingredient in cement. The waste contains
high concentrations of calcium (a necessary ingredient in  cement production)
and very  low levels of hazardous contaminants comparable to levels found  in
typical raw materials used to produce cement.

The  Resource Conservation and Recovery Act (RCRA) regulates the use of
hazardous wastes as secondary materials when the secondary materials are
used on land. Cement manufacturers, who normally would accept the sludge
for recycling, decline to use it because they would be required to get  RCRA
permits, and because the cement produced using the sludge would be
considered a hazardous waste-derived product. Thus, for IBM, the most
practical option under the current regulatory system  is simply to treat and
dispose of the sludge,  rather than realizing its recycling potential. EPA has
agreed to provide site-specific regulatory flexibility to the IBM East Fishkill
facility sludge in  order to  allow recycling.  This XL project, EPA's 45th, was
signed on  September 29,  2000.

By implementing  this XL project, IBM East Fishkill will achieve superior
environmental performance by:
.  Recycling hazardous waste in a commercially available product rather than
  transporting the waste for disposal in a landfill;
.  Increasing landfill capacity to handle other wastes that  cannot be recycled;
  and
.  Reducing the amount of raw materials that must be mined and transported

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  FLEXIBILITY
to a kiln to make cement, thereby reducing the environmental impacts of
surface  mining.

For this XL project, EPA will provide a site-specific exclusion to the RCRA
definition of solid waste for IBM East Fishkill's wastewater treatment sludge.
EPA and IBM will set parameters for the concentrations of hazardous waste in
the sludge, define management conditions to ensure that the sludge is not
released to the environment, and establish a means of assessing the
effectiveness and safety of using the sludge as an ingredient in cement.
 STAKEHOLDER
 INVOLVEMENT
 APPROACHES TO
 BE  TESTED
IBM and the EPA have involved many stakeholders in this project, including
the Common Sense Initiative/Metal Finishing Subcommittee, the Atlantic
States Legal Foundation, local community groups, and national environmental
groups.

Will excluding IBM's wastewater treatment sludge from RCRA regulations
allow IBM to recycle their wastes and use them as an ingredient to produce
cement in an environmentally sound manner?
 CONTACTS
FOR ELECTRONIC
INFORMATION
Regional Contact:
EPA/XL HQ:
State Contact:
Project Sponsor:
      Sam Kerns
Mitch Kidwell
      Larry Nadler
      Salvatore Tranchina
      212-637-4139
202-260-2515
      518-485-8988
      914-892-1629
More information about this project, or Project XL is available on the Internet at
http://www.epa.gov/ProjectXL, or via Project XL's Information Line at
202-260-5754.

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